Privacy Policy

This Privacy Policy is made available by Mulcroft Limited (“we” or “us”), the operator of J.I.M branded studios in the United Kingdom, specialising in the provision of in-person, infrared group exercise services (J.I.M Services).

We understand the importance of privacy and its security to You. We take privacy very seriously and are committed to dealing with Personal Information in accordance with the requirements of the UK GDPR and other applicable UK data protection and data privacy laws.

From time to time we will review our Privacy Policy to keep pace with changes in our service. Please take a moment to read this Privacy Policy so You understand how we collect, store, use and disclose Personal Information. 

Definitions

• “Service/s” means the J.I.M Services, the Website, or associated goods and services we make available to You through the Website.
• “Website” means this website, and other associated websites we have or established for Your use.
• “You” or “Your” means any user of the Website or Services.

Collection and Storage of Personal Information 

We store Your Personal Information securely on our servers and use industry-standard measures to protect it from unauthorised access, use and disclosure. However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Your Personal Information, we cannot guarantee its absolute security.

By accessing the Website or using our Services, You consent to the collection, use, disclosure, storage and processing of their information in accordance with this Privacy Policy.

We may collect:

• Identity Information – We may collect personal details such as Your name, gender, title and date of birth allowing us to identify You;
• Contact Information – We may collect information such as Your email address, telephone number, third-party user names, residential, business and postal address and other information that allows us to contact You 
• Financial Information – We may collect financial information such as bank or credit card details used to transact with us and other information that allows us to transact with You and/or provide You with our Services;
• Statistical Information – We may collect behavioural and statistical information about You in connection with the Services.
• Health Information – We may collect health-related information from You to ensure that our services are suitable and safe for Your use. This information may include details about Your fitness levels, medical conditions, injuries, or any other health-related data You provide us.

We may use different methods to collect Personal Information from You, including:

• From You directly when You provide information to us;
• As part of us providing to You our Services or You procuring from the Services from us;
• When You interact with us on social media, visit our website and send an enquiry through or make a comment or other post at the Website; and
• When You sign up or subscribe to an email marketing list.

Use of Personal Information

We use Personal Information about You for the purpose it was provided or collected, including in the following ways: 

• To provide you with our Services.  In this case, we use your personal information to perform our contract with you;
• To respond to enquiries received from You. In this case, we rely on legitimate interest;
• To verify Your identity. In this case, we rely on legitimate interest;
• To communicate with You and provide You with information (whether by email, post or other means) about our Services. In this case, we rely on legitimate interest or consent, where You have requested or consented to receiving this from us;
• To notify You about changes to our Services.  In this case, we rely on legitimate interest;
• To receive and address feedback or complaints from You.  In this case, we rely on legitimate interest;
• To protect our legal interests and fulfil our legal and regulatory obligations (if and to the extent necessary); and
• In other circumstances, with Your prior consent.

Direct Marketing 

All those with whom we interact have the option to opt-out of receiving marketing communications from us. If You do not wish to continue to receive electronic marketing communications from us and/or selected third parties You should opt-out by clicking on the “unsubscribe” link in any email communications that we might send You. 

Disclosure of Personal Information

We may share Your Personal Information outside our organisation for limited purposes, such as:

• to help us operate our business and provide the Services;
• marketing businesses engaged by us to disseminate materials to which recipients have consented; and
• in a de-identified manner pursuant to this Privacy Policy.

We may also disclose Your Personal Information to third parties outside our organisation: 

• To facilitate fitness class scheduling and bookings through a third party software platform provider, enabling us to deliver the Services;
• To collect and manage membership payments, fees and charges through a third party payment provider; 
• Where we have Your express permission to do so, or it can reasonably be inferred from the circumstances that You consent to the disclosure to the third parties;
• If we are acquired by a third party, in which case Personal Information which we hold may be one of the transferred assets (subject to the same constraints on use and disclosure as under this policy); and
• If we are under a duty or have a legal right to disclose or share Personal Information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions or to protect our rights, property, or the safety of our personnel and Users. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services and associated purposes. We deal with third parties that are required to meet the privacy standards required by law in handling Your Personal Information and use Your Personal Information only for the purposes that we give it to them. 

We may use Your Personal Information in de-identified form (de-identification being a process by which a collection of data or information is altered to remove or obscure personal identifiers and personal information) to assist us in operating our business or providing the Services. We may also provide, including by way of sale, de-identified information in aggregated form, to third parties. This de-identified and aggregated information may be used to:

• provide users with further information regarding the uses and benefits of the Services;
• enhance our business productivity, including by creating insights and trends from the de-identified information and/or the aggregated data;
• assist us to better understand and provide us with insights and trends on how our users are using the Services;
• to improve the Services;
• such other uses that is otherwise reasonable in the daily operation, or Your continued use, of the Services, that is otherwise not capable of identifying You.

When Your Personal Information is included in de-identified, aggregated data, it is not possible to identify You or anything about You from that data. UK GDPR does not apply to aggregated or de-identified information.

International Transfers 

We may transfer Personal Information to service providers that carry out certain functions on our behalf. This may involve transferring Personal Information outside the UK to countries which have laws that do not provide the same level of data protection under the UK GDPR.

Whenever we transfer Personal Information outside of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the appropriate safeguards are in place. We may use specific standard contractual terms approved for use in the UK which give the transferred Personal Information the same protection as it has in the UK.

Security of Personal Information

We take all reasonable steps to protect Personal Information, including through internal and external security, restricting access to Personal Information to those who have a need to know, maintaining technological products to prevent unauthorised computer access and regularly reviewing our technology to maintain security. We choose technology partners based on their security and privacy policies and practices.

Our studios are equipped with CCTV cameras to ensure the safety and security of our members and staff. The footage collected is stored securely and is only accessible to authorised personnel. CCTV footage is used strictly for security purposes and may be shared with law enforcement agencies if required by law.

We have put in place procedures to deal with any suspected loss of, unauthorised access to, or unauthorised disclosure of Personal Information and will notify You and any applicable regulator of a breach where we are legally required to do so.

Third Party Links

Our website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other sites. When You go to other websites from here, we advise You to be aware and read their privacy policy. 

We may also use interfaces with social media sites such as Facebook, LinkedIn, Instagram and others. If You choose to “like” or “share” information from this website through these services, You should review the privacy policy of that service. If You are a member of a social media site, the interfaces may allow the social media site to connect Your visits to this site with other Personal Information. 

Retention of Personal Information

We will retain Your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We may also retain and use Your Personal Information to the extent necessary for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 

Your Legal Rights 

You have a number of rights in relation to Your Personal Information. 

You have the right to:

• Request access to Your Personal Information. This enables You to receive a copy of the Personal Information we hold about You and to check that we are lawfully processing it.
• Request correction of the Personal Information 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.
• Request erasure of Your Personal Information in certain circumstances. This enables You to ask us to delete or remove Personal Information 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 Information 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 Information to comply with local law. 
• Object to processing of Your Personal Information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of Your Personal Information (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process Your information which override Your right to object.
• Request the transfer of Your Personal Information to You or to a third party. We will provide to You, or a third party You have chosen, Your Personal Information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for us to use or where we used the information to perform a contract with You.
• Withdraw consent at any time where we are relying on consent to process Your Personal Information. 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. 
• Request restriction of processing of Your Personal Information. This enables You to ask us to suspend the processing of Your Personal Information.

We may need to request specific information from You to help us confirm Your identity and ensure Your right to access Your Personal Information (or to exercise any of Your other rights). This is a security measure to ensure that Personal Information 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.

Amendments to this Policy

We reserve the right to amend or replace this Privacy Policy at any time, with or without notice to Users, by posting an updated version on the Website, which shall become effective immediately upon posting. In the event that any updates  constitute a material change to this Privacy Policy, we will make reasonable efforts to announce such change on the Website.

Contact Details 

If You have any questions about this Privacy Policy or about the use of Your Personal Information, or You want to exercise Your privacy rights, please contact us at unitedkingdom@joyinmovement.uk.

Complaints 

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues. However, before doing so please make sure You have first made Your complaint to us or asked us for clarification if there is something You do not understand. The ICO will expect You to have done this before reviewing Your complaint.