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© 2019 by Fitluc Pte. Ltd.

PRIVACY POLICY

Introduction

This Privacy Policy explains how FITLUC PTE. LTD. (“we”,”us”, or FITLUC) generally handles your personal information.  We may also provide more specific information relating to particular products or services in our privacy collection notices. 

We will update this policy on our website if we change the way we handle personal information.

This Privacy Policy does not apply to FITLUC’s employee records and contractor records.

Specific types of interactions with us

In addition to the general information in this Privacy Policy, we have included specific sections that you should read if you:

  • have a FITLUC account

  • have are making any bookings or subscription on fitluc.com

  • are based in the European Economic Area (the EEA) during your interactions with us

Who is FITLUC?

This Privacy Policy applies to FITLUC PTE. LTD (UEN No. 201932971N)

Information We Collect

General

The types of personal information that we collect and process about you will depend on our relationship with you.  It will include some or all of the following:

  • General information about you: your name, title, gender, date of birth, contact details, passport or other identification details (which may include your image) and your answer to a security question (for example, your favourite colour)

  • Contact details: such as phone number, address, email address, and social media handle

  • Travel details: such as travel itinerary, baggage, seat preferences, seat and meal requests 

  • Health and dietary information: dietary requirement and health information, including requests for specific assistance, in connection with your use of our products and services

  • Payment details: such as details of your credit or debit card number and expiry date powered by PayPal

  • Your use of our products and services: such as personal training, bootcamps and online coaching programmes

  • Our interactions with you: such as any feedback, complaints, compliments, responses to market surveys, records of any correspondence and interactions with us and our staff (including in person, online, by telephone or email and via social media)

  • Your personal fitness level: such as your body measurements and performance

  • Website: if you use our website, your geo-location, IP address, mobile telephone number or ID, and details of how you use the website and any third party sites that you have accessed from them

  • My FITLUC accounts: your membership subscription details and details of your My FITLUC account. 

  • Incidents: details about any incidents that you are either involved in or that you witness, in connection with any of our products or services

Certain aspects of your personal information, for example details of your fitness level documentation, payment details and contact information, are required for many of our products and services and if you fail to supply such information as requested for specific services, we may be unable to provide you with the products and services in full.

Sensitive personal information

Under privacy laws, certain categories of personal information are considered particularly sensitive and therefore as needing additional protection. These categories include information about health, racial or ethnic origin, political opinions, religious beliefs, trade union membership or your sexual orientation. Sensitive information may also include genetic and biometric data. Information concerning criminal convictions and offences is also viewed as sensitive, for example, under European data protection law.

We may collect and handle your sensitive personal information, for example, when you request special medical or access assistance or if you tell us you have specific dietary requirements relating to your religious beliefs.

We will ask you for your consent to handle this type of personal information, to the extent required under applicable laws, for example under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”) or the European General Data Protection Regulation (“GDPR”). 

How we collect personal information

How we collect personal information about you will depend on our relationship or interactions with you.

Directly from you

We mainly collect information directly from you, for example, when you use our website or social media, you call or write to us, we interact with you in person, such as when you use our products and services or participate in promotions. 

Indirectly

There may be occasions when we collect information about you from someone else, such as:

  • Partners of FITLUC

  • When someone else books or purchases good or services on your behalf

  • Our service providers

  • Third parties that provide us with marketing leads

  • Other FITLUC branded entities

  • Businesses for whom we provide marketing and data analysis services

  • Providers of third party websites, apps and social media platforms

If you provide us with information about other individuals, regardless of whether you are travelling together, you are responsible for telling those individuals and letting them know that they can find a copy of this Privacy Policy on our website.  

How we use your personal information

We may use your personal information for the following purposes:

  • To provide our products and services: to verify your identity, to contact you about your bookings and subscriptions, to process payments, for quality assurance and training purposes, such as training our staff, managing our suppliers.

  • For marketing purposes: to provide you with updates and offers, if you have chosen to receive these; to operate our competitions, promotions and events; to distribute our newsletters and other communications.  We may also use your information for marketing FITLUC and our selected business partners’ products and services to you by post, email, SMS, phone and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.  We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you.

  • To provide customer support: to handle queries, complaints and claims.

  • To operate and facilitate your participation in FITLUC programmes: if you are a member of FITLUC programmes or have a FITLUC account, we will use personal information that we collect about you to ensure that you get the benefit of FITLUC’s and our partners’ programs, including to track your and record your usage of benefits. Partners of FITLUC, may also use your personal information to facilitate your participation in FITLUC programmes.

  • To conduct market, consumer and other research: to improve our products, services and marketing activities, including our websites, and to generate consumer insights that help us to market more efficiently and to be more relevant to you. 

  • To ensure website content is relevant: including to ensure that content from our websites is presented in the most effective manner for you and for your device, which may include automated decision making and passing your data to business partners, suppliers and/or service providers.

We may also combine the information that we collect and hold about you.

Disclosure of personal information

We may disclose your personal information to third parties in connection with: 

  • goods and services that you have bought through us or that we provide to you

  • the operation of, and your participation in, FITLUC programmes

  • the operation of, and your participation in, your FITLUC account

  • our legal obligations, responding to complaints and claims, investigating any activity that we suspect to be fraudulent 

  • your interest in our securities 

including:

  • Partners participating in our FITLUC programmes to allow you to receive offers and benefits in FITLUC programmes

  • Operators of other programs and clubs to allow you to receive offers and benefits in their programmes and clubs

  • Various law enforcement agencies, regulatory authorities and governments around the world and their service providers

  • Such other third parties mentioned in the “How we use your personal information” section above

In addition to the above third parties, we may use service providers for the services listed below, many of whom handle your personal information on our behalf.

  • Billing and payment processing, including detecting fraudulent or suspicious bookings

  • Bootcamp/ Personal Training venue partners

  • Market research and analysis

  • Marketing, printing and distribution (including mailing and email) services

  • Information technology services such as data storage, communication networks, software and system development, maintenance and support, incident investigation and resolution, and information processing, analysis and reporting

  • Investigating and responding to incidents

We may disclose your personal information to comply with our legal obligations, respond to complaints and claims, and investigate and protect ourselves and third parties against any activity that we reasonably suspect to be fraudulent.  We may also disclose your personal information to law enforcement agencies, regulatory authorities and governments around the world and their service providers in connection with their investigations, screening or other functions. 

We may transfer your information between our related bodies corporate and other FITLUC branded entities that are not related bodies corporate of FITLUC. FITLUC branded entities comply with this Privacy Policy. 

FITLUC Programme Members and FITLUC accounts

Membership of and participation in FITLUC programmes and creating a My FITLUC account is subject to the following conditions: 

Personal information we collect

General participation in FITLUC Programmes

In general we collect the information below about members of FITLUC Programmes.

  • Information about your membership: any information supplied as part of applications in connection with FITLUC Programmes.

  • Your payment details: including information related to credit cards and pre-paid cards.

  • Marketing purposes: your preferences, marketing subscriptions, interests and details of other memberships you may have.

  • Total Savings and purchase behaviour: including flight and ancillary prices, discounts and products offered to you and received by you.

Logged in members with a FITLUC account who use fitluc.com

  • We may collect logs of your use of fitluc.com while you have logged in. This information may include date and time of visit, FITLUC Programmes membership status, name, location and actions, for example, pages viewed, and pages submitted. 

  • How we collect information

  • We collect personal information about you as a member of FITLUC Programmes through your registration and participation in FITLUC Programmes. 

  • We may collect information directly from you through our interactions with you.  We may also collect information from others who interact with us on your behalf, our related bodies corporate and FITLUC branded entities.

  • We may also collect information from public sources (for example, Census data) and combine this information with information that we hold about you.

How we use your personal information

Providing and marketing enhanced products and services

We use your personal information to personalise the way we provide and market enhanced benefits, products and services to you.  We aim to enhance the way you use FITLUC Programmes, the website and marketing communications by understanding your preferences, interests and hobbies.

We may also market the products and services of our partners and other third parties who we believe may have products and services in which you would be interested. 

General administration of FITLUC Programmes 

We use the information we hold about you to administer FITLUC Programmes.  These activities include: 

  • assessing your membership applications

  • confirming your eligibility to participate in, and receive the benefits, goods and services, associated with FITLUC Programmes

  • investigating any activity we suspect to be fraudulent

We also use the information we hold to improve our services and customer service.  This may be achieved through activities such research, behavioural analytics, and planning and developing products.

Logged in members with a FITLUC Programmes membership or My FITLUC account who use Fitluc.com

We may use this information we collect when members are logged in and using Fitluc.com to monitor the use of, and improve, the information and functions on Fitluc.com.  We may also use the information to understand your preferences and provide you with information about our products and services and our partners' products and services which we think may interest you. 

Disclosure of your personal information

We may disclose your information to our partners for the purposes outlined in this Privacy Policy.

We may disclose your information to:

  • Providers of goods and services to members of FITLUC Programmes

  • Service providers for FITLUC Programmes

They may use the information to assist us with FITLUC Programmes. Such activities may include:

  • administering FITLUC Programmes generally

  • determining your eligibility for, and providing, products and services

  • providing market research and marketing services

We may also disclose your personal information in the course of investigating any activity we suspect to be fraudulent. 

How we use cookies

Fitluc.com uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard drive by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

Cookies on the Website may be used to ensure a smooth user experience, perform analytics, and for showing relevant advertisements. Please note that third parties (such as analytics software) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. The Website uses Google Analytics. Please refer to http://www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our website and how to control the information sent to Google.

Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to access all or parts of our Website or to fully experience the interactive features of the FITLUC services or websites you visit.

How we hold information and keep it secure​

We strive to maintain the safety of your Personal Information. Any payment transactions will be encrypted using SSL technology. Unfortunately, no internet-based service is completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

If we have given you (or you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures notified to you.  We require that you do not disclose your passwords to anyone else.

Access to, and correction of, information about you

In some countries you have the right to access, or correct, the personal information that we hold about you. If you would like to request access to, or correction of, your personal information that we hold, please contact us at info@fitluc.com

To the extent required by applicable law, we will provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, within a reasonable timeframe (or any time frame stipulated by the laws that apply to your request).  If we are permitted to withhold some of your personal information and we choose to do so, we will advise you when responding to your request. If we refuse to provide you with access to, or to amend, the information, (for example, if we are permitted to refuse access because granting access would interfere with the privacy of others or if it would result in a breach of confidentiality) to the extent required we will notify you in writing of our reasons for the refusal and how you may complain about the refusal.

Where permitted by law, we may recover from you our reasonable costs of supplying you with access to this information. However, we will not charge you for the making of the request or to correct or update your personal information. FITLUC Programmes members and logged in members with a My FITLUC account who use Fitluc.com can update their profile information online or by contacting us at info@fitluc.com

Privacy complaints and further information

If you have a concern about your privacy or you have any query on how your personal information is collected or used please contact us at info@fitluc.com

We will treat your complaints confidentially.  Our staff will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved.  We will aim to ensure that your complaint is resolved in timely and appropriate manner.

If you are not satisfied with our response, you may also contact the body responsible for administering the privacy laws in your country. 

European data protection laws 

This section applies if you are based in the European Economic Area (EEA) during your interactions with us (other than when you are in the EEA solely for travel purposes) and sets out the additional information that we are required to provide to you under European data protection laws.

Under European data protection laws, use of personal information must be based on one of a number of legal grounds and we are required to set out the grounds in respect of each use.  Companies may process personal data only when the processing is permitted by the specific legal ground set out in the law.

Legal grounds for use of personal information

The principal legal grounds for our use of your personal information are as follows:

  • Consent: where you have consented to our use of your information (you will have been presented with a consent form in relation to any such use and may withdraw your consent).

  • Contract performance: where we are required to collect and handle your personal information in order to provide you with the services that we have contractually agreed to provide to you, e.g. where you have booked a flight with us or the use of our freight service.

  • Legal obligation: where we need to use your personal information to comply with our legal obligations.

  • Vital interests: where we need to process your personal information in order to protect the vital interests of you or another natural person, e.g. where you require urgent assistance.

  • Public interest: where we need to process your personal information in order to carry out a task that is in the public interest.

  • Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.

The legal grounds for our use of the sensitive categories of personal information are:

  • Consent: where you have explicitly consented to our use of your personal information. You may withdraw your consent to the use of your personal information.

  • Vital interest: where we need to process your personal information in order to protect the vital interests of you or another natural person where you or the other person is physically or legally incapable of giving consent.

  • Legal claims: where your personal information is necessary for us to establish, exercise or defend any legal claims.

  • Substantial public interest: where we need to process your personal information for reasons of substantial public interest set out in EU law or the laws of the member state in which you are based.

  • Public interest in area of public health: where we need to process your personal information for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health, set out in EU law or the laws of the member state in which you are based.

Disclosure of information outside the EEA

Your personal information will be transferred to, and accessed in, countries outside of the EEA and we may be required by law to take specific measures to safeguard this personal information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information from the EEA to these jurisdictions. In countries which have not had these approvals, we will use appropriate safeguards to protect any personal information being transferred, such as EU Commission-approved model contractual clauses or binding corporate rules permitted by applicable legal requirements.

Retention period

Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either securely destroy it, or irreversibly anonymise the data (and we may further retain and use the anonymised information).

Marketing

You have the right to ask us not to process your personal information for marketing purposes. We will inform you if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by not opting in when we invite you to participate in our marketing activities. You can also exercise the right by contacting us at info@fitluc.com to opt out subsequently.

 

Additional Rights Under EU Law

In addition to the rights outlined elsewhere in this Privacy Policy, under certain conditions you may have the right under EU data protection law to ask us to:

  • provide you with further details on how we use and process your personal information;

  • delete personal information we no longer have grounds to process; and

  • restrict how we process your personal information while we consider an inquiry you have raised.

In addition, under certain conditions, you have the right to:

  • where processing is based on consent, withdraw the consent;

  • lodge a complaint with a supervisory authority;

  • object to any processing of personal information that we process on the “legitimate interests” or “public interests” grounds, unless our reasons for the underlying processing outweighs your interests, rights and freedoms; and

  • object to direct marketing (including any profiling for such purposes) at any time.

You can exercise these rights by contacting us at info@fitluc.com

These rights are subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

Our Contact Details

If you have any questions about privacy, please contact us at info@fitluc.com