Privacy Policy.
In this privacy policy, "TBLDN" means The Basement LDN Ltd, company number 12700194 and whose registered office is at 192-194 Alder Road, Poole, England, BH12 4AX. TBLDN believe in transparency, and are committed to being upfront about privacy practices, including how your personal information is treated. TBLDN have undertaken an extensive exercise to ensure ongoing compliance with the European Union General Data Protection Regulation (EU GPDR). TBLDN have ensured all current business processes and procedures are in line with the GDPR rights and principles and any new processes involving personal information that are implemented will be thoroughly reviewed through a Data Protection Impact Assessment (DPIA) prior to proceeding. All company data protection procedures and policies are reviewed on an annual basis to ensure compliance.
This Privacy Policy sets out the data processing practices carried out through the use of the Internet and any other electronic communication networks by TBLDN, as well as describing the types of personal information that TBLDN may collect about you and the purposes for which this information is used.
1. Accepting the Privacy Policy
2. Information Collected or Received
3. How and why TBLDN use your Personal Information
4. Communication from TBLDN
5. Sharing your Information
6. Keeping your Information Secure
7. TBLDN Retention Policies
8. Staying in Control - Your Rights
9. Privacy Policy Changes
10. Contact
1. ACCEPTING THE PRIVACY POLICY
TBLDN need to process your personal information to run their business and provide you with their services. Upon visiting TBLDN in Club, contacting TBLDN by the phone, or visiting TBLDN website(s), you are accepting and consenting to the practices described in this Privacy Policy.
TBLDN are based in the UK, however process personal information both within the UK/EEA and outside. Any personal information held by either TBLDN or the designated third parties comply with relevant EU GDPR legislations. Third parties which process personal information outside the UK/EEA on behalf of TBLDN have a recognised equivalent legislation in place such as the US Privacy Shield, or a set of GDPR compliant Binding Corporate Rules (BCR).
2. INFORMATION COLLECTED OR RECEIVED
TBLDN collect personal information from Club users, Staff and Suppliers/Sub-contractors to run their business and provide you with their services. This personal information may include the following: name, date of birth, email address, contact number, company name, bank details and credit card details.
TBLDN also collect the following information:
Sensitive Information: The term "sensitive information" in this context refers to information related to your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership. Whilst TBLDN do not generally collect sensitive information unless it is volunteered by you, TBLDN do have a legal requirement to collect health data for the purpose of recording your self-assessment declaring readiness for physical exercise.
Photographs and Identification: In the interests of security and the prevention of crime, TBLDN may take a digital photograph of each Member or guest. Each Member or guest may also be required to provide a form of identification for verification and security purposes.
Audio-Video: TBLDN use CCTV in all Clubs for health and security reasons. If you have any queries in relation to the use of CCTV operating in and around the clubs please contact personaldata@thebasementldn.com. TBLDN have a business legitimate interest to monitor service standards in Club. TBLDN utilise mystery shopper services in which Club users may appear in the background however are never directly filmed. This footage is only used for the purposes of internal monitoring and training of TBLDN staff.
Digital: When visiting TBLDN website(s), your personal information may be collected, stored and used such as traffic data, location data, web logs, communication data and resources that you access, as well as other personal information detailed above. If you connect to TBLDN or register for a tour of TBLDN using an external third-party application, such as Facebook, Instagram, or Twitter, these websites will have their own privacy statement which TBLDN suggest that you read before giving them your personal information. Connecting to TBLDN via a third-party application or service is optional and at your own discretion.
TBLDN will only collect the relevant information required for the purposes of processing and will not use this information for any other purpose without obtaining consent.
3. HOW AND WHY TBLDN USE YOUR PERSONAL INFORMATION
The information in the above, section 2, may be used for the following purposes:
To carry out TBLDN’s obligations arising from any contractual agreement;
To contact you about non-contract aspects of your Membership, such as a change in usage patterns;
To provide you with the information on products or services you request;
To process payments and maintain accounts and records;
To prevent crime, fraud and aid in the prosecution of offenders;
To maintain Membership records;
To improve the TBLDN platform;
To prevent or detect abuses of the TBLDN website;
To create business performance statistics and analysis;
To enable third parties to carry out technical, logistical, research or other functions on behalf of TBLDN;
To send you newsletters and promotions, prize draws, and competitions;
To conduct surveys and request feedback;
To notify you about urgent comms such as a sudden closure of the Club;
To notify you about changes to TBLDN Services, Terms and Conditions, Privacy Policy and Club rules;
To process your job application if you apply for employment at TBLDN;
To collect information about your tastes and preferences, both when you tell us and by analysis of customer traffic, including using "cookies";
To read and respond to comments made regarding TBLDN services.
Other than as set out in this Privacy Policy TBLDN will not use your personal information for any other purpose without your consent, unless required to do so by law.
4. COMMUNICATION FROM TBLDN
On occasion, TBLDN may need to contact you. Primarily, these messages are delivered by email, text or phone, and every individual’s record is required to keep a valid email address and contact number on file to receive these messages.
In response to enquiries and when communicating with Members, TBLDN believe that the content is relevant, valuable, interesting and beneficial to you. TBLDN also believe that you would reasonably expect to receive the type of content that is sent to you as part of your relationship with TBLDN. Therefore, TBLDN’s current assessment is that the communication you receive is covered by the lawful basis for processing of ‘Legitimate Interest’ under recital 47 within the GPDR. For all communication sent under the basis of legitimate interest, opt-out options are provided and detailed later within this section.
For all communication where consent is the only legal basis, preferences will be collected in advance.
TBLDN recognise that you value having control over your own information, so TBLDN gives you the choice of editing your communication preferences if you disagree with the above. For TBLDN Members and Ex Members you may update of your preferences by emailing personaldata@thebasementldn.com with your request.
Please note the following messages from TBLDN fall into the category of compulsory communication and therefore no opt-out options are available:
Urgent Communication (such as, unplanned closure of all or part of a Club, reduced services, a change of opening times)
Automatic Class Booking communication (such as, booking confirmation, waiting list movement, cancellations)
Contract and Subscription related communication (such as, welcome emails, outstanding arrears, upcoming renewals, communication with the TBLDN Member Services Support Team).
You may receive communication from TBLDN via the following communication systems, all of which offer an opt-out service. Please note you must opt-out of each individual communication system should you wish to exercise that right.
Direct email communication from TBLDN staff via Outlook: To opt out you request this specifically by email to personaldata@thebasementldn.com.
Texts via our designated service provider: To opt-out please follow the instructions within the text you receive.
Email communication via our designated service provider: Squarespace, Inc. To opt-out please use the unsubscribe link within the email you receive.
5. SHARING YOUR INFORMATION
Information about TBLDN Club users is an important part to the business and TBLDN do not sell it to others. TBLDN shares member information only as described in this Privacy Policy.
TBLDN have business partners and employ other companies and individuals to perform certain functions on TBLDN behalf. Examples include managing our Membership database, sending texts, e-mails, analysing data, providing marketing assistance, providing personal training and providing debt collection assistance. Third party service providers only have access to the personal information relevant for performing their functions, but will not use it for other purposes. Additionally, they must process the personal information in accordance with this Privacy Policy and as permitted under the EU GDPR. TBLDN will only disclose personal information to reputable companies and suppliers who process data on TBLDN behalf.
Payment Collection: TBLDN may use third parties for payment collection whether that be upfront payment for membership, monthly direct debit payment for membership, one-off POS payments at reception, and debt collection.
Arrears Collection: TBLDN reserves the right to forward a members information to a third party debt collection agency. TBLDN does not have a designated service provider for third party debt collections in the event of non-payment of fees when due, any such service providers so appointed in the future will be notified to members via the updating of this Privacy Policy. Further information on the debt collection process can be found in TBLDN Terms and Conditions.
Personal Training: As stated on the TBLDN Membership Application, any Member who chooses to use a PT understands that their personal information will be provided to a designated personal trainer who will contact them to arrange their sessions.
TBLDN release account and other personal information to third parties when TBLDN believe release is appropriate to comply with the law; enforce or apply membership or other agreements; or protect the rights, property or safety of TBLDN, its users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction. This does not include selling, sharing or otherwise disclosing personally identifiable information from members for commercial purposes in a way that is contrary to the commitments made in this Privacy Policy.
TBLDN may share Member details with any organisation that acquires the Club to which the Member has their Membership.
Other Websites: The TBLDN website may contain links to other websites that are outside TBLDN control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from this policy.
Cookies: A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. Find out more about cookies on https://ico.org.uk/for-the-public/online/cookies/ TBLDN use cookies to identify you when you visit this website and to keep track of your browsing patterns and build up a demographic profile. TBLDN use cookies to allow registered users to be presented with a personalised version of the site, carry out transactions and have access to information about their account. Most browsers will allow you to turn off cookies. If you want to know how to do this please look at the menu on your browser, or look at the instruction on https://ico.org.uk/for-the-public/online/cookies/. Please note however that turning off cookies may restrict your use of our website. By continuing to use this site you are agreeing to the use of cookies as detailed within this section.
6. KEEPING YOUR INFORMATION SECURE
In regards to environmental and physical security, all TBLDN employees receive full training upon commencement on employment and subsequently on an annual basis thereafter. This is completed via training sessions. Further to this audits are completed on a regular basis.
7. TBLDN RETENTION POLICIES
TBLDN have set company retention policies in place and these timescales are set in accordance with any applicable legislation and/or for any agreed legitimate reasons. Where none exists, then TBLDN will keep your information for the duration of any Contract that you have entered into with TBLDN, and then for a period of 7 years after, at which time all the personal information will be pseudonymised.
After that 7 year duration, TBLDN will retain and use your pseudonymised information for the purpose of business statistics and analysis. TBLDN can retract this pseudonymisation to the extent necessary to comply with any legal obligations or to resolve disputes
8. STAYING IN CONTROL - YOUR RIGHTS
TBLDN understand the importance of data subjects remaining in control of their personal data. TBLDN acknowledge the following rights you have under the GDPR, what they mean and how you can exercise them.
The Right to be Informed
This privacy policy states all uses of your personal information and the purposes for processing this information. Should you have any concerns or questions about our privacy policy and practices, or would like a full list of our third party processors, then please email personaldata@thebasementldn.com.
The Right of Access
You have the right to access information that TBLDN hold about you. If you wish to receive a copy of the information that TBLDN hold, please submit a Subject Access Request form (SAR) which you can request from personaldata@thebasementldn.com. Once TBLDN have received your form, they will provide a response within one month. If your request is unusually complex and likely to take longer than a month, you will be informed as soon as possible to tell you how long it’s likely to take.
Please note that whilst in most cases TBLDN will be happy to provide you with copies of the information you request, TBLDN nevertheless reserve the right, in accordance with section 8(2) of the DPA, not to provide you with copies of information requested if to do so would take “disproportionate effort”, or in accordance with Article 12 of the GDPR to charge a fee or refuse the request if it is considered to be “manifestly unfounded or excessive”.
The Right to Rectification, Restrict Processing, Erasure, and to Object
You can ask TBLDN at any time to change, amend or pseudonymise the information that TBLDN hold about you or restrict ways in which your data may be processed. You can update TBLDN with amendments of personal information by submitting a request by email to personaldata@thebasementldn.com.
To pseudonymise the information, or object/request restriction of processing then please email personaldata@thebasementldn.com.
TBLDN will aim to respond to any request as soon as possible, but no later than within one month since receipt of request. Please note that the right to erasure is not absolute and only applies in certain circumstances. For further information on this please visit the following link to the ICO’s website, https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
Right to Data Portability
You have the right to request that your personal data is transferred by TBLDN to another organisation (this is called “data portability”). Please contact us at personaldata@thebasementldn.com with the details of what you would like for TBLDN to do and TBLDN will endeavour to comply with your request. It may not be technically feasible, but TBLDN will work with you to try and find a possible solution.
Right to Prevent Automated Decision Making
You have a right to ask TBLDN to stop any automated decision making. TBLDN do not intentionally carry out such activities, but if you do have any questions or concerns TBLDN would be happy to discuss them with you so please email any concerns or queries to personaldata@thebasementldn.com.
9. PRIVACY POLICY CHANGES
TBLDN may make slight changes to the Privacy Policy, Terms and Conditions and Club Rules, however, will never materially change policies and practices to make them less protective of member information collected in the past without the consent of affected members. TBLDN will display signage with details of any changes to these notices and conditions, but an up to date version will always be available on www.thebasementldn.com.
10. CONTACT
If you have any questions, comments or concerns about data privacy at TBLDN, please e-mail thorough a description to personaldata@thebasementldn.com and TBLDN will endeavour to resolve the issue for you. Alternatively should you wish to escalate any concerns or questions, rather than contact TBLDN directly, please contact the supervisory authority The Information Commissioner’s Office (ICO). For more information please visit the ICO’s website https://ico.org.uk/.