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Introduction
This is our Privacy Policy, which sets out how Pury Hill Limited uses and protects any information that you give us when you communicate with us, sign up for any membership or use our Website. By browsing and using our website you are agreeing to comply with and be bound by this Privacy Policy, which together with our Terms and Conditions govern Pury Hill Limited’s relationship with you. Please read the following carefully so you can understand how your personal data will be treated.
For the purposes of the General Data Protection Regulation 2016/679 (“the Regulation”) or any successor national or supra-national data protection legislation (including, as at the date of the publication of this Privacy Policy, the Data Protection Act 2018”), the data controller is Pury Hill Limited of Pury Hill Business Park, Alderton Road, Towcester NN12 7LS. The term ‘Pury Hill Gym’ or ‘us’ or ‘we’ refers to the operator of Pury Hill Gym and the owner of the Website whose registered office is Pury Hill Business Park, Alderton Road, Towcester NN12 7LS. Our company registration number is 03255445 (United Kingdom). The term ‘you’ refers to the user of Pury Hill Gym that we operate or any other visitor to our Website, as the context dictates.
Subject always to your rights under the Regulation, we may change this Privacy Policy from time-to-time.
The Regulation gives you certain rights which are detailed in the section headed “Your Rights regarding personal information”. The contents of this Privacy Notice are subject to these overriding rights and no provision in any other part of this Privacy Notice is to be construed as restricting the scope of those rights.
What information do we collect?
Any information that you provide by filling in forms including but not limited to your name, address, email address and telephone/mobile number, for the purposes of informing you about the services that we offer, of entering into a contract with you and thereafter of delivering the services which we have agreed to provide under that contract.
Further general information about you, including your personal or professional interests, experiences with our products and services or other products and services and your contact preferences to ensure that you receive services in the manner which is most convenient to you, to deliver a satisfactory service under the terms of our contract with you and to improve the services that we offer for the benefit of you and of other existing and future members.
We may also retain copies of any correspondence you send to us and details of your membership history, for as long as it is appropriate to do so, and (as with all the personal data we process) subject to appropriate technological and organisational safeguards to protect its integrity.
Who do we share this information with?
We may share your personal information with certain companies performing services on behalf of Pury Hill Gym (such as direct marketing agents) who will only use the information to provide a service that Pury Hill Gym has asked them to provide.
Those selected companies will perform a function for us, such as agencies and suppliers whom have been instructed to assist us to more effectively deliver services, manage and conduct promotions and offers, provide technical assistance and support and perform other functions to support marketing activities.
All selected companies may have access to personal information if needed to perform such functions but will only be permitted by us to use personal information for the purpose of performing that function and not for any other purpose.
Where you have given specific consent, your information may be shared with independent self-employed trainers for them to contact you to inform you of personal training services which they would like to offer you.
We may disclose your information to our subsidiaries or ultimate holding company and its subsidiaries, as defined in Section 1159 of the Companies Act 2006.
In all cases, any use of your personal information which has been instigated by us will comply with this Privacy Policy and with applicable data protection legislation. In some circumstances, we may have to disclose your personal information by law.
Save for this, we do not sell, transfer or disclose personal information we have collected from you in connection with our website activities to third parties outside Pury Hill Gym Limited.
Security
We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and corporate policies to safeguard and secure the information we collect online. Please be assured that we will take all steps reasonably necessary to ensure your data is treated securely and in accordance with this Privacy Policy. Any transactions will be encrypted. We cannot, however, guarantee the security of your transmitted data and you submit such data at your own risk.
CCTV policy
This section sets out the appropriate actions and procedures which Pury Hill Gym follows in respect of the use of CCTV (closed circuit television) surveillance systems (“CCTV Systems”) at Our premises.
Sound recording is disabled on all cameras.
Please note that all our gyms are monitored by CCTV during opening hours 7am-7pm. Pury Hill Gym reserves the right for its employees and contractors to review footage as required and by entering onto our sites you consent to your image being recorded and reviewed and waive any and all claims in relation to same. Recorded CCTV footage will be stored securely and retained in compliance with applicable laws.
In drawing up this policy, due account has been taken of the following:
1. The Regulation and any other relevant Data Protection legislation;
2. The CCTV Code of Practice produced by the Information Commissioner (“Code of Practice”); and
3. The Human Rights Act 1998.
This policy will cover all employees and persons providing a service to Pury Hill Gym, visitors and all other persons whose image(s) may be captured by our CCTV Systems.
We will also ensure that the personal data captured by our CCTV Systems is only processed in accordance with the following requirements:
Initial Assessment Procedures
Pury Hill Gym’s CCTV Officer has the legal responsibility for the day-to-day compliance with the requirements of this policy.
The purpose of the use of the CCTV Systems and the collection and processing of CCTV images is for the prevention or detection of crime or disorder, apprehension and prosecution of offenders (including use of images as evidence in criminal proceedings), interest of public and employee Health and Safety, protection of public health and the protection of the Our property and assets.
Prior to any camera installation the CCTV Officer will ensure that the installation complies with this policy and that the use of any camera is justified, necessary and proportionate. The CCTV Officer will regularly assess whether the use of any camera and the CCTV System as a whole continues to be justified, necessary and proportionate.
Siting the Cameras
The location of the equipment is carefully considered because the way in which images are captured needs to comply with the Regulation.
All cameras are located in prominent positions within public view and do not infringe on sensitive areas. All CCTV surveillance is automatically recorded, and any breach of this siting policy will be detected via controlled access to the CCTV System and auditing of the CCTV System.
Quality of the Images
The images produced by the equipment will as far as possible be of a quality that is effective for the purpose(s) for which they are intended. Upon installation, all equipment is tested to ensure that only the designated areas are monitored, and suitable quality pictures are available in live and play back mode. All CCTV equipment is maintained under contract.
Processing the images
Images which are not required for the purpose(s) for which the equipment is being used will not be retained for longer than is necessary. While images are retained, it is essential that their integrity be maintained, whether it is to ensure their evidential value or to protect the rights of people whose images may have been recorded. Access to and security of the images is controlled in accordance with the requirements of the Regulation. Where the images are required for evidential purposes or disciplinary proceedings, a copy file will be moved to an access controlled confidential location on the network and held until completion of the investigation. Viewing of images within the system is controlled by the CCTV Officer or a person nominated to act on their behalf. Only persons trained in the use of the equipment and authorised by the CCTV Officer can access data.
Access to and disclosure of images to third parties
Access to, and disclosure of, the images recorded by our CCTV System and similar surveillance equipment is restricted and carefully controlled. This ensures that the rights of individuals are preserved, and the continuity of evidence remains intact should the images be required for evidential purposes e.g. a police enquiry or an investigation being undertaken as part of an internal procedure.
Access to the medium on which the images are displayed and recorded is restricted to the CCTV Officer, staff authorised by them and third parties as authorised from time to time for specific purposes. Access to and disclosure of images is permitted only if it supports the purpose for which such images were collected.
Access to images by individuals
The Regulation gives any individual the right to request access to CCTV images which contain their personal data.
Individuals who request access to images must submit this formally in writing, with sufficient details to identify the section of footage with which they are concerned and to enable Pury Hill Gym to satisfy itself that the person making the request is the data subject of that specific recording. Upon receipt of the request, the CCTV Officer, or another member of staff authorised by them, will determine whether disclosure is appropriate and whether there is a duty of care to protect the images of any third parties. If the duty of care cannot be discharged, then the request can be refused.
A written response will be made to the individual, giving the decision (and if the request has been refused, giving reasons) within 31 days of receipt of the request.
Your Rights regarding personal information
The Regulation provides certain overriding rights for data subjects. You are entitled to request details of the information we hold about you and how we process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information (including in relation to direct marketing), to stop unauthorised transfers of your personal information to a third party and, in some circumstances to obtain your personal information in a structured, commonly used and machine-readable format or to have it transferred directly to another organisation. You may also have the right to lodge a complaint in relation to our processing of your personal information with a local supervisory authority (for residents of the United Kingdom: the Information Commissioner’s Office; further information can be found at https://ico.org.uk/). If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see the section ” What do we do with the information we collect?”) or that you may not be able to make use of the services and products offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations. If you have a concern about the way we are collecting or using personal information relating to you, we request that you raise your concern with us in the first instance: Pury Hill Office, Pury Hill Limited, Pury Hill Business Park, Alderton Road, Towcester NN12 7LS.
Changes to our Privacy, CCTV & Cookie Policy
We may make reasonable changes to this Privacy, CCTV Policy at any time. It is your responsibility to check with our office at Pury Hill Office, Pury Hill Limited, Pury Hill Business Park, Alderton Road, Towcester NN12 7LS.
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