CYC:D Limited (“CYC:D” or “we” or “us”) is committed to protecting and respecting your privacy. This policy (together with the terms and conditions and any other documents we refer to in this policy or the terms and conditions) set out how we will use your personal information and who it will be shared with. Please read the following carefully.
1. What information do we collect about you?
1.1 We may collect and process the following data about you (“your information”):
(a) information that you submit to us either online via our website when you register or when you register in the Studio, and / or when you login and / or sign up to our mailing, including any details relating to your health and fitness, and your performance in any of our classes;
(b) any correspondence you send to us or when you email us;
(c) details of your visits to our website and the resources that you access (which may include, amongst other things, traffic data and communication data);
(d) details of credits purchased on our website;
(e) reservations you make for our classes; and
(f) information that you provide to us if you are applying for a position with us.
2. How will we use your information?
2.1 We may use your information in the following ways:
(a) to ensure that our site’s content is presented as effectively as possible for you;
(b) for our internal purposes, such as quality control, site performance, system administration and to evaluate use of our site, so that we can provide you with enhanced services;
(c) to notify you about changes to our services;
(d) to provide you with information, products or services that you request from us, or which we feel may interest you (provided of course that you agree);
(e) to provide you with data arising from your performance during CYC:D classes;
(f) to create reports to assist with future marketing;
(g) to carry out our obligations arising from any contracts with you (including processing your payment for credits and to reserve your place on CYC:D classes when you have made a booking); and
(h) to enable you to participate in interactive features of our site, when you choose to do so.
2.2 We may monitor your use of our site and record your email address and/or IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical information about our users’ browsing actions and patterns and does not identify any individual.
2.3 How long we hold your personal information for will vary and will depend principally on:
(a) the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose, and
(b) legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
2.4 We will ensure that the personal information that we hold is subject to appropriate security measures.
3. Grounds for using your information
3.1 We must have a lawful basis for processing your information. The lawful basis will vary on the circumstances of how and why we have your information but typical examples include:
(a) Consent – we may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below).
(b) Performance of a contract – we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
(c) Legitimate interest – we may use your personal information for our legitimate interests, some examples of which are given above; and/or
(d) Compliance with law or regulation – we may use your personal information as necessary to comply with applicable law/regulation.
5.1 If you register on our website or in the Studio to become a client or customer of CYC:D, or if you sign up on our website or in the Studio to join our mailing list, we may use your personal information to send you information that we think may be of interest to you. This may include details of events happening in the Studio, current offers on buying credits, or general information about what is happening at CYC:D. It is within our legitimate interests to use your information in this way.
5.2 You will be given an opportunity to tell us whether or not you wish to receive direct marketing materials and communications from us either at the time you register on our website or in the Studio to become a client or customer of CYC:D, or if you sign up on our website or in the Studio to join our mailing list, and/or within the communication itself.
5.3 If you do not wish to receive any direct marketing material or communications after you register to become a client or customer of CYC:D, or after you have signed up to join our mailing list, please contact us at email@example.com indicating if you do not wish to be contacted for one or more of these marketing purposes. Please note that if you choose not to be contacted, but you continue to hold unused credits, you will not be provided with details of events taking place in the Studio where your credits could be used.
5.4 If you change your mind about being contacted by us in the future, or change address, or if any information that we hold about you is inaccurate or out-of-date, please let us know by: emailing: firstname.lastname@example.org or writing to us at CYC:D, 34c High Street, Haslemere, Surrey GU27 2HJ or calling us on 01428 645055.
6. Who do we share your information with?
6.1 We may share your information with other organisations:
(a) if we sell or buy any business or assets (as we may share your data with the prospective seller or buyer);
(b) if we or substantially all of our company assets are acquired by another party, in which case your information will be one of the transferred assets;
(c) if we have to share your information to comply with legal or regulatory requirements, or if we have to enforce or apply our terms and conditions or any other agreements or to protect the rights, property or safety of CYC:D, our customers or others. This may involve exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6.2 We may also share your information with third parties who provide services to us. This includes sharing your information with Mindbody Inc (“Mindbody”). Mindbody provides the software we use to operate our business, including registering customers, facilitating bookings and storing customer information. MINDBODY stores all data in servers and backup servers located in the United States. Mindbody has Privacy Shield certification which complies with relevant data protection legislation in the UK, including the General Data Protection Regulations, related to transferring data outside of the EU.
6.3 Where we transfer your personal information outside Europe, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of different ways, for instance:
(a) the country to which we send the personal information may be approved by the European Commission;
(b) the recipient may have signed a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal information, or
(c) where the recipient is located in the US, it may be a certified member of the EU-US Privacy Shield scheme.
In other circumstances, the law may permit us to otherwise transfer your personal information outside Europe. In all cases, however, any transfer of your personal information will be compliant with applicable data protection law.
7. How do we keep your information secure?
7.1 All your information is stored on our secure password protected computers. Any payment transactions will be encrypted. If you have a username, password or other login details which enable you to access certain parts of our site, you must not allow any other person to use them and must treat them as confidential. If you believe or suspect that someone else knows your login details you must contact us at email@example.com as soon as possible.
7.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information transmitted to our site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7.3 Our site may from time to time contain links to and from other websites. If you follow a link to any of those sites, please note that those sites ought to have their own privacy policies and that we do not accept any responsibility or liability for those sites or for their privacy policies. Please check those privacy policies before you submit your information to those sites.
8. Your choices and rights
8.1 You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below. Please note that these rights will not apply in all cases or to all information that we hold about you. For example, we may need to continue to hold and process information to establish, exercise or defend our legal rights.
8.2 These rights include:
(a) Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege will not be disclosed other than to our client and as authorised by our client.
(b) Requesting that we correct your personal information if it is inaccurate or incomplete.
(c) Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
(d) Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
(e) Lodging a complaint with the information commissioner, if you think that any of your rights have been infringed by us.
9. How to contact us
9.1 If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at CYC:D Limited, 34c High Street, Haslemere, Surrey GU27 2HJ or firstname.lastname@example.org.