PRIVACY POLICY
At EMS FISICO we will always take the security of your personal data extremely seriously and will process it in a fair, transparent and lawful way.
When you share your information with us through the website and other channels we want you to feel confident that your data is kept securely and that it will only be processed in ways about which you have been informed and where appropriate have given your consent.
EMS FISICO adheres to the requirements of the Data Protection Act (2018) and the General Data Protection Regulation 2016/679 (GDPR).
Should you have any questions relating to this notice or our processing of personal data, please contact us at the following address:
EMS FISICO
11 Litchfield Terrace
Sheen Road
Richmond
TW9 1AE
1. When and how do we collect your data?
Personal data may be processed when:
Registering with and using our website or online app:
When registering with, or using online forms on our website or online app, you will be asked for information to enable us to process your request.
If you cease to use our service, we will remove your contact details after two years.
Becoming a Client
Should you choose to become a client, we will collect information about you to enable us to set up your account and deliver services to you.
This could be online, face to face in our studio or via the phone.
Once you cease being a client, we will remove your bank details from our system. Client records will remain while you continue to use our facilities. We will retain transaction records for up to seven years for activity and usage reporting.
Completing a Client Consent Form or Health Questionnaire (PARQ)
At EMS FISICO we would like to ensure that you exercise safely.
Before your first trial session you will be asked to complete a client consent form or health questionnaire (PARQ).
Booking Classes
If you book to attend a class, you may be asked for information to help us deliver the service.
Visiting our Studio
If you visit our studio, we will record the fact that you have attended. This helps us to better understand how we are performing and improve our services.
Attendance may also be recorded if you use our check-in barcode.
Completing Customer Surveys
If you have used our facilities you may be asked to fill in a feedback form, we use this information to respond to your comments directly and improve our service.
We retain customer feedback data for up to a year after any issue raised has been resolved.
CCTC
In order to ensure the safety of our staff and customers, we operate a CCTV system. These are used to detect and prevent crime or to monitor the safety of our clients and staff.
CCTV recordings are retained for a period of up to one month before deletion, and maybe held for longer if required as evidence in legal proceedings.
2. What personal information do we collect?
The data that we collect and process will depend on the services that you have requested from us:
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Identity: First name, last name, photograph (ID)
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Contact Details: Address, postcode, telephone number, email
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Demographics: Date of birth, ethnicity, gender
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Disability: If you are registered disabled
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Concession: Reason for concession
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Preferences: How you prefer to be contacted
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Bank Details: For standing order or direct debit payments
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Attendance: The date and time of visits
When you visit our website we also collect information automatically about your visits, such as IP address of your device, browsing patterns etc. Information collected in this way is only used in aggregate and anonymous form rather than being linked to identifiable individuals.
Sensitive Information
The GDPR requires us to take particular care when handling sensitive information such as that related to your racial or ethnic origin, any disability you may have, your health or religion (referred to as Special Category Data in GDPR).
In the interest of your safety, EMS FISICO require background health information before you begin electro muscle stimulation training.
We may record information about your ethnicity in order that we are serving all of the communities in which we operate. By giving us these details you are consenting EMS FISICO to use this information. Where we report on this data the information will be in anonymised form.
3. How do we use your information
EMS FISICO will only use your information in a fair and transparent manner and where we have a legal basis for doing so. We will never sell your information or disclose it to anyone without informing you.
With your Consent
Where you have consented for us to do so, we will use your data to:
Send you information about our products and services that we think may be of interest to you.
In Order to Perform our Obligations in a Contact that We Hold with You
We may use and process your data where it is necessary for the performance of a contract with you (such as a class booking) or in order to take steps at your request before entering into a contract with you to:
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Deliver the services you have requested
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Validate your bank and payment details
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Take payments via a direct debit or card
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Send you confirmation of bookings etc
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Notify you when your paid for sessions have expired or have all been used
For our own legitimate interests or those of our clients and customers
EMS FISICO have legitimate interests in:
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Operating our business efficiently
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Marketing our services to potential customers
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Ensuring the safety and security of our staff and customers
In pursuit of these interests we may:
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Ask you to give feedback on your use of our services
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Operate CCTV cameras to detect and prevent crime
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Monitor the safety of members using our facility
When Legally Obliged to Do So
Under certain. Limited conditions we may be obliged by law to disclose data to the relevant authorities such as the police.
4. Sharing Data with Third Parties
In order to deliver some of our services to you it may be necessary to share your data with third parties.
Where we need to do so, we will only disclose the minimum amount of personal data in order to provide the service required.
We have implemented data processing agreements with each of the third parties and have checked to ensure that your data will be kept safe and your rights observed while the data is in their care.
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We may use services of third party Data Processors to deliver our services for example to host our website or send emails.
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In order to process payments, we may pass your payment details to the bank.
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Some of our services, such as our online booking app are provided by a third party software company.
5. How do we Keep your Data Secure
EMS FISICO have implemented a range of technical and organisational controls to ensure that your data is properly protected at all times. Our systems are equipped with access controls to restrict access to authorised personnel.
6. Marketing
EMS FISICO will only send marketing content to customers and consumers if they have given explicit consent to do so when completing online forms, forms in the studio or verbally in the studio.
If you do not wish to receive marketing communication, then consumers can easily withdraw consent by contacting EMS FISCIO.
7. Your Rights
The GDPR legislation provides you with a number of rights in relation to your personal data.
Right to Withdraw Consent
Where you have consented to our processing of your data, you have the right to withdraw that consent at any time. To do so please contact us using the details below:
Right to Access
You have the right to obtain copies of the information that we hold about you.
To request access to any data please email us at the address below explaining which data you require. In the interest of security, you will need to prove your identity before any information can be shared with you.
Under certain circumstances we may not be able to disclose all of the information you request, for example if it contains information about other people or there are legal reasons for us to withhold the data.
Right to Rectification
We would like to ensure that the data we hold about you is accurate up-to-date. If you believe the data we hold is inaccurate, please contact us. However, you may also ask us formally to correct your data by emailing us at the address below:
Right to Erasure or the Restriction of Processing
In certain circumstances you can ask us to remove your data from our systems by emailing or writing to us at the address below:
If there is a legal reason for us to continue holding the data we will let you know., otherwise we will make efforts to comply with your request. You may ask us to restrict our processing of your data if:
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We are using the data for marketing
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You believe that our processing of the data is unlawful
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You object to us using your data (pending investigation)
In these circumstances, we may continue to store your information, but will otherwise only process it with your consent or where we have a legal reason to do so.
Right to Complain
If you are concerned about the way we have processed your personal information, you have the right to complain to the Information Commissioners Officer (ICO). To do so please refer to the ICO website.
8. Cookies
When you visit our website, we may send you cookies. A cookie is a small text file that can be placed on your computer’s hard drive. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number. Two types of cookies are used on our website:
Session Cookies: These are temporary cookies that remain in the cookie file of your browser until you leave our website. These allow you to carry information across pages of our website and avoid you having to re-enter information.
Third Party Cookies: Third parties provide persistent cookies via our website. These are used to compile anonymous, aggregated statistics in order to serve advertisements on our website and track whether these advertisements are clocked on by users, to control how often you are shown a particular advertisement, to count the number of anonymous users of the website and to provide security within transactions.
Our cookies cannot be used by themselves to identify you. You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not nee able to use all the interactive features of our website if cookies are disabled. You may disable cookies through your browser by following the instructions found at www.allaboutcookies.org/manage-cookies.
9. Links
Our website contains links to other websites. Please note that we do not accept responsibility for the privacy practices of such websites and we recommend you read the privacy statements on entering other websites.
10. Changes to our Policy
EMS FISICO reserves the right to make changes to our Privacy Policy from time to time. Where we do so, we will publish the new policy on our website and where appropriate notify you by email.