Privacy policy

1.      Introduction

1.1   Here at Cotswold Personal Training (“Cotswold PT”, “we”, “us” or “our”) we respect the privacy of our customers (“customer”, “you” or “your”) and we are committed to ensuring the safe and secure processing of your personal data in accordance with applicable data protection law.  Cotswold PT is the data controller of your personal data.

1.2   We provide online fitness coaching, one to one training, group fitness training, yoga, pilates, nutrition guidance, rehabilitation and recovery exercises as part of our services (“services”).  This privacy policy describes how we process your personal data in connection with the services, as applicable to you, which are provided by Cotswold PT.

2.      How we use your personal data

2.1   We collect the following personal data from you:

(a)      Your first name (including any other names you elect to provide), surname, address, email address, telephone number and date of birth;

(b)      Name (in the format as you provide to us) and telephone number of your emergency contact;

(c)       Details of health or medical issues such as past, current or ongoing conditions, injuries, illnesses, diseases, allergies or details of surgery or medication or other medical or health related procedures or information (in each case whether past, current or ongoing) as disclosed by you to us or which you may otherwise disclose to us in the future during the course of the provision of our services to you (“Special categories of personal data”);

(d)      Your general habits and patterns of behaviour as it relates to lifestyle, working hours, job, fitness, training, exercise, diet and nutrition (excluding allergies) and such other relevant information relating to the foregoing;

(e)      Updates on your fitness, progression on health and training, including feedback on our services, during the course of provision of services to you;

(f)       Video images of you by CCTV or other security mechanisms at the premises used to provide services to you;

(g)      Photography and videography of you during the provision of our services to you.

       And in each of the above cases, we collect such personal data from you directly.

2.2   We process your personal data for the following purposes:

(a)      To determine, plan, and/or enable to contact you to schedule appointments, arrange for you to attend training sessions (either alone or with other customers) or meetings to discuss or otherwise tailor and provide our services to you under a contract for the provision of services;

(b)      To provide you with information relating to our services or information or content which may help you in addition to our services or to tell you about new services that we may in the future offer to you;

(c)       In the event of an emergency in the provision of services to you, we may contact your emergency contact to assist us in helping you in such an emergency;

(d)      To enable us to understand your current levels of health, fitness and exercise activity, equipment you may have access to, time you may have and exercise or training you have been doing, are able to do or are otherwise not able to do, and further recommend training or exercises or otherwise devise or plan training or nutrition programmes or provide suggestions for recovery or rehabilitation exercises (if applicable as part of the services provided by us to you) to you;

(e)      To receive feedback, provide customer testimonials, comments and reviews of our services;

(f)       To enable us to assess your movement during the course of you training and monitor your progression

(g)      The generation and/or creation of content and marketing information to promote our services to third parties via social media platforms or other methods of communication, such as email or mailshots.

2.3   The provision of certain personal data may be necessary in order for us to provide services to you.  If you do not provide such personal data it may be that we cannot provide services to you or are otherwise prevented from providing such services as we are unable to comply with our legal obligations, such as health and safety.

2.4   We may need to process your personal data to investigate, assess, seek advice or otherwise address any complaints or disputes or claims made by you against us.

3.0   The legal basis for processing your personal data

3.1   The processing of your personal data and the legal basis under which we may process your personal data is as follows:

(a)      The personal data as identified in 2.1(a) is necessary for us, prior to contract to engage with you on the grounds of legitimate interests of Cotswold PT in order to manage and carry out the business operations of Cotswold PT, and post contract is necessary for us to fulfil our contractual obligations with you;

(b)      The personal data as identified in 2.1(b) on the grounds of legitimate interests of Cotswold PT in order to manage and carry out the business operations of Cotswold PT;

(c)       The personal data as identified in 2.1(c) and 2.1(d) is necessary for us on the grounds of protecting your vital interests in the event of dealing with an emergency;

(d)      The personal data as identified in 2.1(d) and 2.1(f) is necessary for us to tailor certain of the services to you and is only provided by you and processed by us with your consent.

(e)      The personal data as identified in 2.1(e) on the grounds of legitimate interests in order to manage and carry out the business operations of Cotswold PT, or, in the case of named customer testimonials, this will only be done with your consent.

(f)          The personal data as identified in 2.1(f) is in the legitimate interests in order to manage and carry out the business operations of Cotswold PT.

(g)      The personal data as identified in 2.1(g) in order to market our services to other potential customers, suppliers or third parties shall only be processed by us with your consent

4.      Providing your personal data to others

4.1   We may disclose your personal data to certain of our fitness coaches and nutritionists or other advisors specific to the provision of the services as is reasonably necessary for the purposes of providing the services.

4.2   We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, addressing complaints or disputes or exercise or defence of legal claims.

4.3   In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4.4   Your personal data may be stored in a data center hosted by Google.  In addition to this privacy policy, the privacy policy of Google shall also apply.  Please see policies.google.com/privacy. 

5.      International transfers of your personal data

5.1   Your personal data will be stored in a location within the United Kingdom, European Union or European Economic Area.

6.      Retaining and deleting personal data

6.1   This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2   Personal data that we process for any purpose or purposes shall be retained for as long as necessary to fulfil the purposes we collected it for, and not be kept for longer than is necessary for that purpose or those purposes.  To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

6.3   We will retain your personal data for not longer than six months following termination of the services to you. 

6.4   Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 

7.      Your rights

7.1   You are entitled to know what Personal Data we are processing regarding you, and you can request a copy of such data. You are entitled to have incorrect personal data regarding you corrected, and in some cases you may request that we delete your personal data. You also have the right to object to certain processing of your personal data, and request that the processing of your personal data be limited. Please note that limitation or deletion of your personal data may result in us not being able to fulfil our obligations to you in respect of the services proposed to be provided.

7.2   If you have questions regarding how we process Personal Data concerning you, you are most welcome to contact contact@cotswoldpt.com, and titling the email “Privacy”.

7.3   If you have any objections or complaints with the way we process your Personal Data, you have the right to lodge a complaint with the relevant data protection supervisory authority.

8.      About cookies

8.1   A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2   Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3   Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

9.      Cookies used by our service providers

9.1   Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

9.2   We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy

10.   Managing cookies

10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)   https://support.google.com/chrome/answer/95647 (Chrome);

(b)   https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)   https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(d)   https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari);

10.2 Blocking all cookies will have a negative impact upon the usability of many websites.

10.3 If you block cookies, you may not be able to use all the features on our website.

11.   Amendments

11.1 We may update this policy from time to time by publishing a new version on our website.

11.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

12.   Our details

12.1 This website is owned and operated by Adam Powell, trading under the name of Cotswold PT.            

12.2 You can contact us by writing to Cotswold PT, c/o Fairview, London Road, Cirencester GL7 5JG or via email to contact@cotswoldpt.com.

13.   Data protection officer

13.1 Our data protection officer's contact details are: Adam Powell, contactable at contact@cotswoldpt.com, titling the email, “Privacy”.