Privacy Policy
In this privacy policy, “EMPIRE DY9” means
Empire Fitness Gym Ltd, whose registered office is at Unit 4, Folkes Road
Trading Estate, Folkes Road, Stourbridge, DY9 8RG. EMPIRE DY9 believe in
transparency, and are committed to being upfront about privacy practices,
including how your personal information is treated. EMPIRE DY9 have undertaken
an extensive exercise to ensure ongoing compliance with the European Union
General Data Protection Regulation (EU GPDR). EMPIRE DY9 have ensured all
current business processes and procedures are in line with the GDPR rights and
principles and any new processes involving personal information that are
implemented will be thoroughly reviewed through a Data Protection Impact
Assessment (DPIA) prior to proceeding. All company data protection procedures
and policies are reviewed on an annual basis to ensure compliance.
This Privacy Policy sets out the data processing practices carried out through the use of the Internet and any other electronic communication networks by EMPIRE DY9, as well as describing the types of personal information that EMPIRE DY9 may collect about you and the purposes for which this information is used.
1. Accepting the Privacy Policy
2. Information Collected or Received
3. How and why EMPIRE DY9 use your Personal Information
4. Communication from EMPIRE DY9
5. Sharing your Information
6. Keeping your Information Secure
7. EMPIRE DY9 Retention Policies
8. Staying in Control - Your Rights
9. Privacy Policy Changes
10. Contact
1. ACCEPTING THE PRIVACY POLICY
EMPIRE DY9 need to process your personal information to run their business and provide you with their services. Upon visiting EMPIRE DY9 in Club, contacting EMPIRE DY9 by the phone, or visiting the website, (www.empirefit.co.uk), you are accepting and consenting to the practices described in this Privacy Policy.
2. INFORMATION COLLECTED OR RECEIVED
EMPIRE DY9 collect personal information from Club users, Staff and Suppliers to run their business and provide you with their services. This personal information may include the following: name, date of birth, email address, contact number, company name, bank details and credit card details.
EMPIRE DY9 may also collect the following information:
Sensitive Information: The term "sensitive information" in this context refers to information related to your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership. Whilst EMPIRE DY9 do not generally collect sensitive information unless it is volunteered by you, EMPIRE DY9 do have a legal requirement to collect health data for the purpose of recording your self-assessment declaring readiness for physical exercise.
Digital: When visiting the Empire DY9 website (www.empirefit.co.uk) your personal information may be collected, stored and used such as traffic data, location data, web logs, communication data and resources that you access, as well as other personal information detailed above. If you connect to EMPIRE DY9 using an external third-party application, such as Facebook, Instagram, or Twitter, these websites will have their own privacy statement which EMPIRE DY9 suggest that you read before giving them your personal information. Connecting to EMPIRE DY9 via a third-party application or service is optional and at your own discretion.
EMPIRE DY9 will only collect the relevant information required for the purposes of processing and will not use this information for any other purpose without obtaining consent.
3. HOW AND WHY EMPIRE DY9 USE YOUR PERSONAL INFORMATION
The information in the above, section 2, may be used for the following purposes:
- To carry out EMPIRE DY9’s obligations arising from any contractual agreement;
- To contact you about non-contract aspects of your Membership, such as a change in usage patterns;
- To provide you with the information on products or services you request;
- To process payments and maintain accounts and records;
- To prevent crime, fraud and aid in the prosecution of offenders;
- To maintain Membership records;
- To prevent or detect abuses of the EMPIRE DY9 website;
- To create business performance statistics and analysis;
- To enable third parties to carry out technical, logistical, research or other functions on behalf of EMPIRE DY9;
- To conduct surveys and request feedback;
- To notify you about urgent comms such as a sudden closure of a Club;
- To notify you about changes to EMPIRE DY9 Services, Terms and Conditions, Privacy Policy and Club rules;
- To collect information about your tastes and preferences, both when you tell us and by analysis of customer traffic, including using "cookies";
- To read and respond to comments made regarding EMPIRE DY9 services.
Other than as set out in this Privacy Policy EMPIRE DY9 will not use your personal information for any other purpose without your consent, unless required to do so by law.
4. COMMUNCATION FROM EMPIRE DY9
On occasion, EMPIRE DY9 may need to contact you. Primarily, these messages are delivered by email, text or phone, and every individual’s record is required to keep a valid email address and contact number on file to receive these messages.
In response to enquiries and when communicating with Members, EMPIRE DY9 believe that the content is relevant, valuable, interesting and beneficial to you. EMPIRE DY9 also believe that you would reasonably expect to receive the type of content that is sent to you as part of your relationship with EMPIRE DY9. Therefore, EMPIRE DY9’s current assessment is that the communication you receive is covered by the lawful basis for processing of ‘Legitimate Interest’ under recital 47 within the GPDR. For all communication sent under the basis of legitimate interest, opt-out options are provided and detailed later within this section.
For all communication where consent is the only legal basis, preferences will be collected in advance.
EMPIRE DY9 recognise that you value having control over your own information, so EMPIRE DY9 gives you the choice of changing your communication preferences if you disagree with the above. You may email empiredy9@gmail.com with your request.
5. SHARING YOUR INFORMATION
Information about EMPIRE DY9 Club users is an important part to the business and EMPIRE DY9 do not sell it to others. EMPIRE DY9 shares member information only as described in this Privacy Policy.
Arrears Collection: EMPIRE DY9 reserves the right to forward a members information to a third party debt collection agency in the event of non-payment of fees when due. Further information on this process can be found in EMPIRE DY9 Terms and Conditions.
EMPIRE DY9 release account and other personal information to third parties when EMPIRE DY9 believe release is appropriate to comply with the law; enforce or apply membership or other agreements; or protect the rights, property or safety of EMPIRE DY9, its users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction. This does not include selling, sharing or otherwise disclosing personally identifiable information from members for commercial purposes in a way that is contrary to the commitments made in this Privacy Policy.
6. KEEPING YOUR INFORMATION SECURE
In regards to environmental and physical security, all EMPIRE DY9 employees receive full training upon commencement on employment.
7. EMPIRE DY9 RETENTION POLICIES
EMPIRE DY9 have set company retention policies in place and these timescales are set in accordance with any applicable legislation and/or for any agreed legitimate reasons. Where none exists, then EMPIRE DY9 will keep your information for the duration of any Contract that you have entered into with EMPIRE DY9, and then for a period of 7 years after, at which time all the personal information will be pseudonymised.
8. STAYING IN CONTROL - YOUR RIGHTS
EMPIRE DY9 understand the importance of data subjects remaining in control of their personal data. EMPIRE DY9 acknowledge the following rights you have under the GDPR, what they mean and how you can exercise them.
The Right to be Informed
This privacy policy states all uses of your personal information and the purposes for processing this information. Should you have any concerns or questions about our privacy policy and practices, or would like a full list of our third party processors, then please email empiredy9@gmail.com
The Right of Access
You have the right to access information that EMPIRE DY9 hold about you. If you wish to receive a copy of the information that EMPIRE DY9 hold, please submit a Subject Access Request form (SAR) which you can request from empiredy9@gmail.com. Once EMPIRE DY9 have received your form, they will provide a response within one month. If your request is unusually complex and likely to take longer than a month, you will be informed as soon as possible to tell you how long it’s likely to take.
Please note that whilst in most cases EMPIRE DY9 will be happy to provide you with copies of the information you request, EMPIRE DY9 nevertheless reserve the right, in accordance with section 8(2) of the DPA, not to provide you with copies of information requested if to do so would take “disproportionate effort”, or in accordance with Article 12 of the GDPR to charge a fee or refuse the request if it is considered to be “manifestly unfounded or excessive”.
The Right to Rectification, Restrict Processing, Erasure, and to Object
You can ask EMPIRE DY9 at any time to change, amend or pseudonymise the information that EMPIRE DY9 hold about you.
To pseudonymise the information, or object/request restriction of processing then please email empiredy9@gmail.com
EMPIRE DY9 will aim to respond to any request as soon as possible, but no later than within 1 month since receipt of request. Please note that the right to erasure is not absolute and only applies in certain circumstances. For further information on this please visit the following link to the ICO’s website, https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
Right to Data Portability
You have the right to request that your personal data is transferred by EMPIRE DY9 to another organisation (this is called “data portability”). Please contact us at empiredy9@gmail.com with the details of what you would like for EMPIRE DY9 to do and EMPIRE DY9 will endeavour to comply with your request. It may not be technically feasible, but EMPIRE DY9 will work with you to try and find a possible solution.
9. PRIVACY POLICY CHANGES
EMPIRE DY9 may make slight changes to the Privacy Policy, Terms and Conditions, however, will never materially change policies and practices to make them less protective of member information collected in the past without the consent of affected members. EMPIRE DY9 will display signage with details of any changes to these notices and conditions, but an up to date version will always be available on the website (www.empirefit.co.uk)
10. CONTACT
If you have any questions, comments or concerns
about data privacy at EMPIRE DY9, please e-mail thorough a description to empiredy9@gmail.com
and EMPIRE DY9 will endeavour to resolve the issue for you.