In this privacy policy, “Victoryontheline” means Sparring Partners Ltd, whose registered office is at Unit 7, 38 New Kent Road, London, SE1 6TJ. Victoryontheline believe in transparency, and are committed to being upfront about privacy practices, including how your personal information is treated. Victoryontheline have undertaken an extensive exercise to ensure ongoing compliance with the European Union General Data Protection Regulation (EU GPDR). Victoryontheline 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.

This Privacy Policy sets out the data processing practices carried out through the use of the Internet and any other electronic communication networks by Victoryontheline, as well as describing the types of personal information that Victoryontheline may collect about you and the purposes for which this information is used.

1. Accepting the Privacy Policy

2. Information Collected or Received

3. How and why Victoryontheline use your Personal Information

4. Communication from Victoryontheline

5. Sharing your Information

6. Keeping your Information Secure

7. Victoryontheline Retention Policies

8. Staying in Control – Your Rights

9. Privacy Policy Changes

10. Contact

1. Accepting the Privacy Policy

Victoryontheline need to process your personal information to run their business and provide you with their services. Upon visiting Victoryontheline in Club, contacting Victoryontheline by the phone, or visiting Victoryontheline website(s), you are accepting and consenting to the practices described in this Privacy Policy.

Victoryontheline are based in the UK, however process personal information both within the UK/EEA and outside. Any personal information held by either Victoryontheline or the designated third parties comply with relevant EU GDPR legislations. Third parties which process personal information outside the UK/EEA on behalf of Victoryontheline have a recognised equivalent legislation in place such as the US Privacy Shield, or a set of GDPR compliant Binding Corporate Rules (BCR).

2. Information Collected or Received

Victoryontheline collect and/or receive personal information from Club and Online 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.

Victoryontheline also collect and have access to 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 Victoryontheline do not generally collect sensitive information unless it is volunteered by you, Victoryontheline do have a legal requirement to collect health data for the purpose of recording your self-assessment declaring readiness for physical exercise.

Photographs and Identification: In the interests of security and the prevention of crime, Victoryontheline 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: Victoryontheline use CCTV in all Clubs for health and security reasons. If you have any queries in relation to the use of CCTV operating in and around the clubs please contact mypersonaldata@Victoryontheline.co.uk. Victoryontheline have a business legitimate interest to monitor service standards in Club. Victoryontheline utilise mystery shopper services in which Club 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 Victoryontheline staff.

Digital: When visiting Victoryontheline website(s) or Victoryontheline Partner websites/apps (Wellhub/Classpass/Archon), 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 Victoryontheline or register for a tour of Victoryontheline using an external third-party application, such as (but not limited to) Facebook, Instagram, Twitter, Archon, Eventbrite, these websites will have their own privacy statement which Victoryontheline suggest that you read before giving them your personal information. Connecting to Victoryontheline via a third-party application or service is optional and at your own discretion.

Victoryontheline 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.

3. How and why Victoryontheline use your Personal Information

The information in the above, section 2, may be used for the following purposes:

– To carry out To carry out Victoryontheline’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 Victoryontheline platform;

– To prevent or detect abuses of the Victoryontheline website;

– To create business performance statistics and analysis;

– To enable third parties to carry out technical, logistical, research or other functions on behalf of Victoryontheline;

– 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 Club;

– To notify you about changes to Victoryontheline Services, Terms and Conditions, Privacy Policy and Club rules;

– To process your job application if you apply for employment at Victoryontheline;

– 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 Victoryontheline services.

Other than as set out in this Privacy Policy Victoryontheline will not use your personal information for any other purpose without your consent, unless required to do so by law.

4. Communcation from Victoryontheline

On occasion, Victoryontheline 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, Victoryontheline believe that the content is relevant, valuable, interesting and beneficial to you. Victoryontheline also believe that you would reasonably expect to receive the type of content that is sent to you as part of your relationship with Victoryontheline. Therefore, Victoryontheline’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.

Victoryontheline recognise that you value having control over your own information, so Victoryontheline gives you the choice of editing your communication preferences if you disagree with the above. For Victoryontheline Members and Ex Members you may update these preferences by logging into the Members area through the login page of the website, (www.victoryontheline.blog). Alternatively you may email mypersonaldata@Victoryontheline.co.uk with your request.

Please note the following messages from Victoryontheline 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 Club, reduced services, a change of opening times)

– Automatic Class 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 Victoryontheline Member Services Support Team).

You may receive communication from Victoryontheline 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 Victoryontheline staff via Outlook: 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@Victoryontheline.co.uk

Texts via CM.com: To opt-out please follow the instructions within the text you receive.

Email communication via SendinBlue: To opt-out please use the unsubscribe link within the email you receive and/or update your communication preferences within the My Profile section of our website. You can also request this specifically to mypersonaldata@Victoryontheline.co.uk

Email communication via UScreen; To opt-out please do so by logging into the Victoryontheline Uscreen platform and going into your Account details to update your preferences.

Email communication via TrustPilot; To opt-out please use the unsubscribe link within the email you receive and/or update your communication preferences within the My Profile section of our website. You can also request this specifically to mypersonaldata@Victoryontheline.co.uk

5. Sharing your Information

Information about Victoryontheline Club users is an important part to the business and Victoryontheline do not sell it to others. Victoryontheline shares member information only as described in this Privacy Policy.

Victoryontheline have business partners and employ other companies and individuals to perform certain functions on Victoryontheline behalf. Examples include managing our Membership database, sending texts, e-mails, analysing data, providing marketing assistance, providing personal training and providing debt collection assistance. Third party service providers only have access to the personal information relevant for performing their functions, but will not use it for other purposes. Additionally, they must process the personal information in accordance with this Privacy Policy and as permitted under the EU GDPR. Victoryontheline will only disclose personal information to reputable companies and suppliers who process data on Victoryontheline behalf.

Enquiries through Victoryontheline website(s): Victoryontheline capture data through Victoryontheline website(s) hosted by third parties (fortyeight.one, GiftPro). These can be for purchasing a giftcard, booking a tour online, joining online, referring a friend online, PT enquiries online, corporate enquiries online. Victoryontheline manage member services requests via their website through a third party (Zendesk). 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 Victoryontheline website.

Victoryontheline also capture data through the Out the Box platform which is hosted by Victoryontheline via a third party (UScreen), should you sign up to that.

Membership System and Bookings App: In order for Victoryontheline to process and manage existing and ex Memberships as well as Prospective Members, they use a third party (Legend Club Management) to provide the membership management system. Class bookings can be processed directly via the website hosted by Legend Club Management as well as the Victoryontheline bookings App hosted by Innovatise who integrate directly with Legend Club Management.

Payment Collection: Victoryontheline use third parties (Accountis, Verifone, Global Payments & 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 an Out The Box subscription.

Arrears Collection: Victoryontheline reserves the right to forward a members information to a third party debt collection agency (ARC Europe Ltd) in the event of non-payment of fees when due. Further information on this process can be found in Victoryontheline Terms and Conditions.

Personal Training: As stated on the Victoryontheline Membership Application, any Member who selects the PT Taster understands that their personal information will be provided to a designated personal trainer who will contact them to arrange their taster session.

Paperwork Destruction: Victoryontheline schedule regular collections of paperwork from a third party company (The Hill Company) who securely and confidentially shred this paperwork off site, on behalf of Victoryontheline.

Reviews: Victoryontheline may contact you via email to invite you to leave a review in order to collect feedback and improve Victoryontheline services. Trustpilot A/S (“Trustpilot”) is the external company used for this purpose, and your name and email address are shared with Trustpilot for this purpose only. If you want to read more about how Trustpilot process your data, you can find their Privacy Policy here.

Victoryontheline provide anonymous or hashed data to third party advertisers (Buddy Media Group, Facebook), to further understand customer trends and patterns, as well as a way to reach new customers who are likely to be interested in Victoryontheline, due to having similar interests to existing Victoryontheline customers.

Victoryontheline may release account and other personal information to third parties when Victoryontheline believe release is appropriate to comply with the law; enforce or apply membership or other agreements; or protect the rights, property or safety of Victoryontheline, its users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction. This does not include selling, sharing or otherwise disclosing personally identifiable information from members for commercial purposes in a way that is contrary to the commitments made in this Privacy Policy.

Victoryontheline may share Member details with another organisation which it partners with for the purposes of managing and maintaining a Membership and/or Club access, for example BJJ, Team Tieu, Wellhub and Classpass.

Other Websites: The Victoryontheline website may contain links to other websites that are outside Victoryontheline control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from this policy.

Cookies: A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. Find out more about cookies on https://ico.org.uk/for-the-public/online/cookies/ Victoryontheline use cookies to identify you when you visit this website and to keep track of your browsing patterns, to build up a demographic profile and to use for advertising purposes. Victoryontheline use cookies to allow registered users to be presented with a personalised version of the site, carry out transactions and have access to information about their account. Most browsers will allow you to turn off cookies. If you want to know how to do this please look at the menu on your browser, or look at the instruction on https://ico.org.uk/for-the-public/online/cookies/. Please note however that turning off cookies may restrict your use of our website. By continuing to use this site you are agreeing to the use of cookies as detailed within this section.

6. Keeping your Information Secure

In regards to environmental and physical security, all Victoryontheline employees receive full training upon commencement on employment and subsequently on an annual basis thereafter. This is completed via an e-learning platform and group training sessions. Further to this, daily, weekly and monthly audits are completed.

7. Victoryontheline Retention Policies

Victoryontheline 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 Victoryontheline will keep your information for the duration of any Contract that you have entered into with Victoryontheline, and then for a period of 7 years after, at which time all the personal information will be pseudonymised.

After that 7 year duration, Victoryontheline will retain and use your pseudonymised information for the purpose of business statistics and analysis. Victoryontheline can retract this pseudonymisation to the extent necessary to comply with any legal obligations or to resolve disputes

8. Staying in Control – Your Rights

Victoryontheline understand the importance of data subjects remaining in control of their personal data. Victoryontheline acknowledge the following rights you have under the GDPR, what they mean and how you can exercise them.