Privacy Policy


Introduction
Welcome to One 10 London Limited's privacy notice. This notice was last updated on 22 May 2018 to comply with GDPR regulations.
One 10 London Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how One 10 London Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
One 10 London Limited is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
Our full details are:
Registered address
One 10 London Limited
1 London Street
Reading
RG1 4PN

Postal address
5th Floor
88 Baker Street
London
W1U 6TQ

Email address: hello@one-10.com
Telephone number: 020 3937 8008

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you including the following:
· Identity Dataincludes first name, last name, username or similar identifier, date of birth and gender.
· Contact Dataincludes postal address, email address and telephone numbers.
· User detailsabout payments to and from you for One 10 class credits and bundled credit packages.
· Technical Data includes internet protocol (IP) address, your login data, browser type and version, communication data and other technology on the devices you use to access this website.
· Profile Data includes your username and password, credits purchased by you, your class data (including bike RPM, calories burnt and average watts per class), feedback and survey response.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Datasuch as statistical or demographic data for any purpose which does not personally identify you. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions.You may give us your Identity, Contact and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· purchase credits and book One 10 classes;
· create an account on our website;
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us some feedback.
Automated technologies or interactions.As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
Third parties or publicly available sources.We may receive personal data about you from various third parties as set out below:
· Technical data from performance analytics providers such as Technogym S.p.A, based inside the EU.
· Contact, financial and transaction Data from providers of technical, payment and delivery services such as Stripe based in the EU.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the services we are obligated to provide to you once you have purchases credits and booked a One 10 class.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate:
To register you as a new customer and create a new account for you. We will use your identity and contact information to do this, in order to fulfil our obligations to provide a service to you.
To manage our relationship with you, which will include notifying you about changes to our terms or privacy policy, and/or asking you to leave a review or take a survey. We will use your identity, contact, profile and marketing data to do this. We will process the data in this way to comply with our legal obligations and for our legitimate interests, to maintain our records and study the use of our services by customers.
To enable you to partake in a prize draw, competition or complete a survey. We will use your identity, contact, profile and marketing data for this. We will process the data in this way for our legitimate interest to help grow and develop our business and fulfil the services due to you.
To administer and protect our business and this website. We will use your identity, contact and technical information for this. This is necessary for our legitimate interests in running our business, provision of administration and IT services and to prevent fraud. We will also be complying with our legal obligations.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve you. We will use your identity, contact, profile, marketing and technical data to do this, to serve our legitimate interest in studying how customers use our products and to develop our business and marketing strategy.
To use data analytics to improve our website, services, marketing and customer experiences. We will use your technical and profile data to do this, in our legitimate interests to define the types of customers for our services and to develop our business.
To make suggestions and recommendations to you about products that may be of interest to you. We will use your identity, contact, technical and profile data to do this to develop our products and grow our business.
To provide data to you regarding your One 10 class.We will use your profile data for our legitimate interests in assisting you in tracking your progress at One 10.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your identity, contact, technical, user and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by paragraph contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, product experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Change of purpose
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out above.
· External Third Parties as set out in the Glossary.
· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data, please contact us.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of your Legal Rights, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Glossary
LAWFUL BASIS
Legitimate Interestmeans the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of the purposes for which we use your personal data.
Performance of Contractmeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligationmeans processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
· Service providers acting as processors based in the UK who provide IT and system administration services.
· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
· HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
· Social media and web design providers acting as processors or joint controllers based in the UK who provide online consultancy services.
YOUR LEGAL RIGHTS
You have the right to:
1.1 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
1.6 Request the transfer of your personal data to you or to a third party. Note that this right only applies to automated information which you initially provided consent for us to use.
1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Our commitment to you
  1. We will respect your personal decisions, and allow you to make your own decisions about what exercise you can carry out. However, we ask you not to exercise beyond what you consider to be your own abilities.

  2. We will make every reasonable effort to make sure that our equipment and facilities are in a safe condition for you to use and enjoy. 

  3. We will take all reasonable steps to
 make sure that our staff are qualified
 to the fitness industry standards as
set out by the Register of Exercise
 Professionals.
  4. If you tell us that you have a
disability which puts you at a
substantial disadvantage in
 accessing our equipment and
 facilities, we will consider what
 adjustments, if any, are reasonable for us to make.
Your commitment to us
  1. You should not exercise beyond your own abilities. If you know or are concerned that you have a medical condition which might interfere with you exercising safely, before you use our equipment and facilities you should get advice from a relevant medical professional and follow that advice.
  2. You should make yourself aware of any rules and instructions, including warning notices. Exercise carries its own risks. You should not carry out any activities which you have been told are not suitable for you. 

  3. You should let us know immediately if you feel ill when using our equipment or facilities. Our staff members are not qualified doctors, but there will be a person available who has had first-aid training.
  4. If you have a disability, you must follow any reasonable instructions to allow you to exercise safely.
This statement is for guidance only. It is not a legally binding agreement between you and us and does not create any obligations which you or we must meet.
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