As you may be aware there is new Data Protection Legislation came in to force in the UK on 25th May 2018. The General Data Protection Regulation (GDPR), is EU wide legislation, and is currently being enacted into UK law and will become the 2018 Data Protection Act. As a Member of PPS, we are obligated to advise you how we will be handling your data to comply with the new General Data Protection Regulation (GDPR). We have created this privacy statement for in order to demonstrate our firm and continuing commitment to the privacy of personal information provided by those visiting and interacting with. We hold the privacy of your personal information in the highest regard.
We recognise the importance of protecting your privacy and our policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us and to assist you in making informed decisions. This policy will be continuously assessed against new technologies, business practices and our customers’ needs.
What are the Organisation's details?
Studio 1F13, The Biscuit Factory
4-6 Anderson Place, Edinburgh
What does consent mean?
Consent means that the individual (You) have given clear consent for us the business to process your personal data for a specific purpose.
What information do we need?
To join classes at Pivot Pole Studio, we require you to complete a health and safety PAR-Q (Physical Activity Readiness Questionnaire). The information required for this is your name, phone number, email address, home address, date of birth, as well as information about your health, sports and fitness experience and the name, phone number of your emergency contact. We may also, from time to time, take photos and video recordings of classes for social media and promotions, or share your images and videos. This is always with your permission and consent.
How does PPS collect your data?
When you visit the website listed below, you will provide us with two types of information: personal information you knowingly choose to disclose that is collected on an individual basis and websites use information collected on an aggregate basis as you and others browse the website.
Why do we need it, how will we use it and how long will we retain it?
We require all the details above in order to ensure it is safe for you to participate in our classes, or if we need to make modifications to our lessons to benefit you. We will store your information indefinitely in our secure system, or for 5 years after you have finished attending classes at Pivot Pole Studio. You do not have to share your details with us, but if you do not we cannot allow for you to participate in class at Pivot Pole Studio. Pivot Pole Studio may also use your email address or phone number to get in touch with you in case of class reminders or emergency/last minute class amendments/ cancellations.
We will only use your data for the purpose for which it was collected. Broadly speaking, we use personal information for purposes of administering our business activities, providing the products and services you requested, to process your payment, to monitor the use of the service, our marketing and promotional efforts and improve our content and service offerings, and customize our site’s content, layout, services and for other lawful purposes. These uses improve our services and better tailor it to meet your needs.
How long will PPS keep my personal data and what if I change my mind?
The ‘Right to be Forgotten’ applies when the personal data is no longer necessary for the purpose, which we originally collected or processed it for.
However please note it is a condition of our Insurance Policy and generally accepted UK wide to take and retain client records. These records shall be kept for at least 7 years following the last occasion on which session was booked or attended. In the case of session involving minors, it is advisable that records should be kept or at least 7 years after they reach the age of majority (18). After which your information will be securely erased as requested.
How will PPS store my data?
For Members who joined prior to November 2018, a paper form of our PAR-Q Health & Safety form will have been completed. These have now been shredded at PPS’ private residency.
If your personal information is kept online it will be securely via those listed below.
What systems that are online is my information kept and therefore have their own GDPR policies?
· Go Team Up (Pivot Pole Studio)
From time to time, Pivot Pole Studio would like to send you information about the services we offer, events or special offers, using the information you have provided (predominantly email), however you need to agree and willingly opt in to receive our newsletter. You may unsubscribe from our newsletters at any point by clicking “unsubscribe” or emailing us at firstname.lastname@example.org.
Will we share your information?
No, Pivot Pole Studio will never share your data with anyone else. We may, from time to time, take photos and video recordings of classes for social media and promotions, or share your images and videos. Pivot Pole Studio will always ask permission from the owner to share your images/ videos publicly and you are under no obligation to agree to sharing.
Can I make a complaint if I feel you are not handling my data correctly?
Yes, please contact us in the first instance on email@example.com if you have any questions or issues with our private policy or the information we hold on you. Should you be unhappy with our response you can also contact the ICO (Information Commissioners Office. You can find their contact details here at: https://ico.org.uk/make-a-complaint/
Who has access to my information?
Only those who need to see your information to fulfil the business requirements will see your information. This will be Jess Knapper, the Owner & Lead Instructor of Pivot Pole Studio. Personally identifiable information or business information will not be shared with parties except as required by law. Health & safety information will be shared (where relevant such as when your health may be impacted by certain activities in class) with other Pivot Pole Studio Instructors.
What about legally compelled ‘Disclosure of Information’?
We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights. We may also disclose account information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Service or to protect the safety of our users and the Public.
Can I see what information is held about me?
Individuals have the right to access their personal data and supplementary information known as a ‘Subject Access Request’.
The fee of £30 per request is based on the administrative cost of providing the information.
Information will be provided without delay and at the latest within one month of receipt.
However please note you do have access to all of the information we hold, which you have provided via your booking account, the above administrative fee would apply if you wish to have physical copies of such information.
Sharing & Selling Information:
We do not share, sell, lend or lease any of the information that uniquely identify a client (Such as email addresses or personal details) with anyone except to the extent it is necessary to process transactions or provide services that you have requested.
Can I have my information updated?
Most certainly yes, we request that your information is as up to date as possible in order for us to provide the best services possible. You have the right to have inaccurate personal data rectified, or completed if it is incomplete. You can make a request for rectification in writing. We have one calendar month to respond to a request from date of receipt, although for reasons stated above we will endeavour to meet such request as soon as physically possible.
Do you review the GDPR and Privacy Information?
We will post any changes here, so be sure to check back periodically.
Acquisition or changes in ownership:
In the event that the web site (Or a substantial portion of its assets) is acquired, your information would be considered part of those assets, and may be part of those assets that are transferred.
Our commitment to data security:
Please note that your information will be stored and processed on our computers in the United Kingdom.
The laws on holding personal data in the United Kingdom may be less stringent than the laws of your Country of residence or citizenship.
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
When you visit the website listed below, you will provide us with two types of information: personal information you knowingly choose to disclose that is collected on an individual basis and websites use information collected on an aggregate basis as you and others browse the websites.
Website Use Information:
Similar to other commercial websites, our website utilizes a standard technology called “cookies” (See explanation below) and web server log files to collect information about how our website is used.
Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our websites, the websites visited just before and just after ours listed above.
What are ‘Cookies’?
A cookie is a very small text document, which often includes an anonymous unique identifier.
When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies.
Each website can send its own cookie to your browser if your browser’s preferences allow it, but (To protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Browsers are usually set to accept cookies.
A cookie cannot retrieve any other data from your hard drive or pass on computer viruses.
How do we use information we collect from Cookies?
Cookies, in conjunction with our Web server’s log files, allow us to calculate the aggregate number of people visiting our websites and which parts of the site are most popular.
This helps us gather feedback to constantly improve our websites and better serve our clients.
Cookies do not allow us to gather any personal information about you and we do not intentionally store any personal information that your browser provided to us in your cookies.
IP addresses are used by your computer every time you are connected to the Internet.
Your IP address is a number that is used by computers on the network to identify your computer.
IP addresses are automatically collected by our web server as part of demographic and profile data known as traffic data so that data (Such as the Web pages you request) can be sent to you.
What about other websites linked to our websites?
We are not responsible for the practices employed by websites linked to or from our websites or the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our websites.