This policy applies to Pilates for Therapy and any of our associated/affiliated businesses, and outlines our obligations and practices in the handling of the Personal Data we collect and hold about our clients, prospects, vendors, suppliers, partners, and all others who come into contact with us, across all touch points of our business operations.
1. Personal Data
In this policy, personal data (“Personal Data”) refers to data, whether true or not, about an individual who can be identified from that data or from that data and other information to which we have or likely to have access. Examples of Personal Data include name, NRIC/FIN, passport number, address, photograph, contact number(s), email address, video and any other information relating to this individual provided to the Company in any forms submitted or via other forms of interaction with the individual.
2. Purpose for Collection
In order to operate efficiently, we have to collect and use Personal Data about the individuals with whom we work with. These may include members of public, current, past or prospective clients, consultants, vendors and partners.
The Company generally collects, uses and discloses Personal Data for purposes below and not limited to:
- Administering and maintaining client records;
- Making decisions and recommendations about your fitness;
- Responding to your queries and requests;
- Processing your instruction or requests;
- Personalising and tailoring our products and services to meet your needs;
- Pictures, videos and testimonials collected for marketing and/or publicity purposes;
- Carrying out billing, accounting, auditing and maintenance of proper book-keeping in relation to our operations and business;
- Managing commercial risks; or
- Purposes which are reasonably related to the above
3. Collection of Personal Data
The Company generally obtains Personal Data in the following ways:
- When you complete the Client Profile Form;
- When you submit forms relating to any of our products or services;
- When you use our services including but not limited to our websites;
- When you communicate with us or authorise others to communicate with us about you, whether electronically or by any other means;
- When you visit our studio for lessons or attend our events; or
- When you submit your Personal Data to us for any other reasons
Personal Data we collect from our websites
The type of Personal Data we collect on our website depends on how you make use of the site. When you visit our website, our host records your server address, domain name, the date and time of the visit and the pages viewed. This information may be collected by using cookies. A cookie is an element of data that a website can send to your browser, which may be stored in your system. The information collected is used to ensure a more personalised service level for our users. The information collected is retained for statistical and website development and is not in a form that would enable us to identify you.
You can adjust your browser settings to disable cookies associated with our website. Please note, however, that you may not be able to access some part(s) of our website. Some functions and services may not be available without cookies. Your user experience may be impacted as a result.
If you request information about our products or services, or respond to a promotion, or provide a feedback on our website, we shall collect your Personal Data in order to respond to your request or feedback.
The Personal Data and information provided may also be retained for product and service planning purposes, and we may use Personal Data to contact the respective individual for direct communication purposes where the individual’s consent was given.
If you send us an email containing Personal Data, we will take reasonable steps to ensure the confidentiality of that information. The content of emails is sometimes monitored by our internet host for maintenance and fault detection purposes. We may also monitor email for legal compliance purposes.
Although we take steps to protect Personal data and information sent by e-mail, e-mail is not a secure method of communication and if you are concerned about sending Personal Data to us in this manner, you may prefer to contact us by any of the other means set out above.
In your interactions with us or in relation to particular services and products, we may have also specifically notified you of other purposes for which we collect, use and disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these purposes as well, unless you have specified otherwise.
Third Party Website
To give you better service, our website may contain links to other websites which are owned or operated by third party providers. Those websites should contain their own privacy statements and their owners or operators are responsible for informing you about their security and privacy practices.
When connecting to such websites, you will no longer be subject to this policy but to the policy of the website that you are visiting. We recommend that you check the policy of the sites that you visit. If you have any concerns or questions, you shall direct them to the owner or operator of the website concerned. We will not be able to respond to you on these.
In addition, if you visit our website from a third party website, you will be subject to this policy. If you have questions or concerns relating to the third-party website that you came from, you shall direct them to the owner or operator of the website concerned.
4. Disclosure of Personal Data
Your Personal Data held by us shall be kept confidential. However, in order to provide you with effective and continuous products and services, and for the purposes listed above, your Personal Data may be disclosed to the following parties:
- Trusted third party service providers who provide operational services to us;
- Trusted third party service providers in connection with promotions, products and services offered by us;
- Relevant regulatory bodies, government agencies, statutory boards, administrative bodies, authorities or law enforcement agencies, to comply with any laws, rules, guidelines and regulations or schemes, to which we may be subject to whether situated locally or overseas;
- Counterparties, billing organisations and their respective banks in relation to payments; or
- Any other party to whom you authorise us to disclose your Personal Data to.
We respect your privacy and your personal information and for this reason, we take care to protect your Personal Data and to keep it confidential. When you request information or sign up for our products and services, you may be required to provide us with your Personal Data. In doing so, you agree and consent us and our respective partners and service providers collecting, using, disclosing and sharing your Personal Data in accordance with this policy.
6. Withdrawal of consent
You have a choice, at any time, not to provide your Personal Data or to withdraw your consent to us processing your Personal Data. You should notify us in writing via our contact details below if you wish to withdraw your consent. We may require up to 4 weeks, upon receipt of the request, for the change to take effect.
If you should withdraw your consent to the processing or handling of your Personal Data in respect of any purpose which we may reasonably consider to be essential in order for us to provide you with the products and/or services requested, we may not be in a position to continue to provide our products or services to you or administer any contractual relationship which may be in place between us. This may include pilates lessons and package promotions. Furthermore, we shall be entitled to treat such withdrawal as your termination of any agreement which you may have with us, without prejudice to any rights and remedies which we may have at law against you. Notwithstanding the generality of the foregoing and for avoidance of doubt, upon the termination or expiry of your contractual relationship with us (howsoever caused), we may still continue to use or disclose your Personal Data as may be necessary, required, authorised or permitted for compliance with applicable law or as may be requested by the relevant regulatory bodies, government agencies, statutory boards, administrative bodies, authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes to which we may be subject, whether situated locally or overseas.
7. Retention of Personal Data
We will retain Personal Data for a reasonable period for the purposes as cited or until you request for us to delete the Personal Data, or as required by law.
8. Security of Personal Data
Security of Personal Data is important to us and we take all reasonable precautions to protect Personal Data from misuse, loss, unauthorized access, modification or disclosure.
9. Update of Personal Data
You should ensure that all Personal Data is submitted to us is complete, accurate and up-to-date. Failure to do so may result in our inability to provide you with products and services that you have requested for.
We make reasonable effort to ensure that the Personal Data we hold is accurately recorded and all relevant parts thereof are collected. From time to time, we may require you to review your Personal Data and/or provide additional documentation to ensure that your Personal Data is accurate and complete.
If there are any changes to your Personal Data or if you believe the Personal Data that we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us so that we may take steps to update your Personal Data.
10. Access to Personal Data
You have the right to access your Personal Data. If you would like to request access to your Personal Data, you may contact us formally through the contact details indicated below. We will respond to you within 30 days from the receipt of your request. We charge an access fee of SGD 10 to cover the reasonable cost of retrieving the information and supplying it to you. We may take steps to verify your identity before fulfilling your request for access to your Personal Data.
We may refuse your request to access to your Personal Data in accordance with the PDPA such as where the Personal Data relates to investigations or the request for access is frivolous or vexatious.
11. Update of Policy
12. Data Protection Officer
If you have any queries or requests or wish to make any applications concerning your personal information or data, please contact our Data Protection Officer at firstname.lastname@example.org.