Identity Data – first name, last name, username or other user identifier; Profile Data – you may provide feedback to JFL through surveys or feedback forms and indicate your preferences to receiving marketing (from us or third parties); Contact Data – your phone number(s) and email address; and Financial Data – bank or payment card details and details of any purchases you make in respect of the JFL Service including in respect of app subscription purchases.
Information we collect about you When you visit or use the JFL Service we may collect the following types of personal data, using our software, hardware and other technologies:
Technical Data – this might include your IP address, account log-in information, browser information, location information, operating system and system configuration, network and software identification and device information; and Usage Data – this includes information about how you use the JFL Service, such as click throughs, time spent on page, download errors.
WHY WE USE YOUR DATA We have set out below, the purposes for using your personal data and the legal basis for doing so:
Purpose >> Types of data >> Lawful basis
To register you as a JFL user >> Identity, Contact, Financial >> Performance of a contract with you
To provide our core service to you, namely, to provide fitness and wellbeing related digital products, content and services through the JFL service >> All >> Performance of a contract with you For internal administration and record keeping purposes >> All >> Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (for effective business administration and service provision)
To provide, maintain, improve and develop the JFL Service >> All >> Performance of a contract with you. Necessary for our legitimate interests (for effective business administration and service provision)
To answer your enquiries which may involve contacting you by e-mail or phone >> Identity, Contact >> Performance of a contract with you. Necessary for our legitimate interests (to ensure our users are informed and satisfied with our service)
To enable us to process payments which you make, for example, when purchasing a subscription through our app >> Identity, Contact, Financial >> Performance of a contract with you
To send you JFL marketing, including about new offers and promotions and our latest news >> Identity, Contact, Profile >> Necessary for our legitimate interests (to improve our products and services and develop our business generally) Consent
To contact you about third-party products and services which we believe may be relevant to you (where you have indicated you would like to hear about these) >> Identity, Contact, Profile >> Consent
To improve and personalise your experience of the JFL Service by delivering more relevant content and advertising and to ensure that the JFL Service is delivered to you in the most effective way possible >> Identity, Contact, Profile, Technical, Usage >> Necessary for our legitimate interests (to develop our business, improve our service and overall user experience and inform our marketing strategy)
To administer the JFL Service, including trouble shooting, testing and analysis and to enable you to participate in interactive features of the JFL Service >> All >> Performance of a contract with you Necessary for our legitimate interests (to ensure that the JFL Service is fully functional and operating in the most effective way for you)
To verify your identity and detect fraud and security issues >> All >> Necessary for our legitimate interests (to prevent and detect fraudulent activity, security incidents and criminal activity)
To enable you to participate in prize competitions or complete a survey >> All >> Necessary for our legitimate interests (to develop our business, promote new products and services, obtain feedback from users to improve our services)
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 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. HOW LONG DO WE KEEP YOUR DATA FOR? We will keep your personal data for as long as you are a registered user of the JFL Service. After this point we may still need to keep hold of your personal data if there is a legal reason for doing so (such as for tax purposes or where we need to resolve any disputes with you). In such circumstances, we will only retain the minimum amount of data necessary for such reason. We may retain aggregated data for any purposes. Third Party Website Links
INTERNATIONAL TRANSFERS OF YOUR DATA Currently, JFL does not transfer any of your personal data outside of the European Economic Area ("EEA"); however, in the future, JFL may need to transfer your personal data to other countries outside of the EEA. This may happen if any of our servers are from time to time located in a country outside of the EEA or if any of our service providers are located in a country outside of the EEA. Before we proceed with any such transfer, we will ensure that we have a legal ground for doing so and have made sure that all adequate protections are in place. These countries may not have similar data protection laws to the EEA. If we transfer your personal data outside of the EEA in this way, we will take the appropriate steps to ensure that your privacy rights continue to be protected and that we continue to process your data in a fair and lawful manner.
Where relevant, you will have the right to see a copy of any safeguards we put in place for international transfers of your data. DISCLOSURE OF YOUR PERSONAL DATA We may disclose your personal data for the following purposes: To our third-party service providers who assist us with delivering the JFL Service, including our website hosting company, app development company and payment service provider. Where you have explicitly consented to us doing so, we may disclose your personal data to third parties for marketing purposes. You can opt-out of any marketing preferences at any time by following the process referred to below. We may also be required to share your personal data with third parties if required by law or regulation. In such circumstances, we will make sure that the disclosure is only to the extent required by law or regulation. If we share personal data with third parties, we will ensure that access is limited on a strictly need to know basis and is subject to suitable obligations relating to confidentiality and security.
WHERE WE STORE YOUR PERSONAL DATA We will store your personal data on servers in the European Economic Area (unless we relocate such servers, see “International Transfers of Your Data”) and will ensure that such personal data is held securely in accordance with good industry standards. Where we have given you a password to access a part of the JFL Service you are responsible for keeping this password secure and confidential. Please do not share this with anyone else. Please be aware that the transmission of data via the internet is not completely secure. Although JFL uses its best endeavours to keep your data secure, we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.
YOUR RIGHTS In certain situations, you are entitled to: access a copy of your personal data; correct your personal data; erase your personal data; object to the processing of your personal data where we are relying on a legitimate interest (as set out in the above table); restrict the processing of your personal data; request the transfer of your personal data to a third party; or where you have provided your consent to certain of our processing activities, in certain circumstances, you may withdraw your consent at any time (but please note that we may continue to process such personal data if we have legitimate legal grounds for doing so).
If you wish to exercise any of these rights, please contact us using the details set out in the “Contact Us” section below. You will not have to pay a fee to exercise any of these rights, unless your request is clearly unfounded, repetitive or excessive (in which case we can charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances.
In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office or your relevant regulator if you are concerned about the way in which we are handling your personal data. HOW TO OPT-OUT You can opt-out of any third-party marketing that you have previously opted into (or any JFL marketing) either by contacting us using the details set out below in the “Contact Us” section or by using the opt-out function detailed in the relevant marketing email.
CONTACT US If at any time you wish to get in touch with us, whether that is to exercise your rights or otherwise, please contact: Email: firstname.lastname@example.org.
Please write to us at: Jennis Fitness Ltd, 3 Filers Way, Weston Business Park, Weston-Super-Mare BS24 7JP. LAST UPDATED: June 2020