FitStudioZ Privacy & Cookies Statement
Easy Studios Limited (trading as "FitStudioZ"), of3-5 Woolwich Road, Greenwich, SE10 0RA("us", "we" or "FitStudioZ") has prepared this Privacy & Cookies Statement ("Statement") for personal trainers who are interested in or use the StudioZ, personal trainers' clients and anyone else who visits and interacts with our website ("you"). In connection with your use of our website and the StudioZ, we have to process your personal data. We think that it is very important that you understand how we use your personal data, and we take our obligations in this regard very seriously. The purpose of this Statement is therefore to give you information about how FitStudioZ collects, processes, stores and otherwise uses information about you, and your rights in relation to that information.
The Firm needs to process your personal data in order to interact with you and process your booking. If we are not able to carry out the processing activities we describe in this Statement we may not be able to communicate with you or continue with your booking. Of course, we hope it would never come to that, and this is simply information we are obliged to provide to you as part of this Statement.
We may need to ask for your specific consent to process your personal data in a particular way in certain circumstances, such as for the purpose of marketing emails where you are not an existing customer.
In this Statement you will see reference to "GDPR" - that refers to the European Union General Data Protection Regulation which is a European law governing your rights in relation to your personal data, and how organisations should protect it.
We may update this document from time to time, for example if we implement new systems or processes that involve the use of personal data.
What categories of personal data does FitStudioZ collect about me?
"Personal data" means any information relating to you. We will collect, process and use the following categories and types of personal data about you:
· identification data, such as your first and last name, photo (if voluntarily provided by you), and CCTV images (if you visit us),
· personal information, such as your emergency contact details and personal bio;
· contact details, such as your home address, telephone number and email address
· experience, such as your qualifications, work experience and personal bio;
· device data, [computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Sites (Usage Data).]
together "Your Data".
In addition to the collection, processing and use of Your Data, we collect, process and use the following special categories of personal data about you which we describe as "Sensitive Data":
medical data, such as information on disability or medical conditions.
Why does FitStudioZ need to collect, process and use my personal data and what is the legal basis for doing so?
We collect and use Your Data and Sensitive Data for a variety of reasons linked to our communication with you and processing your booking (the "Processing Purposes"). However, we can only collect and use this data if we have a valid legal basis for doing so, and we are required to explain the various legal bases that we rely on to you.
To give you the full picture, we have set out each of the reasons why we collect and use Your Data, i.e., the Processing Purposes, and mapped these against the different legal bases that allow us to do so.
1. Administering and processing your booking with the StudioZ including identification data and contact details.
Processing Purposes 1 to 3:
· Legitimate interests of the Firm.
2. To determine your eligibility for the role as a FitStudioZ personal trainer, including identification data, contact details, information about your qualifications and work experience.
3. To promote your services on our website, including identification data, contact details, your personal bio which may include information about your qualification and employment history.
4. Communicating with you, including identification data and your contact details.
5. To send marketing emails, including identification data and your contact details.
Processing Purpose 4 and 5:
· Your consent as data subject - you will opt-in to be contacted about our services and future events and deals (except where you are an existing customer); and
· Legitimate interests of FitStudioZ.
6. Responding to and complying with requests and legal demands from regulators or other authorities in or outside of your home country which involves the processing of identification data and contact details.
Processing Purpose 6:
· Compliance with legal obligations which FitStudioZ is subject to.
Below are the Processing Purposes and corresponding Legal Bases for Sensitive Data:
1. To accommodate your use of the StudioZ and for compliance with legal obligations, we may use health and medical data.
· Your explicit consent as allowed by local data protection law.
We appreciate that there is a lot of information to take in, and we want to be as clear with you as possible over what this means. Where we talk about "legitimate interests" of FitStudioZ, this can include:
Assessing your suitability for representing FitStudioZ;
Managing FitStudioZ's business operations effectively;
Advertising and promoting your personal training services;
Manging your booking and allocating booths;
Compliance with our legal obligations.
When relying on the legitimate interests basis for processing your personal data, we will balance the legitimate interest pursued by us and any relevant third party with your interest and fundamental rights and freedoms in relation to the protection of your personal data to ensure it is appropriate for us to rely on legitimate interests and to identify any additional steps we need to take to achieve the right balance.
Got it - but who might FitStudioZ share my personal data with?
FitStudioZ may transfer personal data to third parties for the Processing Purposes as follows:
Data Processors. As necessary for the Processing Purposes described above, personal data may be shared with one or more third parties to process personal data under appropriate instructions. The Data Processors may carry out instructions related to processing payments, and will be subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal data, and to process the personal data only as instructed.
Although we do not currently transfer data outside of the UK, if this changes, we shall comply with the data protection regulations by ensuring we provide an adequate level of protection of personal data, to ensure that your data is protected when transferred outside the European Economic Area.
How long will FitStudioZ keep my personal data for?
It is our policy not to keep personal data for longer than is necessary. We hold your data for [2 years] after your last contact with FitStudioZ, unless there is a legitimate business reason to hold the data for longer or where applicable local law requires us to do so. For further information, please contact us as set out below to request further details.
How does FitStudioZ protect my personal data?
We have implemented technical and organisational measures in an effort to safeguard any personal data in our custody and control.
While we endeavour to always protect our systems, website and personal data against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet and other risk factors, we cannot guarantee that any personal data, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.
You also have an important role in protecting personal data. You should not share any username, password or other authentication data provided to you with anyone, and we recommend that you do not re-use passwords across more than one website or application. If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.
We use [cookies, web beacons, and similar tracking technologies] (collectively, "cookies") on our website.
What are cookies?
Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognised when you return to a websites.
Cookies on our website are generally divided into the following categories:
Strictly Necessary Cookies:These are required for the operation of our websites. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies that are erased when you close your browser.
Analytical/Performance Cookies:These allow us to recognise and count the number of users of our website and understand how such users navigate through our website. This helps to improve how our website works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser.
Functional Cookies:These improve the functional performance of our website and make it easier for you to use. For example, cookies are used to remember that you have previously visited the website and asked to remain logged into it. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our website. You can delete these cookies via your browser settings.
Targeting Cookies:These record your visit to our website, the pages you have visited and the links you have followed to recognise you as a previous visitor and to track your activity on the website. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our website. You can delete these cookies via your browser settings.
What are your options if you do not want cookies on your computer?
You can review your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Sites, and you may be required to re-enter your log-in details.
What rights do I have in respect of my personal data?
You have a number of rights in relation to Your Data and Sensitive Data. These include:
(i) Right of access
You have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right, and if you want to request more than one copy we may charge a fee.
(ii) Right to rectification
You may have the right to rectify inaccurate or incomplete personal data concerning you. We encourage you to review this information regularly to ensure that it is accurate and up to date.
(iii) Right to erasure (right to be forgotten)
You may have the right to ask us to erase personal data concerning you.
(iv) Right to restriction of processing
In limited circumstances, you may have the right to request that we restrict processing of your personal data, however where we process Your Data and Sensitive Data for the Processing Purposes where we think that we have a legitimate interest in processing, these may override a request that you make.
(v) Right to data portability
You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity.
(vi) Right to object and rights relating to automated decision-making
Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision. We do not currently use any automated decision-making.
To exercise any of these rights, please contact us as stated under below (Who can I contact about this stuff?).
You also have the right to lodge a complaint with the competent data protection supervisory authority, which in the UK is the Information Commissioner's Office (the 'ICO').
Who can I contact about this stuff?
If you have concerns or questions regarding this Statement or if you would like to exercise your rights as a data subject, you can get hold of the right person here: support@FitStudioZ.com