THE SIX PACK COACH LIMITED (“the Website”)
Updated as at May, 2018
2. This policy covers the collection, processing and other use of personal data under the Data Protection Act 1998 (“DPA”) and the General Data Protection Regulations (“GDPR”).
3. The Company’s Website and the Programme is a provider of online general fitness advice.
4. For the purpose of the DPA and GDPR we are the data controller and any enquiry regarding the collection or processing of your data should be addressed to Samantha Dynes at our address The Six Pack Coach Limited, Unit 12158, PO Box 6945, London W1A6US
5. By using the Website and the Programme you consent to this policy. We are registered with the Information Commissioner’s Office for this purpose.
6. It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org
THE NATURE OF PERSONAL INFORMATION WE COLLECT
7. By using the Website or the Programme and its functions, you may provide personal data. Personal data means any information capable of identifying an individual. It does not include anonymised data.
8. We may process certain types of personal data about you as follows:
Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
Contact Data may include your billing address, delivery address, email address and telephone numbers.
Financial Data may include your bank account and payment card details.
Transaction Data may include details about payments between us and other details of purchases made by you.
Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
Usage Data may include information about how you use our website, products and services.
Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
9. We also use analytical and statistical tools that monitor details of your visits to our website and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data but this data will not identify you personally.
10. Your payment information (e.g. credit card details) provided when you make a purchase from our website is not received or stored by us. That information is processed securely and privately by the third party payment processors that we use. Company will not have access to that information at any time. We may share your personal data with our payment processors, but only for the purpose of completing the relevant payment transaction. Such payment processors are banned from using your personal data, except to provide these necessary payment services to us, and they are required to maintain the confidentiality of your personal data and payment information.
11. We require your explicit consent for processing sensitive data, which will be asked at the time when you submit your details.
12. Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
COLLECTION OF PERSONAL INFORMATION
13. It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com
14. We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
order our products or services;
create an account on our site;
subscribe to our service or publications;
request resources or marketing be sent to you;
enter a competition, prize draw, promotion or survey; or
give us feedback;
Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies:
Technical Data from our parties like Mailchimp
analytics providers such as Google
advertising networks; and
search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from data brokers or aggregators.
Before and After Photographs: In the event of you sending us via email or social media your before and after photograph, we may share this on our social media platforms, website and in our emails to promote the effectiveness of our Programme. This may include before and after photographs resulting from sessions with the Website or the Programme. You have the right to request the photograph not to be used or for us to cease sharing your before and after photograph at any time.
USE OF YOUR INFORMATION
15. We may hold and process personal data that you provide to us in accordance with the DPA and GDPR.
16. The information that we collect and store relating to you is primarily used to enable us to provide our services to you, and to meet our contractual commitments to you. In addition, we may use the information for the following purposes:
16.1 To notify you about any changes to our website, such as improvements or service/product changes, that may affect our service;
16.2 If you are an existing customer, we may contact you with information about goods and services similar to those that were the subject of a previous sale to you;
16.3 Where you have consented to receive such information, to provide information on other parties’ products or services that we feel may be of interest to you;
16.4 Where you have consented to receive our exclusive discount coupons for product launches, from time to time to provide that to you.
DISCLOSURE OF YOUR INFORMATION
17. We may disclose your information to regulatory bodies to enable us to comply with the law and to assist fraud protection and minimise credit risk.
18. Where you have consented for us to do so, we may provide your data to selected third parties who may contact you about their goods or services that you may be interested in.
19. If you do not want us to use your data for our or third parties’ use, you will have the opportunity to withhold your consent to this when you provide your details to us on the form on which we collect your data, or you can do so by writing to us at the address detailed in clause 4, or sending us an email to firstname.lastname@example.org.
20. Please be advised that we do not reveal information about identifiable individuals to our advertisers but we may, on occasion, provide them with aggregate statistical information about our visitors.
CONTROLLING THE USE OF YOUR DATA
21. If you have given us consent to use your data for a particular purpose you can revoke or vary that consent at any time. If you do not want us to use your data or want to vary the consent that you have provided you can write to us at the address detailed in clause 4 or email us at email@example.com at any time. Should you opt in to our mailing lists, you will be given the option to unsubscribe at the footer of every email, or you can contact us as outlined above.
WHERE WE STORE AND TRANSFER YOUR DATA
22. As part of the services offered to you, for example through our Website and Programme, the information you provide to us may be transferred to and stored in countries outside of the European Economic Area (EEA) as we use remote website server hosts to provide the website and some aspects of our service, which may be based outside of the EEA, or use servers based outside of the EEA – this is generally the nature of data stored in “the Cloud”. It may also be processed by
staff operating outside the EEA who work for one of our suppliers, e.g. our website server host, or work for us when temporarily outside of the EEA.
24. We do not use or disclose sensitive personal data, such as race, religion, or political affiliations, without your explicit consent.
26. Otherwise, we will process, disclose or share your personal data only if required to do so by law or in the good faith belief that such action is necessary to comply with legal requirements or legal process served on us or the website.
27. You have the right to opt out of our processing your personal data for marketing purposes by contacting us at firstname.lastname@example.org
28. The transmission of information via the Internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data while you are transmitting it to our site; any such transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
29. Where we have given you (or where you have chosen) a password so that you can access certain parts of our site, you are responsible for keeping this password confidential. You should choose a password it is not easy for someone to guess.
THIRD PARTY LINKS
30. You might find links to third party websites on our website. These websites should have their own privacy policies, which you should check. We do not accept any
responsibility or liability for their policies whatsoever as we have no control over them.
The cookies used by our website fall into four categories. The categories are: strictly necessary, preferences, statistics, and marketing.
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
FACEBOOK (VISITOR ACTION PIXEL)
We use the “visitor action pixels” from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our website.
This allows user behaviour to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data
of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
32. The DPA and GDPR give you the right to access information held about you by us. Please write to us or contact us by email if you wish to request confirmation of what personal information we hold relating to you. You can write to us at the address detailed in clause 4, above, or by email to email@example.com. There is no charge for requesting that we provide you with details of the personal data that we hold. We will provide this information within one month of your requesting the data.
33. You have the right to change the permissions that you have given us in relation to how we may use your data. You also have the right to request that we cease using your data or that we delete all personal data records that we hold relating to you. You can exercise these rights at any time by writing to us at the address detailed in clause 4, above, or by email to firstname.lastname@example.org.
CHANGES TO THIS POLICY
34. We may update these policies to reflect changes to the website and customer feedback. Please regularly review these policies to be informed of how we are protecting your personal data.
Version: May 2018