Introduction

In this privacy policy, we have tried hard to let you know exactly how and why we collect and use you data, by using the UK ICO guidance alongside our own research.

We collect data we need in order to provide and market our services. We only keep it as long as is needed, and whilst we have it, we take care to look after it.

We never buy or sell any personal information. The platforms we use to store and use your information are platforms we trust and are all detailed below.

The rest of this page is the full privacy policy, created with the UK ICO guidance in mind. If you have any questions, please do get in touch!

Contents

1. Contact details

2. What information we collect, use, and why

3. Lawful bases and data protection rights

4. Where we get personal information from

5. How long we keep information

6. Who we share information with

7. Sharing information outside the UK

8. How to complain

1. Contact details

Email - [email protected]

2. What information we collect, use, and why

2.1 We collect or use the following information to provide the InReach Pilates teaching service.

Studio classes (in-person in Sheffield):

- Names and contact details

- Payment details (including card or bank information) - for payments/transfers and direct debits. This is so we can take payments for the InReach products and services you use.

- Health information (we ask for age range, and health conditions/injuries/medications) that may impact your safety in class.

- Records of class attendance - to monitor class sizes and check you are using your membership.

- Information relating to compliments or complaints

- Website user information (including user journeys and cookie tracking) - if you go on our website.

Online classes:

For online classes, it's the same as the studio classes above, except for:

- We don't collect health information

- We record online classes to put in the InReach video library. Note: only the instructor's camera and microphone are on during the class.

2.2 We collect or use the following information for service updates or marketing purposes:

- Names and contact details

- Recorded images, such as photos or videos (consent sought each time from anyone featured).

- Records of consent, where appropriate

- Purchase or viewing history (so we can see what people like or dislike so we can improve).

- Website and app user journey information (so we can see what people like or dislike so we can improve).

2.3 We collect or use the following personal information for dealing with queries, complaints or claims:

- Names and contact details

- Payment details

- Purchase or service history

- Health information and consent forms

3. Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases defined in UK GDPR. You can find out more about lawful bases on the ICO’s website: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website.

Your right of access - You have the right to ask us for copies of your personal information.

You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.

Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.

Your right to erasure - You have the right to ask us to delete your personal information.

Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.

Your right to object to processing - You have the right to object to the processing of your personal data.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.

Your right to withdraw consent – When we use consent as our lawful basis, you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

3.1 Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide our Pilates teaching services are:

Consent - We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Legitimate interests – We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

- Safe instruction - tailoring classes to suit all needs and abilities

- Business administration - accounting and sales

- Direct marketing - marketing to maintain business growth and viability

Contractual necessity - We use information to deliver the service our clients have signed up for. Specific examples include:

- Service delivery - The data we hold enables us to manage and communicate class timetables, monitor class sizes and plan lessons.

- Taking your payments - to process monthly memberships and other products sold.

Legal Obligation - Certain information must be kept by law, regardless of our specific business interests, for example:

- Insurance requirements: Many "claims occurring" insurance policies require teachers to retain client records for a specific period (often up to 7–10 years) to defend potential future legal claims.

- Taxation: Retaining financial records for audit and tax purposes as required by HMRC.

- Dealing with any queries or complaints

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

4. Where we get personal information from

We request and receive personal information directly from you, and we never buy or sell any client information.

5. Retaining and deleting personal data

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal data as follows:

- Contact data of contacts that have not purchased an InReach membership or other product will be kept for up to two years from the point that we last interacted with them.

- Contact data of all InReach's former clients will be kept for up to 6 years from the point that we last interacted with them. This is required by InReach's insurers for legal investigatory and legal defence reasons.

- Health-related data collected from InReach's in-person Sheffield studio clients will be kept for 7-10 years. This is required by InReach's insurers for legal defence reasons.

6. Who we share information with

InReach's Data Processors:

- SiteGround

This data processor does the following activities for us: SiteGround - IT & Cloud Services - Web Hosting & Email

- ExpertSpace

This data processor does the following activities for us: Marketing Tech - CRM & Automation

- Stripe

This data processor does the following activities for us: Finance Payment Processing

7. Sharing information outside the UK

Where necessary, we allow our data processors to transfer personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

7.1 Organisation name: SiteGround

Category of recipient: IT & Cloud Services - Web Hosting & Email

Country the personal information is sent to: the Netherlands and the USA

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge). This relates to data transfers to the Netherlands. This is normally limited to backup of data.

Addendum to the EU Standard Contractual Clauses (SCCs). This relates to information that must travel to the US. This is normally limited to system administrative & technical activities.

7.2 Organisation name: ExpertSpace

Category of recipient: Marketing Tech - CRM & Automation

Country the personal information is sent to: the USA

How the transfer complies with UK data protection law: The ExpertSpace platform uses secure US-based infrastructure to handle automated emails, spam filtering, and database management. This transfer is fully protected by the UK-US Data Bridge and official Addendum to the EU Standard Contractual Clauses (SCCs).

7.3 Organisation name: Stripe

Category of recipient: Finance - Payment Processing

Country the personal information is sent to: the USA

How the transfer complies with UK data protection law: We use Stripe to process payments securely. While Stripe stores most of its data for UK customers in Ireland, some information is sent to the USA to ensure your payments are safe and legitimate. Stripe is officially certified under the UK-US Data Bridge. They also use the official Addendum to the EU Standard Contractual Clauses (SCCs)

8. How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint