WE11 is committed to protecting and respecting your privacy.
WE11 understands that your personal data is entrusted to us and appreciates the importance of protecting and respecting your privacy. To this end we comply fully with the data protection law in force in the UK (“Data Protection Laws”).
For the purpose of Data Protection Laws, the data controller is WE11 Ltd, with registered address at: 62 Wilson Street, London, EC2A 2BU a Limited Company Registered in England Number: 11359911
When we refer to ‘we’, ‘us’ and ‘our’, we mean WE11.
What personal data may we collect from you?
When we refer to personal data in this policy, we mean information that can or has the potential to identify you as an individual.
Accordingly, we may hold and use personal data about you as a client, a trainer or therapist or in any other capacity, for example, when you visit one of our websites, complete a form, access our services or speak to us.
Personal data we collect from you may include the following:
· information that you give us when you enquire or become a trainer, therapist or client at WE11 or apply for a job with us including name, address, contact details (including email address and phone number)
· Your professional qualifications to provide services as a Personal Trainer and/or Therapist
· Your professional indemnity insurance details
· details of referrals, quotes and other contact and correspondence we may have had with you
· details of appointments, services and/or treatment you have received at our premises from us or a 3rd party
· information obtained from surveys, promotions and competitions that you have entered or taken part in
· information about complaints and incidents
· information you give us when you make a payment to us, such as financial or credit card information
· other information received from other sources, including from your use of websites and other digital platforms we operate or the other services we provide, information from business partners, advertising networks, analytics providers, or information provided by other companies who have obtained your permission to share information about you.
Where you use any of our websites, we may automatically collect personal data about you including:
· computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform,
· Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
The data that we request from you may include special category data. This includes information that relates to the following:
· racial or ethnic origin, or
· political opinions, or
· religious or philosophical beliefs, or
· trade union membership, or
· genetic data, biometric data for the purpose of uniquely identifying a natural person, or
· health data,
· or data concerning a natural person's sex life or sexual orientation.
When do we collect personal data about you?
We may collect personal data about you if you:
· visit one of our websites
· enquire about any of our services
· register to be a trainer, therapist or client with us
· fill in a form or survey for us
· carry out a transaction on our website or in the front of house café at WE11
· participate in a competition or promotion or other marketing activity
· make online payments
· contact us, for example by email, telephone or via social media
· participate in interactive features on any of our websites.
In the interests of training and continually improving our services, calls to WE11 and its agents may be monitored or recorded.
What personal data we may receive from third parties and other sources?
We may collect personal data about you from third parties such as:
· We have a number of independent third parties acting on our behalf who may collect personal data from you to allow us to carry out the services we offer e.g. an independent physiotherapist may carry out your initial Triage call or a subsequent consultation and collect personal data from you which is subsequently shared with WE11 for the continuity of your care and may be used for quality and monitoring purposes;
· Your work/business contact information e.g. name, job title, address, email, contact number, which may have been collected from agencies, partner organisations or other third parties, for the purpose of business to business marketing activity, to allow WE11 to provide you with direct marketing communication about relevant products or services to you in your professional capacity or your organisation.
How do we lawfully process your personal data?
Set out below are some of the ways in which we process personal data although to do so lawfully we need to have a legal ground for doing so. We normally process personal data if it is:
· necessary to provide you with our services - to enable us to carry out our obligations to you arising from any contract entered into between us and you including relating to the provision by us of services or to you and related matter such as billing, accounting and audit, credit or other payment card verification and anti-fraud screening
· in our or a third party's legitimate interests to do so - see details below. For further information about direct marketing to businesses and legitimate interest, please see the ‘Marketing’ section below.
· required or allowed by any applicable law
· with your explicit consent for example: direct consumer marketing communications
Generally, we will only ask for your consent to processing if there are no other legal grounds to process. In these circumstances, we will always aim to be clear and transparent about why we need your consent and what we are asking it for. Where we are relying on consent to process personal data you have the right to withdraw your consent at any time by contacting us using the details below and we will stop the processing for which consent was obtained.
To process special category data, we rely on additional legal grounds and generally, they are as follows:
· With your explicit consent
· It is necessary to establish, make or defend legal claims or court action
· It is necessary so that we can comply with employment law
· It is necessary for a public interest purpose in line with any laws that are applicable. This should assist in protecting the public against dishonesty, malpractice or other seriously improper behaviour for example, investigating complaints, clinical concerns, regulatory breaches or investigations e.g. the Care Quality Commission or GMC or ICO.
Processing of personal data which you have made public:
As stated above, one of the legal grounds for processing data is where it is in our legitimate interest to do so, taking into account your interest's rights and freedoms. This allows us to manage the relationship that exists between you and us and can include the following reasons:
· provide you with information, products or services that you request from us
· managing all aspects of our relationship with you, our products and services and any third parties who may provide products or services on our behalf
· allow you to participate in interactive features of our services, when you choose to do so
· notify you about changes to our products or services
· keep our records up to date
· respond to requests where we have a legal or regulatory obligation to do so
· check the accuracy of information about you and the quality of the service you have been provided.
· to conduct and analyse market research
· to ensure that content from any of our websites is presented in the most effective manner for you and for your computer
· to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations including to defend ourselves from claims, exercise our rights and adhere to laws and regulations that apply to us and the third parties we work with
· to take part in, or be the subject of, any sale, purchase, merger or takeover of all or part our business.
The security of your personal data
We protect all personal data we hold about you by ensuring that we have appropriate organisational and technical security measures in place to prevent unauthorised access or unlawful processing of personal data and to prevent personal data being lost, destroyed or damaged. We conduct assessments to ensure the ongoing security of our information systems.
Any personal data you provide will be held for as long as is necessary having regard to the purpose for which it was collected and in accordance with all applicable UK laws.
All information you provide to us is stored securely. Any payment transactions on our website will be processed securely by third party payment processors. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.
The transmission of information via the internet cannot be guaranteed as completely secure. However, we ensure that any information transferred to our websites is via an encrypted connection. Once we have received your information, we will use strict procedures and security features to minimise the risk of unauthorised access.
At your request, we may occasionally transfer personal information to you via email, or you may choose to transfer information to us via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you do so understanding the risks associated with doing so.
How long do we retain your personal data?
Unless we explain otherwise to you, we will retain your personal data on the basis of the following guidelines:
· for as long as we have a reasonable business need, such as managing our relationship with you and managing our business
· for as long as we provide services and/or treatment to you and then for as long as someone could bring a claim against us (in general this is a period of 8 years); and/or
· in line with legal and regulatory requirements or guidance.
Disclosure of your personal data to third parties
In the usual course of our business we may disclose your personal data (which will be limited to the extent reasonably necessary) to certain third party organisations that we use to support the delivery of our services.
This may include the following:
· business partners, suppliers and sub-contractors for the performance of any contract we enter into with you,
· organisations providing IT systems support and hosting in relation to the IT systems on which your information is stored,
· third party debt collectors for the purposes of debt collection,
· delivery companies for the purposes of transportation,
· third party service providers for the purposes of storage of information and confidential destruction, third party marketing companies for the purpose of sending marketing emails, subject to obtaining appropriate consent.
Where a third party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under Data Protection Laws.
We may also disclose your personal data to third parties in the event that we sell or buy any business or assets or where we are required by law to do so.
What do we do with any non-personal information collected when accessing the website?
We may also use other companies to set cookies on our websites and gather cookie information for us – please refer to the information detailed below. From time to time we may also analyse Internet Protocol (IP) addresses or other anonymous data sources.
By law, website operators are required to ask for a website user’s permission when placing certain kinds of cookie on their devices for the first time.
Where consent is required, the law states that it should be “informed consent”, which means we must ensure that you understand what cookies are and why we want to use them.
What are Cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
To find out more about cookies, you can visit: www.allaboutcookies.org
CATEGORY 1 COOKIES
These cookies are essential in order to enable you to move around our websites and use its features, such as accessing secure areas of the websites. Without these cookies, services you have asked for cannot be provided.
Your consent is not required for the delivery of those cookies which are strictly necessary to provide services requested by you.
We use these types of cookies.
CATEGORY 2 COOKIES
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All the information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
We use these types of cookies. By using our website and online services you agree that we can place these types of cookies on your device.
CATEGORY 3 COOKIES
These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video. The information these cookies collect is generally anonymised and they cannot track your browsing activity on other websites.
We use these types of cookies. By using our websites these you agree that we can place these types of cookies on your device.
CATEGORY 4 COOKIES
These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
We do not use these cookies on our website.
Definitions used above are consistent with those supplied by the International Chamber of Commerce ‘ICC UK Cookie Guide’ April 2012.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential Category 1 Cookies) you may not be able to access all or parts of our websites. For information on how to delete cookies, please refer to: use https://ico.org.uk/for-the-public/online/cookies
WE11 carries out two types of direct marketing:
1) Business to Consumer (B2C) which means, if you engage with WE11 in your capacity as an individual i.e. you are a customer or client of a trainer or therapist then we may process your personal data for marketing purposes but only if we have your prior consent to do so; and
2) Business to Business (B2B) which means, if you engage with WE11 in your professional capacity e.g. if you are a trainer or therapist with whom WE11 has an existing or prospective business relationship, WE11 may keep you up to date with services we offer/provide.
Business to Consumer (B2C)
You may also receive service communications from time to time which will not include an unsubscribe option as they are not considered marketing communication and will remain unaffected by your marketing preferences.
Business to Business (B2B)
Whether you have received a B2C marketing communication or a B2B marketing communication you will have the right to ask us to stop sending you marketing communication. B2B customers will have the right to opt out of receiving any further specific marketing communication at any time. Our marketing emails will include an unsubscribe option which you can select.
For non-web based marketing information please write to: Marketing Department, WE11 Ltd, 62 Wilson Street, London, EC2A 2BU. We would ask you to give us a reasonable amount of notice, to give us time to update our systems. While the precise timings vary by department, we generally ask that you give us at least 30 days’ notice.
CCTV is installed at our site, to monitor building security and assist in crime prevention and detection.
We operate our CCTV in accordance with the guidance issued by the local data protection authority
We collect this data as part of our role as a service provider to you, and to ensure the health and safety of our staff and visitors to our site.
We will not hold images for longer than necessary and will dispose of them securely
Your Rights under Data Protection Laws
The law gives you certain rights in respect of the personal data that we hold about you as well as information about what we do with it, who we share it with and how long we will hold it for. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs. The website of the Information Commissioner's Office (http://www.ico.org.uk) has a wealth of useful information in respect of your rights in your personal data. In addition to your right to stop marketing, detailed above, below is a short overview of the most commonly-used rights.
· Data Subject Access Request - With some exceptions designed to protect the rights of others you have the right to a copy of the personal data that we hold about you as well as information about what we do with it, who we share it with and how long we will hold it for. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs.
· The Right of Erasure ('Right to be Forgotten') - the right to have your personal information erased where we have no reason to continue processing;
· Data Portability - the right to move, copy or transfer personal information you have provided to us;
· Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you. If we have made a wholly automated decision (i.e. with no human judgement at all) you have the right to request that someone views that decision.
· Right to Rectification - You have the right to have the personal data we hold about you corrected if it is factually inaccurate. If any of your personal data has changed, especially contact information such as: email address, postal address and phone number please get in touch.
· If you want to exercise your rights in respect of your personal data, the best way to do so is to contact us by email on info@WE11.com or to write to us for the attention of the data protection officer at the address below. In order to protect your privacy, we may ask you to prove your identity before we take any steps in response to such a request.
If you are not satisfied with how we handle your request, you can contact the Information Commissioner’s Office on 0303 123 1113 or visit their website (http://www.ico.org.uk).
62 Wilson Street