Privacy Policy

In this privacy policy, “ETHOSGYMS” means ETHOSGYMS, whose registered office is at 22 Hardwicks Square, Wandsworth, London SW18 4JS. ETHOSGYMS believe in transparency and are committed to being upfront about privacy practices, including how your personal information is treated. ETHOSGYMS have undertaken an extensive exercise to ensure ongoing compliance with the European Union General Data Protection Regulation (EU GPDR). ETHOSGYMS 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 ETHOSGYMS, as well as describing the types of personal information that ETHOSGYMS 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 ETHOSGYMS use your Personal Information
   4. Communication from ETHOSGYMS
   5. Sharing your Information
   6. Keeping your Information Secure
   7. ETHOSGYMS Retention Policies
   8. Staying in Control – Your Rights
   9. Privacy Policy Changes
   10. Contact
2. Accepting the Privacy Policy

ETHOSGYMS need to process your personal information to run their business and provide you with their services. Upon visiting ETHOSGYMS in Gym, contacting ETHOSGYMS by phone, or visiting ETHOSGYMS website(s), you are accepting and consenting to the practices described in this Privacy Policy.

ETHOSGYMS are based in the UK, however process personal information both within the UK/EEA and outside. Any personal information held by either ETHOSGYMS or the designated third parties complies with relevant EU GDPR legislations. Third parties which process personal information outside the UK/EEA on behalf of ETHOSGYMS have recognised equivalent legislation in places such as the US Privacy Shield, or a set of GDPR compliant Binding Corporate Rules (BCR).

2. Information Collected or Received

ETHOSGYMS collect personal information from Members, Staff and Suppliers/Sub-contractors 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.

ETHOSGYMS 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 ETHOSGYMS do not generally collect sensitive information unless it is volunteered by you, ETHOSGYMS do have a legal requirement to collect health data for the purpose of recording your self-assessment declaring readiness for physical exercise.

Photographs and Identification: In the interests of security and the prevention of crime, ETHOSGYMS may take a digital photograph of each Member or guest. Each Member or guest may also be required to provide a form of identification for verification and security purposes.

Audio-Video: ETHOSGYMS use CCTV in all gyms for health and security reasons. If you have any queries in relation to the use of CCTV operating in and around the gyms please contact info@ethosgyms.co.uk. ETHOSGYMS have a business legitimate interest to monitor service standards in Gym. ETHOSGYMS utilise mystery shopper services in which gym users may appear in the background however are never directly filmed. This footage is only used for the purposes of internal monitoring and training of ETHOSGYMS staff.

Digital: When visiting ETHOSGYMS website(s), your personal information may be collected, stored and used such as traffic data, location data, weblogs, communication data and resources that you access, as well as other personal information detailed above. If you connect to ETHOSGYMS or register for a tour of ETHOSGYMS using an external third-party application, such as Facebook, Instagram, or Twitter, these websites will have their own privacy statement which ETHOSGYMS suggest that you read before giving them your personal information. Connecting to ETHOSGYMS via a third-party application or service is optional and at your own discretion.

ETHOSGYMS 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 ETHOSGYMS use your Personal Information

The information in the above, section 2, may be used for the following purposes:

– To carry out ETHOSGYMS’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 improve the ETHOSGYMS platform;
– To prevent or detect abuses of the ETHOSGYMS website;
– To create business performance statistics and analysis;
– To enable third parties to carry out technical, logistical, research or other functions on behalf of ETHOSGYMS;
– To send you newsletters and promotions, prize draws, and competitions;
– To conduct surveys and request feedback;
– To notify you about urgent comms such as a sudden closure of a Gym;
– To notify you about changes to ETHOSGYMS Services, Terms and Conditions, Privacy Policy and Gym rules;
– To process your job application if you apply for employment at ETHOSGYMS;
– 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 ETHOSGYMS services.

Other than as set out in this Privacy Policy ETHOSGYMS will not use your personal information for any other purpose without your consent unless required to do so by law.

4. Communication from ETHOSGYMS

On occasion, ETHOSGYMS 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, ETHOSGYMS believe that the content is relevant, valuable, interesting and beneficial to you. ETHOSGYMS also believe that you would reasonably expect to receive the type of content that is sent to you as part of your relationship with ETHOSGYMS. Therefore, ETHOSGYMS’s current assessment is that the communication you receive is covered by the lawful basis for the 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.

ETHOSGYMS recognise that you value having control over your own information, so ETHOSGYMS gives you the choice of editing your communication preferences if you disagree with the above. For ETHOSGYMS Members and Ex-Members you may update these preferences by logging into the Members area through the login page of the website, (www.ETHOSGYMS.com). Alternatively, you may email info@ethosgyms.co.uk with your request.

Please note the following messages from ETHOSGYMS fall into the category of compulsory communication and therefore no opt-out options are available:

– Urgent Communication (such as unplanned closure of all or part of a Gym, reduced services, a change of opening times)

– Automatic Class Booking communication (such as booking confirmation, waiting list movement, cancellations)

– Contract and Subscription related communication (such as welcome emails, outstanding arrears, upcoming renewals, communication with the ETHOSGYMS Member Services Support Team).

You may receive communication from ETHOSGYMS via the following communication systems, all of which offer an opt-out service. Please note you must opt-out of each individual communication system should you wish to exercise that right;

Direct email communication from ETHOSGYMS staff via Outlook: To opt-out you can do either of the following, log into the member’s area on the website to update your communication preferences within the My Profile section. You can also request this specifically to info@ethosgyms.co.uk

5. Sharing your Information

Information about ETHOSGYMS Gym users is an important part of the business and ETHOSGYMS do not sell it to others. ETHOSGYMS shares member information only as described in this Privacy Policy.

ETHOSGYMS have business partners and employ other companies and individuals to perform certain functions on ETHOSGYMS behalf. Examples include managing our Membership database, sending texts, e-mails, analysing data, providing marketing assistance, providing personal training and providing debt collection assistance. Third-party service providers only have access to the personal information relevant for performing their functions, but will not use it for other purposes. Additionally, they must process the personal information in accordance with this Privacy Policy and as permitted under the EU GDPR. ETHOSGYMS will only disclose personal information to reputable companies and suppliers who process data on ETHOSGYMS behalf.

Arrears Collection: ETHOSGYMS 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 ETHOSGYMS Terms and Conditions.

ETHOSGYMS release account and other personal information to third parties when ETHOSGYMS believe release is appropriate to comply with the law; enforce or apply membership or other agreements; or protect the rights, property or safety of ETHOSGYMS, 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.

ETHOSGYMS may share Member details with any organisation that acquires a Gym to which the Member has their Membership.

Other Websites: The ETHOSGYMS website may contain links to other websites that are outside ETHOSGYMS control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from this policy.

Cookies: A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. Find out more about cookies on https://ico.org.uk/for-the-public/online/cookies/ ETHOSGYMS use cookies to identify you when you visit this website and to keep track of your browsing patterns and build up a demographic profile. ETHOSGYMS use cookies to allow registered users to be presented with a personalised version of the site, carry out transactions and have access to information about their account. Most browsers will allow you to turn off cookies. If you want to know how to do this please look at the menu on your browser, or look at the instruction on https://ico.org.uk/for-the-public/online/cookies/. Please note however that turning off cookies may restrict your use of our website. By continuing to use this site you are agreeing to the use of cookies as detailed within this section.

6. Keeping your Information Secure

In regards to environmental and physical security, all ETHOSGYMS employees receive full training upon commencement of employment and subsequently on an annual basis thereafter. This is completed via an e-learning platform and group training sessions. Further to this, daily, weekly and monthly audits are completed.

7. ETHOSGYMS Retention Policies

ETHOSGYMS 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 ETHOSGYMS will keep your information for the duration of any contract that you have entered into with ETHOSGYMS, and then for a period of 7 years after, at which time all the personal information will be pseudonymised.

After that 7 year duration, ETHOSGYMS will retain and use your pseudonymised information for the purpose of business statistics and analysis. ETHOSGYMS can retract this pseudonymisation to the extent necessary to comply with any legal obligations or to resolve disputes

8. Staying in Control – Your Rights

ETHOSGYMS understand the importance of data subjects remaining in control of their personal data. ETHOSGYMS 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 info@ethosgyms.co.uk

The Right of Access

You have the right to access information that ETHOSGYMS hold about you. If you wish to receive a copy of the information that ETHOSGYMS hold, please submit a Subject Access Request form (SAR) which you can request from .info@ethosgyms.co.uk. Once ETHOSGYMS 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 ETHOSGYMS will be happy to provide you with copies of the information you request, ETHOSGYMS nevertheless reserve the right, in accordance with section 8(2) of the DPA, not to provide you with copies of the 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 ETHOSGYMS at any time to change, amend or pseudonymise the information that ETHOSGYMS hold about you or restrict ways in which your data may be processed. You can update ETHOSGYMS with amendments of personal information by submitting a request through the member services area of our website.

To pseudonymise the information, or object/request restriction of processing then please email info@ethosgyms.com

ETHOSGYMS will aim to respond to any request as soon as possible, but no later than 1 month since receipt of the 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 ETHOSGYMS to another organisation (this is called “data portability”). Please contact us at info@ethosgyms.co.uk with the details of what you would like for ETHOSGYMS to do and ETHOSGYMS will endeavour to comply with your request. It may not be technically feasible, but ETHOSGYMS will work with you to try and find a possible solution.

Right to Prevent Automated Decision Making

You have a right to ask ETHOSGYMS to stop any automated decision making. ETHOSGYMS do not intentionally carry out such activities, but if you do have any questions or concerns ETHOSGYMS would be happy to discuss them with you so please email any concerns or queries to info@ethosgyms.co.uk

9. Privacy Policy Changes

ETHOSGYMS may make slight changes to the Privacy Policy, Terms and Conditions and Gym Rules, 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. ETHOSGYMS 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.ETHOSGYMS.com).

10. Contact

If you have any questions, comments or concerns about data privacy at ETHOSGYMS, please e-mail through a description to info@ethosgyms.co.uk and ETHOSGYMS will endeavour to resolve the issue for you. Alternatively, should you wish to escalate any concerns or questions, rather than contact ETHOSGYMS directly, please contact the supervisory authority The Information Commissioner’s Office (ICO). For more information please visit the ICO’s website https://ico.org.uk/.