BACKGROUND:
Total Dojo understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
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Information About Us
Total Dojo Ltd.
Limited Company registered in England .
Registered address: 28 The Brunel Centre, Bletchley, Milton Keynes, MK2 2HE.
Main trading address: 28 The Brunel Centre, Bletchley, Milton Keynes, MK2 2HE.
Data Protection Officer: Stuart Harris.
Email address: info @ totaldojo.com.
Telephone number: 01908 632347.
Postal Address: 28 The Brunel Centre, Bletchley, Milton Keynes, MK2 2HE.
We are a member of WTBA, British Krav Maga Association.
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What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
This Privacy Notice applies to your use of Our Site and the data we collect when you become a member of Total Dojo. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
When you supply your details to Total Dojo they are stored and processed for 4 reasons:
- When you fill in your details on our site you are requesting that we contact you to go through details of our classes.
- We need to collect personal information about your health in order to provide you with the best possible service. Your requesting to join our classes and our agreement to provide those classes constitute a contract. You can of course refuse to provide the information but if you were to do that we would not be able to provide classes that are safe for you.
- We have a “Legitimate Interest” in collecting that information, because without it we couldn’t do our job effectively and safely.
- We also think that it is important that we can contact you about your membership and matters relating to your training. This again constitutes “Legitimate Interest”, but this time it is your “legitimate interest”.
- Provided we have your consent we may occasionally send you general information about classes, seminars or courses that we believe will benefit your training. We may also send out articles, advice or newsletters. You may withdraw this consent at any time – just let us know by any convenient method.
We will retain your records indefinitely in order that we can provide you with the best possible service should you wish to return to us at some future date.
Your records are stored on paper in a locked filling cabinet and the offices that are always locked out of working hours. These will be retained for a maximum of one month whether you choose to sign up or not. If you sign up they will be scanned and held electronically.
Electroncially using Infusionsoft and Nest Management. These providers have given us their assurance that they are fully compliant with the General Data Protection Regulations. Access to this data is password protected, and passwords are changed regularly.
On our office computers. They are password protected and the office is always locked out of work hours.
We will never share your data with anyone who does not need access without your written consent. Only the following people/agencies will have routine access to your data:
- Nest Management in order that they can manage your membership
- Our coaches in order that they can provide the best possible service to you
- Our reception staff because they organise your membership at Total Dojo.
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What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
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What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
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What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Name;
- Date of birth;
- Gender;
- Address;
- Email address;
- Telephone number;
- Job title;
- Profession;
- Payment information;
- Information about your preferences and interests;
- Health information as it pertains to your training.
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How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for or may be used for one of the following purposes:
- Providing and managing your account.
- Supplying our products or services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by clicking the link at the bottom of emails you receive from us or you can let us know by any convenient method.)
- Send you general information about classes, seminars or courses that we believe will benefit your training. We may also send out articles, advice or newsletters. You may withdraw this consent at any time – just let us know by any convenient method or by clicking the link at the bottom of our emails.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone and text message with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
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How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- we will retain your records indefinitely in order that we can provide you with the best possible service should you wish to return to us at some future date. You may ask us to delete this information at any time.
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How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR including:
- Only using supplies who are GDPR compliant.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- Ensuring passwords are used to access your data;
- Ensuring passwords are regularly changed;
- Only appropriate staff are able to access your data and only for relevant purposes.
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Do You Share My Personal Data?
We may sometimes contract with the following third parties to supply services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
- NEST Management, Nottingham. NEST manages payments and details of your membership on our behalf.
- Infusionsoft which is a software application that helps us manages our student database.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
We contract with third parties (as described above), and those third parties that are located outside of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If any personal data is transferred to a third party outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
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How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
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How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Stuart Harris:
Email address: info @totaldojo.com.
Telephone number: 01908 632347.
Postal Address: 28 The Brunel Centre, Bletchley, Milton Keynes, MK2 2HE.
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Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available by an update to this Privacy Notice.