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 we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy:
Personal information we collect about you
We may collect and use the following personal information about you:
• your name and contact information, including email address, postal address and telephone number
• Information to enable us to check and verify your identity, eg your date of birth
• your gender information
• your billing information, transaction and payment card information
• your contact history and purchase history
• information from accounts you link to us, eg Facebook
• Information about how you use our website, IT, communication and MindBody
• Health information, including medical issues and concerns.
This personal information is required to provide productsand services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and 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 emailand/or via our websiteand apps. However, we may also collect information:
• from a third party with your consent, eg your bank or building society, physiotherapist or other medical person.
• from cookies on our websit
• via our IT systems, eg:
– Mindbody and reception logs;
– automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems;
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 following table explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide products and services to you||For the performance of our contract with you to provide pilates, yoga and barre classes|
|Conducting checks to identify our customers and verify their identity 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||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, eg policies covering security and internet use||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||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price|
|Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorised access and modifications to systems||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 enhancingcustomer records||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|
|Ensuring safe working practices, staff administration and assessments||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|
|Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.||For our legitimate interests or those of a third party, ie to promote our business to existing and former customers|
|External audits and quality checks, eg the audit of our accounts||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|
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and 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 it with other organisations outside the Akasha Wellness group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
• contacting us at email@example.com
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
• updating your marketing preferences on our MindBody system.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and 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 services to you, eg payment service providers;
• other third parties we use to help us run our business, eg 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;
• credit reference agencies;
• our insurers and brokers;
• our bank;
• our freelance instructors.
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 relating 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.
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.
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 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.
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|
|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, call or write to see below: ‘How to contact us’; and
• let us have enough information to identify you (eg your full name, address and customer or matter 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 will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we 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.
This privacy notice was published on 15 May 2018 and last updated on 15 May 2018.
We may change this privacy notice from time to time—when we do we will inform you via email.
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How to contact us
Our contact details are shown below:
Akasha Wellness, The Barley Barn, Wickham Hall, Hadham Road, Bishop’s Stortford, CM23 1JG
Tel: 01279 757633