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PRIVACY POLICY

At Pure Fitness we are committed to protecting your privacy. When you visit our website, we may 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 fulfill other legitimate interests. This Privacy Notice applies to the Pure Fitness website (the “Site”), the Pure Fitness Mobile app (the “App”), the use of any Pure Fitness gym location (the “Gym”) and any services offered by Pure Fitness through the Site, App, or Gym (collectively with the Site and the App “Services”).
This Privacy Notice does not apply to any information collected outside of the Services, unless otherwise stated below. Our Privacy Notice explains how we collect, use, share and protect your personal information. By using the Services, you accept and agree to the practices this Privacy Notice describes. When we update this policy we will post any changes on our Services. Your continued use of the Services will be deemed acceptance.

WHEN DO WE COLLECT INFORMATION?

We may collect your personal information when you:

  • Complete an Online Membership Agreement
  • Register interest for upcoming Pure Fitness opening locations
  • Book an exercise class or lesson
  • Ask us for more information about a product or service, or contact us with a question or complaint
  • Take part in a competition, prize draw or survey
  • Visit or browse our website. See our Cookie Policy.
  • Contact our Member Services support team via email or online chat
  • Send an email to an @PureFitness.com email account
  • Enter your PIN number or swipe your fob into one of our gyms
  • You have an accident in our gyms or there was an incident where you were a witness or personally affected
  • When you use certain equipment in the gym
  • CCTV – when you are using our gyms. See our CCTV policy
  • When you use the Pure Fitness app
  • We may also collect, match or acquire information about you from other organizations such as Google and Facebook.

WHAT INFORMATION DO WE COLLECT?

Some of the information we collect is required for the purpose of creating your Member Account and for you to enroll in our gyms. Such information allows you to be identified as a Member of Pure Fitness and includes:

  • Name, date of birth, gender, e-mail address, postal address, telephone number, health declaration and whether you require disabled access
  • Credit or debit card information, information about your bank account number and sort code or other banking information. Note that we do not store your bank or credit card details on our web servers
  • Your usage records and duration of visits
  • Your preferences for particular products or services or interests when you tell us what they are – or when we assume what they are, depending on how you use our products and services
  • Your contact with us, such as an email or other records of any contact you have with us
  • Your membership information – such as dates of payment owed and received, the services you use and any other information related to your account

We may also collect details of your visits to the Services and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data, including your IP address, browser type, the date and time you accessed or left the Services, and which pages you viewed. See the section below called “Do We Use Cookies” to learn more.

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, to improve your website experience, and marketing. We may need to share your information with our service providers, associated organizations and agents for these purposes. We may use your information to:

  • Process your membership application through Exerp, our chosen membership software.
  • 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
  • Confirm your attendance to exercise classes or lessons
  • To allow you to monitor your gym usage in your Member’s area
  • 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, including issues raised during surveys
  • 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
  • Administer and improve our Services
  • Prevent and detect fraud or other crimes We’ll store your information for as long as you are a Member of Pure 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 6 years from the last activity on the account. An ‘activity’ can be classified as access into a gym, a payment made on the membership account or a comment added to the membership following contact with Pure Fitness. We may contact you about Pure Fitness services during this 6-year period if you haven’t opted out of receiving marketing communications from us.

DO WE USE COOKIES?

Pure Fitness uses cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear picture files used to follow your online activities). Cookies collect information that tells us how you use our Site, web-related products and Services. The use of cookies does not give us access to the rest of your computer. This, in turn, helps us make our Services relevant to your interests and needs. We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so we can recognize you if you visit our Site again. You can choose to refuse cookies, or set your browser to let you know each time a website tries to set a cookie. You can find out more information about cookies including information on how to turn them off. Please note however that if you disable our cookies you may not be able to access certain services or facilities on our sites and your use of our sites may be restricted. This could include joining or logging in to your Member’s area. See our cookies policy.

KEEPING YOUR PERSONAL INFORMATION SECURE

We have a dedicated team whose function is to secure our clients’ information and also take appropriate measures to ensure that the information we collect and maintain is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. We ensure the organizations that provide us with services related to your membership have appropriate security measures and only process your information in the way we have authorized them to. These organizations will not be entitled to use your personal information for their own purposes. Communications over the internet (such as emails) aren’t secure unless they’ve been encrypted. Your communications may go through a number of countries before being delivered – as this is the nature of the internet. We can’t accept responsibility for any unauthorized access or loss of personal information that’s beyond our control.

WILL WE DISCLOSE THE INFORMATION WE COLLECT TO OUTSIDE PARTIES?

We may share information about you with:

  • Affiliates, service providers, agents and associated organizations to allow us to service your membership and communicate with you
  • Law enforcement agencies, regulatory organizations, courts or other public authorities where we have a legal obligation to do so

Such third parties have access to personal information as needed to perform their functions, but they are not allowed to use it for other purposes. We use contractual or other means to protect your personal information disclosed to such third parties. We do not sell or rent personal information collected through our Services to anyone. We’ll release information if it’s reasonable for the purpose of protecting us against fraud, defending our rights or property, enforcing or apply the Terms of Use or any applicable user agreement, or to protect the interests of our customers. If we’re reorganized or sold to another organization, we may transfer any personal information we hold about you to that organization. We will inform you if we do. Surveys From time to time, we may ask our members to respond to surveys about the Services and our locations. Survey responses are completely voluntary and do not impact your use of the Services at all. When you complete a survey, we will ask for limited personal information so that we can (i) contact you to ask further questions; (ii) perform analytics on survey responses; and (iii) improve our Services and locations. All survey responses will be kept confidential. Your survey responses, including your personal information, may be disclosed to our affiliate in the United Kingdom, PureGym UK, solely for administering the survey.

Third Party Links

You may find links to third party websites on our Site. 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.

Third-Party Use

We are not responsible for the privacy or security practices of any third party; this includes third parties to whom we are permitted to disclose your personal data in accordance with this policy or any applicable laws. The collection and use of your information by these third parties may be subject to separate privacy and security policies.

General Data Protection Regulation (GDPR)

We do not knowingly collect Personal Information about individuals residing in the European Union. If you believe we have collected or processed personal information about any individuals residing in the European Union, please contact us immediately at [email protected]. We invite our UK visitors to visit our UK site at puregym.co.uk.

Children’s Privacy

We do not knowingly collect personal information from individuals under age 13. If you are under the age of 13, please do not submit any personal information through the Services. If you have reason to believe that we may have accidentally received personal information about an individual under age 13, please contact us immediately at [email protected].

California Privacy Rights

If you are a California resident, please review the California Privacy Notice, below.

International Visitors

Our Services are hosted and operated in the United States. If you are accessing the Services from outside of the United States, please be advised that United States’ law may not offer the same privacy protections as the laws of your jurisdiction.

Changes to Our Privacy Policy

If we decide to change our Privacy Notice, we will post those changes on this page. This notice was last modified on 7th of February 2022.

Contacting Us

If there are any questions regarding this Privacy Notice you may contact us via: Website (online chat): https://www.purefitness.com/help-center/live-chat/ Email: [email protected] Postal Address: Pure Fitness HQ, 6701 Frontier Drive, Springfield, Virginia, 22150

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in Pure Fitness’s Privacy Policy and applies solely to external contacts who reside in the State of California (“you” or “Consumer”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect and Disclose

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal Information does not include: · Publicly available information from government records. · Deidentified or aggregated consumer information. In particular, we have collected the following categories of Personal Information from our Consumers within the last twelve (12) months:

Category Collected Disclosed Identifiers, such as your name, address, phone number, email address, date of birth, or other similar identifiers. Yes directly from you. Disclosed to trusted service providers to fulfil your request or transaction, including, for example, payment processing. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as birthdate, contact information, and payment information. Some personal information included in this category may overlap with other categories. Yes directly from you. Disclosed to trusted service providers to fulfil your request or transaction, including, for example, payment processing.

Protected classification characteristics under California or federal law, such as your age, race, color, ancestry, national origin, citizenship, sexual orientation, or other similar protected information. No Commercial information, such as records of personal property, products or services purchased, or other consuming histories or tendencies. No Biometric information, such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints. No Internet or other similar network activity, such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes Not disclosed. Geolocation data, such as physical location or movements. No Sensory data, such as audio, electronic, visual, thermal, olfactory, or similar information. No Professional or employment-related information. Such as current or past job history or performance evaluations. No Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)), such as educational history or degree (for applicants). No Inferences drawn from other personal information, such as predictions about your interests and preferences. No Use of Personal Information We use your information in accordance with the Section “When do we collect personal data” in our Privacy Policy. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. Sharing Personal Information We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. Please see above for the disclosures we have made in the preceding twelve (12) months for a business purpose. Sales of Personal Information In the preceding twelve (12) months, Company has not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. The Right to Know You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

  • The specific pieces of information we have collected about you;
  • The categories of Personal Information we have collected about you;
  • The categories of sources of the Personal Information;
  • The categories of Personal Information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of Personal Information we have sold and the categories of third parties to whom the information was sold; and
  • The business or commercial purposes for collecting or selling the Personal Information The Right to Request Deletion You have the right to request the deletion of Personal Information we have collected from you, subject to certain exceptions. The Right to Opt Out of Personal Information Sales You have the right to request the deletion of Personal Information we have collected about you to third parties now or in the future. The Right to Non-Discrimination You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process Personal Information, we may no longer be able to provide you our products and services or engage with you in the same manner. “Shine the Light” California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

CCTV

We process information from CCTV of entrances, reception and fitness areas as well as training halls. No camera does infringe on sensitive areas.

This section sets out the appropriate actions and procedures which Pure Fitness follows in respect of the use of CCTV (closed circuit television) in our Gyms.

Please note that all our gyms are monitored by CCTV 24 hours a day. Pure Fitness reserves the right for its employees and contractors to review footage as required and by entering onto our sites you consent to your image being recorded and reviewed and waive any and all claims in relation to same. Recorded CCTV footage will be stored securely and retained in compliance with applicable laws.

Our CCTV is actively being monitored in unstaffed hours between 10pm and 6am by our internal CCTV team.

The purpose of the use of the CCTV Systems and the collection and processing of CCTV images is for the prevention or detection of crime or disorder, apprehension, and prosecution of offenders (including use of images as evidence in criminal proceedings), interest of public and employee Health and Safety, protection of public health and the protection of our property and assets and to ensure compliance with our policies and procedures.

Pure Fitness processing of CCTV is necessary for the legitim interest in monitoring the gyms as part of the implementation of security measures and to be able to exercise or defence a legal claim.

Prior to any camera installation Pure Fitness will ensure that the installation complies with this policy and that the use of any camera is justified, necessary and proportionate. Pure Fitness will regularly assess whether the use of any camera and the CCTV System as a whole continues to be justified, necessary and proportionate.

The recordings are reviewed by random checks, specific suspicions, or other irregularities.

All images are digitally recorded and stored securely within the system’s hard drives. Images are stored for 30 days, unless longer storage is allowed under legislation.

All access to and disclosure of recorded CCTV images is restricted and carefully controlled. Access to and disclosure of CCTV is permitted only if it supports the purpose for which such images have been collected. Disclosure of CCTV from third parties, e.g. a police enquiry or investigation, needs to be supported by a DPA- or consent form from the registered person on the images.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website or our Services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: Website (online chat): https://www.purefitness.com/help-center/live-chat/ Email: [email protected] Postal Address: Pure Fitness HQ, 6701 Frontier Drive, Springfield, Virginia, 22150