Privacy Policy
Effective date: October 23, 2024
1. Purpose
The purpose of this Privacy Policy is to inform Members how their information is being collected,
used and stored by Reform Fitness Headquarters. Reform Fitness Headquarters is dedicated to
protect the privacy and protection of data of Members and information disclosed to Reform
Fitness Headquarters.
Data is collected and processed in an appropriate and lawful manner and in accordance with
the GDPR (Regulation (EU) 2016/679) and Data Protection Act (Cap. 586 of the Laws of Malta).
2. Definitions
2.1. “Personal Data” means any information relating to an identified or identifiable natural
person (“Data Subject”). This can be a name, an identification number, location data, online
identifier, one or more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person. (“identifiers”).
2.2. “Data Subject” means identified or identifiable natural person. An identifiable natural
person is one who can be identified, directly or indirectly, in particular by reference to an
identifier. In this policy the Data Subject may also be referred to as the
“Member”/”You”/”Your”.
2.3. “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 policy the Data Controller is “Reform Fitness Headquarters” which may
also be referred to as “Reform Fitness Headquarters”/”We”/”Our”/”Us”.
2.4. “Processing” means any operation or set of operations which is performed on Personal
Data or on sets of Personal 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.
2.5. “Services” refers to the gym services provided by Reform Fitness Headquarters.
2.6. “Reform Fitness Headquarters” refers to the gym located at 131, Triq il-Wied, L-Imsida,
Malta. The gym is owned by Mr. Jeffrey Montebello.
2.7. “Member/s” refers to the person named in the Membership Form.
2.8. “Website” refers to reformfitnesshq.mt.
3. Which Personal Data is Collected
Reform Fitness Headquarters collects, uses, and stores different kinds of Personal Data about
You. This Personal Data collected, used and stored by Reform Fitness Headquarters includes
(but not limited to):
- Identity Data: first name, last name, and date of birth;
- Contact Data: postal address, contact number, and email address;
- Certain health information: this is processed for the Data Subject’s interest (when We
advise You on a fitness programme and/or in case of a medical emergency) and/or
where specific consent has been provided;
- Communications exchanged with Reform Fitness Headquarters and You.
By providing Reform Fitness Headquarters with this information, You consent to the collection,
storage and use of that information subject to the terms of this Privacy Policy.
If You withhold Your personal information, it may not be possible for Reform Fitness
Headquarters to interact or engage in business with You and/or to provide its Services to You.
This Personal Data is processed by Reform Fitness Headquarters at its operating offices and in
any other place where the parties involved in processing are located. This means that this
information may be transferred to and maintained on computers located outside the Data
Subject’s country. Personal Data is stored electronically as well as physically.
Reform Fitness Headquarters is committed to ensure that the personal information You provide
is secured hence, the necessary procedures are in place to safeguard and secure information,
to prevent unauthorized access or disclosure and to protect it from misuse, interference, and
loss.
4. How is Personal Data Collected
Reform Fitness Headquarters may collect Your Personal Data through:
- Our membership forms;
- b. Our Website;
- c. Documents and/or information provided by the Data Subjects themselves.
5. Why is Personal Data Collected
Reform Fitness Headquarters collects only the data that is necessary, and keeps the data up to
date and only for as long as it is needed. Personal Data is retained for as long as necessary to
fulfill the purpose it was collected for, including for the purpose of satisfying any accounting,
legal, or reporting requirements.
The appropriate retention period is determined by the nature, amount and sensitivity of the
Personal Data, the purposes for which the Personal Data is processed, whether Reform Fitness
Headquarters can achieve those purposes through other means, the potential risk of harm from
unauthorized use or disclosure and the applicable legal requirements.
Reform Fitness Headquarters may use this data for the following purposes:
- To provide and maintain its Services;
- To enter into an agreement with You and to be able to perform the agreement with You;
- To maintain customer record keeping;
- To communicate with You;
- To provide You with information about products and Services;
- For administrative or legal purposes;
- To comply with legal and regulatory requirements.
It is important that the Personal Data Reform Fitness Headquarters holds about You is accurate
and current. Please keep Us informed if Your Personal Data changes during Your relationship
with Us.
Reform Fitness Headquarters’ lawful basis for processing Personal Data fall within any one of
the following scenarios:
- Consent - when the Data Subject has given consent to the processing of their Personal
Data for one or more specific purposes;
- Contract - when processing is necessary for the performance of a contract to which the
Data Subject is a party or to take steps at the request of the Data Subject prior to
entering into a contract;
- Legal Obligation - when processing is necessary for compliance with a legal obligation to
which Reform Fitness Headquarters is subject to;
- Vital Interest - when processing is necessary in order to protect the vital interests of the
Data Subject or of another natural person;
- Public Task - when processing is necessary for the performance of a task carried out in
the public interest or in the exercise of official authority vested in the Data Controller;
- Legitimate Interest - when processing is necessary for the purposes of the legitimate interest pursued by the Data Controller or by a third-party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal Data, in particular where the Data Subject is a child.
6. Sharing and Disclosing of Personal Data
Reform Fitness Headquarters may disclose Your Personal Data to any employees and officers
of Reform Fitness Headquarters insofar as reasonably necessary for the purposes set out in this
Policy.
Reform Fitness Headquarters may share Your Personal Data with the following third-parties:
- Service Providers/Subcontractors/Third parties - Personal Data may be shared with
Service Providers/Subcontractors/Third party who assist in the running of the business;
- Authorities - Personal Data may be shared with authorities for the provision of certain
services;
- Law Enforcement - under certain circumstances, Reform Fitness Headquarters may be
required to disclose Personal Data of Data Subjects if required to do so by law or in
response to valid requirements by public authorities.
Reform Fitness Headquarters may disclose Your Personal Data in good faith believing that such
action is necessary to:
- Comply with a legal obligation;
- Protect and defend the rights or property of Reform Fitness Headquarters;
- Prevent or investigate possible wrongdoing in connection with the Service;
- Protect against legal liability.
7. Your Data Protection Rights
All Data Subjects have certain rights in relation to the processing of their Personal Data. Data
Subjects may exercise these rights under certain circumstances.
Data Subjects have the right to:
- Request information about whether Reform Fitness Headquarters hold personal information about You and what information is being held and/or used and why it is being held and/or used.
- Request access to the Personal Data being held by Reform Fitness Headquarters about You. You can request to have a copy of the Personal Data Reform Fitness Headquarters hold about You as well as to be provided with supplemental information about the processing on Your Personal Data.
- Request correction to Reform Fitness Headquarters to rectify any inaccuracies where the Personal Data being held on You is inaccurate or incomplete.
- Request erasure of Your Personal Data. In certain circumstances this may not be possible.
- Objecting to certain processing of Your Personal Data.
- Request restriction of processing of Your Personal Data in certain ways.
- Request the transfer of Your Personal Data to You or to another party.
- Withdraw consent at any time. If You have given consent to Reform Fitness Headquarters to collect, process, and transfer Your Personal Data for a specific purpose, You can withdraw that consent at any time. Once Reform Fitness Headquarters receives Your withdrawal of consent, Reform Fitness Headquarters will stop processing Your information for the purpose You initially agreed to, unless Reform Fitness Headquarters
has another legitimate basis for doing so in law.
Not all of these rights apply in all circumstances. For Data Subjects to exercise any of these
rights, they are to submit a request in writing to info@reformfitnesshq.mt
You have the right to make a complaint to the Information and Data Protection Commissioner
(“IDPC”) as the supervisory authority for data protection issues. However, it would be
appreciated if any complaints are dealt with Reform Fitness Headquarters prior to approaching
IDPC.
8. Direct Marketing
Reform Fitness Headquarters may use Your Personal Data to deliver direct marketing
communications to You about their products and services and any other products or services
You might be interested in. You may notify Reform Fitness Headquarters if You do not want to
receive these communications. Once Reform Fitness Headquarters receives this notification, it
will comply with Your request and will not use Your Personal Data for such purposes.
9. Website Usage
Reform Fitness Headquarters operates the reformfitnesshq.mt Website. This Privacy Policy also
informs You regarding the collection, use, and disclosure of Personal Data when You use the
Website and the choices You have associated with that data.
We use Your data to provide and improve the Website. By using the Website, You agree to the
collection and use of information in accordance with this Privacy Policy.
9.1. Types of Data Collected
9.1.1. Personal Data
While using the Website, We may ask You to provide Us with certain personally identifiable
information that can be used to contact or identify You (“Personal Data”). Personally identifiable
information may include, but not limited to:
- First name and last name;
- Phone number;
- Cookies and Usage Data.
9.1.2. Usage Data
We may also collect information on how the Website is accessed and used (“Usage Data”). This
Usage Data may include information such as Your computer’s Internet Protocol address (e.g. IP
address), browser type, browser version, the pages of Our Website that You visit, the time and
date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic
data.
9.1.3. Tracking and Cookies Data
We may use cookies and similar tracking technologies to track the activity on Our Website and
hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier.
Cookies are sent to Your browser from a website and stored on Your device. Tracking
technologies also used are beacons, tags, and scripts to collect and track information and to
improve and analyze Our Website
You can instruct Your browser to refuse all cookies or to indicate when a cookie is being sent.
However, if You do not accept cookies, You may not be able to use some portions of Our
Website.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate Our Website.
- Preference Cookies. We use Preference Cookies to remember Your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
9.2. Use of Data
Reform Fitness Headquarters uses the collected data for various purposes:
- To provide and maintain Our Website;
- To notify You about changes to Our Website;
- To allow You to participate in interactive features of Our Website when you choose to do so;
- To provide customer care and support;
- To provide analysis or valuable information so that We can improve Our Website;
- To monitor the usage of Our Website;
- To detect, prevent and address technical issues.
9.3. Transfer of Data
Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
If You are located outside Malta and choose to provide information to Us, please note that We transfer the data, including Personal Data, to Malta and process it there.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
Reform Fitness Headquarters will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
9.4. Disclosure of Data
9.4.1. Legal Requirements
Reform Fitness Headquarters may disclose Your Personal Data in the good faith belief that such
action is necessary to:
- To comply with a legal obligation;
- To protect and defend the rights or property of Reform Fitness Headquarters;
- To prevent or investigate possible wrongdoing in connection with the Website;
- To protect the personal safety of users of the Website or the public;
- To protect against legal liability.
9.5. Security of Data
The security of Your data is important to Us, but remember that no method of transmission over the internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
9.6. Service Providers
We may employ third party companies and individuals to facilitate Our Website (“Service
Providers”), to provide the Website on our behalf, to perform Website-related services or to
assist Us in analyzing how Our Website is used.
These third parties have access to Your Personal Data only to perform these tasks on Our
behalf and are obligated not to disclose or use it for any other purpose.
9.7. Links to Other Sites
Our Website may contain links to other sites that are not operated by Us. If You click on a third
party link, You will be directed to that third party’s site. We strongly advise You to review the
Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or
practices of any third party sites or services.
9.8. Children’s Privacy
Our Website does not address anyone under the age of eighteen (18) (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of
eighteen (18). If You are a parent or guardian and You are aware that Your children have
provided Us with Personal Data, please contact us. If We become aware that We have collected
Personal Data from children without verification of parental consent, We take steps to remove
that information from Our servers.
10. Changes to Data Protection Policy
This Policy may be changed from time to time. We will notify you of any changes by posting the
new Privacy Policy on the Website and by emailing all Members.
If You have any questions about this Privacy Policy, please contact Us:
After reading the Privacy Policy (also available on Reform Fitness Headquarters’ website), the
undersigned:
Minor’s name:
_____________________________
Date of Birth:
_____________________________
Address:
_____________________________
Contact number:
_____________________________
Email Address:
_____________________________
Name of Parent/Guardian #1:
_____________________________
Relationship to Minor:
_____________________________
Contact number:
_____________________________
Email address:
_____________________________
Name of Parent/Guardian #2:
_____________________________
Relationship to Minor:
_____________________________
Contact number:
_____________________________
Email address:
_____________________________
Declare that we have read the Privacy Policy and unconditionally accept all its contents. By
signing this form we consent to the collection, use and processing of the Minor’s Personal Data
as described in the Privacy Policy.
Parent/Guardian #1❐ I consent❐ I do not consent
Parent/Guardian #2❐ I consent❐ I do not consent
To the Minor’s Personal Data being processed by Reform Fitness Headquarters for marketing
purposes as stated in Point 8 of the Privacy Policy.
Date:
_____________________________
Signature Parent/Guardian #1:
_____________________________
Name:
_____________________________
Signature Parent/Guardian #2:
_____________________________
Name:
_____________________________