Fair Processing Notice

Pulse Fitness Ltd. / Rock Merchanting Ltd. are committed to maintaining the accuracy, confidentiality, and security of your personal information. This Fair Processing Notice describes the personal information that Pulse Fitness Ltd. / Rock Merchanting Ltd. collects from or about you, and how we use and to whom we disclose that information.

What Personal Information Do We Collect?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications. Personal information does not include anonymous or non-personal information.

We collect and maintain different types of personal information in respect of those individuals who sign up to our PulseMove App, who join the facilities, who become members of the facility, who are guests using the facilities or who have shown an interest in the facilities including the personal information contained in:

- Online joining web pages

- Details inputted when downloading the PulseMove App

- in the facility at reception for guests, leads or prospects

- in the facility with a member of the sales team

- online information request forms

In addition to the examples listed above, personal information also includes information such as name, home address, telephone, personal email address, date of birth, photograph finger print, bank details, and any other information necessary to Pulse Fitness Ltd. / Rock Merchanting Ltd. business purposes, which is disclosed in the course of your participation within the facility.

As a general rule, Pulse Fitness Ltd. / Rock Merchanting Ltd. collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions). An example of this would be a member has offered your details regarding refer a friend campaigns in the fitness suite.

From time to time, we may use the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us. In that case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Why Do We Collect Personal Information?

The personal information collected is used to provide you with a membership of the facility, to access the facility, to download and use the PulseMove App

- in order to provide you with access to the facilities

- in order to all provide you with a leisure experience

- in providing you with a membership contract

- to allow you to download, log in and utilise the PulseMove App

- to be able to provide a safe workout for you if you have medical history which the staff would need to know about through a PARQ form.

- in order to provide you with the necessary information you request on a regular basis

- to provide you with a direct debit collection for membership service

- such other purposes as are reasonably required by Pulse Fitness Ltd. / Rock Merchanting ltd.

Monitoring

The PusleMove App will monitor and track your GPS tracking as indicated by you whilst using the mobile app. This information is used to help you determine the advantages of using mobile tracking devises for your personal use. Whilst within the fitness suite your workout will be recorded and monitored by the fitness staff in order to provide you with the best experience and to get the most out a physical activity programme.

How Do We Use Your Personal Information?

We may use your personal information for the purposes described in this Policy, or for any additional purposes that we advise you of and where your consent is required by law we have obtained your consent in respect of the use or disclosure of your personal information.

We will use your details at the point of signing up to authorise your address, bank details i.e. sort code and account number are linked to a bank through Postcode Anywhere which is built into the sign up system.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

When Do We Disclose Your Personal Information?

We will not disclose your personal information unless

- as permitted or required by applicable law or regulatory requirements. In such a case, we will not disclose more personal information than is required under the circumstances;

- to comply with valid legal processes such as search warrants, subpoenas or Court orders;

- as part of Pulse Fitness Ltd. / Rock Merchanting Ltd. regular reporting activities;

- to protect the rights and property of Pulse Fitness Ltd. / Rock Merchanting Ltd.;

- during emergency situations or where necessary to protect the safety of a person or group of persons;

- where the personal information is publicly available; or

- with your consent where such consent is required by law.

Notification and Consent

The personal information provided by you as the customer will always be provided prior to any contract being agreed for memberships or before you activate the PulseMove App. In providing this information you are consenting to Pulse Fitness Ltd. / Rock Merchanting Ltd. having this information in order to provide you the necessary service and/or product or access to any facility. In addition, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

To the extent that your consent is required, we will assume, unless you advise us otherwise, that you have consented to Pulse Fitness Ltd. / Rock Merchanting Ltd. collecting, using and disclosing your personal information for the purposes stated above. Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent.

How is Your Personal Information Protected?

Pulse Fitness Ltd. / Rock Merchanting Ltd. endeavours to maintain physical, technical, and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorised access, copying, use, modification, or disclosure.

How Long is Your Personal Information Retained?

Except as otherwise permitted or required by applicable law or regulatory requirements, Pulse Fitness Ltd. / Rock Merchanting Ltd. will retain your personal information only for as long as it believes is necessary to fulfil the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you. In most cases your data will be deleted 6 years after you stopped using the facilities as a full member. If you have stopped using the PulseMove App then after 30 months we will communicate to you before deleting your personal data. Guest, lead and prospect personal data will remain for 3 ½ years after entry to the facilities.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your membership, please keep us informed of such changes or you can log into your online portal to update your details.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Your Personal Information

You can ask to see the personal information that we hold about you. Please note that any such communication may be required in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. If the personal information we hold about you will take considerable amount of time to gather we may charge you a fee to access your personal information; however, we will advise you of any fee in advance otherwise your subject access request is free.

If we cannot provide you with access to your personal information, we will try to inform you of the reasons why, subject to any legal or regulatory restrictions.

Your other legal rights

Data protection legislation also provides you with certain other rights. These are not always absolute rights and must be considered in the wider scope of the legislation. These rights are:

right to erasure, also known as the right to be forgotten. The broad principle underpinning this right is to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing. In some circumstances this is not an absolute right;

right to restrict processing. You have the right to ‘block’ or suppress processing of personal data. Again, this is not an absolute right and will depend on the circumstances and any other legal/statutory obligations Pulse Fitness Ltd. / Rock Merchanting Ltd. may have;

right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling).

rights related to automated decision making including profiling. This is unlikely to apply in the circumstances of your membership.

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