May 8

Privacy Policy and Data Protection Policy

Privacy Policy
We at Your Pilates take your privacy seriously and are committed to protecting your privacy.
This Privacy Policy explains what happens to any personal data that you provide to us, or that we collect from you whilst you visit our site.

Any information you give us is used exclusively by Your Pilates. We do update this policy from time to time so please do review this Policy regularly.

We do not share any personal information with any third parties, or rent, sell, disclose or distribute your information to any outside parties.

The Class Scheduling and Booking System
We use software called Acuity to administer our online booking. You can see their Privacy Policy via this link. https://acuityscheduling.com/privacy.php

Your money is processed by Braintree which accepts most debit and credit cards. You can find out more about them and their security in this document
https://www.braintreepayments.com/en-gb/legal/braintree-privacy-policy

By booking through Acuity, your name, address, email, and phone-numbers, plus a record of the classes you have booked, is stored on a database that only Grace Lillywhite has access to. By booking this way you are agreeing to let us send you the odd email reminding you about your Pilates classes and when new classes or workshops are coming up. You can unsubscribe from these emails at any time by letting me know that you no longer wish to receive them.

Enrolment Forms and Medical Information
We ask everyone who attends a group or private Pilates session to fill in an enrolment form via JotForm or in paper form. You can view the JotForm privacy policy here https://www.jotform.com/privacy/

Your form will ask you for your name, address and phone-numbers and has a large health information section. It also asks you to agree to a list of terms and conditions.

To be able to do our job as Pilates teachers, we need to ask you information about health conditions and injuries. It is very important you give accurate and current information to us, and keep us up-to-date with your state of health.

We do not discuss teaching you or any details of your health with anyone without your express permission. We may ask your permission to talk or email your physiotherapist, consultant, doctor, or other health professional if we think this would benefit your treatment. You would be entitled to see this correspondence if requested.

Disclosing Your Information
We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below:
i. In the event that we sell any or all of our business to the buyer.
ii. Where we are legally required by law to disclose your personal information.
iii. To further fraud protection and reduce the risk of fraud.

Storing Your Personal Data
We do not store any personal data unless we have your prior permission, all data is stored securely. Unfortunately the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically, Sending such information is entirely at your own risk.

Cookies
Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

The cookies that we use allow us to:
remember your preferences during and between visits
continuously improve our services, website, and marketing

We do not use cookies to:
collect any personally identifiable information
collect any sensitive information
pass personally identifiable data to third parties
Cookies on this site are set by Google Analytics.

Our cookie is used to remember if you’ve accepted our cookie / privacy policy.

Google Analytics uses cookies to keep track of the number of times a visitor has been to the site, which pages they visit and how long they spend there, what search terms brought them to the site, what OS / browser / network they’re using, and what links they follow within our site. You can find out more about Google Analytics here:
http://www.google.com/analytics/learn/privacy.html

Turning Cookies Off / Opting Out
Almost all browsers and devices can be instructed not to accept cookies. Please consult the Help pages for your browser (usually available via the F1 key), or your device’s instruction manual for details. Please be aware that the functionality of the site may suffer as a result.

Here are some links for the more popular browsers

Chrome: https://support.google.com/chrome/answer/95647
Firefox: http://support.mozilla.org/en-US/kb/block-websites-storing-site-preferences
Safari: http://support.apple.com/kb/PH11913
Internet Explorer: http://windows.microsoft.com/en-gb/windows7/block-enable-or-allow-cookies

To provide website visitors more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on instructs the Google Analytics JavaScript not to send any information about the website visit to Google Analytics. If you want to opt-out of Analytics, download and install the add-on for your current web browser. The Google Analytics Opt-out Browser Add-on is available for Microsoft Internet Explorer, Google Chrome, Mozilla Firefox, Apple Safari and Opera.

http://tools.google.com/dlpage/gaoptout

Third Party Links
On occasion we include links to third parties on this website. Where we provide a link it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any personal data.

Contacting Us
Please do not hesitate to contact us regarding any matter relating to this Privacy Policy at grace.yourpilates@gmail.com

Access to Information
In accordance with the Data Protection Act 1998 you have the right to access any information that we hold relating to you. Please note that we reserve the right to charge a fee of £10 to cover costs incurred by us in providing you with the information.

Your Pilates Data Protection Policy
Introduction
The purpose of this document is to provide a concise policy statement regarding the Data Protection obligations of Your Pilates. This includes obligations in dealing with personal data, in order to ensure that the organisation complies with the requirements of the relevant legislation, namely the Data Protection Act (1988) and the European Union General Data Protection Regulation (GDPR) (2018).

Rationale
Your Pilates must comply with the Data Protection principles set out in the relevant legislation and regulation. This Policy applies to all Personal Data collected, processed and stored by Your Pilates in relation to its service providers and clients in the course of its activities.

Scope
The policy covers both personal and sensitive personal data held in relation to data subjects by Your Pilates. The policy applies equally to personal data held in manual and automated form.
All Personal and Sensitive Personal Data will be treated with equal care by Your Pilates. Both categories will be equally referred-to as Personal Data in this policy, unless specifically stated otherwise.

Your Pilates as a Data Controller
In the course of its daily organisational activities, Your Pilates acquires, processes and stores personal data in relation to:
•   Clients of Your Pilates            
•   Third party service providers engaged by Your Pilates

Due to the nature of the services provided by Your Pilates, there is regular and active exchange of personal data between Your Pilates and its Data Subjects. This policy provides the guidelines for this exchange of information.

The Data Protection Principles
The following key principles are enshrined in the Irish legislation and EU Regulation and are fundamental to the Your Pilates’s Data Protection policy.
In its capacity as Data Controller, Your Pilates ensures that all data shall:
1. … be obtained and processed fairly and lawfully.
For data to be obtained fairly, the data subject will, at the time the data are being collected, be made aware of:
·       The identity of the Data Controller (Your Pilates)
·       The purpose(s) for which the data is being collected
·       The person(s) to whom the data may be disclosed by the Data Controller
·       Any other information that is necessary so that the processing may be fair.
Your Pilates will meet this obligation in the following way.
·       Where possible, the informed consent of the Data Subject will be sought before their data is processed;
·       Where it is not possible to seek consent, Your Pilates will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.;
·       Processing of the personal data will be carried out only as part of Your Pilates’s lawful activities, and Your Pilates will safeguard the rights and freedoms of the Data Subject;
·       The Data Subject’s data will not be disclosed to a third party other than to a party contracted to Your Pilates and operating on its behalf.
2.     …. be obtained only for one or more specified, legitimate purposes.
Your Pilates will obtain data for purposes which are specific, lawful and clearly stated. A Data Subject will have the right to question the purpose(s) for which Your Pilates holds their data, and Your Pilates will be able to clearly state that purpose or purposes.

3. ….. not be further processed in a manner incompatible with the specified purpose(s).
Any use of the data by Your Pilates will be compatible with the purposes for which the data was acquired.

4. …. be kept safe and secure.
Your Pilates will employ high standards of security in order to protect the personal data under its care. Appropriate security measures will be taken to protect against unauthorised access to, or alteration, destruction or disclosure of any personal data held by Your Pilates in its capacity as Data Controller. Access to and management of customer records is limited to those who have appropriate authorisation and password access.

5. … be kept accurate, complete and up-to-date where necessary.
Your Pilates will:
·       ensure that administrative and IT validation processes are in place to conduct regular assessments of data accuracy;
·       conduct regular assessments in order to establish the need to keep certain Personal Data.

6. … be adequate, relevant and not excessive in relation to the purpose(s) for which the data were collected and processed.
Your Pilates will ensure that the data it processes in relation to Data Subjects are relevant to the purposes for which those data are collected. Data which are not relevant to such processing will not be acquired or maintained.

7.     … not be kept for longer than is necessary to satisfy the specified purpose(s).
Your Pilates keeps personal data for 7 years due to the requirements by Balens Insurance. Once the period has elapsed, Your Pilates undertakes to destroy, erase or otherwise put this data beyond use.

8. … be managed and stored in such a manner that, in the event a Data Subject submits a valid Subject Access Request seeking a copy of their Personal Data, this data can be readily retrieved and provided to them.
Your Pilates has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.

Data Subject Requests
Subject Access Requests
Any formal, written request by a Data Subject for a copy of their personal data  will be processed as soon as possible, with the maximum response time being one month as per GDPR.

Portability Requests
Any formal, written request by a Data Subject for a copy of their personal data  to be transferred to another therapy/medical service will be carried out within one month.

Rectification Requests
Any formal, written request by a Data Subject for the update of their personal data to rectify incorrect or out-of-date information will be carried out within one month.

Erasure Requests
Any formal, written request by a Data Subject for the erasure or ‘right to be forgotten’ of their personal data will be carried out within one month.

Third Party Contractors
Any third parties contracted will be given documented instructions, covering areas including confidentiality obligations, security practices, processing, storage and transfer of data and the return or destruction of the personal data at the end of the relationships.

As a Data Controller, Your Pilates ensures that any entity which processes Personal Data on its behalf (a Data Processor) does so in a manner compliant with the Data Protection legislation. Failure of a Data Processor to manage Your Pilates’ data in a compliant manner will be viewed as a breach of contract, and will be pursued through the courts.

Data Breach Reporting
A breach is a loss of control, compromise, unauthorized disclosure, unauthorized acquisition, unauthorized access, or any similar term referring to situations where persons other than authorized users, for an authorized purpose, have access or potential access to personal data in usable form, whether manual or automated.

All incidents (a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed) will be reported to the Office of the Data Protection Commissioner within 72 hours. Where devices or equipment containing personal or sensitive personal data are lost or stolen, the Data Protection Commissioner is notified only where the data on such devices is not encrypted. The affected data subjects will also be informed.

Data Breach Logging
All data breaches will be recorded in an incident log as required by the Office of the Data Protection Commissioner. The log will maintain a summary record of each incident which has given rise to a risk of unauthorised disclosure, loss, destruction or alteration of personal data.  The record will include a brief description of the nature of the incident and an explanation of why the Office of the Data Protection Commissioner was not informed. Such records will be provided to the Office of the Data Protection Commissioner upon request.
Definitions.

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