24 May 2018

DATA PROTECTION: YOUR PRIVACY

Welcome to FitasaFi privacy notice.

FitasaFi respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how FitasaFi collects and processes your personal data for example when you contact us via email or text or Facebook or even old fashioned letters and paper copies of information.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

FitasaFi is the controller and responsible for your personal data (collectively referred to as FitasaFi, "we", "us" or "our" in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Fiona Lewis using the details set out below.

Contact details

Our full details are:

Full name of legal entity: FitasaFi

Email address: fiona.fitasafi@gmail.com

Postal address: 53 Marlborough Crescent, Sevenoaks TN132HL

Telephone number: 07511 286725

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was created on 24 May 2018 to incorporate changes introduced by the General Data Protection Regulation (GDPR).

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes home address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us (because you might pay FitasaFi by bank transfer so we have some limited transaction data).
Marketing and Communications Data includes your communication preferences.

We do collect limited forms of Special Categories of Personal Data about you as we collect information about your health to help us provide our coaching services.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our coaching services). In this case, we may have to cancel our service but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in Health forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Email us to enquire about FitasaFi;
- request marketing and/or information to be sent to you; or
give us some feedback.

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Where we need to protect your vital interests.

Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to our communications at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below in 3 sections:

- Purpose/Activity

- Type of data

- Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you. As we provide a running coaching service we need to be aware of any health issues you may have that could impact the provision of our service to you.

To process and deliver our service to you including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover money due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c ) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis)

(a) Identity

(b) Contact

(c ) Technical

(a) Necessary for our legitimate interests (for running our business)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

Necessary for our legitimate interests (to develop our products/services and grow our business)

To share some of your Personal Data with your GP, next of kin or emergency and/or NHS services, should you have an accident while undertaking a session with us or should we reasonably believe that your life is in danger.

(a) Identity

(b) Contact

To protect your vital interests, ie to protect your health and life.

Marketing

We aim to limit our marketing contact to what is most relevant and useful for you. For example we do not engage in third-party marketing.

You will receive marketing communications from us if you have requested information from us or purchased services from us

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

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.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in section 3 above.

Your General Practitioner or other health service provider as explained above.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for [tax] purposes.]

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may 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.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:

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.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

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.

Contact

Data Protection: News

Fit as a Fi

24 May 2018

DATA PROTECTION: YOUR PRIVACY