Privacy Policy
Invictus Fitness Centre believe in transparency, and are committed to being upfront about privacy practices, including how your personal information is treated. Invictus Fitness Centre have undertaken an extensive exercise to ensure ongoing compliance with the European Union General Data Protection Regulation (EU GPDR).
Invictus Fitness Centre 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 Invictus Fitness Centre, as well as describing the types of personal information that Invictus Fitness Centre 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 Invictus Fitness Centre use your Personal Information
4. Communication from Invictus Fitness Centre
5. Sharing your Information
6. Keeping your Information Secure
7. Invictus Fitness Centre Retention Policies
8. Staying in Control - Your Rights
9. Privacy Policy Changes
10. Contact
1. ACCEPTING THE PRIVACY POLICY
Invictus Fitness Centre need to process your personal information to run their business and provide you with their services. Upon visiting Invictus Fitness Centre in the studio, contacting Invictus Fitness Centre by telephone, or visiting Invictus Fitness Centre website(s), you are accepting and consenting to the practices described in this Privacy Policy.
INFORMATION COLLECTED OR RECEIVED
Invictus Fitness Centre collect personal information from studio users, 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.
Invictus Fitness Centre 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 Invictus Fitness Centre do not generally collect sensitive information unless it is volunteered by you, Invictus Fitness Centre 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, Invictus Fitness Centre 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.
Digital: When visiting Invictus Fitness Centre website(s), 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 Invictus Fitness Centre or register for a tour of Invictus Fitness Centre using an external third-party application, such as Facebook, Instagram, or Twitter, these websites will have their own privacy statement which Invictus Fitness Centre suggest that you read before giving them your personal information. Connecting to Invictus Fitness Centre via a third-party application or service is optional and at your own discretion.
Invictus Fitness Centre 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 Invictus Fitness Centre USE YOUR PERSONAL INFORMATION
The information in the above, section 2, may be used for the following purposes:
- To carry out To carry out Invictus Fitness Centre’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 Invictus Fitness Centre platform;
- To prevent or detect abuses of the Invictus Fitness Centre website;
- To create business performance statistics and analysis;
- To enable third parties to carry out technical, logistical, research or other functions on behalf of Invictus Fitness Centre;
- To send you newsletters and promotions, prize draws, and competitions;
- To conduct surveys and request feedback;
- To notify you about changes to Invictus Fitness Centre Services, Terms and Conditions, Privacy Policy and Club rules;
- To process your job application if you apply for employment at Invictus Fitness Centre;
- 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 Invictus Fitness Centre services.
Other than as set out in this Privacy Policy Invictus Fitness Centre will not use your personal information for any other purpose without your consent, unless required to do so by law.
4. COMMUNICATION FROM Invictus Fitness Centre
On occasion, Invictus Fitness Centre 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, Invictus Fitness Centre believe that the content is relevant, valuable, interesting and beneficial to you. Invictus Fitness Centre also believe that you would reasonably expect to receive the type of content that is sent to you as part of your relationship with Invictus Fitness Centre.
Therefore, Invictus Fitness Centre’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.
Invictus Fitness Centre recognise that you value having control over your own information, so Invictus Fitness Centre gives you the choice of editing your communication preferences if you disagree with the above. For Invictus Fitness Centre Members and Ex Members you may update these preferences by logging into the Members area through the login page of the website, (https://www.invictusfitnesscentre.co.uk). Alternatively you may email info@invictusfit.co.uk with your request.
Please note the following messages from Invictus Fitness Centre 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 the studio, 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 Invictus Fitness Centre Member Services Support Team).
You may receive communication from Invictus Fitness Centre 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 Invictus Fitness Centre staff via Outlook: To opt out you can do either of the following, log into the members area on the website to update your communication preferences within the My Profile section. You can also request this specifically to info@invictusfit.co.uk
5. SHARING YOUR INFORMATION
Information about Invictus Fitness Centre Club users is an important part to the business and Invictus Fitness Centre do not sell it to others. Invictus Fitness Centre shares member information only as described in this Privacy Policy.
Enquiries through Invictus Fitness Centre website(s): Invictus Fitness Centre capture data through Invictus Fitness Centre website(s) hosted by third parties (Simplar Tech). These can be for purchasing a giftcard, booking a tour online, joining online, referring a friend online, PT enquiries online, corporate enquiries online.
Membership System and Bookings App: In order for Invictus Fitness Centre to process and manage existing and ex Memberships as well as Prospective Members, they use a third party (Simplar Tech) to provide the membership management system. Class bookings can be processed directly via the website hosted by Simplar Tech.
Payment Collection: Invictus Fitness Centre use third parties (Stripe) for payment collection whether that be upfront payment for membership, monthly direct debit payment for membership.
Paperwork Destruction: Invictus Fitness Centre schedule regular collections of paperwork from a third party company (The Hill Company) who securely and confidentially shred this paperwork off site, on behalf of Invictus Fitness Centre.
Invictus Fitness Centre provide anonymous or hashed data to third party advertisers (Facebook), to further understand customer trends and patterns, as well as a way to reach new customers who are likely to be interested in Invictus Fitness Centre, due to having similar interests to existing Invictus Fitness Centre customers.
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/
Invictus Fitness Centre use cookies to identify you when you visit this website and to keep track of your browsing patterns, to build up a demographic profile and to use for advertising purposes. Invictus Fitness Centre 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 Invictus Fitness Centre employees receive full training upon commencement on 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. Invictus Fitness Centre RETENTION POLICIES
Invictus Fitness Centre 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 Invictus Fitness Centre will keep your information for the duration of any Contract that you have entered into with Invictus Fitness Centre, and then for a period of 7 years after, at which time all the personal information will be pseudonymised.
After that 7 year duration, Invictus Fitness Centre will retain and use your pseudonymised information for the purpose of business statistics and analysis. Invictus Fitness Centre can retract this pseudonymisation to the extent necessary to comply with any legal obligations or to resolve disputes
8. STAYING IN CONTROL - YOUR RIGHTS
Invictus Fitness Centre understand the importance of data subjects remaining in control of their personal data. Invictus Fitness Centre 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@invictusfit.co.uk
The Right of Access
You have the right to access information that Invictus Fitness Centre hold about you. If you wish to receive a copy of the information that Invictus Fitness Centre hold, please submit a Subject Access Request form (SAR) which you can request from info@invictusfit.co.uk. Once Invictus Fitness Centre 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 Invictus Fitness Centre will be happy to provide you with copies of the information you request, Invictus Fitness Centre 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 Invictus Fitness Centre at any time to change, amend or pseudonymise the information that Invictus Fitness Centre hold about you or restrict ways in which your data may be processed. You can update Invictus Fitness Centre with amendments of personal information by submitting a request through the member services area of our website using the following link, https://www.invictusfitnesscentre.co.uk
To pseudonymise the information, or object/request restriction of processing then please email info@invictusfit.co.uk
Invictus Fitness Centre 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 Invictus Fitness Centre to another organisation (this is called “data portability”). Please contact us at info@invictusfit.co.uk with the details of what you would like for Invictus Fitness Centre to do and Invictus Fitness Centre will endeavour to comply with your request. It may not be technically feasible, but Invictus Fitness Centre will work with you to try and find a possible solution.
Right to Prevent Automated Decision Making
You have a right to ask Invictus Fitness Centre to stop any automated decision making. Invictus Fitness Centre do not intentionally carry out such activities, but if you do have any questions or concerns Invictus Fitness Centre would be happy to discuss them with you so please email any concerns or queries to info@invictusfit.co.uk
9. PRIVACY POLICY CHANGES
Invictus Fitness Centre may make slight changes to the Privacy Policy, Terms and Conditions and studio 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. Invictus Fitness Centre 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 (https://www.invictusfitnesscentre.co.uk).
10. CONTACT
If you have any questions, comments or concerns about data privacy at Invictus Fitness Centre, please e-mail thorough a description toinfo@invictusfit.co.uk and Invictus Fitness Centre will endeavour to resolve the issue for you. Alternatively should you wish to escalate any concerns or questions, rather than contact Invictus Fitness Centre 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/.
