Base (“BASE”, “we”, “our” or “us”) has created its website https://www.thebasespace.com/  (“Website”).  Our Website offers an overview of our personal training, group classes and Pilates services. 

This Privacy Policy governs those that will access and use our Website as an authorised user (“Authorised User”) enabling you to use the Website, those that we work with in the provision of our services (“Services”), our customers and those that are general visitors to the Website.

This Privacy Policy is not intended to cover off the use of personal data relating to children and we do not knowingly collect or use personal information relating to children.

 

Overview

At BASE, we take privacy very seriously. We have prepared this Privacy Policy (“Privacy Policy'') to ensure that we communicate to you, in the clearest way possible, how we treat your personal information.​

We are committed to ensuring that your personal information remains confidential and secure in accordance with applicable Data Protection Legislation.

This policy sets out how we look after your personal data if you are a:

• Visitor to our Website;

• An Authorised User with a registered account via Momence or other similar platforms;

• Supplier or business contact of BASE;

• A personal trainer or Pilates instructor engaged by BASE;

• A customer of BASE;

• Any third-party organisation that uses BASE;

 

This Privacy Policy (together with any applicable terms and conditions relating to our Services, website terms of use, and any other documents or terms incorporated by reference) describe the types of information that we collect from you through the use of the Website and our Services, and how that information may be used or disclosed by us and the safeguards we use to protect it. The personal information that we collect is used for providing and improving our Services. We will not use or share your information with anyone except as described in this Privacy Policy.

 

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.

We may update this notice from time to time, and you can find our latest version on our website or by asking us for a copy.

This Privacy Policy applies to any personal data we collect through our business and within the Website to enable us to deliver our Services.

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If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us at info@thebasespace.com.

 

We will only process personal information about you in accordance with the UK Data Protection Legislation which for the purposes of this Privacy Policy shall mean: all applicable data protection and privacy legislation in force from time to time in the UK including without limitation the UK GDPR; the Data Protection Act 2018 (and regulations made thereunder) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended; and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data (including, without limitation, the privacy of electronic communications); and the guidance and codes of practice issued by the Commissioner or other relevant regulatory authority and which are applicable to a party (“Data Protection Legislation”). 

 

What does BASE do?

We provide physical fitness, personal training, Pilates and well-being  services to individuals and in group sessions (“Services”).

 

The purpose of this Privacy Policy

The purpose of this Privacy Policy is to set out how we collect and use your personal data when we directly control the personal data as a data controller in respect of the Website.

 

The data we collect and how we collect it.

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 which we have grouped together depending on your relationship with us (for instance, whether you are an Authorised User benefitting from our Services, or a supplier) as follows:

• Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Financial / Transaction Information: details of bank account details or debit / credit card information for payment information.

• Contact Data: your email address, telephone number and postal address.

• Technical Log Data includes internet protocol (IP) address, device ID’s, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, geolocation data, social media preferences, operating system and platform and other technology on the devices you use to access the Website.

• Profile Data includes any authorised username and password, complaints, preferences, and any feedback responses.

• Usage Data includes information about how you use the Website, and our services.

• Cookies Data like many websites, we may use some "cookies" to enhance your experience and gather information about the visitors and number of visits to the Website. Please refer to our Cookie Policy on our BASE Website about cookies, how we use them and what kind.

• Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our website and internet usage.  These third parties use cookies and other technologies to help analyse and provide us the data.  By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

• Special Category and Sensitive Data includes data relating to health or injuries.

• Location Data. We may collect location data in the use of our website or App, but you have the right to turn off location services at any time.

• Images. From time to time we may take photos and videos of classes and sessions in action – all Authorised Users are asked to complete a Waiver and agree to our Terms & Conditions upon booking their initial group class through Momence – this contains a talent release consent section, giving BASE permission to take such images and publish them on our social media platforms and website. If an Authorised User prefers not to have their photo taken and used by BASE we ask that you inform us so we can protect their privacy and not use images of them in our promotional material.

 

You can withhold your personal data from us, but we may not be able to provide our Services to you if you do so.

 

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case, we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on the use of our Website or Services.

 

We may collect your personal data from different sources:

• We collect all the types of data listed above directly from you when you interact with us. This includes when you register with us, or use the Website.

• We collect Technical Data automatically when you interact with the Website, by using cookies and other similar technologies.

 

How we use your personal data

We (or third-party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:

 

Direct interactions. This is information (including Identity, Contact and Financial Data) you consent to giving us about you when you fill in forms and sections through the Website or send to us directly, or by corresponding with us (for example, by email or chat). It includes information you provide when you register or subscribe to any of our Services, visit or use the Website, or when you create an account with us and finally when you report a problem with our Services, or BASE. If you contact us, we will keep a record of that correspondence.

 

Information we collect about you and your device either automated or otherwise. Each time you visit or use the Website, we will automatically collect personal data including Technical Log Data. We collect this data using cookies and other similar technologies including server logs. We may also receive technical data about you if you visit other websites employing our cookies. We may also collect Technical Log Data if you contact us and use our services generally through BASE.

 

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, which include strict confidentiality and contractual terms.

 

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 you have consented before the processing.

●     Where we need to perform a contract, we are about to enter into, or have entered into with you.

●     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.

 

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

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.

When we are acting as a data controller, we will use your personal data for the purposes set out in the table below.

The law sets out several different reasons for which we can collect and use your data. The legal grounds on which we collect and use your data are also set out in the table below. 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. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose for using your data & Legal ground for using your data for this purpose

 

To allow you to access the Website and to register an account with Momence or similar client platform.  To enable access to BASE and to enable you to benefit from our Services.

 

To manage any account with you and to enable us to deliver our Services, including managing and making payments.

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Necessary for our legitimate interests (to allow those with an account on the Website to use it) / Performance of a contract with us. To comply with a legal obligation.

 

Necessary for our legitimate interests (to recover debts due to us and to make payments) / Performance of a contract with us.

 

To provide support to you when you contact us.

 

Necessary for our legitimate interests (to respond to support calls as our users would expect) / Performance of a contract.

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To manage our relationship with you, which will include notifying you about changes to our Privacy Policy, and any key correspondence with you.

 

Necessary for our legitimate interests (to provide important updates to our users)/ Performance of a contract.

 

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

 

Necessary for our legitimate interests (to protect our business, software and website; to keep our services updated).

To deliver relevant system, software and website content and advertisement and promotional activity to measure or understand the effectiveness of the business.

 

Necessary for our legitimate interests (to study how Authorised Users use our products/services, to develop them, to grow our business and to inform our marketing strategy).

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.  Statistical analysis to help us understand our customer base

 

Necessary for our legitimate interests (to continuously improve our services for our customers and users) and to enable us to provide the best service.

Marketing our services to existing and former customers.

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For our legitimate interests, i.e. to promote our business to existing and former customers.

See ‘Marketing’ below for further information.

 

To create anonymous aggregated data, as set out below.

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Necessary for our legitimate interests (to provide additional benefits and functionality to our customers and users without disclosing personal data).

 

To comply with applicable laws and regulatory obligations.

To comply with a legal obligation.

 

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our products, including exclusive offers, promotions or new products. We may also send you newsletters from time to time.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• contacting us at  info@thebasespace.com;

• using the ‘unsubscribe’ link in emails; or

• updating your marketing preferences.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it with other organisations outside the group for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

 

Aggregated Data

We may aggregate and use non-personally identifiable data we have collected from you and others. This data will in no way identify you or any other individual.

We may use this aggregated non-personally identifiable data to:

• assist us to better understand how our users are using the Website and our services;

• provide users with further information regarding the uses and benefits of BASE; and

• otherwise, to improve our Website.

 

Cookies when using the Website

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 the Website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy on our website.

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Who has access to your personal data and who do we share it with?
We may need to share your personal data when using your personal data as set out in the table above. We may share your personal data with the following third parties:

• Our professional advisers, including lawyers, auditors and insurers.

• Momence – our online booking system.

• Our bank.

• Service providers who provide IT and system administration services, or who store data on our behalf.

• 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 Policy.

Where any of your personal data is required for such a purpose, we will take all reasonable steps to ensure that your personal data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the Data Protection Legislation. This type of external data processing is always subject to contractual assurances that personal data will be kept securely and used only in accordance with our specific directions.

We will not misuse your personal data for any other purpose other than as set out in this Privacy Policy.

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Who we share your personal data with;

More details about who we share your personal data with and why are set out here.

Momence

Mail Chimp

Stripe

Go Cardless

Wix

Total Therapy

 

International Transfers

Subject to us complying with Data Protection Legislation and ensuring appropriate safeguards are in place, we may transfer your personal data to third parties providing services to us who are based outside of the UK without obtaining your specific written consent. This may include parties providing IT administration services and hosting services and other organisations which have products or services that are essential in the delivery of our Services; and finally, organisations providing assistance with managing our marketing databases.

 

Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

(a)        the personal data is transferred to or processed in a territory which is subject to adequacy regulations under the Data Protection Legislation that the territory provides adequate protection for the privacy rights of individuals such as the EEA; or

(b)        we participate in a valid cross-border transfer mechanism under Data Protection Legislation, so that we can ensure that appropriate safeguards are in place to ensure an adequate level of protection with respect to the privacy rights of individuals as required under the Data Protection Legislation; or

(c)        the transfer otherwise complies with Data Protection Legislation.

 

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by the Data Protection Legislation and reflected in an update to this Privacy Policy.

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Retention period

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.

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.

For more details of our specific retention periods, please contact us. 
 

Data Security

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through BASE and the Website.

We have implemented significant security measures to maintain a high level of security.

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.

Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.

If we give you a password upon registration and use of the Website, you must keep it confidential. Please don't share it.

 

How do we protect personal information?

We implement a variety of security measures to protect and maintain the safety of your personal information including encrypted software. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.

 

Your rights as a data subject

Under certain circumstances, you have rights under the Data Protection Legislation in relation to your personal data. These rights are set out below.  If you wish to exercise any of the rights set out below, 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.

Your rights are as follows:

• Right of access – you have the right to request a copy of the personal data that we hold about you and to check that we are lawfully processing it.

• Right of rectification – you have a right to request that we correct personal data that we hold about you that is inaccurate or incomplete.

• Right to be forgotten / erasure – in certain circumstances you can ask for the data we hold about you to be erased from our records i.e., when there is no good reason for us continuing to process it.

• Right to restriction of processing – where certain conditions apply, you have a right to restrict or suspend the processing, for example if you want us to establish its accuracy or the reason for processing it.

• Right of portability – you have the right to have the data we hold about you transferred to another organisation.

• Right to object – you have the right to 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 situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

 

There are some exceptions to the above rights.

• Right to withdraw consent.  In the limited circumstances where you have provided your consent to the collection, processing and transfer of the personal data referred to above, you may withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent, or to processing carried out on other legal grounds. 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.

 

All the above requests will be forwarded to the relevant party should there be a third party involved in the processing of your personal data.

Complaints to the Information Commissioner’s Office

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 by emailing us at info@thebasespace.com.

 

Sensitive and special category data

We acknowledge that there are strict rules of access and use of sensitive and special category personal data.

It will be necessary for us to collect personal data that is classified as Sensitive and Special Category Data under the Data Protection Legislation in the provision of our Services to ensure you are fit and well before proceeding with any fitness or physical session with us. This might happen for example when we collect information about your health, existing injuries and diet to enable us to form a profile and report to you in the provision of our Services or to enable us to proceed.

 

We will only do this where we have a lawful basis to do so and extra care will be taken when collecting, processing or sharing this type of data.