ATHLO APP PRIVACY STATEMENT
Consent to installation of the ATHLO App
YES I consent to the installation of the Athlo App for the purposes of selling and/or booking gym classes or use of gym facilities.
NO I do not consent to the installation of the ATHLO App.
How you can withdraw consent
Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us firstname.lastname@example.org but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
Consent to processing Location Data
YES I consent to processing of my Location Data (including details of my current location disclosed by GPS technology so that location-enabled Services are activated to allow ATHLO to populate nearest and available gyms to user).
NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.
ATHLO App Limited (we) are committed to protecting your personal data and respecting your privacy.
- ATHLO APP 1.0 mobile application software (the “ATHLO App”) once you have downloaded or streamed a copy of the ATHLO App onto your mobile telephone or handheld device (“Device”).
- Any of the services accessible through the ATHLO App (the “Services”). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. ThisATHLO App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Important information and who we are
ATHLO App Ltd is the controller and is responsible for your personal data (collectively referred to as "Company""we", "us" or "our" in this policy).
Our full details are:
- ATHLO APP LTD, Company number 11336134, registered in England & Wales
- Email address: email@example.com
- Postal address: 21-23 Ives Street, Chelsea, London, SW2 2ND
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.
This version was last updated February 2022. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the ATHLO App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the ATHLO App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personaldata changes during our relationship with you.
Third party links
The ATHLO App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data.
- Contact Data.
- Financial Data.
- Transaction Data.
- Device Data.
- Content Data.
- Profile Data.
- Usage Data.
- Marketing and Communications Data.
- Location Data
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How is your personal data collected?
We will collect and process the following data about you:
- Information you give us. This is information (including Identity, Contact, Financial, and Marketing andCommunications Data) you consent to giving us about you through your on the ATHLO App, or bycorresponding with us (for example, by email or chat). It includes information you provide when youregister to use the ATHLO App, download the ATHLO App and/or subscribe to any of our Services, searchfor an ATHLO App or Service, and when you report a problem with the ATHLO App or our Services. Ifyou contact us, we will keep a record of that correspondence.
- Information we collect about you and your device. Each time you use the ATHLO App we will automatically collect personal data including Device, Content and Usage Data. We do not collect this data using cookies.
- Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Refer to the Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
Purposes for which we will use your personal data
Type of data
Lawful basis for processing
To install the ATHLO App and register you as a new ATHLO App user
To process in ATHLO App purchases and deliver services including managing payments and collecting money owed to us
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the ATHLO App or any Services
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To administer and protect our business and this ATHLO App including troubleshooting, data analysis and system testing
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve the ATHLO App
Marketing and Communications
Necessary for our legitimate interests (to develop our products/Services and grow our business)
Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table “Purposes for which we will use your personal data”:
- External Third Parties as set out in the Glossary.
We do not transfer your personal data outside the UK.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. You are responsible for keeping your password to the ATHLO App confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any ATHLOApplicable regulator when we are legally required to do so.
By law we have to keep basic information about our users (including Contact, Identity, Financial and Transaction Data)for as long as we continue to process your data.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the ATHLO App for a period of twelve months then we will treat the account as expired and your personal data may be deleted.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Please see the sections below in relation to the following categories to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer or your personal data.
- Right to withdraw consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.You can exercise any of these rights at any time by contacting us at firstname.lastname@example.org.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal third parties
Other companies in the ATHLO Group acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.
External third parties
ATHLO gym partners, and service providers who provide IT and system administration services.
Professional advisers acting as processors or joint controller including lawyers, bankers, accountants, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if ATHLO applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only ATHLO Applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Description of categories of personal data
- Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
- Contact Data: billing address, delivery address, email address and telephone numbers.
- Financial Data: bank account and payment card details.
- Transaction Data: includes details about payments to and from you and details of in-ATHLO App purchases.
- Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
- Content Data: includes information stored on your Device, including login information, photos, videos or other digital content.
- Profile Data: includes your username and password, in-ATHLO App purchase history, your interests, preferences, feedback and survey responses.
- Usage Data: includes details of your use of any of the ATHLO App including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data: includes your current location disclosed by GPS technology.