CONSUMER PRIVACY POLICY

 

Educated Body ( a trading name of Raw Corporate Health Ltd) and Cushman & Wakefield, invites you to read this privacy policy (“Policy”) which explains how we jointly treat personal information we obtain about you, how it is used by us, how we may share it with third parties and how you can manage the information we hold about you.

Our Policy has been developed in accordance with the requirements of new data protection laws contained in the General Data Protection Regulation and the Data Protection Act 2018 (together, the “Data Protection Legislation”) which are in force.

 

1. DATA CONTROLLER

The joint controller of your personal information is Educated Body (a trading name of Raw Corporate Health Ltd) , Unit 9218 The Light Bulb, 1 Filament Walk  London, SW18 4GQ and Cushman & Wakefield, 125 Old Broad Street, London, EC2N 1AR

If you have any questions about how we treat your personal information, please contact us at either of the addresses above or by sending an email to privacy@educatedbody.com or Shane.Townsend@cushwake.com

 

2. DATA THAT WE COLLECT

We collect your personal information which identifies you or from which you can be identified. This information is defined as “personal data” under the Data Protection Legislation. We obtain personal data from you when you sign up to use the wellness facilities we provide or manage. This data includes your personal contact information including address, phone number and email address, information about your health status, activity levels, and the facility you visit. We also collect information on your activity usage with us, purchases, communications and your bookings.

We provide more detail on the data collected by each system we use in the following sections of our Policy.

We collect this data freely from you when you sign up to use our wellness facilities. We also collect some automated usage data when you visit our web applications. Some of this data is mandatory and without it we will be unable to provide certain services to you. We have a legitimate interest in processing data such as your personal contact information so that we are aware who is using our wellness facilities and in order to provide these services to you. Nevertheless, we will seek your explicit consent to collect, retain and share information concerning your health status. We collect data through the use of CCTV systems that operate in all of our wellness facilities. They collect personal data about you when you use our wellness facilities inclusive of the equipment you use, the days on which you use them and the times of your entry and exit to the facility.

How we process your data and the locations where this takes place
We process your data in accordance with the relevant laws of England and Wales which relate to data protection and implement the Data Protection Legislation and we take appropriate technical and organisational security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the data.
We process your data using computers and/or IT enabled systems/tools following our strict company procedures and only for the purposes we have set out in this policy. In addition to Educated Body and Cushman & Wakefield, as the joint controllers, in some instances, the data may be accessible to certain types of person involved in charge of or involved with the operation of our sites including estate management companies and their employees, developers and their employees, residents’ associations and other related parties. We may also process your data with external parties who provide services to us such as third-party technical services, hosting companies, mail carriers and IT companies appointed as data processors by the controller. These providers are outlined in the detailed processing information below.

We also process your data using paper forms and manual processes and these documents are indexed and stored securely.

We process your data in a variety of locations within the European Union and where we use processing services located outside the European Union we ensure that those locations are included in agreements ensuring that all personal data are protected. You may request further information from us in specific instances.

We may view data obtained from CCTV systems for reasons of your own safety and for the purposes of crime prevention and detection. The CCTV footage is not routinely or constantly monitored. The live stream of the CCTV footage can only be viewed by Educated Body or and Cushman & Wakefield. The CCTV recordings will only be reviewed and downloaded in the event of an incident or a claim (e.g. an accident, theft or allegations of abusive conduct). In such instances, the CCTV recordings may be viewed and shared with law enforcement agents.

 

3. RETENTION OF YOUR DATA

We retain your data for the time that you are an active customer of our facilities or the facilities we manage.

Once you cease to be a user of our facilities and/or resident of the development we work at, we retain all of your data for at least 7 years from the time that you cease to be a user of our facilities.
We review the retention of data annually.

 

4. HOW WE USE YOUR DATA

We use your data to allow us to provide our services to you in the wellness facilities that we operate. We also use your data for the following purposes: Analytics and reporting to estate management companies and their employees, developers and their employees, residents associations, interaction with external social networks and platforms, advertising, managing contacts and sending messages via telephone or emails including newsletters, user database management, contacting the user, displaying content from external platforms, handling payments, hosting and backend infrastructure, infrastructure monitoring, interaction with support and feedback platforms, managing support and contact requests, registration and authentication and commercial affiliation.

 

5. DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA

We use various platforms and processors for the management of records relating to users of our facilities inclusive of platforms holding your details including your preferences for receiving communications from us, health and safety reporting, app & website management, communications such as announcements and marketing information, app & website use tracking and obtaining information through social media. Where such information is personal data we put in place appropriate contractual safeguards if any of our processors process personal data outside the European Economic Area or outside those jurisdictions where data protection laws have been found to be adequate and/or where we seek consent where appropriate and necessary.

We may use paper-based declarations for guests of members who use our facilities.

 

6. DIGITAL HEALTH COMMITMENT STATEMENT

Educated Body and Cushman & Wakefield, use a digital-based Health Commitment Statement. We reserve the right to retain this form or the proof this form was agreed to and the information you provide for as long as you use the facility and for 7 years thereafter. We shall delete it 7 years after the time when you inform us when you have ceased to use the gym. The form is retained as a digital copy. Please note that any information held by us relating to your personal details and physical health and condition shall be held in the strictest of confidence and will not be divulged to any third parties to be used for marketing purposes.

 

7. DATA SECURITY

As with all information transmitted over the Internet, security cannot be guaranteed. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and technical and organisational security measures to try to prevent unauthorised access.

All data is collected and/or accessed over secure https connections and any credit card data is only held within systems which are certified as PCI DSS Level 1 security compliant. For more information on PCI DSS please visit:
https://www.pcisecuritystandards.org/pci_security/

 

8. INFORMATION SHARING

We will not give your personal information to a third party outside Educated Body and Cushman & Wakefield, without your express consent or unless required to do so by law or a court order. You will be requested at your option to give us your express consent to allow us to share any of your personal data concerning health with relevant staff of the estate management companies but neither Educated Body or Cushman & Wakefield, shall not do so automatically. In certain circumstances such as the occurrence of life-threatening or seriously health-threatening incidents relevant staff are able to access your personal information lawfully because doing so preserves your vital interests.

 

9. HOW WE USE THE INFORMATION WE PROCESS

We use information held about you in the following ways:
To help us deliver our services safely and effectively in our facilities.
For the purposes of capacity planning, service delivery, product development and purchasing decisions.
For the purposes of contract compliance with organisations who contract us to deliver services on your behalf.
To ensure that content from our website and app is presented in the most effective manner for you and for your computer/device
To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
To allow you to participate in interactive features of our service, when you choose to do so.
To notify you about changes to our service.
Accessing, correcting, deleting and managing the data we hold about you
The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Legislation. This is called a “subject access request”.

If you wish to make a subject access request please mark all correspondence “Data protection: subject access request ” and send via email to privacy@educatedbody.com or Shane.Townsend@cushwake.com

Alternatively make your request in writing via post to either of the addresses at the top of this Policy. To ensure data security and to identify you correctly we may ask you to provide identity documents such as a passport, utility bill, driving licence to confirm you are the person entitled to make the request for data. Once we have established your identity we will destroy all copies of the documents provided.

 

10. YOU CAN ALSO REQUEST THAT

We correct information which is incorrect or incomplete and ask for a copy of your data which will be provided in a machine-readable format such as .xls or .csv
We delete data which is no longer relevant subject to our reasonable processing requirements outlined in our data retention policy and regardless of our legitimate interests.
We stop processing your data whilst we retain the data for the periods we have described in our retention policy.
We erase your personal information completely from systems that are under either Educated Body’s or Cushman & Wakefield, full power and control.
In addition to these rights, you also have the right not to be subject to any decisions made by Educated Body or Cushman & Wakefield, that are based on any profiling or automated decision making if they produce legal effects or significantly affect you to complain to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF (Tel: 0303 123 1113 or go to https://ico.org.uk/global/contact-us/.

 

11. HOW WE WILL CONTACT YOU

We will offer you the option to consent to receive essential mailings and separately for general marketing mailings.

If you provide us with your consent, we will contact you by email, text, or letter when we feel there is information you would like to be aware of. Essential mailings will include unplanned facility closures and changes to the services as well as booking confirmations and reminders and other automated emails linked to your booking activity. Facility guests who prefer to have no contact under any circumstances, can opt out entirely but must make it clear that they understand that Educated Body or Cushman & Wakefield, will take no responsibility when they may be unaware of these essential details.

You can ask us to opt you out of any communications by clicking on an opt out link at the bottom of the email or if you have a login and access to your online account by going to your profile page and editing your contact preferences. You can also contact privacy@educatedbody.com or Shane.Townsend@cushwake.com and ask to change your consents to receive essential and marketing emails.

 

12. COOKIE POLICY

As with most websites when you visit our sites a cookie (a type of code also known as a web beacon) will be downloaded to your computer. This will allow Educated Body or Cushman & Wakefield, to identify your computer in the future. This information may be used in conjunction with information on your Members Only pages of our site and used to track your use of the website.
A cookie is a small text file that is sent to your browser from a website and stored on your computer’s hard drive. Cookies cannot read data from your hard disk or read cookie files that were created by other sites – the website that creates a cookie is the only one a browser will permit to access it.

Like many other websites and applications, the Website and App use cookies to obtain certain types of information. For example, Educated Body or Cushman & Wakefield, might use cookies to control access to certain features such as your password and account, to customise content areas, or to analyse site activity and user behaviour. Educated Body and Cushman & Wakefield, reserve the right to use cookies in the future in conjunction with new content or expanded functionality.

If you are concerned about the use of cookies, you can explore your web browser’s options to notify you whenever a cookie is set, or to disallow cookies altogether. You should be aware that prohibiting the use of cookies will significantly restrict access to certain types of content or features.
Cookies may be issued by websites that you enter through links from our site. Please refer to the privacy policy of these websites for information on how these cookies will be used. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

 

13. CHANGES

Educated Body can change this Policy at any time, so you should check this page frequently to see any updates.

 

14. QUESTIONS AND COMMENTS

Questions, comments and requests regarding this Policy are welcome. Please contact privacy@educatedbody.com or Shane.Townsend@cushwake.com