privacy policy
Welcome to the Drop Gym & Co Limited (“Drop Gym”) privacy policy.
INTRODUCTION
Welcome to the Drop Gym & Co Limited (“DropGym”, "we", "us" or "our") privacy policy, which we have implemented as we collect information about you via our website, app and through our interactions and communications with you in person, by telephone, by email and by SMS text message/instant messaging (which we refer to collectively as “services” in this policy).
At DropGym your privacy is our number one priority and we have taken great care to ensure that we comply with all data protection legislation in the UK to maintain your privacy and keep your data safe and secure.
This privacy policy will inform you as to how we look after your personal data when you use our services (regardless of where you visit our website/app or contact us from) and tells you about your privacy rights and how the law protects you.
If you are accessing this privacy policy online, through our app or on your computer, tablet or phone, this privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW YOUR PERSONAL DATA IS COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. LEGAL BASIS FOR PROCESSING OF PERSONAL DATA
6. DISCLOSURES OF YOUR PERSONAL DATA
7. INTERNATIONAL TRANSFERS
8. DATA SECURITY
9. DATA RETENTION
10. YOUR LEGAL RIGHTS
11. GLOSSARY
12. CCTV POLICY
13. COOKIES
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of our services, including any data you may provide to us by using the services.
Our services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
DropGym is a trading name of Drop Gym & Co Limited, which is the controller of, and is responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Drop Gym & Co Limited (12747420)
Email address: hello@dropgym.io
Postal address: First Floor, 5 Fleet Place, London, EC4M 7RD
Telephone number: 020 4574 9755
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 22nd December 2022. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our services may include links to third-party websites, plug-ins and apps. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or apps and are not responsible for their privacy statements. When you stop using our services to use any third-party services, we encourage you to read the privacy policy of every service that you use.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
● Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
● CCTV images of you (when you are using our gyms). Please see our CCTV policy below at section 12.
● Contact Data includes billing address, delivery address, email address and telephone numbers.
● Financial Data includes bank account and payment card details.
● Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
● Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our services.
● Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
● Usage Data includes information about how you use our services.
● Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
● Due to the nature of the DropGym services, we may also collect, use and share certain Special Categories of data as follows:
● Genetic data.
● Biometric data in the form of facial recognition technology as set out below.
● Data concerning your health.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity, either on its own or in conjunction with any other information. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific service feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, using our website/app or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
● apply for our products or services;
● create an account on our website/app;
● subscribe to our services or publications;
● request marketing to be sent to you;
● enter a competition, promotion or survey; or
● give us feedback or contact us.
Automated technologies or interactions. As you interact with our services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section 13 below for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
● analytics providers such as Google;
● advertising networks; and
● search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
● Where we need to perform the contract we are about to enter into or have entered into with you.
● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
● Where we need to comply with a legal obligation.
Scroll down to the glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
5. LEGAL BASIS FOR PROCESSING OF PERSONAL DATA
Purposes for which we will use your personal data
We have set out below a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We will use the following personal data about you in the following ways and on the following legal bases:
● On the basis that it is necessary to perform our contract with you, to register you as a new user or member of our services, including by processing:
(a) Identity Data
(b) Contact Data
● On the bases that it is in our legitimate interests and necessary for the performance of our contract with you to process, administer and deliver our services to you, including to allow you access, to manage payments, fees and charges, and to collect and recover money owed to us, including by processing:
(a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
● On the bases that it is in our legitimate interests, that it is necessary to perform our contract with you, and that it is necessary in order for us to comply with a legal obligation, to manage our relationship with you, including by notifying you about updates to our servicesor our terms or privacy policy, and by asking you to leave a review or take a survey, including by processing:
(a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Marketing and Communications Data
● On the bases that it is in our legitimate interest to study how customers use our products/services to develop them and grow our business and that it is necessary to perform our contract with you, to enable you to partake in a prize draw, competition or complete a survey including by processing:
(a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Usage Data
(e) Marketing and Communications Data
● On the bases that it is in our legitimate interests to run our business, to provide administration and IT services, to provide network security, to prevent fraud, and in the context of a business reorganisation or group restructuring exercise, and that it is necessary in order for us to comply with a legal obligation, to administer and protect our business and our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), including by processing:
(a) Identity Data
(b) Contact Data
(c) Technical Data
● On the basis that it is necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, including by processing:
(a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Usage Data
(e) Marketing and Communications Data
(f) Technical Data
● On the basis that it is necessary for our legitimate interests to define types of customers for our products and services, to keep our app and website updated and relevant, to develop our business and to inform our marketing strategy, to use data analytics to improve our products/services, marketing, customer relationships and experiences, including by processing:
(a) Technical Data
(b) Usage Data
● On the basis that it is necessary for our legitimate interests to develop our products/services and grow our business, to make suggestions and recommendations to you about goods or services that may be of interest to you and new services, including by processing:
(a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Profile Data
(f) Marketing and Communications Data
● On the basis that it is necessary for our legitimate interests to protect the health and wellbeing of our members, and that it is necessary for your vital interests, to use your personal data to protect your health and wellbeing, including where necessary to allow your data to be shared with a third party, for example if you suffer any significant injuries or health problems while using our services, including by processing and/or sharing:
(a) Identity Data
(b) Contact Data
(c) Genetic Data
(d) Biometric Data
(e) Health Data
Special Categories of data
In the course of providing our services to you, we will collect information that is considered “special category data” for example:
● you may provide health data when we ask you to complete our health, training and/or nutrition questionnaire(s); and
● you may provide biometric data for the purposes of facial recognition.
(1) Health Data:
We will only use your health data with your explicit consent. However, as the nature of our services includes comprehensive assistance with your health, training and nutrition, we are unable to provide our services to you if you do not consent to us using your health data. In order to give your consent to the processing of special category data, you will be required to provide an explicit consent to our processing of your special category health data.
(2) Biometric Data:
The only time we use biometric data is as part of our CCTV system. Some cameras in our gyms (but not all) use facial recognition technology to recognise whether an individual who is not a member has accessed our gym. This is done for the purposes of reducing any criminal activity in the gym (such as theft of personal belongings of members) and other unlawful accessing of our premises. We use this biometric data on the legal basis that it is necessary for our legitimate interests to prevent and reduce crime and other unlawful activity. We use this biometric data on the basis that to do so is in accordance with the substantial public interest condition, specifically for the prevention or detection of unlawful acts.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We may send you direct marketing communications in relation to similar products or services that we provide that may be of interest to you (provided that you have an absolute right to opt-out of any of these communications at any time, including at the time of providing us your personal data or at any time thereafter).
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting-out
You can ask us to stop sending you marketing messages at any time by contacting us at First Floor, 5 Fleet Place, London, EC4M 7RD or by email using hello@dropgym.io.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, subscription, warranty registration, product/service experience or other transactions.
Automated decision making and profiling
We may use your personal data for the purposes of automated decision making or profiling but will notify you beforehand to provide you detailed information in relation to the auto-decision logic used and about the significance and the consequences for you of any automated decision-making or profiling.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where it is authorised by law.
- Where it is necessary to perform any contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at First Floor, 5 Fleet Place, London, EC4M 7RD or by email using hello@dropgym.io.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the Legal Basis for Processing of Personal Data section above. In addition, we will share your personal data with:
● External Third Parties as set out in the Glossary section below.
● Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
● Third parties to assist you should you suffer any significant injury or health problems while using our services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS
We may share or transfer your personal data outside of the UK or the European Economic Area (EEA).
Some of our external third parties may be based outside the UK or EEA so their processing of your personal data will involve a transfer of data outside the UK or EEA.
Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
● We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. These countries include: Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man,Japan, Jersey, New Zealand, Republic of Korea, Switzerland and Uruguay; or
● Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic informationabout our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. YOUR LEGAL RIGHTS
In addition to the right to be informed, under certain circumstances you have rights under data protection laws in relation to your personal data. Please scroll to the relevant heading in the glossary to find out more about these rights:
● Request access to your personal data (Subject Access Request ‘SAR’).
● Request correction of your personal data.
● Request erasure of your personal data.
● Object to processing of your personal data.
● Request restriction of processing your personal data.
● Request transfer of your personal data.
● Right to withdraw consent.
● Rights related to automated decision making and profiling.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. GLOSSARY
LAWFUL BASIS
In assessing legitimate interest, we make sure we consider and balance any potential impact on you (both positive and negative) and your rights and freedoms before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
External Third Parties
● Service providers based worldwide who provide marketing, IT and system administration services, and CCTV services.
● Professional advisers including lawyers, bankers, auditors and insurers based worldwide who provide consultancy, banking, legal, insurance and accounting services.
● HM Revenue & Customs, regulators and other authorities based worldwide who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
● Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
● Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
● Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
● Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
● Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
o If you want us to establish the data's accuracy.
o Where our use of the data is unlawful but you do not want us to erase it.
o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
● Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
● Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
● Be notified in respect of any automated decision-making or profiling in respect of your personal data.
● Request meaningful information about the auto-decision logic used in any automated decision-making or profiling anda bout the significance and the consequences of any automated decision-making or profiling.
● Object to automated decision-making or profiling of your personal data.
12. CCTV POLICY – the use of closed circuit television (CCTV)
At DropGym, we believe that CCTV plays a legitimate role in helping to maintain a safe and secure environment for everyone and protects the integrity of our sites by deterring criminals and to provide evidence to assist with the detection and prosecution of criminal offences.
The purpose of this policy is to enable you to understand how DropGym uses CCTV, who is responsible for CCTV use, the rights you may have in relation to CCTV, who has access to the CCTV images and how you can raise concerns or obtain further information in relation to DropGym’s use of CCTV.
Why we use CCTV
We currently use CCTV at our sites. We believe it is necessary for the following legitimate business purposes:
- to prevent or detect crime or disorder;
- to protect our buildings and assets from damage, disruption, theft and other crime; and
- for the health and safety of those using the facility, equipment and amenities.
Monitoring and operating the CCTV
Where we use CCTV, we ensure that signs are displayed at the entrance of the surveillance zone to alert you that your image may be recorded.
Our CCTV is in the most suitable location to ensure that it provides clear images. We carry out regular checks to ensure the system is continuing to produce high quality images.
CCTV operators must be trained to an adequate standard and such standard must be maintained at all times.
DropGym is the controller for the personal data captured by its CCTV systems.
The CCTV systems which are under DropGym’s control are operated by a dedicated CCTV team. The recordings are confidential and available only to those operating the system. Copies of recorded information are strictly controlled and only made in relation to incidents under specific restrictions.
How we use the data
Data recorded by our CCTV will be stored locally on our servers and backed up on cloud storage. We will not retain this data indefinitely but will permanently delete it in accordance with our Data Retention Policy.
Rights of data subjects
The images obtained from the system which include individuals are personal data and are covered by data protection laws. Data subjects have certain rights in relation to personal data concerning them. For example, data subjects have the right to request a copy of their image. We will provide information to you without delay and at the latest within one month of receipt of the data subjects request.
Requests of disclosure by third parties
We will not disclose any images from our CCTV cameras to third parties without express authorisation given by our IT Operations Department and such data will only be disclosed to a third party in accordance with the data protection legislation.
In other appropriate circumstances, we may allow law enforcement agencies to view CCTV footage where this is required in the detection or prosecution of crime.
Third party service providers
Our service providers provide maintenance services for our cameras. Our service providers only act on our instructions and for the legitimate purposes set out above. We require the service providers to safeguard the privacy and security of personal data which they process on our behalf.
13. COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when apps or websites setor access cookies. If you disable or refuse cookies, please note that some parts of our services may become inaccessible or not function properly. For more information about the cookies we use, please see here.
WE CARE
