Fit-Hubs – New rules relating to how we collect and process personal data – the EU General Data Protection Regulation (GDPR) – will come into effect in the UK from 25 May 2018
What is GDPR?
The GDPR is Europe’s new framework for data protection laws. It replaces the previous 1995 data protection directive, which current UK law is based upon.
The new regulation started on 25 May 2018. It will is enforced by the Information Commissioner’s Office (ICO).
We respect and uphold individual rights to privacy and the protection of personal information. We know how important it is to protect Your personal information and want to make every customer experience safe and secure. In keeping with that goal, we have developed this Policy to explain our practices for the collection, use, and disclosure of Your personal information.
For the purposes of this Policy, “personal information” means information about an identifiable individual, including, for example, an individual’s height, birth date, name, home address, telephone number, social insurance number, sex, income and marital status. We will only collect, use or disclose personal information in accordance with this Policy, or in accordance with laws applicable to the collection, use and disclosure of Your personal information by us (“Applicable Privacy Laws”).
We have appointed a Privacy Officer who is responsible for our compliance with this Policy. Information on how to contact the Privacy Officer can be found below.
COLLECTION AND USE OF PERSONAL INFORMATION
We collect two types of information through our App: personal information and non-personal information. The types of information we collect depend on the nature of Your interaction with us.
We may collect personal information such as:
Your contact information – for example, Your name and email address;
Your personal preferences – for example, language preferences, and marketing consent; and
Your profile information – for example, photographs You upload, and other information You provide in Your personal profile, such as your Post/Zip Code, country and required fields during the Registration process
Non-personal information does not identify You as an individual. For example:
we may collect certain non-personal data when You visit our Website, such as the type of browser You are using or the referring URL; or
we may collect and summarise customer information in a non-personal, aggregate format for statistical and research purposes. We may, for example, summarize our data to determine that a certain percentage of users are male, aged 18 to 25.
You may choose not to provide us with Your personal information. However, if You make this choice we may not be able to provide You with the service, or information that You requested. For example, we require Your email address in order to verify Your account, which is necessary so that notifications may be sent to You electronically. Should You no longer wish to receive notifications from Fit-Hubs when You receive a message from another Fit-Hubs user or when another user adds You as a favorite, Fit-Hubs will not send You notifications after Your account is deleted.
USE OF PERSONAL INFORMATION
We may use Your personal information for a number of different business purposes, for example to:
create and display Your online Well Being’ establishment profile to other users of the Website/App;
• show other users when You have viewed their profiles;
• compare Your profile and preferences with that of other users to provide both You and other users with recruitment matches;
• provide customer support to assist You with Your questions or complaints;
• conduct surveys in order to improve our services;
• advise You of changes to our services, or new services that we may implement from time to time;
• measure and improve the effectiveness of our Website or our marketing endeavours;
• detect and protect against fraud and error;
• track and analyse Your preferences to better understand Your service needs and eligibility; and
• for other purposes as described in this Policy.
We limit the personal information we collect and use to that which is necessary to fulfill our business purposes. We will not collect, sell, distribute or use personal information for any other purposes without Your further consent, except to the extent as required by law or as authorised by Applicable Privacy Laws.
You can log in to our App using sign-in services. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.
We generally retain your Personal Information only for so long as is necessary for the purpose for which it is used, or required by law. As a Fit-Hubs member, you may use the following options for removing your information from our database or if you wish to opt out of receiving future communications.
Go to our website https://fit-hubs.com and complete the Contact form at the bottom right portion of the page. Or send mail to the following postal address:
Fit-Hubs. – 20-22 Wenlock Road, London. N1 7GU United Kingdom
or contact: Colin Hay. Analytics & Compliance. Fit-Hubs UK firstname.lastname@example.org 0844-3510933
Access to Information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a small administration charge to meet our costs in providing you with the details of the information we hold about you. We will respond to all access requests within 30 days.
Correct/Update/Delete personal Information
Fit-Hubs provides members with the opportunity to correct, update, or delete personal information that has been provided to us by using the methods below.
Contacting the Website
If you have any questions about this privacy statement, the practices of this site, you can contact:
Site Administrator – Colin Hay. Analytics & Compliance.
Fit-Hubs. – 20-22 Wenlock Road, London. N1 7GU United Kingdom
Acceptance of Privacy Statement
Your use of our website(s), including any dispute concerning privacy, is subject to this privacy statement and the applicable Terms and Conditions of Service.
When You choose to provide us with Your personal information You consent to the use of Your personal information as identified in this Policy and as may be further identified at the time of collection.
Sometimes You will be asked to give Your express consent to our collection, use or disclosure of personal information – for example, by being asked to check a box to indicate Your consent to receive marketing communications.
Other times, You may provide Your implied consent to our collection, use or disclosure of personal information when we can reasonably conclude that You have given consent by some action You have taken or an action You have decided not to take. Generally, this occurs where the purpose for the use of Your personal information would be reasonably apparent to You – for example, when You provide us with personal information through forms to populate Your online Instructor profile, You provide us with implied consent to publish that information for other users of the Website to view.
Withdrawing Your Consent
You may notify us at any time that You wish to withdraw or change Your consent to our use and disclosure of Your information. We will accommodate Your request subject to legal and contractual restrictions.
PURCHASES AND AUTOMATICALLY RENEWING SUBSCRIPTIONS
You will have the opportunity to purchase products and services from FIT-HUBS. If you purchase a subscription, it will automatically renew – and you will be charged – until you cancel.
FIT-HUBS may offer products and services for purchase through iTunes, Google Play, or other external services authorized by FIT-HUBS (each, an “External Service,” and any purchases made thereon, an “External Service Purchase”). FIT-HUBS may also offer products and services for purchase via credit card or other payment processors on the Website or inside the App (“Internal Purchases”). If you purchase a subscription, it will automatically renew until you cancel, in accordance with the terms disclosed to you at the time of purchase, as further described below. If you cancel your subscription, you will continue to have access to your subscription benefits until the end of your subscription period, at which point it will expire.
Because our Services may be utilised without a subscription, cancelling your subscription does not remove your profile from our Services. If you wish to fully terminate your membership, you must terminate your membership.
8a. EXTERNAL SERVICE PURCHASES AND SUBSCRIPTIONS
External Service Purchases, including subscriptions, may be processed through the External Service, in which case those purchases must be managed through your External Service Account. Subscriptions automatically renew until you cancel.
When making a purchase on the Service, you may have the option to pay through an External Service, such as with your Apple ID or Google account (“your External Service Account”), and your External Service Account will be charged for the purchase in accordance with the terms disclosed to you at the time of purchase and the general terms applicable to your External Service Account. Some External Services may charge you sales tax, depending on where you live, which may change from time to time.
If your External Service Purchase includes an automatically renewing subscription, your External Service Account will continue to be periodically charged for the subscription until you cancel. After your initial subscription commitment period, and again after any subsequent subscription period, the subscription will automatically continue for the price and time period you agreed to when subscribing.
To cancel a subscription: If you do not want your subscription to renew automatically, or if you want to change or terminate your subscription, you must log in to your External Service Account and follow instructions to manage or cancel your subscription, even if you have otherwise deleted your account with us or if you have deleted the App from your device. For example, if you subscribed using your Apple ID, cancellation is handled by Apple, not FIT-HUBS. To cancel a purchase made with your Apple ID, go to Settings > iTunes & App Stores > [click on your Apple ID] > View Apple ID > Subscriptions, then find your FIT-HUBS subscription and follow the instructions to cancel. You can also request assistance at https://getsupport.apple.com. Similarly, if you subscribed on Google Play, cancellation is handled by Google. To cancel a purchase made through Google Play, launch the Google Play app on your mobile device and go to Menu > My Apps > Subscriptions, then find your FIT-HUBS subscription and follow the instructions to cancel. You can also request assistance at https://play.google.com. If you cancel a subscription, you may continue to use the cancelled service until the end of your then-current subscription term. The subscription will not be renewed when your then-current term expires.
INFORMATION WE MAY COLLECT DIRECTLY FROM YOU
Listed here are some further examples of the ways that we collect personal information directly from You and how we use it.
Follow-Up and Surveys
From time to time, we may send You a follow-up letter to thank You for Your use of the Website, or we may contact You to ensure that You are completely satisfied.
We may use contact information collected online to conduct occasional surveys and other customer research. These surveys are entirely voluntary and You may easily decline to participate.
Our Website can be browsed anonymously. However, to engage in certain special features or functions of our Website, You may be asked to provide certain personal information, such as Your email address or demographic information. We use this information to create Your account, contact and correspond with You about Your account, respond to Your inquiries, and monitor functions of our Website that You choose to use.
Our Mobile Applications
If You use any mobile device to access our site and download any of our applications, we may collect device information (such as Your mobile device ID, model and manufacturer), operating system and version information, and IP address.
If You use the Fit-Hubs Android application, You are asked to allow for the Device & App permission to obtain information regarding which applications are stored on Your device, their activity on Your device, and which apps are running, in order to learn more about You and Your preferences, as part of Fit-Hubs’s algorithm for finding appropriate Instructors and providing you more relevant advertisements. By accepting the requested permissions before installation, You acknowledge and understand that the program performs these functions and agree to this, and You understand that You can withdraw Your consent at any time by uninstalling the Fit-Hubs Android application.
DISCLOSURE AND SHARING OF YOUR INFORMATION
We do not sell or license Your personal information to any other party. However, in the normal course of business we may share some of Your personal information with our affiliates and with third parties acting on our behalf or as permitted or required by Applicable Privacy Laws.
We may use third party service providers (for example, web hosting providers, data management providers and/or payment processers) to manage one of more aspects of our business operations, including the processing or handing of personal information. When we do use an outside company, we use contractual or other appropriate means to ensure that Your personal information is used in a manner that is consistent with this Policy.
When using the Fit-Hubs app to book Classes via our online payment portal. Your credit card details, Fit-Hubs will use the credit card information You provide to bill You for Classes. By providing Your credit card details to Stripe Payment Gateway Services. We DO NOT store any payment details on our (Fit-Hubss Database) You consent to and authorise us to provide Your credit card details to payment processors and Stripe Payment Gateway Services necessary to process Your payment. For more information on how your information is used for payment purposes, please visit https://stripe.com/privacy-center/legal
To provide increased availability of the Website/App, some of these operations may result in personal information collected by Fit-Hubs being stored outside the United Kingdom and, as a result, such personal information stored outside the United Kingdom may be accessible to law enforcement and regulatory authorities in accordance with applicable laws of countries outside the United Kingdom.
Information Shared Amongst Our Affiliates, Subsidiaries and Divisions
We may share personal information gathered on our Website/App with and amongst our corporate subsidiaries, affiliates or divisions for internal business purposes in accordance with this Policy. If we do, we will ensure that Your information continues to be used only in accordance with this Policy and Your expressed choices.
We may disclose Your information as permitted or required by law. For example, we may be compelled to release information by a court of law or other person or entity with jurisdiction to compel production of such information. If we have reasonable grounds to believe information could be useful in the investigation of improper or unlawful activity, we may disclose information to law enforcement agencies or other appropriate investigative bodies.
SECURITY OF PERSONAL INFORMATION
The security of Your personal information is a high priority for us. We maintain appropriate safeguards and current security standards to protect Your personal information, whether recorded on paper or captured electronically, against unauthorised access, disclosure, or misuse. For example, electronic records are stored in secure, limited-access servers; we employ technological tools like firewalls and passwords; and we ensure our employees are trained on the importance of maintaining the security and confidentiality of personal information. Reasonably secure methods are used whenever we destroy personal information. For example, we currently use SSL encryption with a 2048 bit RSA key digital certificate. However, no system can be completely secure. While Fit-Hubs takes steps to secure Your information, we do not promise, and You should not expect, that Your personal information will always remain secure.
REQUESTS FOR ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
Applicable Privacy Laws allows any individual the right to access and/or request the correction of errors or omissions in his or her personal information that is in our custody or under our control. Our Privacy Officer will assist the individual with the access request. This includes:
identification of personal information under our custody or control; and
information about how personal information under our control may be or has been used by us.
We will respond to requests within the time allowed by Applicable Privacy Laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organisation it was disclosed to.
In certain exceptional circumstances, we may not be able to provide access to certain personal information it holds about an individual. For security purposes, not all personal information is accessible and amendable by our Privacy Officer (Colin Hay – email@example.com). If access or corrections cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
REMOVAL OF YOUR INFORMATION
We keep Your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters.
Digital Millennium Copyright Act Notice
If You believe that Your copyrighted work has been copied in a way that constitutes copyright infringement and is accessible on this Site, please notify Fit-Hubs’s copyright agent, as set forth in the Digital Millennium Copyright Act of 1998 (DMCA). For Your complaint to be valid under the DMCA, You must provide the following information in writing:
- An electronic or physical signature of a person authorized to act on behalf of the copyright owner;
• Identification of the copyrighted work that You claim is being infringed;
• Identification of the material that is claimed to be infringing and where it is located on the Site;
• Information reasonably sufficient to permit Fit-Hubs to contact You, such as Your address, telephone number, and e-mail address;
• A statement that You have a good faith belief that use of the material in the manner complained of is not authorised by the copyright owner, its agent, or law; and
• A statement, made under penalty of perjury, that the above information is accurate, and that You are the copyright owner or are authorised to act on behalf of the owner.