The Bridal PT: Privacy Notice
We are committed to protecting and respecting your privacy.
This Privacy Notice sets out how we collect, use, maintain and disclose Personal Data, including any information provided through our website (the “Website”).
Your privacy is of the utmost importance to us. Please read this Privacy Notice carefully to understand our views and practices regarding your personal data and how we will treat it.
Whenever you provide personal information, we are legally obliged to use it in accordance with the laws concerning the protection of personal information.
Who we are
KIRSTY VICTORIA (THE BRIDAL PT) is a business operated by Kirsty Armstrong (a sole trader) in England and Wales whose address is at Unit 21806, PO Box 6945, London, W1A 6US (the “Bridal PT”)
For the purposes of the Data Protection Act 2018, the General Data Protection Regulations and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation”), the Bridal PT will be the ‘data controller’ for all personal information that we determine the means and purpose of processing. We are registered with the Information Commissioners Office under registration number ZA365282.
By “Personal Data” we refer to information collected or held by the Bridal PT, that identifies and relates to you as an individual.
Information we may collect We may collect personal information about you when you request our services or engage us through the My PT Hub app and website, including: • your name; • date of birth; • gender; • GP details; • next of kin; • details of your health and lifestyle, including, height, weight, body measurements, photos to track start and end progress for our services, details on our PAR-Q form of your current health status and details of any injuries or conditions; • postal address; • invoicing details/address; • information regarding the services you request; • supplementary information you provide us about yourself when contacting us; • email address; • telephone numbers (including mobile); and • payment details (where you pay by card). This is managed through Stripe.
What do we do with the information we collect? We will use your personal information for a number of purposes including: • to liaise with you in relation to the sessions provided through our services; • to plan your service programme; • internal record keeping; • to give you information that you request from us and to improve our services; • to notify you about changes to our services; • to allow us to operate the Website efficiently; • to ensure that the content from our Website is presented in the most effective manner for you and your computer; • any relevant troubleshooting, testing or statistical analysis as appropriate; and • to keep the Website secure.
Where we have your permission to do so, we may also use the information collected to: • provide you with information about our services that we offer via promotional communications; and • keep you up to date with features on the Website, however, you can opt-out of any of these data uses at any time by emailing firstname.lastname@example.org.
Data retention We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where you have engaged us to provide you with services, our standard approach is to delete any Personal Data relating to you upon the fulfilment or termination of the services.
1 1057.518.1 © Cracknell Law 2019
Legal basis of processing We will only process your information for as long as we have a relevant legal basis to do so. This is usually in order to provide you with the contractual services you have requested from the Bridal PT or if you have provided us with adequate consent to process your information for other purposes.
If we choose to process your information under the legal basis of legitimate interests, we will always inform you of our legitimate business interest and your right to object.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com.
Protecting your information We are committed to ensuring that your information is secure and we have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect online.
However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.
Transfer of data outside of the EU The information you provide or the data we collect via the Website may be stored and processed in any country where we or our service providers operate and/or have facilities. As a result, your Personal Data may be transferred to countries or regions without data protection or privacy laws similar to those in effect in your home country. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data, which provide enforceable legal remedies and rights over your personal data equivalent to those under the applicable Data Protection Legislation.
Sharing your information with others Please be assured that we will not share your information for any other reason unless we are required by law or permitted to do so under this Privacy Notice. The main circumstances in which we will be permitted or required to disclose this is by law will be by court order, to government bodies and law enforcement agencies.
However, sometimes we may share your information with third parties in the following ways: • we may use carefully selected sub-processors to help us collect, store or manage your information. This will always be managed under the terms of a written data processing agreement or with your express consent; • we may share your progress photos on our Website and/or social media platforms with your prior consent; • analytics and search engine providers that assist us in the improvement and optimisation of the Website; and • if the Bridal PT is acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets. We process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the relevant seller or buyer of our business may not be able to provide services to you.
Access to your Personal Data You have rights in relation to any Personal Data that we hold about you. If you wish to access your Personal Data you may make a formal subject access request by contacting the Bridal PT.
The information you request must relate to you or another person that you have authority to act on their behalf. The Bridal PT will require a confirmation of your ID prior to providing any information about the data we hold. If you are unable to provide sufficient information to prove your ID, the Bridal PT reserves the right to refuse your request for access to Personal Data. The rights you have in relation to the Personal Data we hold regarding you are: • the right to rectify any inaccuracies in the information we hold; • the right to erasure of information in specific circumstances; • the right to request transfer of your information to another controller; and • the right to object to processing in certain circumstances.
If you have provided us with consent to process your information, you always reserve the right to withdraw this consent via the method detailed in the paragraph below. We are committed to ensuring that your wishes are respected and upon notification that you wish to withdraw your consent, the Bridal PT will immediately cease processing the information in question.
Please send your request to the Bridal PT by emailing firstname.lastname@example.org. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to this Privacy Notice We may change this Privacy Notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Data.
Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Data handling practices. The date of the changes will be listed in the ‘Last updated’ section below. We 2 1057.518.1 © Cracknell Law 2019
will endeavour to notify all of our current clients of any updates to this notice via email and we will post the relevant announcement on our website homepage.
We recommend that you print a copy of this page for your reference.
How can you make a complaint? Please note that if you are not satisfied with the processing of your Personal Data as set out in this Privacy Notice, please contact us at email@example.com.
You have the right to issue a complaint directly with the Information Commissioners Office, the data protection supervisory authority for England and Wales (https://ico.org.uk/concerns/).
Contacting us Please contact us at firstname.lastname@example.org if you have any questions, comments or requests regarding this Privacy Notice.
Last updated March 2019
3 1057.518.1 © Cracknell Law 2019