1. How We Collect Data About You

1.1 Information Provided by You

You may provide us with personal data on your consultation forms and related questionnaires, online or over the telephone.

This includes your name, address, date of birth, email address and payment and personal details. We use this information to manage and administer your training and nutrition programmes and any requests for support you may make.

We may keep information contained in any correspondence you have with us by post, email or telephone.

We may obtain sensitive personal health and fitness information directly from you when you register with us or which you may provide at the start or during your training programme.

The provision of this information is subject to you giving us express consent. If we do not receive this consent from you, then we may be unable to provide the most appropriate training and nutrition support.

The provision of this personal data is essential for us to be able to collect payments and administer your training programme, including verifying your identity when you contact us to discuss your programme. This means that the legal basis of our holding your personal data is for the performance of a contract.

1.2 Information We Get from Other Sources

We only obtain information from third parties if this is permitted by law. We may also use legal public sources to obtain information about you, for example, to verify your identity.

This information (including your name, address, email address, date of birth, etc.) as relevant to us, will only be obtained from reputable third-party companies that operate in accordance with the General Data Protection Regulation (GDPR).

You will already have submitted your personal data to these companies and specifically given permission to allow them to pass this information to other companies that provide similar or complimentary services and products to those we offer.

2. How We Use Your Personal Data

2.1 Purposes for Which We Will Use Your Personal Data

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you by email or text message. We do sometimes ask for your consent, specifically in relation to special category personal data like your health information, and we will rely on your consent if it is given. You have the right to withdraw consent at any time by contacting our data privacy lead whose contact details are provided in section 6 below.

In the following table, we have set out the ways we plan to use your personal data and the legal bases for which we are using your data. Please contact our data privacy lead if you require further information.

Please note that we may process your personal data for more than one lawful reason depending on the specific purpose for which we are using your data.

Purpose/Activity	Legal Basis for Processing
To register you as a new client	Performance of contract with you
To set you up with your personal trainer, we will pass your contact details to one of our self-employed personal trainers	Performance of contract with you
To process and deliver services to you including: Management of payments, fees and charges Collection and recovery of money owed to us Provision of training and nutrition plans	Performance of contract with you Necessary for our legitimate interests (recovery of money owed to us)
To manage our relationship with you which will include: Telling you about changes to our terms or privacy notice Asking you to leave a review or take a survey	Performance of contract with you Necessary to comply with legal obligation Necessary for our legitimate business interests (to keep our records updated and study how clients use our services/products)
To allow you to take part in a prize draw, competition or complete a survey	Performance of contract with you Necessary for our legitimate business interests (to study how clients use our services/products, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of any business reorganisation exercise) Necessary to comply with a legal obligation
To deliver relevant electronic content and advertisements to you and measure or understand the effectiveness of the advertising we conduct	Necessary for our legitimate interests (to study how clients use our services/products, to develop them, to grow our business and inform our marketing strategy)
To use data analytics to improve our services, products, marketing, website, client relationships and experiences	Necessary for our legitimate interests (to define types of clients for our services/products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and/or recommendations to you about services or goods that may be of interest to you	Necessary for our legitimate interests (to develop our services/products and grow our business)
To use ‘before and after’ photographs and other body composition measurements to highlight success stories to our clients and social media followers	We will always get your explicit consent before publishing such information

2.2 Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting our data privacy lead whose contact details are given in section 6.

2.3 Do We Use Your Personal Data for Marketing Purposes?

Any information that you choose to give us will not be used for marketing purposes by us without your express consent.

3. Sharing Information

We will keep information about you confidential and we will, from time to time, share your personal information where legally required to do so, for example, for purposes of audit and compliance monitoring.

We will only disclose your information to other third parties with your express consent with the exception of the following categories of third parties:

3.1 Categories of Third Parties

The categories of third parties we may share information with are set out below:

• any legal or crime prevention agencies and/or to satisfy any regulatory request if we have a duty to do so or if the law allows us to do so
• anyone to whom we may transfer our rights and duties under any agreement we have with you
• any mailing or printing agents, contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential
• regulatory authorities and other agencies to comply with any legal and regulatory issues and disclosures

3.2 Transfer of Your Personal Data Outside of The European Economic Area (EEA)

We do not currently transfer your personal data outside the EEA. If in the future we transfer your personal data, in accordance with the terms of this Policy outside the EEA, we will make sure that the receiver agrees to provide the same or similar protection as we do and that they only use your personal data in accordance with our instructions.

If you require further information regarding such transfers, please contact our data privacy lead, whose contact details are set out in section 6 below.

4. Data Accuracy, Security and Retention

4.1 Data Accuracy

To provide the highest possible level of service to all our clients, we need to keep accurate personal data about you.

We take reasonable steps to ensure the accuracy of any personal data or sensitive information we obtain.

We ensure that the source of any personal data or sensitive information is clear and we carefully consider any challenges to the accuracy of the information.

We also consider when it is necessary to update the information, such as name or address changes and you can help us by informing us of these changes when they occur.

4.2 Data Protection

We have put in place appropriate security measures to prevent your personal data being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

All data is stored on secure servers in the UK and European Union. Laptops and other electronic equipment storing your data are password protected and any paper records that we hold are stored securely and destroyed when no longer needed.

4.3 How Long Do We Keep Information About You?

We only keep your personal data for as long as necessary to fulfil the purposes for which we collected it, including the satisfaction of any legal, accounting or reporting requirements.

To determine the appropriate retention period for your personal data, we consider:

• the amount, nature, and sensitivity of the personal data
• the potential risk of harm from unauthorised use or disclosure
• the purposes for which we process the personal data and if we can do this through other means, and
• the applicable legal requirements

In some circumstances, you can ask us to delete your data, please see below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which we may use this information indefinitely without further notice to you.

5. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

5.1 Request access

Request access to your personal data (commonly known as a ‘data subject access request’). This allows you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

5.2 Request correction

Request correction of the personal data that we hold about you. This allows you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

5.3 Request erasure

Request erasure of your personal data. This allows you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, in response to your request.

5.4 Object to processing

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

5.5 Request restriction of processing

Request restriction of processing of your personal data. This allows you to ask us to suspend the processing of your personal data in the following scenarios:

1. if you want us to establish the data’s accuracy;
2. where our use of the data is unlawful but you do not want us to erase it;
3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

5.6 Request the transfer of your personal data

Request the transfer of your personal data to you or a third party. We will provide to you, or a third party that you have chosen, your personal data in a structured, commonly used, machine-readable format (i.e. useable on a computer). Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

5.7 Withdraw your consent at any time

Withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain services or products to you. We will advise you if this is the case at the time you withdraw your consent. Also, we may still be allowed to process your data following the withdrawal of consent if another lawful justification for such processing exists.

If you wish to exercise any of the rights set out above, please contact our data privacy lead, whose contact details are provided in section 6 below.

5.8 Charges to Exercise Rights

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

5.9 What We May Need from You

We may need to request specific information from you to help us to confirm your identity and to ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request in order to speed up our response.

5.10 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

6. Important Information

6.1 Questions and Queries

If you have any questions or queries which are not answered by the Privacy Notice, or have any potential concerns about how we use the personal data we hold, please write to our data privacy lead, Lucas Sheehan at:

Lucas Sheehan Personal Training Ltd
50 Saxon Drive
London
W30NR

Or, email Info@lucassheehanpt.com

6.2 Privacy Notice Changes

This Privacy Notice is regularly reviewed to make sure that we continue to meet the highest standards and to protect your privacy.

We reserve the right, at all times, to update, modify or amend this Notice. We suggest that you review this Privacy Notice from time to time to ensure you are aware of any changes we may have made.

However, we will not significantly change how we use information you have already given to us without your prior agreement.

6.3 If You Have a Complaint

If you have a complaint regarding the use of your personal data or sensitive information then please contact us by writing to our data privacy lead, Jonathan Taylor, and we will do our best to help you.

If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 123 1113.

You also have the right to judicial remedy against a legally binding decision of the ICO where you consider that your rights under this regulation have been infringed as a result of the processing of your personal data. You have the right to appoint a third party to lodge the complaint on your behalf and exercise your right to seek compensation.

6.4 Glossary

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law).

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.

Third parties include the following:

• Our personal trainers with whom we enter into a contract to provide training and nutrition services on a self-employed basis.
• Service providers, acting as joint controllers or processors, based in the UK, in the EEA or outside of the EEA, who provide outsourced services to us.
• Professional advisors, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the UK, in the EEA or outside of the EEA, who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers, based in the UK or the EEA who require reporting of processing activities in certain circumstances.