We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom and elsewhere) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Key terms
It would be helpful to start by explaining some key terms used in this policy:

We, us, our Ashbourne Management Services Limited incorporated and registered in England and Wales with company number 03803567 and whose registered address is at Corner Oak, 1 Homer Road, Solihull, West Midlands, B91 3QG
Our data protection officer Jo Quigley
Email address: dataprotection@ashbournemanagement.co.uk
Personal information Any information relating to an identified or identifiable individual
Special category personal information Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Data concerning health, sex life or sexual orientation
This includes information provided to us by you on the Physical Activities Readiness Questionnaire (“PARQ”)

Personal information we collect about you
We may collect and use the following personal information about you:
▪ Contact Data including your name and contact information, including email address and telephone number and company details
▪ Identity Data including information to enable us to check and verify your identity, e.g. your full name, title, date of birth and gender
▪ Financial Data including your billing information, transaction and payment card information
▪ Profile Data including your contact history, purchase history and saved items and your responses to surveys, competitions and promotions your personal or professional interests
▪ Technical Data information about how you use our website, IT, communication and other systems
▪ Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences
▪ Information from accounts you link to us, eg information stored on your Fitbit which is linked to YourApp+
▪ Location data, if you choose to give this to us
▪ Your professional online presence, eg LinkedIn profile

This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.

How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:
▪ directly from a third party
▪ from a third party with your consent, eg your bank or building society
▪ via our IT systems, eg:
  ▪ door entry systems and reception logs;
  ▪ automated monitoring of our websites and other technical systems, such as our computer networks and connections, and access control systems, communications systems, email and instant messaging systems;

Any personal information which is not obtained directly from you will also be processed in a manner which is compliant with this privacy policy.

How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
▪ to comply with our legal and regulatory obligations;
▪ for the performance of our contract with you or to take steps at your request before entering into a contract;
▪ for our legitimate interests or those of a third party; or
▪ where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for Type of Data Our reasons
To provide products and/or services to you (a) Identity
(b) Contact
(c) Profile
For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you (a) Identity (b)
Contact
For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator
(a) Identity
(b) Contact
(c) Profile
(d) Financial
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies (a) Identity
(b) Contact
(c) Usage
(d) Marketing and communication
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, eg policies covering security and internet use (a) Identity
(b) Contact
(c) Technical
For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control (a) Identity
(b) Contact
(c) Technical
For our legitimate interests or those of a third party, ie to be as efficient as we can so we can delivery the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information (a) Identity
(b) Contact
For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures (a) Identity
(b) Contact
(c) Financial
(d) Marketing and communications
For our legitimate interests or those of a third party, ie to be as efficient as we can so we can delivery the best service for you at the best price
Preventing unauthorised access and modifications to systems (a) Identity
(b) Contact
(c) Profile
For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
Updating and enhancing customer records (a) Identity
(b) Contact
(c) Profile
For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns (a) Identity
(b) Contact
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments (a) Identity
(b) Contact
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts (a) Identity
(b) Contact
For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations

The above table does not apply to special category personal information, which we will only process with your explicit consent.

Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organisations outside the group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:
▪ using the ‘unsubscribe’ link in emails.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with
We routinely share personal information with:
▪ third parties we use to help deliver our products and/or services to you, eg payment service providers, warehouses and delivery companies;
▪ other third parties we use to help us run our business, eg gym owners, marketing agencies or website hosts;
▪ third parties approved by you, eg social media sites you choose to link your account to or third party payment providers; and
▪ our banks

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers in order to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, eg in relation to ISO or Investors in People accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

Where your personal information is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:
▪ to respond to any questions, complaints or claims made by you or on your behalf;
▪ to show that we treated you fairly;
▪ to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Your rights
You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal information (the right of access)
Rectification The right to require us to correct any mistakes in your personal information
To be forgotten The right to require us to delete your personal information—in certain situations
To withdraw consent The right to withdraw your consent at any time by following the steps outlined below. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Restriction of processing The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data
Data portability The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
▪ email or write to us or our Data Protection Officer—see below: ‘How to contact us’; and
▪ let us have enough information to identify you (eg your full name, address and customer or gym reference number);
▪ let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
▪ let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Insert details of any specific security measure that you wish to mention to reassure data subjects, eg encryption technologies (this is purely optional).
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy
This privacy notice was published on and last updated on 14th May 2018.
We may change this privacy notice from time to time—when we do we will inform you via our website or other means of contact such as email.

How to contact us
Please contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:

Our contact details Our Data Protection Officer’s contact details
Ashbourne Management Services Limited,
PO BOX 10920
Shirley
Solihull
B90 8YB
Jo Quigley,
Ashbourne Management Services Limited,
PO BOX 10920
Shirley
Solihull
B90 8YB

Email address: dataprotection@ashbournemanagement.co.uk

Do you need extra help?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).

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