In our capacity as controller within the meaning of the General Data Protection Regulation, we are obliged to comply with statutory provisions on data protection. As a matter of course, we greatly value the protection of your personal data along with fair and transparent data processing. We have provided you below with all the information you need to verify and exercise your data protection rights.This is not an exhaustive list and Spot Performance has the right to use its sole discretion to add or alter at any time to prevent a breach of our Terms & Conditions.

We keep this policy under regular review and may change it. If we change the policy we will post the changes on this page and place notices on other pages of the Website and/or mobile application as applicable so that you can be aware of the information we collect and how we use it at all times. You are responsible for ensuring that you are aware of the most recent version of this policy as it will apply each time you access the Website and/or mobile application.

This policy was last updated on 28/03/2023

This policy aims to provide you with all the relevant details about how we process your information in a concise, transparent, intelligible and easily accessible form, using clear and plain language. If you have any difficulty in reading or understanding this policy, or if you would like this policy in another format e.g. audio, large print or braille, please let us know.

1. Who is responsible for data processing?

The responsible party is Spot Performance Limited 47 Great Eastern Street EC2A 3HP London Company house: 

Amedia Carlyle House 

235-237 Vauxhall Bridge Road, Lower Ground Floor,

SW1V 1EJ London.

Any enquiries about your data should be sent to us by email at info@spotperformance.co.uk

2. Spot Performance’s Privacy and data protection policy

At Spot Performance, we are committed to protecting and respecting your privacy and Personal Data in compliance with the law and guidelines of the EU General Data Protection Regulation (“GDPR”). This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Customers (personal trainers or individuals)
• Suppliers
• Business contacts

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

3. Why and on what legal basis do we process personal data – Information we hold:

When you use the Website and/or Mobile Application we may collect the following information about you • Personal information including first and last name, date of birth, phone number and photograph.

• Contact information including residential address, geographic location, primary email address and/or primary phone number;
• If you sign up to the Website and/or Mobile Application through a third-party service such as Facebook or Google, we may extract information from your Account e.g. name, email address, photograph and any other personal information that your privacy settings permit us to access;
• Information about your contacts when you invite others to join your workout session or as apart of any promotional activities we run.
• Technical information including IP address, operating system, browser type and related information regarding the device you used to visit the site, the length of your visit and your interactions with the site;
• We may monitor your use of the Website and Mobile 

Application through ‘cookies’ or similar tracking technologies (Facebook Pixel and Google Analytics). We may also monitor traffic, location or other data and information about users of the Website and Mobile Application. Such data and information, to the extent that you are individually identifiable from it, shall constitute information as defined above.

However, some of this data will be aggregated or statistical, which means that we will not be able to identify you individually; We will keep your information only for as long as we need to hold it. If required we will delete your information from our database.

4. Consent

You will be required to give consent to certain processing activities before we can process your information. Where applicable, we will seek this consent from you when you first submit information through the Website and/or Mobile Application.

If you have previously given consent you may freely withdraw such consent at any point by emailing info@spotperformance.co.uk. 

If you withdraw your consent then we will stop processing your information. Please note that if you withdraw your consent you won’t have access to our app anymore.

5. Use of information

We will use your information in the following manner:

• To operate, administer, maintain, provide, analyse and improve the Website and/or

Mobile Application along with the services available through them. Our application is powered by Squat limited.

When entering your information in our app, you also submit your information to Squat Limited.

• To investigate and address any comments, enquiries or complaints made by you regarding the Website and/or Mobile Application and any similar or related comments enquiries or complaints from other users;
• To ensure the content on the Website and/or Mobile Application is presented in the most effective manner for you and for your device;
• To conduct research, statistical analysis and behavioural analysis which includes anonymising data for these purposes;
• To allow you to participate in interactive features of the Website and/or Mobile Application including inputting information and providing feedback;
• To contact you for marketing purposes, where applicable subject to Clause 4
• To notify you about the changes to the Website and/or Mobile Application 
• To comply with our legal obligations, including related to the protection of Personal Data.

6. Marketing

If you have given us permission, we may contact you through the following messaging services to inform you about products, promotion, offers, services and other important information:

• Email
• Notifications via the application
• Social media
• SMS/Whatsapp

If you prefer not to receive any direct marketing communication from us, or you no longer wish to receive them, you can withhold consent and/or opt out anytime by sending us an email at info@spotperformance.co.uk

7. Disclosure of information and monitoring

• To third-party organisations, business partners and/or service providers to enable them to undertake services for us and/or on our behalf.
• If we are under a duty to disclose or share Personal Data in order to comply with any legal obligation including but not limited to any request or order from law enforcement agencies and/or HMRC in connection with any investigation to help prevent unlawful activity;
• If our whole business is sold or integrated with another business your information may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

While we will use all the reasonable efforts to safeguard your information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any information that is transferred from you or to you via the internet.

We may monitor and record communications with you such as telephone conversation and emails for the purposes of provision of services, quality assurance, training, fraud prevention and compliance purposes. Any information that we receive through such monitoring and communications will be added to the information we already hold about you.

8. Payment processing:

Payment details you provide will encrypted using secure sockets layer (SSL) technology before they are submitted over the internet. Payments made on the Website and/or Mobile Application are made through our payment gateway provider, Stripe.

You will be providing debit or credit card information directly to Stripe which operates a secure server to process payment details, encrypting your information and authorising the payment. Information which you supply to Stripe is not within our control and is subject to Stripe’s own Privacy Policy and Terms.

9. Rights:

You have the right to request information about the Personal Data that we may hold and/or process about you, including whether or not we are holding and/or processing your Personal Data, the extent of the Personal Data we are holding and the purposes and extent of the processing.

You have the right to request that any inaccurate information we hold about you to be updated and/or corrected. If you require any changes to your information or you become aware of any inaccuracies in such information, please let us know by forwarding your request to info@spotperformance.co.uk..

You have the right in certain circumstances to request a copy of the Personal Data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different Controller (“Right To Data Portability”).

You have the right in certain circumstances to object to the processing of your Personal Data. If so, we shall stop processing your Personal Data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests. If, as a result of your circumstances, you do not have the right to object to such processing, we will let you know.

If you have any concerns about how we collect or process your information then you have the right to lodge a complaint with a supervisory authority, which for the UK is the UK Information Commissioner’s Office (“ICO”). Complaints can be submitted to the ICO through the ICO helpline by calling 0303 123 1113. Further information about reporting concerns to the ICO is available at https://ico.org.uk/concerns/.

10. Cookies

Our software may issue (“Cookies”) which are small text files on your device. When you access and use the Website, you will be asked to consent to this the first time you visit our Website or each time after your cache has been cleared. Cookies do not affect your privacy or security as a Cookie cannot read data from your system or other Cookie files created by other websites.

Our Website uses Cookies and other tracking software to distinguish our users, collect standard internet log information and to collect visitor behaviour information. This information is used to track user interactions with the Website and allows us to provide you with a personalised and improved experience along with improving our site and build statistical reports. We may also use Cookies to allow us to effectively continue marketing to you after visiting our Website.

You can set your system not to accept cookies, if you wish. You can do this by changing your browser settings so that cookies are not accepted. However, please note, that some of our Website features may not function if you remove cookies from your system. For further general information about cookies, please visit https://www.aboutcookies.org or https://www.allaboutcookies.org.

11. CCTV Policy

This section sets out the appropriate actions and procedures which Spot Performance Limited follows in respect of the use of CCTV (closed circuit television) surveillance systems (“CCTV Systems”) at our premises. The sound recording is disabled on all cameras.

Please note that all our Network are monitored by CCTV 24 hours a day. The CCTV is provided by Squa-t Limited. Spot Performance 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. In drawing up this policy, due Account has been taken of the following: The Regulation and any other relevant Data Protection legislation; The CCTV Code of Practice produced by the Information Commissioner (“Code of Practice”); The Human Rights Act 1998.

The personal data captured by CCTV is:

• Processed fairly, lawfully and in a transparent manner;
• It will only be collected for specified, explicit and legitimate purposes and not further processed in any manner incompatible with those purposes;
• It will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• It will be accurate and, where necessary, kept up to date;
• It will not be kept for longer than is necessary for the purposes for which the personal data are processed;
• 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.

The location of the equipment is carefully considered because the way in which images are captured needs to comply with the Regulation.

All cameras are located in prominent positions within public and staff view and do not infringe on sensitive areas. All CCTV surveillance is automatically recorded, and any breach of this siting policy will be detected via controlled access to the CCTV System and auditing of the CCTV System.

The images produced by the equipment will as far as possible be of a quality that is effective for the purpose(s) for which they are intended. Upon installation, all equipment is tested to ensure that only the designated areas are monitored, and suitable quality pictures are available in live and play back mode. All CCTV equipment is maintained under contract.

All images are digitally recorded and stored securely within the Squat-t box installed at Spot Performance. Images are stored for a maximum of 7 days.

Where the images are required for any other purpose, for example system testing, evidential purposes or disciplinary proceedings, a copy file will be moved to an access-controlled confidential location and held until completion of the investigation. Viewing of images within the system is controlled by the CCTV Officer or a person nominated to act on their behalf. Only persons trained in the use of the equipment and authorised by the CCTV Officer can access data.

Access to, and disclosure of, the images recorded by our CCTV System and similar surveillance equipment is restricted and carefully controlled. This ensures that the rights of individuals are preserved, and the continuity of evidence remains intact should the images be required for evidential purposes e.g. a police enquiry or an investigation being undertaken as part of an internal procedure.

The Regulation gives any individual the right to request access to CCTV images which contain their personal data.