Privacy Policy

CLUB TREIGN GDPR and PRIVACY POLICY

 

Introduction

 

CLUB TREIGN (“us”, “we”, or “our”) is committed to protecting, respecting, and safeguarding its users’ privacy. This Policy outlines the types of information we may collect, the manner in which data will be utilised, stored,processed, and disclosed and how long such data will be collected, used and maintained for: CLUBTREIGN Website engagement including but not limited to navigation data, interaction data, marketing data and profiling data and data linked to sales made through online shopping and the corresponding pre and post-sales support activities ii. Attendance/engagement at physical events and consuming our goods and/or iii. Any other interaction requiring data collection and processing shall be retained to ensure your data is safe.

We take responsibility for safeguarding the security of users’/ engagers’/ customers’ (“you” and “your/s”) data,providing you with precise information on its usage, and ensuring that your data rights are upheld.

This Privacy Policy is regulated by European Regulation no. 2016/679, the General Data Protection Regulation (the “GDPR”) and any other relevant privacy legislation (collectively referred to as the “Privacy Laws”). ThesePrivacy Laws ensure that the processing of personal data is conducted in accordance with fundamental rights and freedoms, as well as with due regard for the dignity of the data subject.

Please also read the General Terms and Conditions since they contain essential information on our Club.

Scope

This policy applies to all staff, contractors, and third-party vendors who process personal data on behalf of CLUB TREIGN. It covers all gym operations, including membership registration, class bookings, payments, and marketing communications.

Definitions as per Article 4 of the EU GDPR

 

• ‘Personal data means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’
• ‘Processing means any operation or set of operations which is performed on personal data or on sets ofpersonal data, whether or not by automated means, such as collection, recording, organization,structuring, storage, adaptation or alteration, retrieval,

 

consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.’

• ‘Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, in this case being BORCAM Limited , having its registered address at The Penthouse, Sant’antnin Block A, Triq San Anton Abbati, 123
• ‘Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller’
• ‘Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, including both processors and controllers’
• ‘Legal basis’ means a lawful ground for data processing under the GDPR or similar and applicable laws, rules, principles and/or regulations in this regard.
• ‘Consent of the data subject means any freely given, specific, informed and unambiguous indication of thedata subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreementto the processing of personal data relating to him or her;’
• third party’ means a natural or legal person, public authority, agency or body other than the data subject,controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

Personal Data

Why do we process it, and based on what Legal Basis?

 

We process different kinds of information, which may be collected from you when you visit the CLUB TREIGN Website. The data which is collected with your Consent includes the following types of data:

• Personal data related to browsing is processed both for the purpose of allowing the CLUB TREIGNWebsite to function properly, to manage the sending of messages relating to purchases, and to enable you to manage contractual relationships with third parties related to sales activities, and for marketing This can be further explored when referring to our cookie policy.
• Personal data which is provided by you (your name and surname, email address, other contact details such as telephone number, password when registering an account with the CLUB TREIGN Website, shipping and billing address, date of birth, data related to any specific request addressed to customer care and/or provided via telephone call or email and processed by CLUB TREIGN and or the Company to respond to user request and ensure the services are offered. In the instance that phone calls are to be made, it should benoted that upon explicit consent from you, the call may be recorded to allow us to         monitor            services                            offered   to                    users/ Kindly be aware that registering and accessing via a social media profile will entail sharing specific personal information(such as first name, last name, email, and any other data associated with the user’s profile on the socialnetwork). This necessitates the

 

user’s explicit permission before logging in, enabling the execution of activities using the user account.Occasionally, social networks may request feedback and information regarding the login process. For further details, please consult the pertinent privacy documentation the social network provides.

• Personal data provided by you in relation to purchase data, individual details, delivery

and contact details (including but not limited to capturing images of parcels and delivery location toprovide proof of delivery), payment preferences and data related to pre and post-sales requests as part of online purchase of products from our e-store (as well as all other pertinent interactions for activitiesnecessary for the sale and other pre and post-sale activities and assistance and related services including those provided at CLUB TREIGN as well as any other activities pertaining to return rights, statutory and contractual guarantees and product assistance;

•  

CLUB TREIGN

Personal data which is processed for marketing purposes, meaning information which is processed for information and updates on products such as purchase data, personal particulars, and contact details, encompassing the dissemination ofinformation and updates regarding products, sales, promotional campaigns, events, and other initiatives promoted by CLUB TREIGN and/or the Company. This dissemination occurs through traditional means such as postal mail andtelephone calls, as well as via telematics, including newsletters, emails, text messages, MMS, and smart messages. Additionally, these commercial communications may entail reminders for pending purchases and/or actions on theCLUB TREIGN Website and related long with endeavours to assess customer satisfaction and the quality of service provided by Company.GN and/or the

• Personal data related to user purchases and user preferences are processed to analyse habits, preferences, This analysis seeks to tailor the services and needs to better align with the tastes and needs ofusers and/or customers, ensuring that everyone receives offerings and experiences that are most pertinent to their preferences and needs.
• Personal data, including identification details, payment information, location data, and purchase records,processed to prevent and mitigate fraudulent or unlawful activities in adherence to prevailing regulations, contractual agreements, and principles of fairness and good faith. Such processing may involve collaboration with third-party entities, including specialised firms in online fraud detection, public authorities, investigative bodies, law enforcement agencies, and judicial authorities.
• Other Information You Provide: we collect other information you may provide, such as when you participate in events or surveys or provide us with information to establish your age or identity (collectively, “Other Information You Provide”).
• Log Data: Information your browser or device automatically sends when using our Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our Services.
• Device Information: includes the name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on your device type and its settings.

 

• Cookies and Similar Technologies: the CLUB TREIGN Website employ cookies and analogous technologies like pixels and beacons to gather data. These technologies are commonly utilised to enable site functionality, enhance efficiency, and furnish insights

to site owners, such as your language preferences, sign-in details, or usage of site services and applications. Cookies are additionally employed to display products and services tailored to user preferences, and to enable third-party partners to deliver pertinent advertising. Comprehensive details on cookies and how to adjust your preferences can be accessed in our Cookie Notice.

Such information, as outlined above, may be collected when you:

• contact us in any manner whatsoever,
•  

Website,

visit/browse the CLUB TREIGN

• place an order, attempt to place an order and/or receive a produce demo,
• interact by visiting our social media pages (including but not limited to Instagram, Google, Facebook, LinkedIn, Pinterest X, etc.)
• Provide your personal data to third party sources, including our service providers, or
• interact with us or our personnel, agents or representatives in

The Purpose for Processing and Legal Basis for the Processing

 

Where applicable under the GDPR or similar laws, the legal basis for our collection and use of your personal data may include any of the following:

Processing reference as per paragraph above	Purpose/Activity	Legal Basis
(a)	Use of Cookies	Allowing   the   CLUB TREIGN Website tofunction properly (as per the legitimate interest where permitted by Privacy Laws) Promotional activities and analysis, incorporating local storage information (subject to Consent).
(b)	Account registration and access and use of personal account and customer care support	Providing the user/customer with the facility to create an account and other pertinent options

 

		Creating access to a personal account using a social- network log-in Allowing CLUB TREIGN AND/OR THE COMPANY t o provide users/customers customer care assistance Registration of telephone calls the legal basis of which being consent (contractual relation & provision of service).
(c)	Retail and pre and after sales service	Ensuring compliance with legal        and        contractual obligations of the retailer.
(d)	Promotion and distribution of commercial messages (including  reminders  for abandoned carts)	Consent is the legal basis here.
(e)	Analytics    and    preference generated content tailored to the user/customer	Consent is the legal basis here.
(f)	Anti-Fraud interaction and activity	Safeguarding                 rights (legitimate interest where catered for by PrivacyLaws) as  well  as  obligations emanating from the law.
(g)	Measuring participation and outcomes/feedback  through surveys/ events	Legitimate interest to prevent and prosecute any fraudulent activity
(h)	Log Data enables us to identify our customers/users, this may be beneficial especially in the instance that fraud/disguise or any other legal issue arises.	Legitimate interest and consent are the legal bases here.
(i)	Device Information is useful also in identifying the user should any legal issue arise and in other user assessments	Legitimate interest and consent are the legal bases here.

 

(j)	Improvement                      of user/customer experience through the use of cookies, making the CLUBTREIGN Website work more efficiently	Consent is the Legal basis here.

 Legal Bases Explained

 

• Performance of a contract. We process your personal data as necessary to perform our obligations under any agreement/contract with you, such as providing the CLUB TREIGN Website and services and/or completing transactions.
• We may ask for your consent to use your personal data, including if we need your consent to engage incertain marketing activities. If we obtain your consent as a legal basis for processing, you may withdraw your consent at any time.
• Legitimate We have a legitimate interest in using your personal data for our business purposes,including operating, improving, and marketing our business, CLUB TREIGN Website, and services, as well as protecting our services from abuse, fraud, or security risks.
• Compliance with a legal obligation. We may need to use your personal data to comply with applicable law orwhen we protect our or our affiliates’, users’, or third parties’ rights, safety, and property.

Sources of Personal Data

 

The data collected is derived from you, the user (through the steps as outlined above); however, the following exceptions apply:

• Data derived from navigation (i.e. cookies)
• Data collected through social media
• Data collected and processed to prevent fraud and malfeasance (as per (f)) on the

CLUB TREIGN Website.

Your Rights

 

As a user you possess several rights in relation to the use of your Personal Data, which rights are dependent on specific circumstances which may enable you to exercise one or more or all of the following rights:

1. The right to obtain confirmation as to the existence of your personal data and whether or not it is beingprocessed, as well as obtaining a copy in a comprehensible format of the respective information which is processed.

 

1. The right to be informed of the source of the personal data, the purposes and methods of processing, the logic involved in electronic processing, and the identification details of the controller and data processors.

• The right to know the individuals or categories of individuals who may access or become aware of yourPersonal Data, such as data processors or agents acting as data supervisors or processors.

1. The right to access to and/or create duplicates of the personal data retained, (ii) receive the personal data concerning you, in a structured, commonly used and machine-readable format

1. The right to data portability allows you to request the transfer of their data to another controller, without hindrance from our end

1. The right to request updates, corrections, additions, deletions, anonymization, or blocking ofpersonal data that has been processed unlawfully, including data no longer necessary for its original collection or subsequent processing. Additionally, the right to receive notification regarding these actions and their contents, unless such disclosure is impossible or Where the dataprocessing is based on your consent, refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time;

• The right to institute legal action and seek remedy with pertinence to any potential breach of your rights regarding the processing of your personal data, as well as to lodge complaints before the competent data protection regulators.

• The right to request restriction of processing of their personal

1. The right to object to:

1. Object to our processing of your Personal Data for direct marketing at any
2. Object to the manner in which we process your Personal Data when such processing is solely based on legitimate interest, which is outright

1. The right to withdraw consent at any point in

1. The right related to automated decision-making, including profiling. We utilise profiling to provideyou with personalised and pertinent Profiling involves the computerised analysis of personal data to assess specific aspects of an individual, such as their interest in particular designers orproducts. We refrain from employing automated decision-making processes that could adversely affectyou.

 

However, in the event that we do, you have the right to request human intervention, express your perspective, receive an explanation of the decision, and contest it. To do so, refer to clause/point 9, and contact us to raise your concerns, have us address your rights, and ensure that they are seen to.

Disclosure of Personal Information

Your information may be shared with employees, contractors, agents, suppliers, or affiliates, as necessaryand per this policy. CLUB TREIGN and/or the Company ensures that any third parties handle your information in compliance with data protection laws.

We may also disclose information if required by law, court order, or legal request. When disclosing information tothird parties, we will take reasonable steps to protect your privacy.

Storage and Security

We are committed to securing personal information with physical, electronic, and administrative safeguards to prevent unauthorized access, loss, or disclosure.

Direct Marketing

CLUB TREIGN may send you direct marketing communications about our products, services, and any otherofferings that may interest you. If you prefer not to receive these communications, simply let us know, and we will honour your request, ceasing the use of your personal information for this purpose.

In line with this Privacy Policy, we will only use or share your personal information for direct marketing if:

1.     We collected the information from you directly:

• It is reasonable to expect we would use your information for direct
• We provide an easy way for you to opt-out of receiving these
• You have not previously opted out of receiving such

2.     We collected the information from a third party:

• You have provided consent, or obtaining consent is
• We provide a straightforward way for you to opt-
• You have not already opted out of receiving these To opt-out, you may:

• Click the “unsubscribe” link in our
• Contact us directly using the details

Cross-border Data Transfers

If personal information is transferred internationally, CLUB TREIGN will ensure that such transfers complywith GDPR requirements and that adequate safeguards are in place.

Use of Cookies and Website Data

We may collect non-personal information through cookies on the CLUB TREIGN Website to improve the user experience. Cookies help us monitor site usage and personalize content. You can disable cookies inyour browser settings, but this may limit some site functionalities.

 

CLUB TREIGN’s Website may link to third-party sites, which have their privacy policies. We recommendreviewing these policies, as CLUB TREIGN is not responsible for third-party practices.

Data Breaches

In the event of a data breach likely to result in harm, we will notify affected individuals and the relevant dataprotection authority promptly. If you suspect a data breach, please contact us immediately.

Changes to Privacy Policy

CLUB TREIGN and/or the Company reserves the right to modify this policy. Any updates will be posted onour website, and significant changes will be communicated directly.

Contact Details

For questions, requests, or complaints related to this policy, please reach out to:

The Management at CLUB Treign Email: [email protected] Mobile Number: +356 79717011

Approval and Acknowledgement

 

I, the undersigned, acknowledge that I have read and understood the Terms and Conditions and GDPR Compliance Policy and agree to adhere to all the requirements.