We, REVOOLA Ltd (also referred to as “we”, “us”, or “our”), are a registered company in England (Company no. 10990391). Our registered address is at 27 Old Gloucester Street, London WC1 3AX.
To ensure data privacy and protection has appropriate focus within our organisation we have appointed a Data Protection Officer who reports to our senior management team. The Data Protection Officer’s contact details are as follows: REVOOLA Ltd, at 27 Old Gloucester Street, London WC1 3AX. email: dpo@REVOOLA.com
If you have any questions regarding this Notice, the use of your data or your Individual Rights please contact our Data Protection Officer using the details above.
THE PURPOSE OF THIS NOTICE
REVOOLA is the Data Controller and Data Processor of the information that you provide to us to access our services and training. We also work with selected third party organisations to process data on our behalf and provide REVOOLA services, we only do this to provide or improve Revoola’s use case or features. We never use the data for other purposes, including transfer to advertising platforms, data brokers, or information resellers.
While providing you with products and services we will collect and process information that is commonly known as personal data.
This Notice describes how we collect, use, share, retain and safeguard personal data.
Our website (www.REVOOLA.com) or our App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or App, we encourage you to read the privacy notice of every website you visit.
This policy will be reviewed from time to time and the latest version will be available on our website and or our app so do check back.
We are registered with the Office of the Information Commissioner, registration number: ZA532738.
WHAT IS PERSONAL DATA?
Personal data is information about you that can identify you or information which when combined with other information could identify you. Examples include your name, age, address, date of birth, height, weight, gender and contact details.
Some personal data is regarded as much more sensitive, this includes health, genetic and biometric data.
Children’s personal data requires specific protection. We are committed to providing the level of protection required and appreciate that this will sometimes vary depending on jurisdiction.
PERSONAL DATA WE COLLECT
In General. We collect both personally identifiable information and non-personally identifiable information from you as described in greater detail below. This is information about you that you give us when you browse or use the site, use the REVOOLA App, correspond with us by phone, SMS, email, social media or otherwise. We may collect some or all of the following information:
- Identity Data includes first name, maiden name, last name, username or similar identifier, date of birth and gender.
- Contact Data includes billing address, email address.
- Financial Data includes bank account and payment card details. If you choose to purchase REVOOLA products or services, you may be asked to provide your payment information, such as a credit card number and/or other related information that may be required from you to complete your purchase (“Financial Information”). Unless we tell you otherwise at the time of your purchase we do not collect, store or maintain your Financial Information.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your usernames and passwords, details of your membership, your purchases of our services, your use of our services, your interests, preferences, notes of your interactions with us, feedback and survey responses.
- Usage Data includes information about how you use products, services, website and mobile app.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data. For example, we may aggregate your Usage Data to understand usage or to calculate the percentage of users accessing a specific feature or class. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
- We collect Special Categories of Personal Data about you (health and biometric data), but only when such data is volunteered by you, for example in connection with your use of our personal training services.
HOW DO WE COLLECT AND RECEIVE YOUR PERSONAL DATA?
We collect and receive personal data from you through your interactions with us, including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- join us as a member;
- purchase or schedule a class or other services;
- access and use your membership account on our website or mobile app
- download and use our mobile app;
- enter a competition, promotion or survey; or
- contact us (whether by post, phone, email or otherwise) or provide us with feedback.
- As you use our services, we collect Usage Data.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out under Sharing Data below. below
- Identity and Contact Data from your employer (if you are a corporate member) or other membership intermediary (if you join us as a member through such an intermediary, including Vitality).
- Contact, Financial and Transaction Data from providers of technical, payment, debt recovery and fraud protection services based inside the EU such as BACS, Stripe (in relation to payment card services.
- Profile Data from providers of research and data analysis.
HOW DO WE USE THIS INFORMATION?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
You can read more below about the types of lawful basis that we rely on to process your personal data.
Purposes for which we will use your personal data
The table below sets out below a description of the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at dpo@REVOOLA.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
The following explains some of the terms used above in connection with the lawful basis for our processing:
Legitimate interests is where we have a business reason to use your personal data, including helping us improve our services and products and provide a better customer experience provided your rights do not override those interests.
Performance of a contract means processing your personal data where it is necessary for the performance of a contract we have with you, such as the fulfilment of a service that you have signed up to as part of your membership.
Consent where you have given us your consent, such as to send you marketing communications or information about selected third parties which we think you will find interesting. You can withdraw that consent at any time by modifying your preferences in emails we send you [ or whatever system you use] We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. See Marketing below.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
|Purpose/Activity||Type of data||Lawful basis for processing
including basis of legitimate
|To create a membership record
for you as a new customer
||Performance of a contract with you|
To manage your membership and other transactions with us:
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
Performance of a contract with youNecessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to analyse how customers use our products/services in order to improve and personalise them)
|To enable you to participate in promotions, competitions, prize draws or complete surveys||
||Necessary for our legitimate interests (to analyse how customers use our products/services in order to improve and personalise them and grow our business)|
|To administer and protect our business, our website and our mobile app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent and detect fraud and other crime)
Necessary to comply with a legal obligation
|To improve our website and mobile app to ensure content is presented to you in the most effective manner, that content is relevant to you, and to present advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
||Necessary for our legitimate interests (to analyse how customers use our products/services, to improve and personalise them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, mobile app, products/services, marketing, customer relationships and experiences||
||Necessary for our legitimate interests (to analyse customer activities and behaviours in relation to our products and services, to personalise our products and services for customers, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about our products or services that may be of interest to you as a member||
||Necessary for our legitimate interests (to develop our products/services, improve your service functionality and grow our business including by personalising our products and services)|
|To enable us to establish, exercise or defend legal claims in relation to our business||
||Necessary for our legitimate interests (to protect our business in the event of legal claims)|
|Marketing communications from third parties||
||Where you have given us your Consent. See marketing below.|
Automated decision making
We do not process your personal data for automated decision making where that decision making has any legal or similarly significant effect on you.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need from us, or what may be of interest to you, and to decide which products, services, promotions and offers may be relevant for you.
You will receive marketing communications from us in relation to our products and services if you are a member of ours and you did not opt out of receiving marketing communications from us when you joined us as a member and have not opted out of receiving marketing from us since.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at unsubscribe@REVOOLA.com
If you opt out of receiving marketing messages from us but remain a customer, you will continue to receive non-marketing communications (for example, information communications about your class bookings or other appointments with us, communications relating to the management of your membership or the services we provide you with).
We will not share your personal data with any external companies for marketing purposes unless you have given us your express opt-in consent to receive marketing from such third parties before we do so.
SHARING YOUR PERSONAL DATA
We do not sell or share your personal data with other organisations for their marketing purposes. We only share your personal data as explained in this Privacy Notice.
We may share your personal data (for the purposes set out in the table above explaining our use of your personal data) with external third parties who perform certain functions on our behalf or provide us with services to enable us to deliver our products and services and manage our business. The services these third parties provide include our membership management system, our IT support and service providers, payment processing and debt collection services, communication distribution services and marketing and data analysis services.
If you are a corporate member and your membership is paid for in part or in full by your employer, or you join through another membership intermediary (such as Vitality), we may share your Usage Data and Identity Data in connection with the management of our membership scheme with your employer or membership intermediary.
We may also share your personal data with third parties to whom we may sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If such a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law, including putting in place appropriate contractual obligations and protections. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for the specified purposes for which we engage them and in accordance with our instructions.
WHERE YOUR INFORMATION IS STORED
Your information is held securely within the UK however, it may be stored or processed by external third party service providers which have or may have parts of their business based outside the European Economic Area (EEA), for example some of our IT support and service providers. Where we engage the services of a third party based outside the EEA, or engage with a part of the business of a third party outside the EEA, their processing of your personal data as part of their provision of services to us will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it as is the case within the EEA by ensuring that your data remains protected at all times to the standard imposed by the general data protection regulation and the data protection Act 2018. We require our trusted third parties to meet our data protection standards. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your data.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. All our suppliers and contractors meet the same standards we require.
We have put in place procedures to deal with any suspected personal data breach or loss .
Unfortunately. No data transmission or storage system is completely secure. If you feel that the security of your account or interaction with us has been compromised, please contact us immediately. If such a disclosure does occur, we will contact you as soon as possible to explain what has happened and take all steps required of us to meet our obligations under legislation.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
For research or statistical purposes, we may anonymise your personal data on the condition that no personally identifiable information can be derived from it and so that it can no longer be associated with you)for research or statistical purposes in which case we may use this information indefinitely..
YOUR LEGAL RIGHTS
You can ask us to make changes in how your data is handled and we will respond promptly should a request be made. You have the following rights over the personal data about you that we are holding and processing. If you want to exercise any of the rights set out below, please speak to your club team or contact us at sars@REVOOLA.com
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it, at no cost to you.
- Request correction of the personal data 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 data. This enables you to ask us to delete or remove personal data where we no longer need to it for the purposes for which it was collected. You also have the right to ask us to delete or remove your personal data 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 data to comply with a legal obligation. Note, however, that we may not always be able or required to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Receive an electronic copy of any information you have consented to us holding where this is technically feasible. This is called data portability We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where our processing of the information is necessary for the performance of a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. 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. We will advise you if this is the case at the time you withdraw your consent. This right only applies where we process the personal data in question based on your consent.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
Time limit to respond
We will respond to your subject access request within 20 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
If you are dissatisfied with any aspect of the way in which we process your personal data and you wish to make a complaint, please contact our Data Protection Officer using the contact details . If we have been unable to resolve your complaint then you have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office(ICO). The ICO may be contacted via its website which is https://ico.org.uk/concerns/, by live chat or by calling their helpline on 0303 123 1113.