Active Stirling Limited
means the General Data Protection Regulation
Gordon McAllister, Director of Governance
Register of systems
means a register of all systems or contexts in which personal data is processed by the Charity.
Active Stirling Limited (registered company number SC298585; registered charity number SCO37632) is committed to protecting and respecting any personal information you share with us for purposes of our activities and associated brands.
A new data protection law will come into effect on 25 May 2018. This new law, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) sets out the principles and rules about how companies can process personal data and your rights in relation to your data.
This privacy notice is a public statement that describes:
- how we apply data protection principles to processing data;
- what types of information we collect from you;
- how it is used by us;
- how we may share it with others;
- how long we hold the information;
- how you can manage the information we hold, and
- how you can contact us.
This version of our privacy statement is live from 25 May 2018.
The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of these changes.
How we apply data protection principles to processing data.
We will comply with data protection law. This says that the personal information we hold about you must be:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- relevant to the purposes we have told you about and limited only to those purposes;
- accurate and kept up to date;
- kept only as long as necessary for the purposes we have told you about;
- kept securely.
What types of information do we collect from you?
We collect information about you when you
- visit Active Stirling’s online booking system or other sites accessible from the online booking system, websites, applications and our customer services or Bookings platforms.
- Register with and buy services from us;
- Take part in promotions, competitions, customer surveys and questionnaires;
- Contact us for example in writing, by email, letter or telephone.
Some of this information will not identify you personally, but provides us with information about how customers use our services and engage with us. We only collect information which is necessary, relevant and adequate for the purpose for which you are providing it. We use this information to improve our services and make them more useful to you.
Information we collect includes some (or all) of the following:
- Name (including title);
- Phone number;
- Date of birth;
- Email address;
- The date and time you used our services;
- The pages you visited on our website and how long you visited us for;
- Your IP address;
- Your GPS location (where you have permitted access to this);
- Cookie, Pixels or Beacon information;
- The website address from which you accessed our website;
- Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses).
- Photographs; and
- Any information within correspondence you send to us.
Active Stirling will only process information that is necessary for the purpose for which it has been collected. We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you;
- Where we need to comply with a legal obligation;
- 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.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else's interests).
- Where it is needed in the public interest or for official purposes.
These circumstances are further expanded in the list below:
Where you have provided your consent, we may use and process your information to contact you from time to time about promotions, events, products, services or information which we think may be of interest to you. Please don’t worry, it is not our intention to bombard you as we recognise how irritating this can be.
We will always give you the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products and services that you request from us.
We will seek your explicit consent if we wish to use any photographs or videos of you by asking you to sign an image release form. This might include (but is not limited to), the right to use your photographs in their printed and online form for publicity, social media, press releases and funding applications and to share them with key partners.
You can withdraw your consent at any time by contacting us on the details provided within the 'How can I manage the information we hold about you' section below or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.
We may use and process your personal information where this is necessary to perform a contract with you and to fulfil and complete your orders, purchases and other transactions entered into with us.
We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.
- To respond to correspondence you send to us and fulfil the requests you make to us, (for example: service requests, brochure requests or information about specific sports activities);
- To provide information on our services (for example Gym opening times, membership prices).
- To analyse, evaluate and improve our products and services so that your visit and use of our website, applications, customer service and bookings functions are more useful and enjoyable (we will generally use data amalgamated from many people so that it cannot identify you personally);
- To undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services that we think you will be interested in. We will only send marketing communications to you if you have provided your consent for us to do so or which we have obtained in the ways mentioned in the paragraphs above. We have already emailed you separately regarding opting in/ out to marketing communications;
- For product development purposes (e.g. to improve equipment quality, performance and sports classes);
- In some cases, we may use automated methods to analyse, combine and evaluate information that you have provided to us. We collect and analyse this information in this way so that we can deliver the most appropriate customer experience to you by tailoring and making relevant all our service and communications;
- To send you marketing information from time to time after you have purchased a product or service from us or made a purchasing enquiry or requested a brochure or other information of interest. We will only contact you with information about our own products and services (and in ways the law allows), which we hope you will like. You have the right to object to us sending you this information at any time;
- To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business or where we have obtained your business contact details from our authorised network or an online or public business directory. In relation to any such information we send by email or SMS, we will include an option allowing you to object to receiving future messages by unsubscribing;
- To contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us;
To administer competitions and promotions that you enter with us from time to time and to distribute prizes.
- To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
- For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
- To comply with a request from you regarding the exercise of your rights (for example where you have asked us not to contact you for marketing purposes), we will keep a record of this in order to be able to comply with your request;
- To inform you of updates to our terms and conditions and policies.
We may process your personal information to comply with our legal requirements (for example if we are making a payment into your bank account).
Sometimes we will need to process your personal information to contact you (for example if there is an urgent safety notice and we need to tell you about it.)
We do not sell your information to third parties, but we do work closely with our third party suppliers who fulfil business activities for us (like marketing, events and market research etc). We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
An example of how we share customer data would be:
Life Fitness who provide a digital platform for members within the gym. The platform allows users to opt out of sharing their personal data with Life Fitness. We have entered into contractual arrangements with Life Fitness on how they will use our customer data and we have agreed to comply with required data security standards, policies and procedures. Life Fitness may share your personal information with other third parties including their subscribers, business partners and service providers. For further information please contact us on the details below.
We will not hold your personal information in an identifiable format for any longer than is necessary. If you are a customer or otherwise have a relationship with us, we will hold personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship.
How can you manage the information we hold about you?
You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to us using your personal information (for example where we rely on our business interests to process and use your personal information).
You have several rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received any request (including any identification documents requested).
You have the right to:
- Ask for a copy of the information that we hold about you;
- Correct and update your information;
- Withdraw your consent (where we rely on it);
- Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
- Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information;
- Transfer your information in a structured data file (in a commonly used and machine readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.
You can exercise the above rights and/or manage your information by contacting us using the details below:
The Data Protection Team
Active Stirling Limited
Unit 23, 15 Borrowmeadow Road
Phone: 01786 273555
If you have any specific data protection concerns or a complaint, you can address it to our Data Protection Team at firstname.lastname@example.org
If you are unhappy, you have the right to lodge a complaint with a data protection regulator in Europe and, in the country where you work or live or where your legal rights have been infringed.
The contact details for the Information Commissioner’s Office, the data protection regulator in Scotland, are below:
The Information Commissioner's Office - Scotland
45 Melville Street
Phone: 0303 123 1115