PRIVACY NOTICE - VERSION 7 March 2023.
Privacy Notice
INTRODUCTION
At WildStrong we are committed to protecting your privacy.
We collect and process personal data about you to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or to fulfil other legitimate interests.
Our Privacy Notice explains how we collect, use, share and protect your personal information. When we update this policy we will post any changes on our website.
In addition when visiting our website we will provide you with “just in time” notices at the moment of data collection.
If you have any questions or queries about this Notice including requests to exercise your legal rights, please contact us at WildStrong, Cambo Farmhouse, Kingsbarns, St. Andrews, Scotland, KY16 8QD . Alternatively send an email to info@wildstrong.co
IDENTITY OF DATA CONTROLLER
The Data Controller in respect of this Privacy Notice is Strong and Wild Ltd (Co. No. SC690533), with its registered office at Cambo Farmhouse, Kingsbarns, St. Andrews, Scotland, KY16 8QD .
WHEN DO WE COLLECT INFORMATION?
We collect your personal information when you:
Complete an Online Membership Agreement
Book or attend an exercise class or lesson
Ask us for more information about a product or service, or contact us with a question or complaint
Visit or browse our website.
Send an email to an @wildstrong.co email account
You have an accident in our classes or there was an incident where you were a witness or personally affected
When you book classes, courses and inductions
When our teams take photos of your attendance as part of an event or in a class (Your permission will be sought in advance)
WHAT INFORMATION DO WE COLLECT?
Personal data or information is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The information we collect is required for the purpose of creating your Member Account and for you to enrol in our classes. If you do not provide the information, we will not be able to proceed with your membership. Such information allows you to be identified as a member of WildStrong and includes:
Name, date of birth, gender, e-mail address, postal address, telephone number, health declaration and whether you require disabled access
Credit or debit card information, information about your bank account number and sort code or other banking information. Note that we do not store your bank or credit card details on our web servers
Your usage records and duration of visits
Your preferences for particular products or services or interests when you tell us what they are – or when we assume what they are, depending on how you use our products and services
Your contact with us, such as a note or recording of a call you make to our contact centre, an email or other records of any contact you have with us
Your membership information – such as dates of payment owed and received, the services you use and any other information related to your account
We will need to process information relating to your physical and mental health and any conditions you have (so called “special category data”). We process special category data to assess your fitness to receive Services, to address any medical incidents or issues which may arise and to comply with our health and safety obligations. The processing is to perform a contract with you and to protect your health. When opening your Member Account, you will be asked to give your explicit written consent to our processing your special category data. You are entitled to withdraw any consent given, but we will not then be able to provide any Services to you. (This information is our appropriate policy regarding special category data).
HOW DO WE USE THIS INFORMATION?
We will use your personal information to provide you with the services, products or information that you have requested, for administration purposes, to improve your website experience, and marketing. We may need to share your information with our service providers, associated organisations (such as our franchisees) and agents for these purposes. We may use your information to:
Bill you for using our services as part of your membership
Keep you informed about our services including operational matters relating to your Membership
Confirm your attendance to exercise classes or lessons
To share event photos (Your permission will be sought before a picture is taken)
Contact you with offers or promotions based on our analysis of how you use our services and what we think will be of interest to you (unless you choose not to receive our marketing messages)
Respond to any questions or concerns you might have about our services
Understand how you use our services, to help us develop relevant and updated services
Carry out research and statistical analysis to monitor how customers use our services
Prevent and detect fraud or other crimes
Covid-19 Track & Trace - To prevent the spread of infection around the UK we will support the NHS Track & Trace system. If requested by the NHS to provide visitor information, due to an outbreak in the vicinity of one of our gyms, we will supply your name, mobile and time of arrival and departure for members who had recently visited the specific site. This is voluntary and you are able to request to have your data excluded. Please email us at info@wildstrong.co with you name and we will not pass your details on.
Our lawful bases for processing your personal data are to perform a contract with you, where it is necessary for our legitimate interests or necessary to comply with a legal obligation
We’ll store your information for as long as you are a Member of WildStrong, or following cancellation and to meet legal requirements including financial audit, anti-fraud and money laundering regulations. We will store your information for no more than 6 years from the last activity on the account. An ‘activity’ can be classified as access into a gym, a payment made on the membership account or a comment added to the membership following contact with WildStrong. We may contact you about WildStrong services during this 6 years if you haven’t opted out of receiving marketing communications from us.
WildStrong will only send you information relating to your membership. We will not share your data with any 3rd parties for marketing purposes. If you cancel your membership with WildStrong we will only send you information that we think will be of interest to you. You can choose to opt out of all marketing or select your marketing preferences.
DO WE USE COOKIES?
WildStrong uses cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear picture files used to follow your online activities). These collect information that tells us how you use our websites, web-related products and services. The use of cookies does not give us access to the rest of your computer.
This, in turn, helps us make our website relevant to your interests and needs. We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so we can recognise you if you visit our website again.
You can choose to refuse cookies, or set your browser to let you know each time a website tries to set a cookie.
Please note however that if you disable our cookies you may not be able to access certain services or facilities on our sites and your use of our sites may be restricted. This could include joining or logging in to your members area.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have a dedicated team whose function is to secure our clients’ information and also take appropriate measures to ensure that the information we collect and maintain is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.
We have put in place appropriate security measures to prevent your personal data from 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.
We ensure the organisations that provide us with services related to your membership have appropriate security measures and only process your information in the way we have authorised them to. These organisations will not be entitled to use your personal information for their own purposes.
Communications over the internet (such as emails) aren’t secure unless they’ve been encrypted. Your communications may go through a number of countries before being delivered – as this is the nature of the internet. We can’t accept responsibility for any unauthorised access or loss of personal information that’s beyond our control.
WILL WE DISCLOSE THE INFORMATION WE COLLECT TO OUTSIDE PARTIES?
We may share information about you with:
Service providers, agents and associated organisations (such as our franchisees) to allow us to service your membership and communicate with you; for example, financial institutions to process payments, and freelance personal trainers when you sign up to classes
Law enforcement agencies, regulatory organisations, courts or other public authorities where we have a legal obligation to do so
Covid-19 Track & Trace - To prevent the spread of infection around the UK we will support the NHS Track & Trace system. If requested by the NHS to provide visitor information, due to an outbreak in the vicinity of one of our gyms, we will supply your name, mobile and time of arrival and departure for members who had recently visited the specific site. This is voluntary and you are able to request to have your data excluded. Please email us at info@wildstrong.co with you name and we will not pass your details on
We’ll release information if it’s reasonable for the purpose of protecting us against fraud, defending our rights or property, or to protect the interests of our customers.
If we’re reorganised or sold to another organisation, we may transfer any personal information we hold about you to that organisation. We will inform you if we do.
USE OF PERSONAL DATA FOR AUTOMATIC DECISION MAKING
We do not intend to use your personal data for automatic decision making.
THIRD PARTY TRACKING
We use tools such as Google Analytics for collecting personal data about our website visitor’s online activities over time and across different web sites for marketing purposes. This is so we can ensure our website gives you the best possible experience.
DO NOT TRACK (DNT)
The WildStrong website does not respond to DNT signals.
COLLECTION OF CHILDREN'S DATA
WildStrong does not collect or process children’s data.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
YOUR PRIVACY RIGHTS
You have the following rights in relation to your data privacy: the right of access; the right of rectification; the right of erasure (the “right to be forgotten”); the right to restriction of processing; the right to be notified; the right to data portability; the right of objection; the right to not be subject to automated profiling and, where we are relying on your consent, the right to withdraw that consent.
Access. You have the right to ask for a copy of the information we hold about you and to have any inaccuracies in your information corrected. Please contact us through email to info@strongandwild.com, the contact us section of the website or writing to the address below. There is not normally a fee for this service.
We may need to request specific information from you to help us confirm your identity and 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 you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could 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
Rectification. If you believe we’re holding inaccurate information about you, or your personal details change, please update your profile on the WildStrong website in the member’s area. Debit, Credit and Bank account changes can be made in your member’s area on the WildStrong website.
Erasure. You have the right to the erasure of the data we hold on you, when it is no longer needed for the purposes of your Membership, or when you withdraw your consent for our processing (and we have no other lawful basis to hold your data).
Restriction. You have the right to ask us to place restrictions on processing your data in certain circumstances.
Notification. You have the right to be notified of any rectification, erasure or restrictions in relation to your personal data.
Portability. You have a right to receive the data we hold on you electronically in a format that allows it to be easily transferred to another data controller. 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.
Object. You have the right to object to data processing of your personal data (for example, for direct marketing or profiling purposes).
Profiling. You have the right not to be subject to any decision based on automatic processing of your personal data.
Withdrawal of consent. 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 withdraw your consent. If you withdraw your consent, we may not be able to provide services to you. We will advise you if this is the case at the time you withdraw your consent.
The address to be used to obtain a copy of your personal information is: Strong and Wild Ltd, Cambo Farmhouse, Kingsbarns, St. Andrews, Scotland, KY16 8QD or by emailing info@WildStrong.com
GOVERNMENT TRACK AND TRACE
To prevent the spread of infection around the UK we will support the NHS Track & Trace system. If requested by the NHS to provide visitor information, due to an outbreak in the vicinity of one of our gyms, we will supply your name, mobile and time of arrival and departure for members who had recently visited the specific site. This is voluntary and you are able to request to have your data excluded. Please email us at info@WildStrong.com with you name and we will not pass your details on.
CHANGES TO THIS PRIVACY NOTICE
We will update this privacy notice to reflect the way in which we process and protect your data. If we do so, we will post notice of the change on our website and you will have the opportunity to adjust your communications preferences via your Member Profile within the Members Area of the website.