Last updated Tuesday 24th May 2018
1. Who We Are
P4 BODY (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
P4 BODY’s registered office is at 142 Cromwell Road, KENSINGTON, London SW7 4EF
We are registered on the Information Commissioner's Office Register; registration number ZA388304, and act as the data controller when processing your data. Our designated Data Protection Officer/Appointed Person is Dylan Jones, who can be contacted at email@example.com or by post at 142 Cromwell Road, KENSINGTON, London SW7 4EF.
2. Information That We Collect
P4 BODY processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect from is: -
· Date of Birth
· Home Address
· Personal Email
· Business Email
· Home Telephone Number
· Mobile Telephone Number
· Passport Number
· Driver’s License Number
· Special Category Data (i.e. health/medical information, details about religion, sexuality etc)
We collect information in the following ways: -
online forms, website orders, emails, telephone calls, text messaging, medical screening and pre activity readiness questionnaires.
3. How We Use Your Personal Data
P4 BODY takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below: -
· We collect your personal data in the performance of a contract or to provide a service and to ensure that orders are completed and can be sent out to your preferred address
· We collect and store your personal data as part of our procedure to medically screen, evaluate and monitor your fitness goals and progress in order to provide you with the service that we have contractually agreed to deliver.
· We will occasionally send you marketing information where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests and can be opted out at any stage.
· We collect and store your personal data to send you relevant fitness information, products and marketing after you have given your consent (by ‘opting in or submitting your personal information) on form on our website, App or social media platform.
· We use “Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalise our website for our users and to collect a limited set of information about our visitors. We may also use web beacons in email communications in order to understand the behaviour of our customers.
To process purchases, we may require your name, address, phone number, email address and credit card information. Such information is used primarily to process your order or as otherwise described herein.
4. Your Rights
You have the right to access any personal information that P4 BODY processes about you and to request information about:
· What personal data we hold about you
· The purposes of the processing
· The categories of personal data concerned
· The recipients to whom the personal data has/will be disclosed
· How long we intend to store your personal data for
· If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
5. Sharing and Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. P4 BODY uses third-parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
We use Virtuagym.com to help us with our digital platform to deliver video enabled exercises and programmes online and through our App to our clients. We share the information you provide such as name, address, telephone number, email, medical history, Exercise history, progress pictures and measurements are kept within your online portal on purchasing any online plan or becoming a PRO online client. This will be held until you for it to be erased OR for 1 year after you cancel your membership.
For more information about Virtuagym, please read their Privacy Notice at https://virtuagym.com/software/en/?page_id=538
MAILCHIMP & CONSTANT CONTACT
We use mail chimp and Constant Contact as our web marketing platforms to store information given by you when signing up and opting in or consenting using our newsletter forms on our website or other related form. The only information we processes is name and email address.
For more information about Mailchimp, please read their Privacy Notice at https://mailchimp.com/legal/privacy/
For more information about Constant Contact, please read their Privacy Notice at https://www.constantcontact.com/uk/legal/privacy-statement
6. Safeguarding Measures
P4 BODY takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place.
7. Transfers Outside the EU
P4 BODY utilise some products or services (or parts of them) that may be hosted/stored in P4 BODY, which means that we may transfer any information which is submitted by you through the website outside the European Economic Area ("EEA") for the below purposes: -
Mail Chimp & Constant Contact – Email Marketing
Dot Squares – Email Servers and Hosting
Squarespace – Website hosting
Virtuagym - Digital App Hosting
Therefore, when you [use our website/send us an email/sign up to our newsletter etc], the personal information you submit may be stored on servers which are hosted in [non-EU countries]. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by P4 BODY to protect your data and comply with the relevant data protection laws.
8. Consequences of Not Providing Your Data
You are not obligated to provide your personal information to P4 BODY], however, as this information is required for us to provide you with our services/deliver your products/legitimate interest, we will not be able to offer some/all our services without it.
9. Legitimate Interests
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
We use the legitimate interests’ legal basis for processing fitness related information and have identified that our interests are necessary in order for us to deliver the service, products and information we set out to provide.
10. How Long We Keep Your Data
P4 BODY only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
11. Special Categories Data
Owing to the products, services or treatments that we offer, P4 BODY sometimes needs to process sensitive personal information (known as special category data) about you, to medically Screen and evaluate your readiness to perform physical activity prior to and during the fitness programme that you have signed up to. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
Where we rely on your consent for processing special category data, we will obtain your explicit consent through a tick box on our digital form. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.
If you consent to us collecting and using your medical history for the purposes stated above, please tick the appropriate box when asked.
Occasionally, P4 BODY would like to contact you with the products/services/promotions that we provide. If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting P4 BODY directly.
13. Lodging A Complaint
P4 BODY only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
P4 Body -Data Protection Office
142 Cromwell Road
Information Commissioner's Office