Privacy Policy

This privacy policy outlines how activeNewham collects, uses, and protects your personal information. activeNewham is committed to ensuring your privacy is protected. If we ask you to provide certain information by which you can be identified when using our services, you can be assured that it will only be used in accordance with this policy. This policy covers data we collect from or about you via our websites (see links below), our App, at our centres, venues and through the various services we offer.

www.activenewham.org.uk
join.activenewham.org.uk
connect.activenewham.org.uk
help.activenewham.org.uk

We are the ‘controllers’ of the information we collect about you (‘personal data’).

We are registered with the ICO and our registration number is: ZA062143

As controllers of your personal data, we are responsible for how your data is processed. The word ‘process’ covers most things that can be done with personal data such as the collection, use, storage, sharing and erasure of that data. We are committed to complying with data protection legislation in our handing of your personal data.

You have certain rights in relation to your personal data including the right to object to the processing of your information in certain circumstances. Further information about your rights is included in section 13 of this policy.

‘Personal data’ is any information that relates to a living, identifiable person. This data can include your name, contact details, and other information we gather as part of our relationship with you.

It can also include ‘special categories’ of data, which is information about a person’s race or ethnic origin, religious, political or other beliefs, physical or mental health, trade union membership, genetic or biometric data, sex life or sexual orientation. The collection and use of this type of data is subject to strict controls. Similarly, information about criminal convictions and offences is also limited in the way it can be processed.

We will collect your personal data mostly through our contact with you and the data is usually provided by you but in some instances, we may receive data about you from other people or organisations. We will explain when this might happen in this policy.

We are committed to protecting your personal data and will only process the data if we need to for a specific purpose and providing we have a legal basis, as explained below.

here are various legal bases on which we may collect and process your data. We may have your consent, for example, you have informed us that you are happy for us to process your information for a specific purpose such as providing a service to you or receiving further information about what we do. Sometimes there is a contractual reason such as being able to process a monthly Direct Debit payment and deliver our services to you. If so, we will not be able to enter into a contract with you in the absence of the data. Occasionally there may be a legal reason for collecting or sharing data, such as for employees when we have to collect the information for the HMRC, or should you have an accident, we may need to provide details of this to the relevant health and safety authorities, e.g. the Health and Safety Executive (HSE). We may also process your data based on our legitimate business interests, for example, in order to operate and improve our business.

The types of information we may collect includes, but may not be limited to:

• Name and contact information, including email address, telephone number, and postal address.
• Date of birth, and gender.
• Health information
• Emergency contact information
• Usage data, including website activity, service usage, and performance metrics.
• Other information relevant to customer surveys and/or offers.

Personal data description	Purpose(s) for processing
Any personal details you give us or we obtain from third parties	Information you type into our websites or provide to one of our colleagues such as when you become a member, create your profile, update your member profile, provide activity data from other devices, make a booking, or visit one of our centres or any of our community services. This information may include your personal contact data, fitness-related data which has been obtained in order to create personalised fitness workouts for you or health related data. We use this data to provide you with the services you request, tell you about services you are eligible for, to keep in contact with you, manage your account and the services we provide. If you contact us by email, via the website, in person or by telephone we may keep a record of your contact information and enquiry and may subsequently use your contact details to respond to your enquiry. We will store and provide on request attendance and associated contact information to third parties in line with legislation, including temporary legal requirements such as the Government’s Test and Trace authorities to assist them in identifying those who may have come into contact with Covid-19 infected individuals.
Information which allows us to recognise you.	Such as a unique ID number; storing this data saves you from re-entering your details again when you return to the website. activeNewham can recognise you by your photograph as well, which also allows us to ensure that your card is not misused if lost or stolen and helps us identify you to ensure we support you on your activity journey. For services paid for in advance, we require your photo to be stored in our systems for identification purposes.
Details of your transactions	We collect data for any transactions you carry out through our websites and services, so that we can administer the services you have with us. Please note that we never store your payment details on our website.
Sensitive health data.	We collect any personal health data you provide to us when registering and signing up for appropriate services. We collect this information to ensure we are offering you the right services and so your progress can be tracked by yourself and us. We may ask you for information about your health in order to recommend appropriate exercise regimes or offer our other services.
Banking data	We will store your bank account number and sort code data where you have a Direct Debit mandate in place. When the Direct Debit mandate finishes, we will remove this data from our operational systems within 30 working days. We comply with BACS regulations for the processing of this data. We process bank card information at the time we take payment in order to administer our services. This data is not stored on our systems and is processed on Payment Card Industry Data Security Standard (PCIDSS) compliant banking systems. If you opt to save your details for future use, we will store a bank issued code that can only be used by our systems, but not your credit card details. If you have opted to save your details for future reference and have changed your mind, please contact us and we will action your request. Financial data used during in-app purchases is not stored or processed by activeNewham but transacted solely through payment services providers, which may include Apple and Google. Any purchases, refunds or cancellations bought through in-app purchases are administered by payment services providers, which may include Apple and Google and not by activeNewham.
Customer feedback	We will record customer comments and surveys about how we are performing.
Other Sensitive data	We are sometimes required to collect information about your ethnicity and other sensitive data in order to provide aggregated reports to the local authority. This information is used only for statistical purposes and is always kept secure. If you prefer not to provide us with this data, we will not hold this data.
Information about website visits including IP address	We use your IP address to capture information about website visits, so we can learn more about how our customers use the website in order to find ways to improve the website and our products and services for your benefit.
Your communication preferences	We keep a record of any permissions and preferences you give us about what types of communication you are happy to receive from us.
Email Tracking	We may use tools such as Tracking Pixels in emails to track whether an email has been opened and links have been clicked. We store this information to improve communications to customers. The data we store is the IP Address, User Agent and data/time of views. If you do not wish to receive marketing emails from us, you can opt out by clicking unsubscribe on the email or visiting this article .
CCTV	We use CCTV at centres for security and safety. CCTV footage maybe shared with the Police or other statutory bodies in the event of an incident, in line with Data Protection law.

We use cookies on our sites and services to enhance your experience and ensure the site is functional, while also providing you with a good experience when browsing our sites.

Further information about the use of cookies, why we use them and how they are applied can be found on our Cookie Policy .

Our services are used by people of all ages. activeNewham may accept website registrations and collect personal information from individuals under the age of 16.

Children aged under 16 years must have a parent or guardian’s consent before providing personal information to us. We do not wish to collect any personal information without this consent.

We will not knowingly market to children aged under 16 years.

Proof of age maybe required and retained for access to some services.

These are the basic guidelines we use to look after your personal data.
 

• We maintain secure systems to protect your personal information.
• We respect your wishes about how we contact you, whether by post, telephone, email or text message.
• We will update your information or preferences promptly when you ask us to.
• We will respond fully to requests from you to see the information that we hold about you.
• We will not hold your personal information for longer than is necessary for our legitimate business purposes.
• We follow strict procedures when storing or handling information that you have given us. Some information is encrypted, such as payment transactions and password.
• We will never sell your personal information to a third party.

TRANSFERS OF DATA OUTSIDE THE EEA

We will store most of your data on systems within the UK.

Where your data is transferred outside of the EEA we will ensure that there is a robust contract in place with safeguards to protect your personal data.

We retain personal information in line with our requirement to comply with our legal obligations. Where this data is not needed for legal or statutory purposes, we will delete this information if you request. See the contacts section to request your data to be deleted.

CCTV footage is stored for 30 days. In the event of an incident or where the requirement is for longer for evidentiary purposes, we may retain it until any investigations are concluded, and to comply with our legal obligations.

We may share information with third party organisations that provide specific services on our behalf which enhance our products and your experience with us. These organisations act as a Data Processor under our instructions. They may process data securely outside of the EU. There is a contract in place with each third party which includes strict terms and conditions to protect your privacy.

Our current processing partners include Claranet, Fitronics, Gladstone Software, Life Fitness, Playfinder, and Technogym.

Please note: Use of services provided by our partners Life Fitness and Technogym will be subject to the terms and conditions and/or Privacy Policies of these third party organisations. Please see the links to these third party terms that also apply above and beyond these here:

 

• Life Fitness - Privacy Policy
• Technogym - Privacy Policy

Sometimes third parties will use our centres for delivering their own service. Where this takes place the third party will remain the controller of the data for the services that they provide. The data will not enter our database unless the individuals that take part in these services also provide us with their personal data directly or already appear within our database.

For these Services the third-party will be responsible for upholding and responding to the rights of individuals.

activeNewham will never sell your personal information to any third party for marketing or other purposes.

We work in partnership with third parties to delivery our own marketing, e.g. HubSpot

activeNewham may use your personal information to improve our services for you. We may use your information for the following purposes:
 

• To provide services and products that you have purchased or requested.
• To check your identity.
• To check your eligibility, where appropriate.
• To update our records with any new information you give us.
• To notify you if we will be unable to provide a service you have booked before.
• For research and analysis so we can develop and improve our services for your benefit.
• To process payments and manage your account.
• To communicate with you about our services and products, including marketing communications.
• To improve our services and products.
• To conduct research and analysis.
• To comply with legal and regulatory requirements.
• To safeguard users of our services.

There are certain communications we need to send to you so we can provide our services. We call these service communications and include for example notices about your direct debit payments, change of password, registration confirmations, appointment reminders and waiting list announcements. We would not be able to provide you with services if we did not send these.

We may from time to time contact you about our services or products we think you might find interesting by email, by post, telephone or SMS, but only if you have given us your permission to do so.

If you buy a service from us for a fixed period of time with a specific end date, such as an annual membership, we will contact you at the appropriate time to tell you that the service is coming to an end and how you can renew.

If you do not want us to contact you other than for service emails let us know when you next visit us or contact us using the details below.

• Accuracy of data: we will always try to ensure the data we hold about you is accurate and relevant. If you believe the information we hold about you is out of date or incorrect, please tell a member of staff or see the contacting us section below. You will need a form of identification to request any changes.
• Seeing your data – subject access request: you have the right to know what personal information we hold about you. This is called a Subject Access Request.
• Removing your data: if you no longer use our services and products and wish us to delete your personal data, we will do this if there are no legal or statutory regulations requiring us to keep this information.
• Restricting processing: you can restrict the processing of your data including some processing we do under legitimate business interests.
• Transferring your data: in some circumstances you can ask us to transfer your information to another organisation.
• Objection to processing: you can object to the processing of your data in certain circumstances such as marketing.
• Withdrawing consent: if we are relying on consent to process your data, you may withdraw your consent at any time by contacting us.

To exercise any of the above rights please write to us using the details set out in section 16.
 

COMPLAINTS ABOUT HOW WE MANAGE YOUR DATA

If you are not happy about the way we manage your data, please contact us as quickly as possible by contacting your centre or usual contacts for providing our service. You may also write to the Data Protection Officer – dpo@activenewham.org.u k – who will investigate your complaint and get back to you as soon as possible.

INFORMATION COMMISSIONER'S OFFICE (ICO)

The ICO is the UK’s independent authority set up to uphold information rights. You have the right to contact them should you wish. Details can be found on their website: ico.org.uk

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the website in question.
 

activeNewham may update this privacy policy from time to time by posting a new version on our website. You should check this page occasionally to ensure that you are happy with any changes. If you have any questions or comments about our Privacy Policy or how we use your personal information, please contact us at data.protection@activenewham.org.uk .

In most instances it is best to contact us locally where you take part in our services such as the Leisure Centre you normally attend. We can usually deal with most of your queries here.

You can also contact us through our contacts pages on our website such as www.activenewham.org.uk .

Alternatively, you can contact the Data Protection Officer regarding any of your data protection rights by emailing them at dpo@activenewham.org.uk .