At CoLA Lettings Ltd, we are committed to protecting your privacy.
We collect and process personal data about you to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.
This Privacy Notice explains how we collect, use, share and protect your personal information. We will keep you informed of any changes to this policy via email and our website.
CoLA Lettings Ltd is a subsidiary of the City of London Academies Trust. The City of London Academies Trust (4th Floor North Wing, Guildhall, London, EC2P 2EJ) are the ‘data controller’ for the purposes of data protection law.
Our data protection officer is Data Protection Education Ltd (see ‘Contact us’ below)
WHEN DO WE COLLECT INFORMATION?
We collect your personal information when you:
· Complete a Membership Agreement
· Complete our Health Questionnaire
· Book or attend an exercise class or lesson
· Ask us for more information about a product or service, or contact us with a question or complaint
· Contact our Member Services support team through telephone, email or online chat
· Send an email to an @cityacademy.co.uk email account
· You have an accident in our gyms or there was an incident where you were a witness or personally affected
· CCTV – when you are using our gyms.
WHAT INFORMATION DO WE COLLECT?
The information we collect is required for the purpose of creating your Member File and for you to enrol in our gyms. Such information allows you to be identified as a member of CoLA Fitness and includes:
• Your personal details – name and date of birth
• Your contact details
• Your medical information (gym members)
• Details of your lettings or membership including invoice details, payment dates. Please note that we do not store any specific payment details such as bank account or card numbers.
• CCTV Images
HOW DO WE USE THIS INFORMATION?
We will use your personal information to provide you with the services, products or information that you have requested, for administration purposes and marketing. We may need to share your information with our service providers, associated organisations and agents for these purposes. We may use your information to:
• Bill you for using our services as part of your membership
• Keep you informed about our services including operational matters relating to your Membership.
• Provide relevant services to you
• Contact you with offers or promotions based on our analysis of how you use our services and what we think will be of interest to you (unless you choose not to receive our marketing messages)
• Respond to any questions or concerns you might have about our services
• Understand how you use our services, to help us develop relevant and updated services
• Carry out research and statistical analysis to monitor how customers use our services
• Prevent and detect fraud or other crimes
Our legal basis for using this data
We will only collect and use your information when the law allows us to. Most often, we will use your information where:
· We need to comply with the law
· To fulfil our contractual obligations to you
Sometimes, we may also use your personal information where:
· You have given us permission to use it in a certain way
· We need to protect your interests (or someone else’s interest)
Where we have got permission to use your data, you may withdraw this at any time. We will make this clear when we ask for permission and explain how to go about withdrawing consent.
Some of the reasons listed above for collecting and using your information overlap, and there may be several grounds which mean we can use your data.
KEEPING YOUR PERSONAL INFORMATION SECURE
We’ll store your information for as long as you are a member of CoLA Fitness, or following cancellation and to meet legal requirements including financial audit, anti-fraud and money laundering regulations we will store your information for no more than 1 year from cancellation.
When using our gyms, CCTV is in operation 24 hours a day. CCTV footage is permanently erased after 6 months.
We have a Records Retention Policy which sets out how long we must keep information about pupils. Please see ‘Contact Us’ below to request a copy of the Records Retention Policy.
WILL WE DISCLOSE THE INFORMATION WE COLLECT TO OUTSIDE PARTIES?
We do not share personal information about you with anyone outside the Trust or our Academies without your permission, unless the law or our policies allow us to do so.
Where it is legally required, or necessary for another reason allowed under data protection law, we may share personal information about you with:
We’ll release information if it’s reasonable for the purpose of protecting us against fraud, defending our rights or property, or to protect the interests of our customers.
USE OF PERSONAL DATA FOR AUTOMATIC DECISION MAKING
We do not intend to use your personal data for automatic decision making.
THIRD PARTY TRACKING
We use tools such as Google Analytics for collecting personal data about our website visitor’s online activities over time and across different web sites for marketing purposes. This is so we can ensure our website gives you the best possible experience.
DO NOT TRACK (DNT)
The CoLA Lettings website does not respond to DNT signals.
YOUR PRIVACY RIGHTS
How to access personal information we hold about you
You can find out if we hold any personal information about you, and how we use it, by making a ‘subject access request’, as long as we judge that you can properly understand your rights and what they mean.
If we do hold information about you, we will:
· Give you a description of it
· Tell you why we are holding and using it, and how long we will keep it for
· Explain where we got it from, if not from you or your parents
· Tell you who it has been, or will be, shared with
· Let you know if we are using your data to make any automated decisions (decisions being taken by a computer or machine, rather than by a person)
· Give you a copy of the information
You may also ask us to send your personal information to another organisation electronically in certain circumstances.
If you want to make a request, please contact our data protection officer.
Your other rights over your data
You have other rights over how your personal data is used and kept safe, including the right to:
· Say that you don’t want it to be used if this would cause, or is causing, harm or distress
· Stop it being used to send you marketing materials
· Say that you don’t want it used to make automated decisions (decisions made by a computer or machine, rather than by a person)
· Have it corrected, deleted or destroyed if it is wrong, or restrict our use of it
· Claim compensation if the data protection rules are broken and this harms you in some way
We take any complaints about how we collect and use your personal data very seriously, so please let us know if you think we’ve done something wrong.
You can make a complaint at any time by contacting our data protection officer.
You can also complain to the Information Commissioner’s Office in one of the following ways:
· Report a concern online at https://ico.org.uk/concerns/
· Call 0303 123 1113
· Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact: