DATE
5 August 2020
VERSION
1
URL
STUDIO PILATES INTERNATIONAL PRIVACY POLICY
This Policy represents how Studio Pilates International Pty Ltd and its related entities, affiliates and franchisees (“Studio Pilates International”) manages your personal information in accordance with applicable law, including the Australian Privacy Act 1988 (Cth) and the New Zealand Privacy Act 1993 as applicable, and in accordance with applicable privacy laws in other countries where we operate including the United States. Our Privacy Policy seeks to safeguard the privacy of your personal information in accordance with the Australian Privacy Principles (“the APP’s”) and the New Zealand Information Privacy Principles, and the privacy principles in other countries where we operate, including the United States.
In addition to this Privacy Policy, we may also have specific and additional privacy provisions that apply to certain activities and promotions. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions provided to you will apply.
Please note that if at any time Studio Pilates International is required by law to release information about you, Studio Pilates International must cooperate fully.
This Privacy Policy may be amended from time to time and may be revised. This Privacy Policy represents the latest version of the Studio Pilates International Privacy Policy.
1. YOUR PERSONAL INFORMATION
Studio Pilates International recognises that your privacy is very important to you and that you have a right to control your personal information. We know that providing personal information is an act of trust and we take that trust seriously.
Unless you give us explicit consent to act otherwise, the following policy will govern how Studio Pilates International handles your personal information and safeguards your privacy. By applying for and using Studio Pilates International products and services, you consent to Studio Pilates International using your personal information as set out in this Privacy Policy.
1.1 What does “personal information” mean?
Personal information is any information about you that identifies you or by which your identity may be reasonably determined. By collecting this personal information we are able to:
Contact you when and where necessary;
Ensure that you attain the best possible service; and
Identify you and protect you from any unauthorised access to your personal information.
If you choose not to provide personal information to us, we may not be able to provide you with access to parts of the website or to certain content, products and services available on or from our website or in our studios.
1.2 Types of Personal Information Collected
We collect your personal information directly from you, via our website and in our studios. We collect your information to provide selected services to you at your request and to ensure that you receive the best possible service.
Some of the types of information which Studio Pilates International gathers include:-
(a) Information that you give us
Information that is entered into http://www.studiopilates.com/ or provided on an application at our studios is received and stored by Studio Pilates International. We may utilise the information you provide, such as your name, date of birth, residential address, email address and phone number on creating your account to communicate with you.
(b) Automatic information
Studio Pilates International may record anonymous information which tells us about visitors to our website but not the identity of those visitors. For example, we may collect information about the date, time and duration of those visits and which pages of our website are being commonly accessed. We may also use “cookies” that are small pieces of information that allow an organisation to track websites browsed by you. You may be able to adjust your browser to disable cookies. However, if you do disable cookies, you may not be able to interact with our website or take advantage of the improved functionality that cookies enable.
(c) Email communications
We receive personal information from you when you provide your contact details and email address when you interact with or contact Studio Pilates International.
(d) Digital communications
We receive personal information from you when you interact with, or contact us via, Studio Pilates International social media, such as, but not limited to, Facebook and Instagram.
(e) Information regarding your use of the website or in studio
(i) Information that you provide to us for the purposes of registering on our website or in our studios (which may include credit card information for billing purposes);
(ii) Information about your transactions carried out between yourself and Studio Pilates International;
(iii) Information that you provide for the purposes of subscribing to the services offered by Studio Pilates International;
(iv) Any other information that you send or provide to Studio Pilates International.
(f) CCTV footage with audio
To ensure that Studio Pilates International is able to provide you with the best possible service our studios have been fitted with CCTV cameras and audio. These cameras and audio are used strictly for security and training purposes only. Access to this footage is restricted and can only be viewed by authorised personnel.
1.3 How Studio Pilates International Collects and Holds Personal Information
Studio Pilates International will collect your personal information directly from you, online and in our studios.
As a general rule, we do not collect “sensitive information”. Sensitive information is a type of personal information that has a special definition under Australian law. It can include, but is not limited to, information about an individual’s health, opinions and beliefs. However, if we do collect sensitive information, it will usually be for the purposes of providing our services and we will seek your consent to collect it. Note that a medical history form is required to be completed prior to the first class.
Studio Pilates International holds and stores personal information within a number of controlled third-party applications discussed in detail at point 3 below.
1.4 Why Does Studio Pilates International Collect and Hold Personal Information?
Studio Pilates International collects and holds personal information about you in order to provide our products and services to you. Personal information is used only for the purpose for which it is submitted or for such other secondary purposes that are related to that purpose, unless we disclose other uses in this Privacy Policy or at the time of collection.
We collect your personal information for purposes including:-
(a) Administering the website, http://www.studiopilates.com/;
(b) Enabling your access to use the website services;
(c) Sending to you products that you may purchase through the site, http://www.studiopilates.com/;
(d) Supplying to you the services which you have requested;
(e) Providing you with updates on news and upcoming promotions;
(f) Updating you in relation to products or services that have or could be provided to you;
(g) Sending you statements and invoices and collect payments from you;
(h) Improving the quality of services provided to you; and
(i) Sending you marketing communications, where you opt in to receiving them.
We may use personally identifiable information in a summative form to improve our services and make them more responsive to the needs of our customers. This statistical compilation and analysis of information may also be used by us or provided to others as a summary report for marketing, advertising or research purposes.
We will not sell, transfer, assign or rent your personal information, except as set out in this Privacy Policy. In order to operate the website and to deliver to you the service which you have requested, we may sometimes share your personal information with an affiliate or subsidiary which is necessary to deliver your requested items or services to you. Information that is collected by our studios (which are franchisees of Studio Pilates International Pty Ltd) is also shared with Studio Pilates International Pty Ltd, and vice versa. We will not otherwise disclose your personal information to other companies without your consent.
Personal information is also collected to ensure that the products or services that have been sought from Studio Pilates International are effectively and efficiently delivered to you.
We may also use the information collected to provide to you information (via email or post) that has been requested by you personally. If at any time you receive material that you did not request or do not want to receive any such material anymore, see 2 and 5 of this Privacy Policy.
1.5 Who would Studio Pilates International disclose your personal information to?
As explained above, your personal information will be shared between Studio Pilates International Pty Ltd and its studios (which are franchisees).
Studio Pilates International may also need to disclose your personal information where you have consented to us doing so in providing you with our service or where disclosure is necessary to achieve the purpose for which it was submitted.
We may need to disclose or transfer your personal information if Studio Pilates International is acquired or merged with another entity.
Please note that if at any time Studio Pilates International is required by law to release information about you, we must cooperate fully. We may also disclose your information in order to investigate, halt or take action regarding illegal activities.
2. DIRECT MARKETING
If you subscribe to receive information from this Site, in studio, via email or social media, then your email address and other information that you provide will be recorded. Studio Pilates International may, from time to time, use your personal information, such as your address or contact details, to provide you with information about other services that we offer.
If at any time you do not wish to receive any information about these services, please feel free to select the unsubscribe link contained within the email or alternatively contact your local studio or email marketing@studiopilates.com.
3. YOUR PERSONAL INFORMATION AND OVERSEAS DISCLOSURE
Information which Studio Pilates International collects may be stored and processed in and transferred between the countries abroad in which Studio Pilates International operates to enable the use of that information in accordance with this Privacy Policy.
You agree to such cross-border transfers of personal information.
Studio Pilates International also uses a number of types of software and tools for storing and internally sharing your information. These include but are not limited to Google Drive through Google Enterprises, WordPress, Active Campaign, Mindbody online, Loyalsnap, Leadsbridge, Mailchimp, Studio Pilates branded App, Studio Pilates Amplify App, Studio Pilates Strong App, Capsule, Zapier, YouTube, Vimeo, Instagram, Facebook, Snapchat, Tik Tok Linked In and Twitter. Please refer to the relevant privacy policy on the website of the relevant vendor/partner/supplier.
4. DATA QUALITY AND SECURITY
Studio Pilates International endeavours to take all reasonable steps to keep secure any personal information which we hold about you, and to keep this information accurate and up to date. However, as the internet is not a secure environment, any information that you send to us via that method is sent at your own risk.
We strive to ensure the security, integrity and privacy of the personal information of our clients. We use a variety of physical and electronic security measures including restricting physical access to our offices and firewalls and secure databases to keep personal information secure from misuse, loss, modification, unauthorised access or disclosure. In addition, our employees are obliged to respect the confidentiality of personal information held by Studio Pilates International.
5. HOW CAN YOU ACCESS YOUR PERSONAL INFORMATION AND / OR SEEK CORRECTION?
You may access and/or request that your personal information be edited or corrected by logging onto your account and updating your information yourself, contacting your local studio (see the Studio Pilates International website for details) or by writing to one of the following:
Email: admin@studiopilates.com
By Post: Studio Pilates International, PO Box 802, Bulimba, Queensland 4171, Australia
We strive to ensure that all personal information stored is accurate, up-to-date and complete.
6. HOW CAN YOU COMPLAIN ABOUT A BREACH OF PRIVACY?
If you have any questions or concerns about our privacy policies and practices, or the manner in which Studio Pilates International has dealt with your personal information, or you wish to complain, you can direct your questions, concerns or complaints to:-
Email: admin@studiopilates.com
By Post: The Manager, Studio Pilates International, PO Box 802, Bulimba, Queensland 4171, Australia
Where Australian law applies:
? Studio Pilates International will, within fourteen days, respond to you and attempt to resolve with you your issues as they pertain to your personal information.
? If you are still unsatisfied, you may wish to direct your complaint to the Office of the Australian Information Commissioner at http://www.oaic.gov.au/ or alternatively:
? By phone: 1300 363 992
? In writing: The Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001 Australia
Where another country’s or state’s law applies, we will receive and respond to your complaint in accordance with applicable statutory timeframes (or if not, then within a reasonable period). We will attempt to resolve your complaint with you directly, but if you are unsatisfied, you may direct your complaint to the applicable privacy regulatory body (eg the Office of the Privacy Commissioner in New Zealand).
7. CALIFORNIA RESIDENTS
California law provides additional rights and notices for California residents, under the California Consumer Privacy Act.
Right to Know
You have the right to request that we disclose what personal information we collect, use, disclose and sell. To submit such a request, you may contact us at the email or mailing address listed above in Section 6.
If you request disclosure of categories of personal information we have collected about you, we will provide you with an individualized response with the categories of personal information about you that we have collected, sold or disclosed in the past 12 months, the categories of sources from which the personal information was collected, the business or commercial purpose for which it was collected, and the categories of third parties with which we have shared the information.
If you request specific pieces of personal information that we have collected, then we will provide you with a copy of the personal information we have collected about you. In our response, we will redact your social security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers or unique biometric data.
Request to Delete
You have the right to request the deletion of your personal information collected by us. You may make the request to the email address or mailing address listed above in Section 6.
Right to Opt Out
You have the right to opt-out of the sale of your personal information. You may make such a request to the email address or mailing address listed above in Section 6. Currently, we do not sell personal information.
Verification of Request
If we receive a request to know or a request to delete, we will take measures to verify with a reasonable degree of certainty that the person making the request is the consumer about whom we have collected information. If you have a password protected account with us, then we may verify your identity through our existing authentication practices for your account. If you do not have a password protected account with us, then we will verify the requestor’s identity by matching the identifying information provided by the requestor to the personal information already maintained by us, by matching at least two data points. In the case of a request to know specific pieces of personal information, we will require matching of at least three data points together with a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request. If we cannot verify the requestor’s identity from the information already maintained by us or the password authentication process, we may request additional information to verify your identity and for security or fraud-prevention purposes.
If you use an authorized agent to submit the request, we may require the agent to provide us with a power of attorney, or we may require the agent to provide us with a signed permission and verification of the agent’s identity as well as requiring you to directly confirm with us that you have provided the authorized agent permission to submit the request.
8. SPECIAL CONSIDERATIONS FOR COVID-19 RELATED INFORMATION
In an effort to keep the Studio Pilates International community safe in light of the COVID-19 pandemic, we are collecting additional information from our clients, employees, and guests in countries and states where the law to do so applies. Our transparency is key to maintaining your trust, and during these unprecedented times, we are especially mindful of striking the right balance between ensuring your health and safety and respecting your privacy.
As the current circumstances and the needs of our community evolve, this Privacy Notice may be modified or updated, and effective immediately upon posting. Please review this Privacy Notice periodically to ensure you are aware of any changes.
What Information We’re Collecting
We may collect certain information about your potential exposure to COVID-19 and health through periodic health declarations or questionnaires we ask you to complete. We may also collect measurements of your body temperature when you are at a studio. We will not record or store your body temperature measurement, but if your body temperature registers higher than our permitted threshold for studio access, we reserve the right to record and indicate in our system that you were denied entrance and are not eligible to return for three days. In addition, we may collect information provided by you, or a public health authority or other government agency, if you test positive for COVID-19, including information about how you interacted with Studio Pilates during the time in which you may have been infected with COVID-19. All of the foregoing is referred to in this Privacy Notice as “Screening Information”.
What We’re Doing with Screening Information
We collect and use Screening Information to help provide a safe environment for our employees and clients. We will not use your Screening Information for any marketing or promotional purposes.
How We May Share Screening Information
While we generally will not share your Screening Information without your consent, we reserve the right to disclose this information, and other related information, to government and regulatory authorities, such as state health authorities, in support of public health or safety. If we are notified that you tested positive for COVID-19 within 14 days after your last visit to Studio Pilates, or if we otherwise determine that you may pose a risk to our community, we reserve the right to disclose to our employees and clients that an individual who tested positive, or otherwise poses a risk to our community, was in our facilities and while we will not disclose your name unless legally required to do so, we may disclose information such as the date and time of your visit, and studio areas and amenities you used.
How We Retain Screening Information
Your Screening Information will be protected as described in our Privacy Policy below, and will be retained only as long as we determine reasonably necessary to ensure the health and safety for our clients, employees, and studio visitors and in accordance with applicable law. As noted above, your body temperature measurement will not be stored unless required by applicable law, but we will retain your acknowledgements of the health declaration, as well as any records (if any) that you were denied entrance and not permitted to return for three days. Any information that we retain will be stored for a reasonable period of time, including as we determine necessary to comply with applicable law or to establish or defend our legal rights.
Your Options
At this time, Studio Pilates requires you to provide Screening Information as a condition of entry to its studios in several states and countries. However, if you are uncomfortable with providing any requested Screening Information or do not wish to consent to this Privacy Notice, we are happy to place your membership on a complimentary freeze during the period in which Screening Information is required. Please contact your local studio if you have any questions regarding our screening procedures.
9. UPDATING THIS POLICY
Studio Pilates International may update this Privacy Policy from time to time by posting a new version of the Policy on this website. Please review this Privacy Notice periodically to ensure you are aware of any changes.