Welcome to Fortitude Academy Hub - Privacy Notice

We respect your privacy and we are committed to protecting your personal data. This privacy notice informs you about how we look after your personal data which you may have provided to us and it tells you about your privacy rights and how the law protects you.

1. Important information and who we are
2. The data we collect about you
3. If you fail to provide personal data to us
4. How is your personal data collected
5. How we use your personal data
6. Purposes for which we will use your personal data
7. Automated decision making
8. Marketing from us
9. Opting out
10. Cookies
11. Change of purpose
12. Disclosures of your personal data
13. International transfers
14. Data security
15. Data retention
16. Your legal rights
17. Glossary
18. Contact details
19. Changes to our privacy notice

It is important that you read this privacy notice. It aims to give you information on how we collect and process your personal data (including such data in respect of any child who is intended to be the student and you are the parent or guardian) when you use our website or make an enquiry, book a lesson or sign up as a member of Fortitude Academy Hub.

Please note that our website is not intended for children – children wishing to train in [Martial Arts / Dance] will require their parents or legal guardian to contact us.

Controller

We, being Fortitude Academy Hub are the data controller which means that we decide how your personal information is processed and for what purposes (referred to as “us”, “we” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

• Our details are: Fortitude Academy Hub
• Email address: fortitudelink@gmail.com
• Postal address:
  Literary and Social Institute
  Lower Ground
  East Grinstead
  West Sussex
  RH19 1BG
  
  
• Telephone number: 01342302192

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

When you opt in to marketing communications, register on our website, register for classes or tuition via our website, or directly we collect data from you to enable us to deliver our services. This may include your name, address, email, contact details, emergency contact details, details of you children including name, date of birth, permissions you grant us to provide medical assistance, who can and can’t collect them and any other medical or learning needs you wish to make us aware of and your payment details.

Additionally, we may collect website usage information using cookies.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes data which you provide via our enquiry form or membership agreement, such as first name, last name, marital status, title, date of birth and gender including such data in respect of any child who is intended to be the student and you are the parent or guardian.
• Contact Data includes email address, telephone numbers and emergency contact details.
• Training Data includes details of attendance at tuition, competition results and gradings/assessments undertaken.
• Health data includes details of any health conditions, medications and allergies (this is known as sensitive personal data).
• Visual images include videos and photographs of students.
• 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 username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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.

Where we need personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with tuition). In this case, we may have to cancel the service you have with us but will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Attend a trial lesson with us.
• Enquire about our products or services.
• Subscribe to our publications.
• Request marketing to be sent to you.
• Give us some feedback.
• Enter into an agreement with us for tuition.
• When you attend a lesson or grading event.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Third parties
We may receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:
  1. analytics providers such as Google Analytics; and
  2. advertising networks such as Google AdWords and Facebook.
• Contact, Financial and Identity Data from providers of technical, payment and delivery services such as NEST Management Limited (who are based in the EU) (who provide us with various services including tuition fee collection and administration, and business management software applications).
• Contact and Identity Data from providers of introductory services such as NEST Management Limited (Get Into Martial Arts) (who are based in EU).

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are 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 if you need details about the specific legal ground we are relying on to pro cess your personal data where more than one ground has been set out in the table below.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are 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 if you need details about the specific legal ground we are relying on to pro cess 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 Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

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.

We do no 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 personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and services may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have opted-in to receive that marketing.

You can ask us to stop sending you marketing messages at any time by sending an email to us or contacting us by phone or post.

If you opt out of receiving marketing message from us but remain a member, or continue to receive our services or make a purchase from us, you will continue to receive non- marketing communications about your class bookings or other appointments with us, communications relating to the management of your membership, and service communications about the academy or services we provide you with).

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

We use Google Analytics cookies to help understand how visitors engage with our website. Google uses a set of cookies to collect information and report website usage statistics without personally identifying individual visitors to Google ourselves.

We use Google Advertising cookies to help make sure only relevant and interested parties see our web advertisements. Google uses a set of cookies to collect information and serve adverts over their network without personally identifying individuals to Google ourselves.

We use Facebook Pixel to help make sure only relevant and interested parties see our Facebook advertisements Facebook uses a set of cookies to collect information and serve adverts over their network.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We do not sell or share your personal data with any other organisations for their marketing purposes. We only share your personal data as explained in this privacy notice.

We may have to 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 services and manage our business.

The services these third parties provide include our business management system, our IT support and service providers, including payment processing and debt collection services and professional advice such as legal, tax and accountancy, and in the event we act as a franchisee, our master franchisor.

We may also share personal data with national governing bodies, regulatory associations and other similar organisations in connection with the tuition subject you /student is receiving.

We may also need to share your personal data with HM Revenue and Customs and other regulatory authorities.

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 may also need to share your personal information to third parties in exceptional or emergency circumstances, where we believe that the sharing of information about your or your child is vital to protect you, your child or another person.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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 specified purposes and in accordance with our instructions.

We do not transfer your personal data outside the European Economic Area (EEA).

We take the steps required by data protection law to protect your personal information 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.

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 of your personal data” below.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

• Request access to your personal data:
  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.

• Request correction of your personal data:
  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.

  If you become aware that we hold incorrect information please contact us and We will make the correction, for example: address changes and contact details changes such as address, telephone number or e-mail details.

• Request erasure of your personal data:
  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able 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 (or those of a third party) 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 your personal data:
  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.

• Request transfer of your personal data:
  Request the transfer of your personal data to you or to a third party. 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 we used the information to perform a contract with you.

• Right to withdraw consent:
  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.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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 try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

NEST Management Limited a company which provides us with various services including tuition fee collection and administration, and business management software applications.

We, us, our means owners of this website and the business providing tuition and other services which you may be using or enquiring about through this site.

• Fortitude Academy Hub
• Literary and Social Institute, Lower Ground, East Grinstead, West Sussex, RH19 1BG.
• Tel: Tel: 01342302192
• E-mail: fortitudelink@gmail.com

We may amend this privacy notice from time to time. This Privacy Notice was last updated 17 July 2018 - Version 1.5.