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Circadian Trust Privacy Notice

CIRCADIAN TRUST PRIVACY NOTICE

Circadian Trust operates Active Lifestyle Centres based in South Gloucestershire. We take your privacy seriously and we always handle personal information confidentially and securely. This Privacy Notice sets out how we collect, use and protect any personal information you provide. It also explains your data rights.

 

How to contact us

If you have any data protection related queries you can contact our Data Protection Officer at Circadian Trust, Thornbury Leisure Centre, Alveston Way, Thornbury, South Gloucestershire BS35 3JB. Contact email: privacy@circadiantrust.org

 

How do we collect your information?

We collect personal information in the following ways. If you:

  • Register for an Active Card.
  • Join as a pre-paid Active Member.
  • Take part in an activity or when using the cafes at Active Lifestyle Centres.
  • Enquire about services in person by phone, email or submitting your details on a website or printed enquiry form.
  • Register to use related third party applications such as Technogym, MyWellness Cloud, and HomePortal.
  • Register or booking a Lifestyle trial.
  • Take part in our Active Lifestyle GP Referral Programme.
  • Participate in a survey, competition, event or a promotion.
  • Are captured on CCTV located within our Centres and/or car parks.

 

What personal information do we collect from you?

We collect the following types of personal information in relation to the services we provide:

  • Contact information including residential address, email and phone number.
  • Personal details such as name, age, occupation, ethnicity and any disability, where relevant.
  • Information such as your preferences, activities and interests.
  • Physical activity levels, body composition measurements and medical conditions provided in person or through related third-party applications you use.
  • Financial details relating to either single transactions or when taking out any pre-paid or direct-debit membership.
  • Other information relevant to customer surveys and providing feedback.
  • If you choose to share your location and device information.

 

How we use your personal information

The following table sets out the purposes for which we collect and use personal information. We make sure we have a lawful basis for our activities, as stated below. We’ve included where we rely on the lawful basis of legitimate interests.

 

Purpose Lawful Basis
To fulfil a request for services and/or to administer and deliver services relevant to your membership or booking, including confirming your bookings and purchases. Performance of a contract
To process payments, refunds and keep financial records. Performance of a contract; Legal Obligation
To fulfil customer services queries. Performance of a contract
To send communications about relevant services and any other information linked to your membership. Consent
Use of CCTV at several locations including swimming pools for the safety and security of customers, visitors and staff. Legitimate Interests.
To enable you to take part in research about our services and service delivery, such as customer survey. Legitimate Interests
If you use a third party fitness application (such as Technogym) and tag us as your gym, we may be given access to certain personal information to help and support you with your fitness goals. With your consent
If you are referred to us for the Active Lifestyle GP Referral Programme we will hold personal information to track and report on your progress on the programme. With your consent
To maintain records of any accidents and incidents which occur onsite. Legal obligation
To send marketing communications about our products and services. With your consent
To meet our obligations to offer leisure facilities that represent the needs of the local community; a requirement of our partnership with South Gloucestershire Council. For example, information relating to ethnicity and disability. With your consent

 

Active Lifestyle GP Referral Programme

Information about programme participants is confidential and will not be used for any other purpose than the GP Referral Programme. When you attend GP Referral sessions, our Active Healthy Lifestyle Specialist will record information about your physical and mental wellbeing, as well as biometric measurements, in order to measure and report on your progress. Your information is stored securely on a secure online patient referral system which is only accessible by Active Healthy Lifestyle Specialists and your GP Practice. Your information will only be used by Active Healthy Lifestyle Specialists and your GP to monitor your progress on the programme.

 

Marketing communications

We may contact you by email from time to time with information and updates about our products and services provided you have given us your consent to do so. You can unsubscribe at any time using links in any of these emails or opt-out using the contact details above.

 

Sharing personal data

We may disclose personal data if required to do so by law. For example, CCTV footage maybe shared with the Police or other statutory bodies in the event of an incident.

We use external service providers to support the efficient running of our business. For example, to handle memberships and payment processing. These providers handle your personal data on our behalf, and we have appropriate contractual arrangements in place to cover these relationships. Where a service provider is located based outside the UK, the transfer of personal information is covered by appropriate legal safeguards.

We never share personal information with any other organisations for them to use for their own marketing.

 

Keeping your personal information secure

We are committed to handling personal information in accordance with the principles and practices of UK data protection laws. We are committed to keeping your information secure at all times. We maintain appropriate physical, electronic and operational measures to protect the information we hold and prevent any unauthorised access or disclosure.

 

How long do we retain your information?

We keep your personal details for as long as necessary for the specific purposes we are using them for. How long we hold the data for depends on our relationship with you and the services you use. Retention periods depend on if there’s a legal obligation to keep information for a minimum period, and where there’s no legal requirement, we assess of our business necessity to keep personal details for specific reasons. We securely dispose of personal information when it’s no longer required.


Young customers

We hold limited personal information about young people for the purpose of delivering services to them. For example, to provide swimming lessons. We will not contact young people directly with services or products related to their membership unless they have specifically requested for us to do so.

 

Your personal information rights

You have a number of rights under UK data protection laws:

  • Informed: You have the right to be informed about how we handle your personal data.  This privacy notice is one of the ways we do this.
  • Access: You have the right to ask for a copy of the personal data we hold about you and the purposes for which we are using it.
  • Rectification: You have the right to ask us to change any personal details which are incorrect and need updating.
  • Erasure: You have the right to ask us to erase your personal details. We will assess any deletion request on a case-by-case basis and in some cases we may refuse requests to erase your details. Examples include if your membership contract has not expired and you owe an outstanding sum of money, where we need to retain information for legal reasons, or if you have been banned from using our facilities and premises.
  • Object: You have the absolute right to object to receiving direct marketing communications from us. See the ‘Marketing communications’ section for how to do this. You also have the right to raise an objection about other ways we are handling your personal information.
  • Restriction: You have the right to ask us to restrict or suppress your personal information. This would mean we’d store it but not use it.
  • Portability: You have the right to obtain and reuse your personal data for your own purposes across different services.

If you’d like to exercise any of these rights or have any other query please contact us using the contact details at the top of the page.

 

How to raise a complaint

If you believe the way in which we’ve handled your personal information may have infringed data protection law you can raise a formal complaint using the contact details at the top of the page. Please provide as much information as possible about the nature of your complaint and the outcome you’re seeking. We’ll acknowledge we’ve received your complaint as soon as possible and aim to provide a full response within 30 days. Should a complaint require a more detailed investigation, we’ll let you know within 30 days when you can expect a response from us.

In most cases, the Information Commission Office (ICO) is likely to expect you to go through our own complaints process first. If you’re unhappy with our response, you can raise a complaint with the ICO.

 

Cookies

We use cookies and similar technologies on our website. When you arrive on the website for the first time you should see a cookie notification, and we’ll ask for your consent to use any non-essential cookies. You can decline at any time.

 

External links

If you use a link to go from our website to another website, or you request a service from a third party, this Privacy Statement will no longer apply once you have left our website. Any browsing and interaction on any other website is subject to that website’s own rules and policies.

Updates

This Privacy Notice will be updated from time to time on this page. Any significant changes will be communicated to our customers by email.