In May 2018, a new European law called the General Data Protection Regulation (GDPR) became law. The purpose of this law is to give people more control over how organisations use their data. This web page explains how Jenna Caley collects data and what we do with it.
Who We Are
Protecting your Privacy
We know that there’s a lot of information here but we want you to be fully informed about your rights, and how Jenna Caley uses your data.· We hope the following information will answer any questions you have but if not, please do get in touch with us.
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive our marketing emails.
When collecting your personal data, we’ll only collect the data that is necessary for us operate our group classes, one-to-one services and retail operations.
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase and may need to pass this onto a courier or royal Mail to deliver it
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you or make available relevant special offers.
We may also combine the data of many customers to identify trends, develop new services, or types of memberships.
We will also use your email address details to send you our monthly newsletter keeping you up-to-date about news at our studio, our classes and offers that we think might interest you.
When Do We Collect Your Personal Data?
Visit our website, call us or visit our studio
Create an account with us
Book, amend or cancel a class
Buy products and services
Engage with us on social media.
Recommend a friend
Enter Challenges, Prize Draws or competitions.
Book any kind of appointment with us or book to attend an event
Complete a survey that we send you.
Comment on or review our services
Fill in any forms. For example, if an accident happens in studio or you make an enquiry via the contact us section of our website.
Given a third-party permission to share with us the information they hold about you.
We may collect data from publicly available sources when you have given your consent to share information or where the information is made public as a matter of law.
When you use our studio, which may have CCTV systems operated for the security and safety of both customers and employees. These systems may record your image during your visit.
What Sort of Personal Data Do We Collect?
If you have an account with us: your name, gender, date of birth, billing/home address, email and telephone numbers (home and mobile), nominated emergency contact details, etc.
For your security, we’ll also keep an encrypted record of your login password.
Details of your interactions with us through our studio, or online. For example, we collect notes from our conversations with you, details of any comments you make, details of purchases you made classes attended, and how and when you contact us.
Copies of documents you provide to prove your age or identity where the law requires this (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
Details of your visits to our website, and which site you came from to ours.
Personal details which help us to recommend services of interest. We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your experience with us. Of course, it’s always your choice whether you share such details with us.
Payment card information.
Your comments and service reviews.
Your image may be recorded on CCTV when you visit our studio
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
How and Why Do We Use Your Personal Data?
We want to give you the best possible customer experience at Jenna Caley. One way to achieve that is to get to know who you are by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service to you. Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section, below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services that you’ve asked for. For example, if you’ve asked us to tell you which membership is best for you or expect to hear about new offers then we can’t do that if you’ve withdrawn use of your personal data for marketing purposes.
Here’s How Jenna Caley Will Use Your Personal Data
- To process any orders that you make when using our website or in studio. If we don’t collect your personal data at the checkout then we won’t be able to process your order and comply with our legal obligations.
- To respond to your queries, refund requests and complaints. Handling the information you sent us enables us to respond. We may also keep a record to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this to meet our contractual obligations to you, our legal obligations and in our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll do this as part of our legitimate interest. For example, by checking your password when you sign-in and using automated monitoring of IP addresses to identify possible fraudulent logins from unexpected locations.
- To protect our customers, premises, assets, contractors and employees from crime, we may choose to operate CCTV systems in our studios which record images for security. If we do this, it will be on the basis of our legitimate business interests.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, post and telephone about relevant services including tailored special offers, discounts, promotions, events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To display the most interesting content to you on our website or apps, we may choose to use data we hold about your favourite location, classes, and so on. We do so on the basis of your consent to receive app notifications and / or for our website to place cookies or similar technology on your device. For example, we might offer you recommendations based on your purchase history and any other data you’ve shared with us.
- To develop, test and improve the systems and services we provide to you. We’ll do this on the basis of our legitimate business interests. For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having.
- To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our classes more relevant to you and help us monitor instructor quality. Of course, you are free to opt-out of receiving these requests from us at any time.
- To build a better picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured at Jenna Caley with third party data from publicly-available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ We will do this on the basis of our legitimate business interest.
- To process your class booking/appointment requests. Sometimes, we’ll need to share your details with a third party who is providing a service (such as an instructor). We do so to organize the appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
How We Protect Your Personal Data
We know how much data security matters to all our customers. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it. We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured to ensure it is protected.
We regularly monitor our website for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
How Long Will We Keep Your Personal Data
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
When you place an order, we’ll keep the personal data you give us for six years so we can comply with our legal and contractual obligations.
If you’ve not used your account for more than three years, it will be flagged as inactive and we’ll close the account and delete or anonymise the personal data associated with it.
Who We Share Your Personal Data With
We sometimes share your personal data with trusted third parties. For example, with our contracted Pilates instructors, couriers, for fraud management, or to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
IT companies who support our website, booking system and other business systems.
Operational companies such as delivery couriers.
Direct marketing and digital marketing companies
Google/Facebook to show you services that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
Data insight agencies to ensure your details are up to date and accurate.
We do not share your personal data with third parties for them to promote their services to you. Neither do we sell your data.
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or on our systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
We currently use the following companies who will process your personal data as part of their contracts with us:
Where Your Personal Data May Be Processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may hold personal data that we collect from you to third-party data processors in countries that are outside the EEA, such as the USA. For example, this may be required so we can fulfil class bookings, process your payment details or provide support services.
What Are Your Rights Concerning Your Personal Data?
You have the right to request:
Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
Review by a senior member of staff of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You can contact us to request to exercise these rights at any time as follows:
To ask for your information please contact
41a Altenburg Gardens
SW11 1JH - London
or email email@example.com and mark your email subject line ‘Data Access Request’.
To ask for your information to be amended please contact your studio. If we choose not to action your request we will explain to you the reasons for our refusal.
Your Right to Withdraw Consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data for our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
How Can You Stop the Use of Your Personal Data for Direct Marketing?
There are several ways you can stop direct marketing communications from us:
Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further marketing emails to you.
Write to the Data Protection Officer
41a Altenburg Gardens
SW11 1JH - London
Please note that you may continue to receive communications for a short period after changing your preferences, while our systems are fully updated.
What if you live outside the UK
This Privacy Notice is currently only available in English
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK or USA.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK or US.
We’ll ensure that any third parties process your personal data only in accordance with their legitimate interests.
These third parties may be subject to different laws from those which apply in your country of residence. Please note that we do not take active steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us on firstname.lastname@example.org