INTRODUCTION

Right this may take a little while to read through, but I'm not stopping you!  Make yourself comfy, grab a coffee and lets go! 

We am committed to maintaining the trust and confidence of my visitors to this website. In particular, we want you to know that we are NOT in the business of selling, renting or trading email lists with any other companies and businesses for marketing purposes.

What you do with your information is up to you! 

But just in case you don’t believe us, in this Privacy Policy, we have provided lots of detailed information on when and why we collect your personal information, how we may use it, the limited conditions under which we may disclose it to others and how we keep it secure.

Still sure you want to read on...? Can't say we didn't warn you for this riveting read! 

BUSINESS INFORMATION

TrainRX is the sole business name for which this service is provided. We take your privacy seriously and as such have laid out the following privacy notice in line with the General Data Protection Regulation (GDPR) 2018.

By using the facility and any of the services you agree to be bound by the policies set out in this privacy notice. We are fully committed to protecting the privacy, and safeguarding the use of your personal information, and we will look to keep this privacy notice updated, therefore check back here regularly to review any amendments.

Any questions relating to this privacy policy or this notice should be directed in writing to hello@trainrx.uk. 

WHAT DATA WE COLLECT AND HOW WE USE IT

We collect and process your personal information (such as name, date of birth, contact information, payment information and information relating to health conditions and usage) in order to administer your accounts and subscriptions with myself – to process orders, payments or applications submitted by you.

We also use it to carry out my obligations in relation to any agreement or contract you have with myself including any subscription to my service, or to verify your identity.

We will NOT share your data with any third party other than those utilised to service my business or if legally obligated to do so. External partners (processors) may be utilised to perform tasks including but not limited to: processing payments, making bookings, marketing, accounting and account management – We agree terms with all of my partners to ensure that they all comply with high levels of confidentiality and best practice in privacy and security standards in line with the GDPR 2018. 

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in a number of physical, electronic and managerial procedures to safeguard and secure the information we collect from you.

CCTV Policy

At TrainRX we believe that CCTV plays a legitimate role in helping to maintain a safe and secure environment for all trainers, and members, and potential customers. Images recorded by CCTV are Personal Data and as such must be processed in accordance with data protection laws. We are committed to complying with our legal obligations in order to appropriately handle and protect Personal Data and ensure that the legal rights of our trainers, members and potential customers relating to their Personal Data, are recognised and respected.

This policy is intended to enable trainers, members and potential customers to understand how the TrainRX uses CCTV, those individuals responsible for CCTV use, the rights individuals may have in relation to CCTV, who has access to CCTV images and how individuals can raise any queries or concerns they may have.

Definitions

For the purposes of this policy, the following terms have the following meanings:

CCTV: means cameras, devices or systems including fixed CCTV and any other systems that capture information of identifiable individuals or information relating to identifiable individuals.

CCTV Data: means any Data in respect of CCTV, e.g. video images, static pictures, etc.

Data: means any information which is stored electronically or in paper-based filing systems.

Data Subject: means any individuals who can be identified directly or indirectly from CCTV Data (or other Data in our possession). Data Subjects include trainers, their clients and individual gym users and potential customers, therapists, teachers, contractors and members of the public.

CCTV users: are those of TrainRX whose work involves processing CCTV Data. This will include those whose duties are to operate CCTV to record, monitor, store, retrieve and delete images. Data users must protect the CCTV Data they handle in accordance with this policy.

Data Controller: is the organisation or authority which, determines how and for what purpose the Personal Data are processed. When operating CCTV, The Directors of TrainRX (Matthew Halls) are the relevant Data Controllers and are responsible for ensuring compliance with the Data Protection Laws. 

Data Protection Laws:

means:

a) General Data Protection Regulation 2018 (the “GDPR”) and any equivalent or implementing legislation;

b) all other applicable laws, regulations or court judgements relating to the processing of personal data, data privacy, electronic communications, marketing and/or data security;

Processing: is any activity which involves the use of CCTV Data, whether or not by automated means. It includes collecting, obtaining, recording or holding CCTV Data, or carrying out any operation or set of operations on the CCTV Data including organising, structuring, amending, retrieving, using, disclosing or erasing or destroying it. Processing also includes transferring CCTV Data to third parties.

Site: means the TrainRX, 46 Brampton Road, Eastbourne, BN22 9BN

About this policy

We currently use CCTV to view and record individuals at our Site, 24 hours per day, 7 days per week. This policy sets out why we use CCTV, how we will use CCTV and how we will process any CCTV Data recorded by CCTV to ensure that we are compliant with Data Protection Law.

The images of individuals recorded by CCTV are Personal Data and therefore subject to the Data Protection Laws. 

This policy covers everyone present on site, or any relevant to members of the public visiting the Site.

Staff responsible

TrainRX has overall responsibility for ensuring compliance with Data Protection Laws and the effective operation of this policy. Day-to-day operational responsibility for CCTV and the storage of CCTV Data recorded is the responsibility of the Duty Security Controller. Should you have any queries on the use of CCTV or surveillance systems by us please contact hello@trainrx.uk

Why we use CCTV

We currently use CCTV around our Site as outlined below. We believe that such use is necessary for the following legitimate business purposes:

To prevent or detect crime and protect buildings and assets from damage, disruption, theft, vandalism and other crime;

For the personal safety of trainers, members and potential customers, and to act as a deterrent against crime;

For health and safety compliance of those using the gym and accessing the building safely

To support law enforcement bodies in the prevention, detection and prosecution of crime; and

We may implement or use CCTV for purposes other than those specified above which we will notify you of from time to time.

Monitoring

The locations of the CCTV are chosen to minimise the viewing of spaces/individuals which are not relevant to the legitimate purpose of the monitoring as specified above.

A live feed from the CCTV is monitored continuously and images are only revisited in the event of an incident or if a request is made.

How we operate CCTV

How we use the Data

In order to ensure that the rights of individuals recorded by our CCTV are protected, we will ensure that CCTV Data gathered from such systems is stored in a way that maintains its integrity and security. This is currently on a hard drive.

We will ensure that any CCTV Data is only used for the purposes specified in the above sections. We will not use CCTV Data for another purpose unless permitted by current Data Protection Laws.

Retention and erasure of Data

Data recorded by our CCTV will be stored locally on servers and on a cloud based storage system. We will not retain this Data indefinitely but will permanently delete it once there is no reason to retain the recorded information. Exactly how long the Data will be retained for will vary according to the purpose for which it was recorded. For example, where images are being recorded for crime prevention purposes, CCTV Data will be kept only for as long as it takes to establish that a crime has been committed or where we are using the CCTV Data for staff disciplinary purposes, the images will be kept until the process is completed. In all other cases, recorded images will be kept for no longer than 90 days before being overwritten and permanently deleted.

Ongoing review of our use of CCTV

We will periodically review our ongoing use of existing CCTV at our Site to ensure that its use remains necessary and appropriate and in compliance with Data Protection Laws.

We will also carry out checks to ensure that this policy is being followed.

Rights of Data Subjects

As CCTV Data will identify individuals, it will be considered Personal Data under applicable Data Protection Laws. Under Data Protection Laws, Data Subjects have certain rights in relation to the Personal Data concerning them. These are as follows:

(a) the right to access a copy of that Personal Data and the following information (this may include CCTV Data captured by our CCTV):

(i) the purpose of the processing;

(ii) the types of Personal Data concerned;

(iii) to whom the Personal Data has or will be disclosed; and

(iv) the envisaged period that the Personal Data will be stored, or if not possible, the criteria used to decide that period;

(b) the right to request any inaccurate Personal Data that we hold concerning them is rectified, this includes having incomplete Personal Data completed;

(c) the right to request the Personal Data we hold concerning them is erased without undue delay, where it is no longer necessary for us to retain it in relation to the purposes it was collected;

(d) the right to request restriction of our processing of Personal Data in certain circumstances; and

(e) the right to lodge a complaint with the Information Commissioner’s Office, if the Data Subject considers that our processing of the Personal Data relating to him or her infringes Data Protection Laws.

Requests of disclosure by third parties

No images from our CCTV cameras will be disclosed to any third party without express permission being given by Matt Halls. Data will only be disclosed to a third party in accordance with Data Protection Laws.

In other appropriate circumstances, we may allow law enforcement agencies to view or remove CCTV footage where this is required in the detection or prosecution of crime.

Complaints

If any TrainRX member has questions about this policy or any concerns about our use of CCTV, then they should speak to the director (Matthew Halls) in the first instance.

INFORMATION ABOUT PRODUCTS AND SERVICES AND MARKETING

From time to time we may send you details of products and services that may be of interest to you via email or SMS. This is only if you opt to receive this information, via informed opt-in consent or via legitimate interest, whereby you could reasonably expect to hear from myself following a recent enquiry, purchase, content download or referral from someone you know. 

YOUR RIGHTS AND KEEPING MY RECORDS UP TO DATE AND ACCURATE

The law requires that we tell you about your rights and my obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org.

You can opt out from any promotional, non-essential or marketing content at any time by clicking the unsubscribe link in an email or by contacting myself directly.

You may also contact myself directly to request information about what data of yours is recorded,  how it is stored and what it is. If you would like a copy of the information held on you please write to me by email.

If you believe that any information I am are holding on you is incorrect or incomplete, please write to or email us as soon as possible. I will promptly correct any information found to be incorrect. You also have the right to lodge a complaint with a supervisory authority if you feel your privacy has been violated.

In general I retain and process personal data for a reasonable period following initial enquiry, purchase or the lapsing of an account with myself. Certain records such as health screening forms may be retained for a longer period, in line with fulfilling contractual obligations of due care to my customers and visitors, in line with industry standards.

THIRD PARTY SITES, APPS AND SERVICES

We cannot be responsible for the privacy policies and practices of other websites, apps or services even if you access them using links from my site(s), or during the delivery of my services. We fully recommend that you check the policy of each site you visit, any apps you use or any third party services that you may register with.

SOCIAL MEDIA

We advise members and visitors to take all due care when taking photographs or filming on site to ensure that no one else appears in their photos or footage. We do occasionally arrange/take filming or photographs for use on my Social Media or other communications. All due care will be taken to ensure that no one appears in filming or content created by myself without prior expressed consent. If you find you do appear in error, and would like an image or video to be removed from my Social Media channels or communication please contact Matthew Halls immediately.

DISCLOSING YOUR INFORMATION TO OTHERS

Other than the disclosures referred to in this policy, we will not sell, distribute or lease your personal information to third parties unless we have YOUR permission or am required to by law.