Introduction
Barrow Forward Limited takes your privacy very seriously and is committed to protecting your personal information when you use our service.
This Privacy Notice sets out the way in which any personal information you provide to us is used and kept secure by Barrow Forward. It applies whenever we collect your personal data (including when you use our website or other digital platforms), this also forms part of our membership terms and conditions so please read it carefully.
About Barrow Forward
This privacy notice (“the Privacy Notice”) applies to all personal information processing activities carried out by Barrow Forward Limited.
Barrow Forward Limited is a Local Authority Trading Company incorporated and registered in England and Wales with company number 13358547 whose registered office is at the Town Hall, Duke Street Barrow-in-Furness LA14 2LD. Further information on Barrow Forward can be found http://www.barrowleisure.co.uk
We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business.
Barrow Forward complies with all applicable Data Protection Regulations. This Privacy Notice was published in September 2021. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.
Supplementary Notice – COVID 19
This supplementary notice is to make it easier to understand and provide you with more information about how we may process your personal information in relation to the prevailing government guidance or legislation at any time regarding the coronavirus pandemic (COVID 19).
We may seek to share your personal data limited to contact information only with the necessary Government bodies in support of the track and trace scheme, or government measures in place at the time to ensure the safety and well-being of all our customers and employees.
Such information which is shared will only be shared on a ‘need to know’ basis, with appropriate individuals/bodies. Only the minimum information for the purpose will be shared.
The legal basis for processing the date for this purpose is that it is necessary to protect the vital interests of individuals in monitoring and dealing with the COVID-19 pandemic.
Contacting Us
If you need to contact us with our processing of your personal data you can contact us as below:
Email: enquiries@barrowleisure.co.uk
Please put PRIVACY NOTICE in the title bar.
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK regulator for data protection issues. Further information including contract details is available at https://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.
Collecting Your Personal Information
Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, (including emergency contact first name and last name), marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers (including emergency contact telephone number).
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about membership payments from you to us 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 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 and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or the gym at a particular time. 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 policy.
- Special Categories of Personal Data
- Some information is ‘special’ and needs more protection due to its sensitivity. It is often information you would not want widely known and is very personal to you. This is likely to include anything that can reveal information relating to:
- Health Data, which includes your medical history; and
- Ethnic Origin Data, which includes details about your race and ethnicity.
- We will only collect this type of information if it necessary to your contract so that we can provide the right services to you.
- We may at times need to share this information. We will only do this if we have your consent or if there are legal requirements for us to do so.
- If we ask for any sensitive personal data about you, we will always tell you why we need it and ask for your consent to hold it.
- Due to the sensitive nature of Special Category Data, in order to collect it, we are required to have a separate Appropriate Policy Document in place, which details how and why we collect this data.
- Why We Need Your Personal Data
- We may need to use some information about you to:
- Help us deliver the right services and to support you
- Carry out our obligations arising from any contracts entered into between you and us
- Manage those services we provide to you
- Service improvement
- Prevention/detection of crime/fraud
- Help investigate any complaints you have about our services
- Monitor the quality of our services
- Failure to Provide Personal Data
- Where we need to collect 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 a gym memberships). In this case, we may have to cancel or decline your membership application with us but we will notify you if this is the case at the time.
Communicating With You
At Barrow Forward we believe in putting our customers in the driving seat when communicating. When we communicate with you, we will do so either because it forms part of your contract with us, we have your consent or where we have a legitimate interest to communicate with you.
We have outlined our primary communication activities below which tells you how we may communicate with you and how you can update your preferences.
Customer Service Communications
We may contact you or send communications to tell you about a service enhancement such as improvements to your facilities/services, a service change or to keep you informed of your current membership status. We won’t need your consent to communicate with you this way because we have assessed that it forms part of our agreement with you.
Customer communications may also include customer surveys, as we feel your feedback and experiences are important to help us improve the services we provide to you. We do not ask for your consent to contact you for these surveys as we have assessed that it is our legitimate interest to contact you in this case.
Customer Service Communications
If you supply us with your email or mobile phone number, we may use them to call or send you operational SMS/text or email messages, this will include former customers (for up to twelve months after leaving us). Examples of operations text messages include:
- Confirming an appointment, you have requested
- Emergency site or service change updates
- General service updates, offers and promotions
- Asking you to contact a named person/service provider
Prospective Customer Communications
We would like to send you occasional messages and to keep you informed about products or service information when you make an enquiry with us. We will keep your contact information for twelve months after which time we will delete your data from our systems if you have not become a member or have not been communicating back with us. We will always give you an opt-out route when communication with you. To make sure you keep receiving our latest offers beyond this time, email us at: enquiries@barrowleisure.co.uk or just speak to a member of Customer Services at reception when in the centre. Please put PRIVACY NOTICE in the title bar.
Former Customers
If you are a past member and have not opted out of marketing we would love to stay in touch and welcome you back. We will send you occasional messages and keep you information about our products, offers or service information. We will continue to share these updates with you for twelve months following the end of your membership, after which time we will stop this communication.
If you want to opt out at any time, or change your preferences please email us at: enquiries@barrowleisure.co.uk Please put PRIVACY NOTICE in the title bar.
Collecting Your Personal Data
Where we can, we will only collect and use personal information if we need it to deliver a service or meet a requirement.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial, Health and Ethnic Origin Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply for a membership
- Make a booking
- Create an account on our website
- Request marketing to be sent to you
- Enter a competition or promotion
- Complete a survey
- Provide feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- If your membership began prior to 1st December 2021, your Identity, Contact, Financial, Transaction and Profile data from Stockport Sports Trust trading as LIFE LEISURE, being the entity with whom you took out your gym membership, and which transferred your personal data to us as part of the transfer of the business, which was communicated to you by Stockport Sports Trust.
- Technical Data from analytics providers such as Google based outside the UK.
- Identity, Contact, Financial and Transaction Data from agencies such as the SLAC (Safeguarding and Looked-After Children) regime based inside the UK where you either sign up for one of our gym memberships via or are referred to our gyms by such agencies.
Use of Your Personal Data
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. In relation to the Special Category Data we collect, please find further details in the Appropriate Policy Document which follows this Privacy Notice in the table below.
Note that 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(s) we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new member of our gym or customer for a booking. |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To process and deliver your gym membership including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover any debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, 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 goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
|
To contact your next of kin or emergency contact in the event there is an emergency at facility. |
(a) Identity (b) Contact |
Necessary to comply with a legal obligation |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional Offers
We may use your Identity, Contact, Technical, Usage and Profile 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, services and offers may be relevant for you and to market to you.
You will receive marketing communications from us if you have requested the same in your marketing preferences in your online account and you have not opted out of receiving that marketing.
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We will never share your Special Category Data in such a way.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to communications relating to your gym membership.
Cookies
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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of Purpose
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above:
- Internal third parties as set out in the Glossary.
- External third parties as set out in the Glossary.
- Specific third parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets with. Alternatively, we may seek to acquire other businesses or merge with them. If 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 policy.
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.
International transfers
We do not transfer your personal data outside the UK.
Data security
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 legitimate business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
Retention of Personal Data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is the potential of litigation in respect of our relationship with you.
- 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, regulatory, tax, accounting or other requirements.
- You will be advised of any variation to our standard retention periods for different aspects of your personal data as appropriate.
- In some circumstances you can ask us to delete your data: see our legal rights below for further information.
- In some circumstances we will 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can:
- 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 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 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 (see below), 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 of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- 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;
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- 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.
- 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 our Data Controller as detailed above.
Fees
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 could refuse to comply with your request in these circumstances.
Our Requirements
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.
Response Times
We try to respond to all legitimate requests without undue delay and within one month. Occasionally it could 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.
Glossary BASIS of terms
LAWFUL
- 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
- Other group companies acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake management reporting tasks.
External Third Parties
- Service providers acting as processors based in the UK who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
In the event you do not make any payment due to us on its due date, we will share your personal data with our appointed debt recovery agency, Limited. We will only share the data necessary for the performance of their debt collection services (Identity, Contact, Financial and Transaction Data).
Changes to Privacy Policy and Your Personal Data
We keep our Privacy Policy under regular review we will advise you of any 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
This website 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 data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.