PRIVACY NOTICE FUSION LIFESTYLE
INTRODUCTION
Fusion Lifestyle and Active Life Limited are registered office 3 & 4 Blake House, Schooner Court, Crossways Business Park, Dartford, England DA2 6QQ. Company registration number: Fusion Lifestyle – 05324416, Active Life – 04376721
Fusion Lifestyle and Active Life are registered charities (Fusion Lifestyle Charity Number 1095215/ Active Life Charity Number 1095215), operating in the sports and leisure sector.
Fusion Lifestyle and Active Life are registered with the ICO Z9088606
This privacy notice describes how we collect, use and store personal information about you during and after your business relationship with us, in accordance with the Data Protection Act 2018 / UK GDPR.
Fusion Lifestyle and Active Life are the “data controller”. This means that we are responsible for deciding how we hold and use and store personal information about you. We are required under the DPA 2018 / UK GDPR to notify you of the information contained in this privacy notice. When you share your information with us through the website and other channels, we want you to feel confident that your data is kept securely and that it will only be processed in ways about which you have been informed and, where appropriate, have given consent.
Should you have any questions relating to this notice or the processing of personal data, please email DPO@Fusion-Lifestyle.com, DPO@activelifeltd.co. Alternatively, you can contact us at the above address.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information.
DATA PROTECTION PRINCIPLES
We will comply with all relevant data protection law (including the DPA 2018 / UK GDPR). This requires that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have informed you about.
6. Kept securely.
WHAT IS CONTAINED IN OUR PRIVACY NOTICE
1. When and how do we collect your data
a. Information we collect about children under 16
2. What personal information we collect
3. How we use your personal information
4. Who we will share your data with
a. Sharing data with third parties
5. If you fail to provide personal information
6. Data retention
7. Transfer of personal data outside the UK
8. Marketing
9. Your data protection rights
10. Cookies
11. Links
12. Changes to our policy
13. How to make a complaint
1. WHEN AND HOW DO WE COLLECT YOUR DATA
Fusion Lifestyle and Active Life operate a number of leisure centres and provide services for our customers, in the centres, online, and by telephone. Fusion Lifestyle have implemented a range of technical and organisational controls to ensure your data is protected at all times.
Referral
You may be referred to our service by a healthcare professional or hospital. As part of the referral they may share with us your contact information and the reason for their referral including information about your medical history and existing health conditions. Where the referral is provided by a health professional, or other body, they will seek your consent to share your information with us.
If you chose not to participate in our service then referral information will be removed, otherwise it will be added to the information we collect about you at registration.
Registering with and using our Website or Online App
When registering with, or using online forms on our websites or online app, you will be asked for information to enable us to process your request and provide the service to you.
At Fusion Lifestyle and Active Life we would like to ensure that you exercise safely. We will collect information about you to enable us to provide you with the best programme for you and to monitor your progress and further needs.
All new joiners will be required to complete a health and wellbeing questionnaire (PARQ for on-site joiners and HCS for online joiners).
Becoming a member
Should you choose to become a member we will collect information about you and if appropriate your family, to enable us to set up your membership and deliver services to you.
This could be online, face to face in one of our centres, or via the phone.
Once your membership ceases we will remove your bank details from our system, membership records will remain while you continue to use our facilities.
Booking classes and activities
If you book to attend a class or take part in one of our activities, you may be asked for information to help us deliver the service.
Participating in our Swim School
If you, or your child is registered with our swim school programme, our swimming teachers may record information about your/their progress.
This is linked to the Swim School online portal.
Visiting our centres
If you visit one of our centres, we will record the fact that you have attended. This helps us to better understand how we are performing and improve our services.
Attendance may also be recorded if you use your membership card to enter through the turnstile.
Completing Customer Surveys
If you have used any of Fusion Lifestyles or Active Life facilities you may be asked to fill in a feedback form (PTUWYT), we use this information to respond to your comments directly and improve our service.
We retain customer feedback data for up to a year after any issue raised has been resolved.
CCTV
In order to ensure the safety of our staff and customers, we operate CCTV systems in some of our centres. These are used to detect and prevent crime or to monitor the safety of swimmers.
CCTV recordings are retained for a period of up to a month before deletion and may be held longer if required as evidence in legal proceedings.
1.a INFORMATION WE COLLECT ABOUT CHILDREN UNDER 16
There will be times when we will need to collect data on children under 16, we will usually collect:
For general purposes
o Name of child
o Age of child
o Gender
o Health information (if you use our Gym or Spa facilities)
Swim School
o Name of child
o Age of child
o Gender
Swim school progress
Creche facility
Some of our centres have this facility and the information will be held in our booking system If you cancel your membership with us and stop using the creche facility you are entitled to ask for this information to be removed from the system. For more information on this, please contact DPO@Fusion-Lifestyle.com or DPO@activelifeltd.co.uk.
Information held at these facilities includes:
o Name of child
o Age of child
o Any emergency health questions in relation to allergies or food allergies.
2. WHAT PERSONAL INFORMATION WE COLLECT
The data that we collect and process will depend on the services that you have requested from us:
o Identity: First Name, Last Name, Photograph (for ID), Membership Number, NI number, NHS number.
o Contact details: Address, Postcode, Telephone Number, Email, Next of kin/emergency contact.
o Demographics: Date of Birth, Ethnicity, Gender.
o Health: Healthcare information, disability information, medical history, medications you use, GP name.
o Referral: who referred you, reason for referral.
o Concession: Reason for concessionary membership.
o Employer: If you are part of a corporate membership scheme.
o Preferences: How you prefer to be contacted, marketing preferences.
o Attendance: The date and time of your visits
o
If you hold a membership, we may also record:
o Bank Details: For direct debit payments
When you visit our website, we also collect information automatically about your visits such as the IP Address of your device, browsing patterns etc. Information collected in this way is only used in aggregate and anonymous form rather than being linked to identifiable individuals.
Sensitive information
The GDPR requires us to take particular care when handling sensitive information such as that related to your racial or ethnic origin, any disability you may have, your health or religion (referred to as Special Category Data in GDPR).
In the interest of your safety, Fusion Lifestyle requires background health information before you join a membership.
We may record information about your ethnicity in order to ensure that we are serving all of the communities in which we operate. By giving us these details you are consenting for Fusion Lifestyle to use this information. Where we report on this data the information will be in anonymised form.
3. HOW WE WILL USE YOUR PERSONAL INFORMATION
Fusion Lifestyle and Active Life will only use your information in a fair and transparent manner and where we have a legal basis for doing so. We will never sell your information or disclose it to anyone without informing you.
With your consent
Where you have consented for us to do so, we will use your data to:
o Send you information about our products and services that we think may be of interest to you . This may be by mail, email, telephone or SMS, but we will offer you the chance to opt in or out of receiving these messages.
o Under some circumstances, it may be that we feel additional support services would be of use to you which may be provided through other service providers.
In order to perform our obligations in a contract that we hold with you
We may use and process your personal data where it is necessary for the performance of a contract with you (such as a membership or class booking) or in order to take steps at your request before entering into a contract with you to:
o Deliver the services you have requested
o To keep in contact with you
o Validate your bank and payment details
o Take payments via direct debit or card
o Send you confirmations of bookings etc
o Notify you when your membership is up for renewal
For our own legitimate interests or those of our clients and customers
Fusion Lifestyle and Active Life have legitimate interests in:
o Operating our business efficiently
o Marketing our services to potential customers
o Ensuring the safety and security of our staff and customers
o Informing our local authority partners about the performance of our services
In pursuit of these interests we may:
o Ask you to give feedback on your use of our services
o Provide reports on visitor numbers to our clients (where we do so the data will be anonymised)
o Operate CCTV cameras to detect and prevent crime
o Monitor the safety of swimmers in our pools
When legally obliged to do so
Under certain, limited conditions we may be obliged by law to disclose data to the relevant authorities such as the police.
4. WHO WE WILL SHARE YOUR DATA WITH
In order to provide our services to you and to comply with our legal obligations, it may be necessary for us to share some data we hold with the following:
o Exercise on Referral coordinators who manage our services.
o Exercise instructors to help them develop and deliver programmes.
o Our own legal advisors
o Swim school staff
4a SHARING DATA WITH THIRD PARTIES.
In order to deliver some of our services to you it may be necessary to share your data with third parties.
Where we need to do so, we will only disclose the minimum amount of personal data in order to provide the service required.
We have implemented data processing agreements with each of the third parties and have checked to ensure that your data will be kept safe and your rights observed while the data is in their care.
o We may use the services of third-party Data Processors to deliver our services, for example to host our website or send emails.
o In some of our contracts we utilise a secure referral portal to receive and process referrals from healthcare professionals (Refer-All).
o Booking and membership management systems are supported by our systems providers (Gladstone Health and Leisure).
o Contract Exercise Instructors.
In most cases, Fusion Lifestyle and Active Life operate our leisure centres on behalf of a local authority client.
At the end of our contract, in order to ensure continuity of service, it may be necessary to pass your data on to the local authority, or another company that they select to run the facility. Where we do so, you will always be informed that the operation of the service is changing hands.
In the unlikely event that Fusion Lifestyle were sold to a third party, details of our customers would be passed on to that third party as part of the sale of the business.
5. IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
If you fail to provide certain personal information when requested by us, we may not be able to perform the contract we have entered into with you (such as providing you with our services or guarantees), or we may be prevented from complying with our legal obligations (such as financial and tax reporting and insurance maintenance).
6. DATA RETENTION
We will store your personal data for as long as we need to fulfil the purposes outlined in this Privacy Notice. For details regarding how long we keep information, please contact DPO@Fusion-Lifestyle.com or DPO@activelifeltd.co.uk.
If you have any questions in relation to our retention of personal data, please contact the data protection officer – DPO@Fusion-Lifestyle.com or DPO@activelifeltd.co.uk
7. TRANSFER OF DATA OUTSIDE OF THE UK
Our core business systems, are located in data centres within UK
8. MARKETING
Fusion Lifestyle and Active Life will only send marketing content to customers and consumers if they have given explicit consent to do so when completing online forms, forms in centres or verbally in centres.
It is the right of the individual to opt-out of, or unsubscribe from, any marketing material. Full details of how to do this will be included within each marketing communication. You may also opt-out by contacting us at the above contact details, or by logging in to your online account and editing your preferences.
9. YOUR DATA PROTECTION RIGHTS
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
There are eight rights available to you, but not all of them will apply to every situation. It will depend on which lawful basis for processing we use to process your information. For more information on this please contact our data protection officer at DPO@Fusion-Lifestyle.com or DPO@activelifeltd.co.uk
Your Rights:
The right of Access – . You may submit a Subject Access Request – this enables you to receive a copy of the personal information we hold about you. We require a suitable form of identification and under normal circumstances, we will supply this to you within one calendar month of your request and of identification being received. No fee is usually payable; however, we may apply an appropriate fee if the request is deemed to be excessive, or repetitive.
The right of Rectification – this enables you to have any incomplete or inaccurate information we hold about you corrected.
The right to Erasure – this enables you to request us to delete or remove personal information when there is no good reason for us to continue processing it.
The right to be Informed – you have the right to be informed of how we will collect and use your data, most of the information you will need is in this privacy notice.
The right to Object to processing – in certain circumstances, you have the right to request we suspend the processing of your data.
The right to Restrict processing – you have the right to request that we limit the way we use your data, whilst we are not obliged to delete the data, we have refrain from using it.
The right of Data Portability – you have the right to request the transfer of your personal data to a third party.
Rights in relation to automated decision making and profiling – you have the right not to be subject to a decision based solely on automated means including profiling.
To action any of these requests, please email the Fusion Lifestyle data protection officer at DPO@Fusion-Lifestyle.com, DPO@activelifeltd.co.uk or contact us on the above address.
Right to Withdraw Consent – where we rely on consent to process your data, you have the right to withdraw this at any time, without giving reason. To withdraw your consent, please contact the Privacy Officer. Once received, we will not process your data for the reasons you have agreed to, unless we have another legal basis for doing so.
10. COOKIES
When you visit our website, we many send you cookies. A cookie is a small text file that can be placed on your computer’s hard drive. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number. Two types of cookies are used on our website:
Session cookies – these are temporary cookies that remain in the cookie file of your browser until you leave our website. These allow you to carry information across pages of our website and avoid you having to re-enter information.
Third party cookies – third parties provide persistent cookies via our website. These are used to compile anonymous, aggregated statistics in order to serve advertisements on our website and track whether these advertisements are clicked on by users, to control how often you are shown a particular advertisement, to count the number of anonymous users of the website and to provide security within transactions.
Our cookies cannot be used by themselves to identify you. You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our website if cookies are disabled. You may disable cookies through your browser by following the instructions found at: www.allaboutcookies.org/manage-cookies.
Please see below for a list of Cookies used on Fusion Website .
o Fusion (www.fusion-lifestyle.com) This is the cookie our site sets for every visitor. It stores no visitor information and is used solely to register your visit to our site. It is mostly used for tracking and administrative staff when they are working on website content in our CMS.
o CAKEPHP (www.fusion-lifestyle.com) This cookie is set by the application framework that we use to power our website. It collects no personal information.
o FUSION_SPLASH_PAGE_VIEWED (www.fusion-lifestyle.com) This cookie is set when you view one of our splash pages. It collects no personal information and is only set to tell our site to not show any other splash pages during your visit. Blocking or clearing this cookie will result in splash pages being shown on every visit to a Centre or Contract homepage.
o utma, __utmb, __utmc, __utmx, __utmv, __utmz (www.google.com) These cookies are used to collect data about your visit to our site and provide analysis via Google’s Analytics platform. For more information on these cookies please visit https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
For more information on which cookies we use please see our Cookie Policy on our website.
11. LINKS
Our website contains links to other websites. Please note that we do not accept responsibility for the privacy practices of such other websites and we recommend you read the privacy statements on entering other websites.
12. CHANGES TO OUR POLICY
Fusion Lifestyle reserves the right to make changes to our privacy policy from time to time. Where we do so, we will publish the new policy on our websites www.fusion-lifestyle.com www.activelifeltd.co.uk and where appropriate we will notify you by email.
If you have any questions about this privacy notice, please contact our Data Protection Officer – DPO@Fusion-Lifestyle.com or DPO@activelifeltd.co.uk
13. HOW TO MAKE A COMPLAINT
As an addition to the rights listed above, you also have the right to complain if you think we have made an error with your data. Of course, we would like you to contact us first to see if we can help to rectify any issues, contact us at:
Fusion Lifestyle, Suite 3&4 Blake House, Crossways Business Park, Dartford, DA2 6QQ or email DPO@fusion-lifestyle.com.
Active Life, Suite 3&4 Blake House, Crossways Business Park, Dartford, DA2 6QQ, or email DPO@activelifeltd.co.uk.
You also have the right to complain to the Information Commissioners Office (ICO). Their details are:
The Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Phone number: 0303 123 1113
https://ico.org.uk/for-the-public/
This Privacy Notice was last updated June 2024.