FLOAT HUB have ensured all current business processes and procedures are in line with the GDPR rights and principles and any new processes involving personal information that are implemented will be thoroughly reviewed through a Data Protection Impact Assessment (DPIA) prior to proceeding. All company data protection procedures and policies are reviewed on an annual basis to ensure compliance.
2. Information Collected or Received
3. How and why FLOAT HUB use your Personal Information
4. Communication from FLOAT HUB
5. Sharing your Information
6. Keeping your Information Secure
7. FLOAT HUB Retention Policies
8. Staying in Control – Your Rights
FLOAT HUB are based in the UK, however process personal information both within the UK/EEA and outside. Any personal information held by either FLOAT HUB or the designated third parties comply with relevant EU GDPR legislations. Third parties which process personal information outside the UK/EEA on behalf of FLOAT HUB have a recognised equivalent legislation in place such as the US Privacy Shield, or a set of GDPR compliant Binding Corporate Rules (BCR).
- INFORMATION COLLECTED OR RECEIVED
FLOAT HUB collect personal information from Site users, Staff and Suppliers/Sub-contractors to run their business and provide you with their services. This personal information may include the following: name, date of birth, email address, contact number, company name, bank details and credit card details.
FLOAT HUB also collect the following information:
Sensitive Information: The term “sensitive information” in this context refers to information related to your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership. Whilst FLOAT HUB do not generally collect sensitive information unless it is volunteered by you.
Photographs and Identification: In the interests of security and the prevention of crime, FLOAT HUB may take a digital photograph of each Member or guest. Each Member or guest may also be required to provide a form of identification for verification and security purposes.
Audio-Video: FLOAT HUB use CCTV in all float centres for health and security reasons. If you have any queries in relation to the use of CCTV operating in and around the sites please contact mypersonaldata@Floathub.co.uk. FLOAT HUB have a business legitimate interest to monitor service standards in Site. FLOAT HUB utilise mystery shopper services in which Site users may appear in the background however are never directly filmed. This footage is only used for the purposes of internal monitoring and training of FLOAT HUB staff.
Digital: When visiting FLOAT HUB website(s), your personal information may be collected, stored and used such as traffic data, location data, web logs, communication data and resources that you access, as well as other personal information detailed above. If you connect to FLOAT HUB or register for a tour of FLOAT HUB using an external third-party application, such as Facebook, Instagram, or Twitter, these websites will have their own privacy statement which FLOAT HUB suggest that you read before giving them your personal information. Connecting to FLOAT HUB via a third-party application or service is optional and at your own discretion.
FLOAT HUB will only collect the relevant information required for the purposes of processing and will not use this information for any other purpose without obtaining consent.
- HOW AND WHY FLOAT HUB USE YOUR PERSONAL INFORMATION
The information in the above, section 2, may be used for the following purposes:
– To carry out FLOAT HUB’s obligations arising from any contractual agreement;
– To contact you about non-contract aspects of your Membership, such as a change in usage patterns;
– To provide you with the information on products or services you request;
– To process payments and maintain accounts and records;
– To prevent crime, fraud and aid in the prosecution of offenders;
– To maintain Membership records;
– To improve the FLOAT HUB platform;
– To prevent or detect abuses of the FLOAT HUB website;
– To create business performance statistics and analysis;
– To enable third parties to carry out technical, logistical, research or other functions on behalf of FLOAT HUB;
– To send you newsletters and promotions, prize draws, and competitions;
– To conduct surveys and request feedback;
– To notify you about urgent comms such as a sudden closure of a Site;
– To process your job application if you apply for employment at FLOAT HUB;
– To collect information about your tastes and preferences, both when you tell us and by analysis of customer traffic, including using “cookies”;
– To read and respond to comments made regarding FLOAT HUB services.
- COMMUNCATION FROM FLOAT HUB
On occasion, FLOAT HUB may need to contact you. Primarily, these messages are delivered by email, text or phone, and every individual’s record is required to keep a valid email address and contact number on file to receive these messages.
In response to enquiries and when communicating with Members, FLOAT HUB believe that the content is relevant, valuable, interesting and beneficial to you. FLOAT HUB also believe that you would reasonably expect to receive the type of content that is sent to you as part of your relationship with FLOAT HUB. Therefore, FLOAT HUB’s current assessment is that the communication you receive is covered by the lawful basis for processing of ‘Legitimate Interest’ under recital 47 within the GPDR. For all communication sent under the basis of legitimate interest, opt-out options are provided and detailed later within this section.
For all communication where consent is the only legal basis, preferences will be collected in advance.
FLOAT HUB recognise that you value having control over your own information, so FLOAT HUB gives you the choice of editing your communication preferences if you disagree with the above. For FLOAT HUB Members and Ex Members you may update these preferences by logging into the Members area through the login page of the website, (www.FloatHub.co.uk ). Alternatively you may email mypersonaldata@Floathub.co.uk with your request.
Please note the following messages from FLOAT HUB fall into the category of compulsory communication and therefore no opt-out options are available:
– Urgent Communication (such as, unplanned closure of all or part of a location, reduced services, a change of opening times)
– Automatic Booking communication (such as, booking confirmation, waiting list movement, cancellations)
– Contract and Subscription related communication (such as, welcome emails, outstanding arrears, upcoming renewals, communication with the FLOAT HUB Member Services Support Team).
You may receive communication from FLOAT HUB via the following communication systems, all of which offer an opt-out service. Please note you must opt-out of each individual communication system should you wish to exercise that right;
Direct email communication from FLOAT HUB staff via Gmail: To opt out you can do either of the following, log into the members area on the website to update your communication preferences within the My Profile section. You can also request this specifically to mypersonaldata@Floathub.co.uk
Texts via CM.com: To opt-out please follow the instructions within the text you receive.
Email communication via Mailchimp: To opt-out please use the unsubscribe link within the email you receive.
- SHARING YOUR INFORMATION
Enquiries through FLOAT HUB website(s): FLOAT HUB capture data through FLOAT HUB website(s) hosted by third parties (Mailchimp, Gleam.io). FLOAT HUB manage member services requests via their website through a third party (Float Helm). This process is in place in order for our member services team to respond to and action any query that is submitted through this avenue on the FLOAT HUB website.
Membership System and Bookings App: In order for FLOAT HUB to process and manage existing and ex Memberships as well as Prospective Members, they use a third party (Float Helm booking software) to provide the membership management system. Bookings can be processed directly via the website hosted by Float Helm.
Payment Collection: FLOAT HUB use third parties (PaySafe, Stripe) for payment collection whether that be upfront payment for membership, monthly direct debit payment for membership, one-off POS payments at reception, debt collection, or membership subscription.
Arrears Collection: FLOAT HUB reserves the right to forward a members information to a third party debt collection agency in the event of non-payment of fees when due. Further information on this process can be found in FLOAT HUB Terms and Conditions.
Paperwork Destruction: FLOAT HUB schedule regular collections of paperwork from a third party company who securely and confidentially shred this paperwork off site, on behalf of FLOAT HUB.
FLOAT HUB may share Member details with any organisation that acquires a Site to which the Member has their Membership.
- KEEPING YOUR INFORMATION SECURE
In regards to environmental and physical security, all FLOAT HUB employees receive full training upon commencement on employment and subsequently on an annual basis thereafter. Further to this, daily, weekly and monthly audits are completed.
- FLOAT HUB RETENTION POLICIES
FLOAT HUB have set company retention policies in place and these timescales are set in accordance with any applicable legislation and/or for any agreed legitimate reasons. Where none exists, then FLOAT HUB will keep your information for the duration of any Contract that you have entered into with FLOAT HUB, and then for a period of 7 years after, at which time all the personal information will be pseudonymised.
After that 7 year duration, FLOAT HUB will retain and use your pseudonymised information for the purpose of business statistics and analysis. FLOAT HUB can retract this pseudonymisation to the extent necessary to comply with any legal obligations or to resolve disputes
- STAYING IN CONTROL – YOUR RIGHTS
FLOAT HUB understand the importance of data subjects remaining in control of their personal data. FLOAT HUB acknowledge the following rights you have under the GDPR, what they mean and how you can exercise them.
The Right to be Informed
The Right of Access
You have the right to access information that FLOAT HUB hold about you. If you wish to receive a copy of the information that FLOAT HUB hold, please submit a Subject Access Request form (SAR) which you can request from mypersonaldata@Floathub.co.uk. Once FLOAT HUB have received your form, they will provide a response within one month. If your request is unusually complex and likely to take longer than a month, you will be informed as soon as possible to tell you how long it’s likely to take.
Please note that whilst in most cases FLOAT HUB will be happy to provide you with copies of the information you request, FLOAT HUB nevertheless reserve the right, in accordance with section 8(2) of the DPA, not to provide you with copies of information requested if to do so would take “disproportionate effort”, or in accordance with Article 12 of the GDPR to charge a fee or refuse the request if it is considered to be “manifestly unfounded or excessive”.
The Right to Rectification, Restrict Processing, Erasure, and to Object
You can ask FLOAT HUB at any time to change, amend or pseudonymise the information that FLOAT HUB hold about you or restrict ways in which your data may be processed. You can update FLOAT HUB with amendments of personal information by submitting a request via mypersonaldata@FloatHub.co.uk
To pseudonymise the information, or object/request restriction of processing then please email mypersonaldata@FloatHub.co.uk
FLOAT HUB will aim to respond to any request as soon as possible, but no later than within 1 month since receipt of request. Please note that the right to erasure is not absolute and only applies in certain circumstances. For further information on this please visit the following link to the ICO’s website, https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
Right to Data Portability
You have the right to request that your personal data is transferred by FLOAT HUB to another organisation (this is called “data portability”). Please contact us at mypersonaldata@Floathub.co.uk with the details of what you would like for FLOAT HUB to do and FLOAT HUB will endeavour to comply with your request. It may not be technically feasible, but FLOAT HUB will work with you to try and find a possible solution.
Right to Prevent Automated Decision Making
You have a right to ask FLOAT HUB to stop any automated decision making. FLOAT HUB do not intentionally carry out such activities, but if you do have any questions or concerns FLOAT HUB would be happy to discuss them with you so please email any concerns or queries to mypersonaldata@Floathub.co.uk
If you have any questions, comments or concerns about data privacy at FLOAT HUB, please e-mail thorough a description to mypersonaldata@Floathub.co.uk and FLOAT HUB will endeavour to resolve the issue for you. Alternatively should you wish to escalate any concerns or questions, rather than contact FLOAT HUB directly, please contact the supervisory authority The Information Commissioner’s Office (ICO). For more information please visit the ICO’s website https://ico.org.uk/.