Updated 10th October 2019
Team RH Fitness Ltd is fully committed to compliance with the requirements of the Data Protection Act 2018 and all other data protection legislation currently in force. The Regulation applies to anyone processing personal data and sets out principles which should be followed and gives rights to those whose data is being processed.
This privacy notice tells you what to expect us to do with your personal information when you make contact with us or use one of our services.
In this Privacy Notice we’ll tell you:
• why we are able to process your information;
• what purpose we are processing it for;
• whether you have to provide it to us;
• how long we store it for;
• whether there are other recipients of your personal information;
• whether we intend to transfer it to another country; and
• whether we do automated decision-making or profiling.
Team RH Fitness takes its responsibilities seriously and adheres to the Data Protection Principles as listed below.
When processing data we will ensure that it is:
• processed lawfully, fairly and in a transparent way
• processed only for the purpose that the data was collected for
• limited to what is necessary
• accurate and kept up to date
• kept for no longer than is necessary
• kept safe and secure
• only shared with other Organisations who can demonstrate compliance with the regulations
1. Our contact details
Team RH Fitness Ltd is the controller for the personal information we process, unless otherwise stated.
There are many ways you can contact us, including via Facebook, post or email, as follows:
Name: Team RH Fitness Ltd
Postal Address: Unit 11 Portobello Trade Park, Portobello Road, Birtley, Chester-le-Street, DH3 2SB
Facebook Contact: https://www.facebook.com/teamrhfitness/
Our Data Protection Officer is Sarah Burns, Data2action Ltd. You can contact her at Info@data2action.co.uk or via our postal address. Please mark the envelope ‘Data Protection Officer’.
2. Collecting and processing your personal data
2.1 The type of information we have
We collect and process the following information:
• Personal data such as your name and contact details (address, email address, telephone number)
• other personal identifiers such as IP Addresses
• Payment details
• Your date of birth, gender, weight and height
When you use our services, you also have the option to provide us with other items of personal data including data we may use to help support you with your goals. This data can include:
• Photographs showing your before and after profile(non mandatory)
• Health conditions (non mandatory)
Uploading progress photographs and/ or any health conditions are not mandatory requirements of your subscription. Should you wish to remove them at any time, you can do so via your Team RH Fitness web and App accounts, or alternatively you can request us to do this for you.
2.2 How we obtain your data and the purpose for collecting and processing it
Most of the personal information we process is provided to us directly by you for one or more of the following reasons:
• Enquiry about our products and services via the Team RH Fitness Ltd website or Facebook pages
• To purchase products from our online shop
• Managing and providing services to you as part of your Team RH Fitness Lifeplan subscription
• Post updates or record updates on your weight and fitness progress to the Team RH Fitness App, website or Facebook pages
• To seek and receive coaching advice via the Team RH Fitness Members Group on Facebook
2.3 Lawful bases for processing
Under the current regulations we are obliged to advise you of our lawful bases or reason for processing yourinformation. In most cases, this will be in order to fulfil the obligation of our contract with you, when you subscribe to our services and as detailed in our Terms and Conditions.
Included in our contractual terms, is the option to upload your ‘before and after’ progress photographs. This is purely optional and is not a mandatory element of your Lifeplan subscription. If you do choose to upload any photographs they will only be visible to you and our coaches. On occasion, we may ask for your consent for them to be published on our Website of Facebook pages. Where you grant us permission to do so, they will only be published on our Website and/or Facebook pages and you have the option to remove your consent at anytime. If do wish to have these removed please contact Team RH Fitness via our Facebook page https://www.facebook.com/teamrhfitness/
In addition, you have the option to provide us with details of any health conditions. Our coaches will use this purely for the purposes of assessing your weight and fitness progress. As with your ‘before and after’ photographs, you can amend or delete your health data at any time via your account on the Team RH Fitness App.
Other lawful bases which we rely upon for processing your data are:
• our legal obligations, for example, financial audit obligations, complaint handling, and the common law duty to mitigate our contractual losses;
• your consent, for example, in respect of placing cookies on your devices;
• our legitimate interests, for example:
- to provide our goods and services to you;
- to manage your account and our relationship with you;
- to manage payments, fees, charges, and to collect debts which you may owe to us;
- to increase our business and promote our brand;
- to improve our products and services;
- to conduct web analytics;
- to administer and protect our business, website, mobile app, and social media profiles;
- for the prevention and detection of fraud and spam; and
- for the establishment, exercise and defence of legal claims.
2.4 What we do with the information we have
We only collect and process personal data that is necessary and which is used for the following reasons:
• Set up your subscription account on our website
• Grant you access and use of the Team RH Fitness App
• Grant you access to the Team RH Fitness Facebook Membership page and associated coaching and support pages
• Purchase goods from our online shop
• Receive and respond to any queries you may have
• Share your progress photographs with others (only where you have given us your consent to do so).
2.5 How we store your information and for how log
We securely store all your data in the Team RH Fitness website, mobile appand associated storage systems.
• We store this for the duration of your Lifeplan subscription and for 12 months after your subscription has ended. This is to ensure anyone wishing to re-subscribe within this period are able to do so without loss of any historical progress data. After 12 months, your data is fully deleted from our Website, App and associated data storage systems.
• Details relating to any payment transactions (ie subscription, purchase of products, payments to you for ‘refer a friend’) are retained for 6 years in order to comply with our financial audit obligations.
• We may also retain certain data for as long as it is necessary for the purpose of protecting our business, and the establishment, exercise and defence of legal claims.
2.6 Third parties we share your data with
We share your data with third party service providers which we use to operate our business, for example, our website and app developers and an encryption service to protect any data files we send you, hosting services providers, payment processing providers and parcel delivery providers. We also use your data to enable you access to our Facebook group. We have contracts in place with our suppliers to ensure that your personal data is protected.
We may also:
• disclose your personal data to our staff;
• disclose your personal data to our professional advisers (e.g. lawyers, accountants, auditors or insurers) who provide professional services to us;
• disclose and exchange certain information with law enforcement agencies and regulatory bodies to comply with our legal obligations; and
• share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring.
• The recipients of the information will be bound by confidentiality obligations.
We will not share your information with any third parties for the purposes of direct marketing.
2.7 Joint controllers
In order to process any payments such as for your Lifeplan subscription, payment to you under the ‘refer a friend’ scheme or for goods purchased via our online shop, we share your payment details with other third parties who are classed as joint controllers under the regulation. This is because they decide what and how your data is processed. These third parties are:
• GoCardless (https://gocardless.com/privacy)
• Stripe (https://stripe.com/gb/privacy)
• PayPal (https://www.paypal.com/uk/webapps/mpp/ua/privacy-full#Updated_PS)
• Ashbourne Management Services Ltd (https://ashbourne-memberships.com/privacy-policy/)
Your payment details are entered by you and are then stored in the Team RH Fitness website in an encrypted format meaning they are not visible to any member of Team RH Fitness staff norour website developer.
These details are then transferred to the payment companies who process your data to ensure payment is made. Details of their processing arrangements of your payment details are explained in their privacy notices, which can be accessed via the above web links.
Any questions you have in relation to how your data is used to process such payments should be made to the relevant payment company.
2.8 Social Media
We have both an open page on Facebook (for members and non members) as well as closed group for members only.
Our staff have administration access to moderate the pages on our members only group, on our behalf and as such, they have access to all information shared on our Facebook pages and at times will decide how to we manage it. For example, if you send a message via our Facebook pages that needs a response from us, we may process it in our case management system as anenquiry or a complaint.
Team RH Fitness fully complies with Facebooks ‘pages, groups and events’ policy, ‘Data Privacy’ Policy,‘Community Standards’ and their ‘Terms and Conditions’.
As owners and administrators of the Team RH Fitness Facebook pages, we collect your data as follows and for the purposes as set out below:
• Name, Email address and Team RH Fitness customer number to grant you access to our membership only pages.
Any posts you make to these pages will be available to view by anyone else in the group.
Where you specifically ask for any data you post to the page not to be shared, our moderators will make all endeavours to ensure your post remains confidential and only visible to those Team RH Fitness employees who are granted with administration access.
Under the general terms and conditions of Facebook, you are able to remove any of your posts at your free will and at any time whilst you’re a member of Team RH’s Lifeplan. You may also remove your access to the page or request Team RH Fitness to remove your access, and any of your personal data from this page. Team RH Fitness cannot be responsible for any content that you have posted and which is subsequently shared by other members of the page.
To request your data to be deleted please contact Team RH Fitness via our Facebook page.
When interacting withTeam RH Fitness through the Facebook social media platform, we suggest you also familiarise yourself with Facebooks:
3. Data Subject Rights
3.1 Your data protection rights
Under UK data protection law, you have rights including:
1. Your right of access - You have the right to ask us for copies of your personal information.
2. Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
3. Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
4. Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.
5. Your right to object to processing - You have the the right to object to the processing of your personal data in certain circumstances.
6. Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
3.2 How to complain
Should you not be entirely satisfied with any aspect of how we have used your data, you can also complain to the ICO at the following address:
Information Commissioner’s Office
Helpline number: 0303 123 1113