THE CHAPEL CLUB Privacy Notice 1. General 1.1 The Chapel – Luxury Personal Training, is the trading name of Alex Minors Limited (company number 05741243) (“The Chapel” “we”, “us” or “our”). The Chapel takes the privacy of your information very seriously. Our Privacy Notice is designed to tell you, the user of our services about our practices regarding the collection, use and disclosure of personal information which may be provided to us via our website, collected in person or collected through other means such as an online form, email, or telephone. 1.2 This notice applies to personal data provided by our customers and clients, whether they are an ongoing client for our services or otherwise. In this notice “you” refers to any individual whose personal data we hold or process (other than our staff and contractors). 1.3 In this notice references to the “Services” are references to any services provided by us which relate to any personal data held or processed by us. 1.4 This notice is governed by the Data Protection Act 1998 and by the retained UK law version of the EU General Data Protection Regulation as incorporated into UK law under the European Union (Withdrawal) Act 2018 (“GDPR”), and any other applicable data or privacy legislation. 1.5 This notice may be updated from time to time. Changes to this notice are effective when they are posted on our website. 2. Basis on which we process personal data 2.1 Personal data we hold about you will be processed either because: 2.1.1 in the case of data relating to your fitness or health, you have consented to our holding and using that data (and you will be asked to sign a consent form in relation to this data); 2.1.2 the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security; 2.1.3 you have consented to the processing for the specific purposes described in this notice; 2.1.4 the processing is necessary in order for us to comply with our obligations under a contract between you and us. 3. Personal data we collect 3.1 We may collect and process the following personal data (information that can be uniquely identified with you) about you: 3.1.1 Contact information for our clients, customers and potential clients and customers such as names, email addresses, phone numbers, addresses (“Contact Information”). We process this information when we communicate with you or provide services to you on the basis of the performance of our contract with you and on the basis of our legitimate interest in providing our services to our clients. 3.1.2 Information relating to your health and fitness (“Health and Fitness Information”). We process this information in order to provide our services in a safe and effective way on the basis of your consenting to us holding and using this data. 3.1.3 A record of any correspondence or communication between you and us (“Communication Information”). We process this information when we monitor our relationship with you and provide services to you on the basis of the performance of our contract with you and on the basis of our legitimate interest in providing our services to our clients. 3.1.4 Marketing information we may hold about you in order to provide information about our services this may include names, email addresses, phone numbers, addresses, and other information (“Marketing Information”). We process this information in order to communicate with you about our products and services on the basis of our legitimate interests in communicating with you about our services or on the basis that you have consented to receive the information. 3.1.5 Financial information completed in our payment mandate form, including credit or debit card information, bank account information, including your sort code and account number (“Financial Information”). We process this information with the legitimate interest of charging for our fees to our clients in line with our terms and conditions of service. 3.1.6 Information relating to your use of our services, including frequency of visits (usage records) and your preferences in relation to certain services we offer (“Usage Information”). We process this information with the legitimate interest of better understanding our customers habits regarding our services to enhance our customer offering. 3.2 We also utilise CCTV, please see below for further information. 3.3 We will collect information either from you directly or from a third party (for instance an introducer). If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice. 3.4 We will not collect any sensitive personal data (other than information relating to your health and fitness) without your prior consent. By sensitive personal data we mean data which falls within certain ‘special categories’ which are defined in the GDPR and which require additional protection and consent measures. 3.5 If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice. 3.6 You do not have to supply any personal information to us but our services may not be operable without providing data to us. In particular we will not be able to activate your subscription without collecting some personal data from you. 3.7 You may withdraw our authority to process your personal data (or request that we restrict our processing – see clause 9) at any time but we will be entitled to complete any orders we are then processing and we may need to withhold some personal data for legal or other reasons (see below). 4. Data Retention 4.1 Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following: Category of personal dataLength of retention Records relevant for tax purposes8 years from the end of the tax year to which the records relate Personal data processed in relation to a contract between you and us7 years from either the end of the contract or the date you last used our services or placed an order with us, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim Personal data held on marketing or business development records3 years from the last date on which you have interacted with us 4.2 For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data or (if later) the end of the relevant contract, arrangement or interaction with that person. 4.3 The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data). 4.4 We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required. 4.5 If you wish to request that data we hold about you is amended or deleted, please see clause 10 below, which explains your privacy rights. 5. CCTV 5.1 We utilise CCTV for the legitimate interest of protecting the safety of our staff and service users, as well as to collect evidence if required for criminal or other legal proceedings. CCTV is in use in the grounds of the property, within the reception and fitness areas, but not in the changing rooms or other sensitive areas. 5.2 Our employees, contractors and other third parties are able to review footage as required. By utilising our facilities, you provide consent to your image being recorded and reviewed, as proportionate and necessary for our legitimate interests. 5.3 Our CCTV is processed in accordance with the Data Protection Act 2018, which is the UK’s implementation of the General Data Protection Regulations (GDPR). We believe CCTV not only evidences crime, put supports the prevention of it. 5.4 We register our CCTV with the Information Commissioners office annually. 6. Sharing your information 6.1 If we collect payment via credit or debit card. Credit and debit card information will be provided to our payment processing partner. This information will be supplied to our payment processing partner directly, even if you provide the information while using our services. 6.2 Our payment processing partner will have their own privacy policies and notices. But we will take steps to ensure that they are compliant with applicable data protection legislation and we will consult with them in relation to maintaining the security of payment information. 6.3 We do not disclose any personal data you provide to any third parties other than as follows: 6.3.1 If we engage self-employed staff (e.g. personal trainers) we may disclose personal data to them in order for them to provide services; 6.3.2 If we need to disclose information to our suppliers who are assisting with the provision of services to you; 6.3.3 certain third-party suppliers including IT technical support providers, website developers, marketing and business development service providers may have access to personal data; 6.3.4 where we carry out research to gain an insight into the use of our services, the results of this research (but not your personal data itself) may be transferred to interested third parties; 6.3.5 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime); 6.3.6 in order to enforce any terms and conditions or agreements for our services that may apply; 6.3.7 we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected; 6.3.8 to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 6.4 Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice. 7. Email and Other Communications 7.1 If you are a current or former client of ours we may from time to time contact you. We may also contact you with information about our services if you have expressly consented to receive such communications (e.g. by signing up via our website). 7.2 When we send email and other electronic communications we will comply with applicable regulations including the Privacy and Electronic Communications Regulations 2003. In particular we will identify the nature of the message and the sender clearly and you will have an opportunity to opt out of receiving any further communications from us. 8. Security 8.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary): 8.1.1 protecting our servers by both hardware and software firewalls; 8.1.2 locating our data processing storage facilities in secure locations; 8.1.3 encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered; 8.1.4 ensuring that all communication with our servers is encrypted through Secure Sockets Layer (SSL), an industry standard encryption method that encrypts data between your computer and our servers so that in the event of your network being insecure no data is passed in a format that could easily be deciphered; 8.1.5 when necessary, disposing of or deleting your data so it is done so securely; 8.1.6 regularly backing up and encrypting all data we hold. 8.2 We will ensure that our staff are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations. 8.3 This notice and our procedures for handling personal data will be reviewed as necessary. 8.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us via email or our website. Once we have received your information, we will use the procedures and security features referred to in this notice to try to prevent unauthorised access. 9. Your privacy rights 9.1 The GDPR gives you the following rights in respect of personal data we hold about you: The right to be informedYou have a right to know about our personal data protection and data processing activities, details of which are contained in this notice. The right of accessYou can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below. The right to correctionPlease inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information. The right to erasure (the ‘right to be forgotten’)Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible. We will communicate the erasure to any third parties to whom we have passed the same information. The right to restrict processingYou can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data. The right to data portabilityYou have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible). The right to objectUnless we have overriding legitimate grounds for such processing, you may object to us using your personal data if you feel your fundamental rights and freedoms are impacted. You may also object if we use your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing, unless we have overriding legitimate grounds. Right to withdraw consentIf we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above). 9.2 All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to the contact details set out below. 9.3 We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests). 10. Data Breaches 10.1 If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO). 10.2 If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible. 11. Other websites 11.1 Our services may contain links and references to other websites. Please be aware that this notice does not apply to those websites. 11.2 We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via our services. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. 11.3 In addition, if you came to our services via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions. 12. Transferring your information outside the European Area 12.1 We will not transfer your personal in a systematic way outside of the UK or EEA (“European Area”) but there may be circumstances in which certain personal information is transferred outside of the European Area, in particular: 12.1.1 If you use our services while you are outside the European Area, your information may be transferred outside the European Area in order to provide you with our services; 12.1.2 We may communicate with individuals or organisations outside of the European Area in providing our services, those communications may include personal information (such as contact information) for example you may be outside of the European Area when we communicate with you; 12.1.3 From time to time your information may be stored in devices which are used by our staff outside of the European Area (but staff will be subject to our cyber-security policies). 12.2 If we transfer your information outside of the European Area, and the third country or international organisation in question has not been deemed by the EU Commission or UK Secretary of State to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice. If you would like to obtain details of the safeguards we have put in place then please contact us at the details below. 12.3 By submitting your personal information to us you agree to the transfer, storing or processing of your information outside the European Area in the manner described above. 13. Notification of changes to the contents of this notice We will post details of any changes to our policy on our website to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties. 14. Contact us If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following email address: alex@thechapel.club. If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.