PRIVACY POLICY

OUR COMMITMENT TO PROTECTING YOUR PRIVACY

Spirit Health Clubs are committed to complying with the General Data Protection Regulation and the Data Protection Act 2018. We know that you care how information about you is used and shared. Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely. This privacy policy describes the type of personal information that we may collect about you when you join our leisure club, how we use any personal information, the circumstances in which we may share the information and the steps we take to safeguard the information to protect your privacy.

We have published this notice to help you understand

  • how Spirit Health Clubs uses your personal data;
  • who we share your information with, why and on what basis;
  • and what your rights are.

If we make changes to this notice we will notify you by updating it on our website.

"Personal data" means any information collected and logged in a format that allows you to be identified personally, either directly (e.g. name) or indirectly (e.g. telephone number). Before providing us with this information, we recommend that you read this document describing our customer privacy protection policy.

This Customer Privacy Policy forms part of the terms and conditions that govern our hotel and leisure club services.

WHAT PERSONAL DATA WE COLLECT

When you join the leisure club as a member, you are entering into a membership contract agreement with us, a copy of the terms & conditions for which you can find on the leisure club website. To enable us to set-up your membership and to help us improve your leisure club experience we will ask you to provide some personal information which may include:

  • Contact details (last name, first name, telephone number, email)
  • Date of birth
  • Bank account details (for direct debit memberships)
  • Photograph
  • Health Information
  • Our leisure clubs use CCTV for safety and security monitoring purposes.

HOW WE USE YOUR INFORMATION

Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:

  • CONTRACT - your personal information is processed in order to fulfil a contractual arrangement.
  • CONSENT - where you agree to us using your information in this way e.g. for sending you information on hotel or leisure club promotions
  • LEGITIMATE INTERESTS - this means the interests of Spirit Health Clubs in managing our business to allow us to provide you with the best service.
  • LEGAL OBLIGATION - where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.

We use your information in a number of different ways, primarily to fulfil a contract and also provide excellent service to our customers.

The below set this out in detail, showing what we use the information we collect for:

Contact Details

  • To manage the membership application and administration of your club membership.
  • To verify your membership status
  • To manage payment records.
  • Carrying out surveys and analyses of questionnaires and customer comments
  • Managing claims/complaints
  • Offering you the benefits of our loyalty program
  • To carry out obligations arising from membership contractual agreements.
  • To facilities booking of a class

Personal Information

  • To improve services, to input to our marketing programme.
  • For demographic profiling of our customer base, to assist promotion of our services, and adapting and improving our products and services.

Information relating to your children

  • We do not collect personal information from individuals under 18 years of age without the permission of their parent or guardian.
  • Only supplied by a parent or guardian as required by the membership application process we will require the name, date of birth and age of any member under the age of 18.

Bank Account Details

  • If you are paying for your membership via monthly direct debit we will collect and securely store your bank account information for membership administration purposes.

Photograph

  • In the interests of security and the prevention of crime, we may take a digital photograph of each member to whom a membership card is issued.
  • To identify you as a club member.
  • By providing the digital photograph to us, you are consenting to our using it in the manner set out in this Policy.

Membership Number

  • To manage your access to the club.
  • To monitor your usage of the club to assist us to supporting you achieve your exercise and health goals.

Sensitive Information

  • As part of the gym induction process, at your discretion you may also share with us information about your general health and medical conditions
  • This information is used to inform the prescription of an appropriate exercise programme*
  • By providing sensitive information to us, you are consenting to our using it in the manner set out in this Policy.

Questions / Comments

  • To collect feedback to improve our services and monitor customer experience.

*Your attention is drawn to the Health Commitment Statement policy which outlines our responsibilities and what we can reasonably expect of each other in regards to your health, exercise any medical conditions.

YOUR RIGHTS

You are entitled to request the following from Spirit Health Clubs, these are called your Data Subject Rights and there is more information on these on the Information Commissioners website www.ico.org.uk

  • THE RIGHT TO BE INFORMED – The right to be informed about how your personal information is being used and processed (as described in this policy).
  • RIGHT OF ACCESS – The right to access the personal information we hold about you.
  • RIGHT TO RECTIFICATION – The right to request the correction of inaccurate personal information we hold about you and to have incomplete personal information completed
  • THE RIGHT TO ERASURE (also known as the Right to be Forgotten) - The right to request that we delete your data, or stop processing it or collecting it, in some circumstances.
  • RIGHT TO RESTRICTION OF PROCESSING – to restrict processing of your personal information.
  • RIGHT TO DATA PORTABILITY - to electronically move, copy or transfer your personal information in a standard form, or port elements of your data either to you or another service provider.
  • RIGHT TO OBJECT – The right to object to processing of your personal information
  • THE RIGHT TO STOP DIRECT MARKETING messages, and to withdraw consent for other consent-based processing at any time.
  • THE RIGHT TO COMPLAIN to your data protection regulator - in the UK, the Information Commissioner’s Office. We encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.

If have any general questions about your rights or if you want to exercise your rights or have a complaint, please contact us, details in the contact us section at the end of this document.

WHO WE SHARE YOUR INFORMATION WITH AND WHY

Within Spirit Health Clubs, in order to offer you the best service, we can share your personal data and give access to authorised employees including:

  • Leisure Club & Hotel staff
  • IT departments
  • Commercial partners and marketing services
  • Legal services if applicable
  • Generally, any appropriate person within Spirit Health Clubs for certain specific categories of personal data.

Information about our leisure club members are an important part of our business and we do not sell this information to others. Spirit Health Clubs works with a number of trusted suppliers, agencies and businesses in order to provide you the high quality services you expect from us. Your personal data may be sent to a third party for the purposes of supplying you with services and improving your leisure club membership experience.

Some examples of the categories of third parties with whom we share your data are:

IT Companies

Spirit Health Clubs work with business who support our website and other business systems.

Marketing Companies

We work with marketing companies who help us manage our electronic communications with you or carry out surveys and reviews on our behalf. If customer have opted-in to receiving information regarding our goods and services we may utilise a marketing company to send out such information. For further information see the ‘Keeping in touch with you’ section of this policy.

Payment Processing

Spirit Health Clubs work with trusted third party payment processing providers and banks in order to securely take and manage payments.

Debt Recovery and Fraud Prevention

We release your personal information on the basis that we have a legitimate interest in preventing fraud and money laundering, when we believe release is appropriate to comply with the law; enforce or apply our contractual agreements; or protect the rights, property or safety of Kew Green Hotel or our customers. This includes exchanging information with other companies and organisations for verification of identity fraud protection, credit risk reduction and debt collection.

Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address and vehicle details.

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

Local Authorities

We may also be obliged to send your information to local authorities if this is required by law or as part of an inquiry and in accordance with local regulations.

Business Transfers

As we continue to develop our business, we might sell or buy hotels or leisure clubs. In such transactions, hotel guest and leisure club member information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the customer or member consents otherwise). Also, in the unlikely event that Spirit Health Clubs or substantially all of its assets are acquired, personal information will be one of the transferred assets.

Website

To improve our platform, prevent or detect fraud or abuses of our website and enable third parties to carry out technical, logistical, research or other functions on our behalf.

Outside the UK

Whenever we transfer personal information to countries outside of the European Economic Area in the course of sharing information as set out above, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection.

KEEPING YOUR INFORMATION

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 5 years after the date it is no longer needed by us for any of the purposes listed under the ‘How we use your information’ section within this policy.

The only exceptions to this are where:

  • the law requires us to hold your personal information for a longer period, or delete it sooner;
  • you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
  • we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
  • In limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

HOW WE SECURE YOUR INFORMATION

Spirit Health Clubs take data security seriously, and we take appropriate technical and organisational procedures, in accordance with applicable legal provisions, to protect your personal data against illicit or accidental destruction, accidental alteration or loss, and unauthorised access or disclosure.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

Our information security policies and procedures are aligned with widely accepted international standards, we apply the controls detailed in the Payment Card Industry Data Security Standard to all environments storing personal data. These standards are applied and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements.

To this end, we have taken technical and organisational measures/

TECHNICAL MEASURES:

  • We have taken technical measures such as firewalls and encryption of computer and mobile device systems.
  • When personal data is transferred encryption technology is used.
  • When you submit credit card data when making a reservation, SSL (Secure Socket Layer) encryption technology is used to guarantee a secure transaction.
  • Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; 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.
  • User ID / Password systems and procedures

POLICIES & PROCEDURES:

  • We have measures in place to protect against accidental loss and unauthorized access, use, destruction, or disclosure of data
  • We place appropriate restrictions on the levels and type of access to personal information and have organisational measures such as user IDs / passwords to control staff access to personal data in line with their job requirements.
  • We implement appropriate measures and controls, including monitoring and physical measures, to store and transfer data securely
  • We conduct Privacy Impact Assessments in accordance with legal requirements and our business policies
  • Training for employees and contractors
  • We require privacy, information security, and other applicable training on a regular basis for our employees who have access to personal information and other sensitive data
  • We take steps to ensure that our employees and contractors operate in accordance with our information security policies and procedures and any applicable contractual conditions
  • We require, through the use of contracts and security reviews, our third-party vendors and providers to protect any personal information with which they are entrusted in accordance with our security policies and procedures

KEEPING IN TOUCH WITH YOU

We want to keep our customers up to date with information about special offers, benefits and improvements to our facilities and services.

When you engage with our marketing activities, or join our leisure clubs, either electronically on-line via website or social media for example, or in person at the hotel, we will ask you if you want to opt-in to receive this type of promotional information. If you have consented to receive marketing, you may opt out at a later date.

If you decide you do not want to receive this marketing information you have the right to ask us not to process your personal information for marketing purposes. You can request that we stop contacting you for marketing purposes by contacting us directly or via the unsubscribe link within any marketing Email or SMS which you receive. You may continue to receive marketing information for a short period while your request is dealt with.

Spirit Health Clubs will not share your information with outside companies for their marketing purposes.

We reserve the right to contact our hotel customers or leisure club members as necessary to fulfil the obligations and administration of our service. We will also communicate as deemed appropriate by Spirit Health Clubs in regards to any changes to the product, services and facilities of the hotel or leisure club which may impact on you.

CHANGES TO HOW WE PROTECT YOUR PRIVACY

We may change or update this Privacy Policy from time to time, to reflect how we are processing your data. If we make significant changes, we will make that clear on our website, or by some other means of contact such as email, so that you are able to review the changes before you continue to use our services.

ACCESS, MODIFICATION & CONTACTING US

You have the right to access your personal data collected by Spirit Health Clubs and to modify it subject to applicable legal provisions. Should you need to contact us if you have any questions about this notice, would like us to stop using your information, want to exercise any of your rights as set in this Privacy Policy, or have a complaint; please contact us.

Spirit Health Clubs is operated by 3 hotel groups.

For Spirit Clubs operated by Kew Green Hotels:
Birmingham, Chester, Colchester, Haydock, Ipswich, Lancaster, Leeds Brighouse, Norwich, Portsmouth, Rochester, Rugby, Runcorn, Stoke, Swindon, Taunton, please contact us at: data.privacy@kewgreen.co.uk

For Spirit Clubs operated by Interstate Hotels:
Eastleigh, Hemel Hempstead, Farnborough, Hull Marina, Leicester, Reading, Southampton, Leeds CP, Aylesbury, Coventry, Fareham, Gloucester, Maidstone, please contact us at: privacy@interstatehotels.com

For Spirit Clubs operated by LHMUK Hotels:
Brentwood, Bristol, Cambridge, Edinburgh, Guildford, London-Heathrow, London-Sutton, Maidenhead, Milton Keynes, Oxford, please contact us at: privacy@LHMUK.com

For the purposes of confidentiality and personal data protection, we will need to identify you in order to respond to your request. You will be asked to include a copy of two official pieces of identification, such as a driver's license or passport, along with your request.

If your personal data is inaccurate, incomplete or not up to date, please send the appropriate amendments to the Data Privacy department as indicated above.

All requests will receive a response as swiftly as possible and in accordance with applicable law.

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