General Data Protection Regulation
Policy Statement
Arnould’s Gym will use and store personal information about our customers, employees and suppliers. It is important that this information is handled lawfully and appropriately in line with the requirements of the Data Protection Act 2018 and the General Data Protection Regulation (GDPR). Arnould’s Gym is registered with the ICO to ensure your Data is always protected.
About This Policy
This policy will explain the process we use for any personal data we collect.
The Directors at Arnould’s Gym are responsible for ensuring compliance with the Data Protection Requirements and with this policy. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Directors of Arnould’s Gym.
Who we are?
Our website address is https://arnouldsgym.com.
What is Personal Data?
Personal data means data (whether stored electronically or paper based) relating to a living person who can be identified directly or indirectly from that data (or from that data and other information in our possession).
Processing is any activity that involves use of personal data. It includes obtaining, recording or holding the data, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
Sensitive personal data includes personal data about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic, biometric, physical or mental health condition, sexual orientation or sexual life. It can also include data about criminal offences or convictions. Sensitive personal data can only be processed under strict conditions, including with the consent of the individual.
We collect your personal information when you:
- Complete an online Membership Agreement.
- Book or attend an exercise class, lesson or induction.
- Ask us for more information about a service or product or contact us with a complaint or a question.
- Visit or browse our website. See our cookie policy.
- Contact Arnould’s Gym through telephone, email or online chat.
- Send an email to hello@arnouldsgym.com email account
- Take part in a competition etc.
- Enter your QR code or day pass to enter our gym.
- You have an accident in our gyms or there was an incident where you were a witness or personally involved or affected.
- CCTV – when you are using Arnould’s Gym.See CCTV Policy.
- When you use the Arnould’s Gym Clubright app. See Clubright privacy policy.
- When we take photos of you at the gym as part of an event or in a class (Your permission will be asked beforehand)
When using our gyms CCTV is being recorded 24 hours a day. CCTV is permanently erased after 31 days.
We may also collect, match or acquire information about you from other organisations such as Google and Facebook.
When visitors leave comments on the website, we collect data shown in the comments form and also the visitors IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here:
http://automattic.co./privacy/
After approval of your comment, your profile picture is visible to the public in the context of your comment,
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
WHAT INFORMATION DO WE COLLECT?
The information we collect is required to create your Membership account and for you to enrol in our gym. This information allows you to be identified as a member of Arnould’s Gym and includes:
- Name, date of birth, gender, e-mail address, postal address, telephone number, health declaration.
- Credit or debit card information, information about your bank account number and sort code or other banking information. Note that we do not store your bank or credit card details on our web servers.
- Your usage records and duration of visits.
- Your preferences for particular products or services or interests when you tell us what they are – or when we assume what they are, depending on how you use our products and services.
- Your contact with us, such as a note or recording of a call you make to us, an email or other records of any contact you have with us.
- Your membership information – such as dates of payment owed and received, the services you use, and any other information related to your account.
HOW DO WE USE THIS INFORMATION?
We will use your personal information to provide you with the services, products or information that you have requested, for administration purposes, to improve your website experience, and marketing. We may need to share your information with our service providers, associated organisations and agents for these purposes. We may use your information to:
- To process your membership application through Clubright, our membership software.
- To bill you for using our services as part of your membership.
- Keep you informed about our services including operational matters relating to your Membership.
- Provide relevant services to you.
- Confirm your attendance to exercise classes/lessons.
- To share gym event photos on our internal social media platform (Your permission will be asked first before.)
- Contact you with offers or promotions based on our analysis of how you use our services and what we think will be of interest to you (unless you choose not to receive our marketing messages.)
- Respond to any questions or concerns you might have about our services.
- Understand how you use our services, to help us develop relevant and updated services.
- Carry out research and statistical analysis to monitor how customers use our services.
- Prevent and detect fraud or other crimes.
We’ll store your information for as long as you are a Member of Arnould’s Gym or following cancellation and to meet legal requirements including financial audit, anti-fraud and money laundering regulations.
Anyone processing personal data, must ensure that data is:
- Processed fairly, lawfully and in a transparent manner.
- Collected for specified, explicit and legitimate purposes and any further processing is completed for a compatible purpose.
- Adequate, relevant and limited to what is necessary for the intended purposes.
- Accurate, and where necessary, kept up to date.
- Kept in a form which permits identification for no longer than necessary for the intended purposes.
- Processed in line with the individual’s rights and in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
- Not transferred to people or organisations situated in countries without adequate protection and without firstly having advised the individual.
Fair and Lawful Processing
The Data Protection Requirements are not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the individual.
In accordance with the Data Protection Requirements, we will only process personal data where it is required for a lawful purpose. The lawful purposes include (amongst others): whether the individual has given their consent, the processing is necessary for performing a contract with the individual, for compliance with a legal obligation, or for the legitimate interest of the business. When sensitive personal data is being processed, additional conditions must be met.
Notifying Individuals
If we collect personal data directly from an individual, we will inform them about:
- The purpose or purposes for which we intend to process that personal data, as well as the legal basis for the processing.
- Where we rely upon the legitimate interests of the business to process personal data, the legitimate interests pursued.
- The types of third parties, if any, with which we will share or disclose that personal data.
- The fact that the business intends to transfer personal data to a non-EEA country or international organisation and the appropriate and suitable safeguards in place.
- How individuals can limit our use and disclosure of their personal data.
- Information about the period that their information will be stored, or the criteria used to determine that period.
- Their right to request from us as the controller access to and rectification or erasure of personal data or restriction of processing.
- Their right to object to processing and their right to data portability.
- Their right to withdraw their consent at any time (if consent was given) without affecting the lawfulness of the processing before the consent was withdrawn.
- The right to lodge a complaint with the Information Commissioners Office.
- Other sources where personal data regarding the individual originated from and whether it came from publicly accessible sources.
- Whether the provision of the personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the individual is obliged to provide the personal data and any consequences of failure to provide the data.
- The existence of automated decision-making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the individual.
If we receive personal data about an individual from other sources, we will provide them with this information as soon as possible (in addition to telling them about the categories of personal data concerned) but at the latest within 1 month. An example of where this may happen is where the ESFA may transfer learners to us.
Adequate, Relevant and Non-excessive Processing
We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.
Accurate Data
We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.
Timely Processing
We will not keep personal data longer than is necessary for the purpose or purposes for which it was collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required.
Processing in line with Data Subject’s Rights
We will process all personal data in line with data subjects’ rights, in particular their right to:
- Confirmation as to whether or not personal data concerning the individual is being processed.
- Request access to any data held about them by a data controller
- Request rectification, erasure or restriction on processing of their personal data.
- Lodge a complaint with a supervisory authority.
- Data portability.
- Object to processing including for direct marketing.
- Not be subject to automated decision-making including profiling in certain circumstances.
Data Security
We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental or unlawful destruction, damage, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.
We will put in place procedures and technologies to maintain the security of all personal data from the point of the determination of the means for processing and point of data collection to the point of destruction. Personal data will only be transferred to a data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.
We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
- Confidentiality means that only people who are authorised to use the data can access it.
- Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
- Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on the Company’s central computer system instead of individual PCs.
Security procedures include
- Secure lockable cupboards. Cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)
- Data minimisation
- Methods of disposal. Paper documents should be shredded. Digital storage devices should be physically destroyed when they are no longer required.
When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the following conditions are met:
- We will check the caller’s identity to make sure that information is only given to a person who is entitled to it.
- We will suggest that the caller put their request in writing if we are not sure about the caller’s identity and where their identity cannot be checked.
- Where a request is made electronically, data will be provided electronically where possible.
CCTV Policy
Our CCTV systems are operated throughout Arnoulds Gym and the car park 24 hours a day
All recorded CCTV will be stored securely and retained in compliance with applicable laws. Arnoulds Gym ltd is registered as a Data Controller with the ICO.
The use of the CCTV will always be for a specified purpose and necessary to meet an identified pressing need.
This includes giving confidence to members and staff that they are in a safe and secure environment, protecting the integrity of the site by deterring criminals and to provide evidence to assist with the detection and prosecution of criminal offences.
At Arnoulds Gym is the Data Controller for the Personal Data captured by our CCTV systems and managed by the Data controller officer Robert Arnould.
The recordings are confidential and available only to those directly connected with operating the system. Copies of recorded information are strictly controlled and only made in relation to incidents under specific restrictions and require the approval of the Data Controller Officer.
Only images and information should be stored that is strictly required for the stated purpose of a surveillance camera system, and such images and information should be deleted once their purposes have been discharged.
CCTV operators should be trained to an adequate standard and such standard must be maintained at all times.
Surveillance camera system images and information should be subject to appropriate security measures to safeguard against unauthorised access and use.
Cookies Policy
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Changes to this Policy
We reserve the right to change this policy at any time. Where appropriate, we will notify changes by email.