SR PERFORMANCE SERVICES LIMITED (t/a The Edge HPL)
This version was last updated on 7th of April, 2022 and historic versions are archived and can be obtained by contacting us.
1. We are the data controller in respect of your personal data.
Our full name: SR Performance Services Limited (t/a The Edge HPL) (“SRP”)
Our contact details: The Hovel, Blisworth Hill Properties, Stoke Road, Blisworth, Northamptonshire, United Kingdom, NN7 3DB
Registered in registered in England and Wales under company number 11553979
Registered at the ICO under: ZA542921
The "Platform" is the website at: https://www.memberships.theedgehpl.com and includes our Android and iOS mobile applications.
For data privacy and data protection matters our contact details are firstname.lastname@example.org
2. You must be 18 or over to subscribe to the Platform. We do not knowingly collect personal data relating to individuals under the age of 18. If you are a parent or legal guardian of an individual under the age of 18 who you believe has provided personal data to SRP through the Platform, please contact our Data Privacy Manager at email@example.com.
3. This notice explains:
3.1.1 What personal data we collect and how we use it;
3.1.2 The legal basis for processing your personal data;
3.1.3 Disclosure of your personal data;
3.1.4 How we keep your data safe and who has access;
3.1.5 Your responsibilities in keeping your information up to date;
3.1.6 Your rights to know what we know about you, make changes or ask us to stop using your data;
3.1.7 Our commitment to safeguarding children's personal data; and
3.1.8 How we handle any changes to this policy.
WHAT PERSONAL DATA WE COLLECT AND HOW WE USE IT
4. If you access our Platform, contact us, attend our premises, engage with us on social media platforms, and/or otherwise interact or communicate with us, we may collect the following information:
· information that you provide to us (including your name, email address, home address, telephone);
· information that you provide to us for billing and/or other activities relating to undertaking transactions with us and other clients (e.g. contact phone number, billing address, payment card details);
· information that you upload to your User Subscription account (including your image, photograph, nickname);
· personal and very occasionally Special Category Data (as further described below),
· the information you submit when completing forms and surveys issued by us as and when required (for example, dietary requirements);
· information that you provide to us if you email us about a question, complaint or to report a problem with the Platform;
· photographs of your progress or attendance at the lab, if we have your clear, unambiguous consent to do so;
· if you contact us by email, phone or otherwise, we may keep a record of that correspondence;
· technical information such as your IP address, device type, cookie ID, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Platform, including the pages accessed and links clicked. Please see our Cookies Policy for further information.
5. Not all of the list above will necessarily apply to you - it depends on your particular interaction and communications with us. We mainly use your data to:
5.1 fulfil contractual obligations to you;
5.2 to register you as a client and/or subscriber and verify that you are who you say you are;
5.3 to process any orders which you place through the Platform or at our premises;
5.4 to take payment and to collect and recover money owed to us (if applicable);
5.5 to comply with health and safety and other legal obligations and uphold our duty of care towards you and other individuals;
5.6 to administer general record keeping;
5.7 to communicate with you;
5.8 to provide you with any customer support and handle any cancellation or refund requests
5.9 to market to you.
6. We may transfer, store and process your personal data outside the UK.
7. Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
8. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
8.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
8.2 Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK
By submitting your personal information to us (or our partners on our behalf) you agree to this transfer, storing or processing at a location outside the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
9. In most cases, we process your personal data either on the basis of your consent, where this has been given unambiguously, or on the basis that it is necessary for the performance of a contract between you and SRP. Where you have given your consent to us sending you marketing materials, you may withdraw your consent at any time by contacting us at firstname.lastname@example.org.
10. In some cases, we have a legitimate interest to process your personal data. Before using your personal data for our legitimate interests, we shall make sure that we have taken into account any potential impact that such use may have on you to ensure that your interests and fundamental rights and freedoms do not override those interests. In other words, we shall determine that we have a legitimate need to process your personal data and that we are not aware of any reasons that, on balance, mean we should not be doing so. If you have concerns about our processing please refer to 'Your rights to know what we know about you, make changes or ask us to stop using your data' Contact us: email@example.com.
11. In rare circumstances, we may also use your personal data because:
11.1 we need to comply with a legal obligation (for example, because the court has ordered us to do so); or
11.2 it may be necessary to protect yours or someone else's vital interests in emergency situations.
12. As part of the services we provide for you we may collect Special Category Data. “Special Category Data” means personal data from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data sexual life or judicial data (including information concerning the commission or alleged commission of a criminal offence). In some very rare instances, financial records may form part of Special Category Data where you are located. We only process Special Category Data in your jurisdiction if and to the extent permitted or required by applicable law.
13. We only use Special Category Data in accordance with data protection law. In most instances we reply on your explicit written consent. If we do so, we (or a third party) will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
DISCLOSURE OF YOUR PERSONAL DATA
14. The recipients or categories of recipients of your personal data are:
14.1 our third party suppliers who help us to fulfil any of the Services e.g. our third party payment processors, which are presently Stripe;
14.2 our third party suppliers who help us maintain the Platform and run our business e.g. our hosting provider, which is presently Thinkific.
14.3 credit reference agencies; law enforcement and fraud prevention agencies, so we can help tackle fraud or investigate any breach of the Legal Terms and/or Privacy Notice or any other notice provided to you from time to time.
15. We may also disclose your personal data to any prospective buyer of our business or assets or our professional advisors who provide legal, accounting, consulting, banking, or insurance services.
HOW WE KEEP YOUR DATA SAFE AND WHO HAS ACCESS
16. We are committed to protecting the information we receive from you. We follow reasonable technical and management practices to help protect the confidentiality, security and integrity of data stored on our system. While no computer system is completely secure, we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved.
17. The Platform may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, these websites have their own privacy notice and that we do not accept any responsibility or liability for these notices. Please check these notices before you submit any personal data to these websites.
YOUR RESPONSIBILITIES IN KEEPING YOUR INFORMATION UP TO DATE
18. We really appreciate it if you let us know if your contact details change. You can do that by firstname.lastname@example.org.
19. We will hold your personal data only for so long as it is necessary to provide you with the services you have requested or to perform the purpose for which it was originally collected, after which it will be deleted, unless it is necessary for us to continue to process it in order to comply with any legal obligations to which we are subject or for another legitimate and lawful purpose.
YOUR RIGHTS TO KNOW WHAT WE KNOW ABOUT YOU, MAKE CHANGES OR ASK US TO STOP USING YOUR DATA
20. Under certain circumstances, you have rights under data protection laws in relation to your personal data.
20.1 Request access to your personal data.
20.2 Request correction of your personal data.
20.3 Request erasure of your personal data.
20.4 Object to processing of your personal data.
20.5 Request restriction of processing your personal data.
20.6 Request transfer of your personal data.
20.7 Right to withdraw consent.
21. If you wish to exercise any of the rights set out above, please send a description of the information you want to see and proof of your identity to email@example.com. If you would like to stop us processing your personal data, and if it’s not necessary for the purpose you provided it to us for (e.g. registering you for an account) we will do so.Contact us at firstname.lastname@example.org if you have any concerns.
22. If we are relying on your consent to process data, you may withdraw your consent at any time by notice to us.
23. If you have any questions please send these to email@example.com and for further information see the Information Commissioner’s guidance here. This is an external link. You have the right to complain to the Information Commissioner's Office about the manner in which or otherwise in respect of the manner in which we process your personal data.
24. Your provision of personal data to us is not in general subject to a contractual or legal requirement, although it is subject to a contractual requirement in the event of a purchase of any Services from us. In all other circumstances, if you choose not to supply your personal data to us, however, you may not be able to access certain areas of the Platform, nor use certain services.
HOW WE HANDLE ANY CHANGES TO THIS POLICY
25. We may change this page from time to time, to reflect how we are processing your data so we recommend that you review this page on a regular basis to make sure that you remain comfortable with our processing activities. However, if we make significant changes, we will endeavour to bring these to your attention either by making it that clear on the Platform and/or by some other means of contact such as email, so that you are able to review the changes before you continue to use the Platform.