1. Types of Information Collected

2. Legal Basis, Use and Retention of Information

3. Third Party Data Processors and Service Providers

4. Cookies

• “Essential Cookies” are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. Because of their essential nature, you cannot opt out of these cookies.
• “Functional Cookies” enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages.
• “Analytics Cookies” allow us to count visits and traffic sources, so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous.
• Additionally, “Advertising Cookies” may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.

5. Opting Out of Promotional Communications

6. Compliance with Laws

7. Your Rights Under the General Data Protection Regulation (“GDPR”)

• Right of access. You have the right at any time to ask us for a copy of the personally identifiable information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personally identifiable information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
• Right of portability. In certain instances, you have a right to receive any personally identifiable information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third party organization. The above right exists only in respect of personally identifiable information that: (i) you have provided to us previously; and, (ii) is processed by us using automated means. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organization's systems. We are also unable to comply with requests that relate to personally identifiable information of others without their consent.
• Right to rectification. The right to obtain rectification of your personally identifiable information without undue delay where that personally identifiable information is inaccurate or incomplete.
• Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed.
• Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information.
• Right to object. The right to object, on grounds relating to your particular situation, to the processing of your Personal Information, and to object to processing of your Personal Information for direct marketing purposes, to the extent it is related to such direct marketing.

8. Your California Rights

• Right to Know. The right to know the Personal Information that we collect from you, the purposes for which we use it, the sources from which we collect it, the limited circumstances under which we share it, with whom we share it, and your rights regarding it.
• Right to Request Access and Data Portability Rights. The right to request we disclose certain information to you about our collection and use of your Personal Information (as used in this section “Personal Information” has the definition set forth in CCPA) over the past 12 months, upon verifiable consumer request. Once we receive and confirm your verifiable consumer request, we will disclose to you: (i) the categories of Personal Information we collected about you, (ii) the categories of sources for the Personal Information we collected about you, (iii) our business or commercial purpose for collecting or selling that Personal Information, (iv) the categories of third parties with whom we disclosed or sold that Personal Information, (v) and/or the specific pieces of Personal Information we collected about you (also called a data portability request). You may make a “request to know” up to two times in a 12-month period free of charge, subject to limitations described in the law. A general description of the categories of information that we collect, the purpose for collecting, using and sharing such information, and types of service providers we share information with is set forth above in the “Information and Collection,” “Legal Basis, Use and Retention of Information” and “Third Party Data Processors and Services Providers” sections.
• Right to Request Deletion. The right to request we delete your Personal Information that we collected from you and retained. Once we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records, subject to certain exceptions under applicable law.
• Right to Opt Out of Sale. The right to opt out of the “sale” of your personal information to “third parties.”
• Authorized Representatives. You may also designate an authorized representative to make consumer rights requests on your behalf. We will require verification that you did in fact authorize the representative.
• No sale of personal information. Although we do not believe we sell personal information, CCPA has very broadly defines “sale” as to qualify our limited sharing of your personal information as a “sale”.
• No Discrimination. We will not discriminate against any consumer for exercising their rights under the CCPA. We will not deny you goods or services, charge you different rates, or give you different discounts because you used one of these rights.

9. Children's Privacy

10. Data Transfer

• The country to which the personally identifiable information will be transferred has been granted a European Commission adequacy decision;
• The recipient of the personally identifiable information is located in the U.S. and has certified to the EU-U.S. Privacy Shield Framework in its current form; or
• We have put in place appropriate safeguards with respect to the transfer, for example the EU Model Standard Contract Clauses and/or Binding Corporate Resolutions.

11. Security

12. Changes To This Privacy Policy

13. Contact Us

1. Types of Information Collected

2. Legal Basis, Use and Retention of Information

3. Third Party Data Processors and Service Providers

4. Cookies

• “Essential Cookies” are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. Because of their essential nature, you cannot opt out of these cookies.
• “Functional Cookies” enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages.
• “Analytics Cookies” allow us to count visits and traffic sources, so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous.
• Additionally, “Advertising Cookies” may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.

5. Opting Out of Promotional Communications

6. Compliance with Laws

7. Your Rights Under the General Data Protection Regulation (“GDPR”)

• Right of access. You have the right at any time to ask us for a copy of the personally identifiable information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personally identifiable information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
• Right of portability. In certain instances, you have a right to receive any personally identifiable information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third party organization. The above right exists only in respect of personally identifiable information that: (i) you have provided to us previously; and, (ii) is processed by us using automated means. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organization's systems. We are also unable to comply with requests that relate to personally identifiable information of others without their consent.
• Right to rectification. The right to obtain rectification of your personally identifiable information without undue delay where that personally identifiable information is inaccurate or incomplete.
• Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed.
• Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information.
• Right to object. The right to object, on grounds relating to your particular situation, to the processing of your Personal Information, and to object to processing of your Personal Information for direct marketing purposes, to the extent it is related to such direct marketing.

8. Your California Rights

• Right to Know. The right to know the Personal Information that we collect from you, the purposes for which we use it, the sources from which we collect it, the limited circumstances under which we share it, with whom we share it, and your rights regarding it.
• Right to Request Access and Data Portability Rights. The right to request we disclose certain information to you about our collection and use of your Personal Information (as used in this section “Personal Information” has the definition set forth in CCPA) over the past 12 months, upon verifiable consumer request. Once we receive and confirm your verifiable consumer request, we will disclose to you: (i) the categories of Personal Information we collected about you, (ii) the categories of sources for the Personal Information we collected about you, (iii) our business or commercial purpose for collecting or selling that Personal Information, (iv) the categories of third parties with whom we disclosed or sold that Personal Information, (v) and/or the specific pieces of Personal Information we collected about you (also called a data portability request). You may make a “request to know” up to two times in a 12-month period free of charge, subject to limitations described in the law. A general description of the categories of information that we collect, the purpose for collecting, using and sharing such information, and types of service providers we share information with is set forth above in the “Information and Collection,” “Legal Basis, Use and Retention of Information” and “Third Party Data Processors and Services Providers” sections.
• Right to Request Deletion. The right to request we delete your Personal Information that we collected from you and retained. Once we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records, subject to certain exceptions under applicable law.
• Right to Opt Out of Sale. The right to opt out of the “sale” of your personal information to “third parties.”
• Authorized Representatives. You may also designate an authorized representative to make consumer rights requests on your behalf. We will require verification that you did in fact authorize the representative.
• No sale of personal information. Although we do not believe we sell personal information, CCPA has very broadly defines “sale” as to qualify our limited sharing of your personal information as a “sale”.
• No Discrimination. We will not discriminate against any consumer for exercising their rights under the CCPA. We will not deny you goods or services, charge you different rates, or give you different discounts because you used one of these rights.

9. Children's Privacy

10. Data Transfer

• The country to which the personally identifiable information will be transferred has been granted a European Commission adequacy decision;
• The recipient of the personally identifiable information is located in the U.S. and has certified to the EU-U.S. Privacy Shield Framework in its current form; or
• We have put in place appropriate safeguards with respect to the transfer, for example the EU Model Standard Contract Clauses and/or Binding Corporate Resolutions.

11. Security

12. Changes To This Privacy Policy

13. Contact Us

ABC collects information about you that is provided in conjunction with your purchase of services from one of ABC’s health club clients, including information provided on your health club membership agreement(s) and personal training agreement(s). Information about you is typically obtained from the agreement you sign with the club from whom you purchase services. Your personal information may also be collected from you when you provide information directly to ABC in any manner, or when you update account or contact information at the club or online. The information ABC collects about you may include your name, postal address, email address, phone numbers, bank account or credit card information, audio recordings of phone calls with you or made in relation to your account, photographs voluntarily taken at the club, and e-mail correspondence with you or in relation to your account. ABC collects such personal information about you for the purpose of processing and collecting payments owed by you to the club, to contact you in relation to your health club account, and to otherwise provide third party payment processing and administrative services to your club. ABC uses information it collects to communicate with health club members, collect payments owed to its health club clients, and maintain up to date account information for members. ABC’s Privacy Policy is available at https://www.abcfitness.com/privacy-policy/.