PRIVACY/GDPR FOR OUR ONLINE STORE, WEBSITES, APPLICATIONS & SAAS

Last updated: 3 November 2026

Thank you for choosing to be part of our community at UBX. In this policy, “UBX Training”, “UBX”, “UBX Fitness”, “we”, “us” or “our” means UBX Global Limited, as explained in “Who is responsible for your information” below. We are committed to protecting your personal information and your right to privacy.If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at support@ubxtraining.com with the subject line: [ATTN: UBX COMPLIANCE]

When you visit our mobile applications, purchase kits and merchandise through our online store, and use our services, you provide us with your personal information. We take your privacy very seriously. In this policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important.

This policy applies to all information collected through our mobile applications, ("Apps"), Websites, Online Stores and/or any related services, sales, marketing or events (we refer to them collectively in this policy as the "Services"). It does not cover how your gym handles your gym membership records, which is explained in your gym's own privacy notice. For the purposes of both the EU and UK General Data Protection Regulations (GDPR), UBX Global Limited is the controller of the personal data it processes for its own purposes, as described in “Who is responsible for your information” below.

Who is responsible for your information

  • Your gym and your gym membership. Every UBX gym is independently owned and operated by a franchisee, licensee or master franchisee (“your gym”). Your gym sells your membership to you and is the controller of your gym membership records. UBX gyms use ABC Glofox, a member management platform and member app (the UBX Member App) provided to the gym by Zappy Limited (trading as Glofox), a company registered in Ireland. Membership payments are processed through Glofox's payment services, which use a third-party payment provider such as Stripe. No UBX company is the payment processor for gym memberships. For questions about your membership records, please contact your gym.
  • Technology used by your gym. Your gym may also use technology supplied to it by Performance Hub, such as CCTV systems, access control, screens, duress alarms, reporting tools and AI-assisted tools. Your gym buys these services directly, decides how they are configured and used, and is the controller of the information processed in them; Performance Hub processes that information on your gym's behalf. Depending on your gym's location and set-up, some of your membership information may be synchronised from ABC Glofox into these systems, for example your name and gym access records for access logs, CCTV-based tailgating detection, and reporting and AI-assisted insights for your gym. Please see your gym's privacy notice, or contact your gym, for details.
  • This website, the UBX apps and the online store. UBX Global Limited (company number 12350456), registered office c/o RPGCC, 40 Gracechurch Street, London EC3V 0BT, United Kingdom, operates ubxtraining.com, the TRAIN: On Demand and The Training Camp apps and the UBX online store (shop.ubxtraining.com). When you use these or buy from them directly, UBX Global Limited is the controller of your information and the seller.
  • UBX newsletters and Head Office communications. UBX Global Limited sends UBX brand newsletters and Head Office communications to members and decides how your information is used for that purpose, so it is the controller of that information. We may receive your name and email address from your gym for this purpose. You can unsubscribe from UBX newsletters at any time (see “Opting out of email marketing” below).
  • Hosting on behalf of gyms. Where UBX Global Limited hosts or processes information on behalf of a gym, for example on its Amazon Web Services cloud account, it does so on the gym's instructions as the gym's service provider (processor).
  • The UBX franchise system. As franchisor, UBX Global Limited may receive information from gyms in connection with the franchise system, such as membership status (for app benefits) and transaction totals (for royalties).

Please read this policy carefully as it will help you make informed decisions about sharing your personal information with us.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when registering at the Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Apps(such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Apps, the choices you make and the products and features you use. The personal information we collect can include the following:

Identification and Contact Information Provided by You. We collect first name, maiden name, last name, and nickname; current and former address; phone numbers; email addresses; social media; and other similar data. In addition we also collect the contact details of provided by you as part of any "refer a friend" option exercised by you.

Fitness and App Information Provided by You. We collect data about health, MyZone/FitBit and similar apps data; app usage; and other similar data.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. This applies to purchases you make from us directly, such as in the UBX online store or in our Apps. Payments for gym memberships are taken by your gym through Glofox's payment services, not by UBX.

Social Media Login Data.  We may provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.

Health Information. We collect a limited amount of data which may disclose information relating to your health (including effort levels, fitness metrics, weight).

All personal information that you provide to us should be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Apps.

We automatically collect certain information when you visit, use or navigate the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookies Policy: ubxtraining.com/legal/cookie-policy.

Online Identifiers. We collect devices; applications; tools and protocols, such as IP (Internet Protocol) addresses; device's geolocation; Radio Frequency Identification (RFID) tags; cookie identifiers, or others such as the ones used for analytics and marketing; and other similar data.

Information collected through our Apps

In short: We may collect information regarding your geo-location, mobile device, push notifications, when you use our apps.

If you use our Apps, we may also collect the following information:

  • Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, calendar, sensors, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
  • Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
  • Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

2. HOW DO WE USE YOUR INFORMATION?

In short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent (however, we only rely on consent in relation to the collection and processing of health data).

We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" for further information.
  • To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below). UBX newsletters and Head Office communications are sent by UBX Global Limited. Your gym may send you its own messages.
  • Fulfill and manage your orders. We may use your information to fulfil and manage your orders, payments, returns, and exchanges made through the Apps or on the online store.
  • Gym membership benefits. Your gym manages your membership and your access to the gym using ABC Glofox and the UBX Member App. If you are a member of a UBX gym, we may receive confirmation of your membership status from your gym so that we can give you membership benefits in our Apps, such as TRAIN: On Demand Premium access.
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

Referral Program and Use of Contact List Information

We respect the privacy of our users and the trust you place in us when participating in our referral program. This program allows you to refer a friend to our services, enhancing your and your friend's experience with us. Here's how we handle your contact list available on your mobile device or your email accounts, or where you provide your friends’ contact information manually (collectively, the Contact List) information:

  • Collection and Use: When opting into our referral program, you are explicitly consenting to our use of the Contact List information as set out below. We access your Contact List information to create an unidentifiable hash of your friend's contact details. This hashed information is linked to your member profile to identify and reward both you and your friend if they join our services. When communicating with your friends, we may include your name and photo in order to let them know that you are the person extending the invitation or sending the message. With your permission, we may also send reminder emails to your friends on your behalf, which may also include your name and photo, and enable you to send invitations to your friends via email or SMS/text. Even after your consent has been withdrawn we may retain your friends’ email addresses to let you know when the recipient received a gift card or other communication from us.
  • Consent and Control: Access to your Contact List is based on your above explicit consent. You have full control and can choose not to participate in the referral program going forward by sending an email to us at “notice@ubxtraining.com” .
  • Privacy and Security: We prioritize the privacy and security of your information. The hashed data cannot identify your friend unless they decide to join our services, and we implement strict security measures to protect against unauthorized access.

Profile Customization and Use of Image Information

We also collect image information, which includes information about how you use and interact with the Apps and our Service, including any content you post to any of the Services (for example, if you share photos and video from a mobile device, we will access your device camera roll and camera with your permission as needed to post your content on our Services) Such information collectively referred to as Image information and we will use such information to allow users to customize their profiles with avatars or photos. This enhances user experience by enabling identification on leaderboards within our apps.

  • Collection and Use: Image information is collected when you choose to set or select an avatar for your profile. This is used exclusively for identifying your profile on our app's leaderboards and is not shared outside of our app ecosystem.
  • Consent and Control: Your provision of Image information for profile customization is entirely voluntary and based on your consent. You can change or remove your avatar at any time through the app settings.
  • Privacy and Security: We are committed to ensuring the security of your Image information. It is used solely within the app ecosystem and protected against unauthorized access and use.

3. LAWFUL BASES FOR PROCESSING AND SHARING YOUR INFORMATION

In short: We only process and share information to comply with laws, to provide you with services, to protect your rights, to fulfil business obligations, or, in relation to the collection and processing of health data, with your consent.

We may process or share data based on the following legal basis:

  • Consent: We may process your health data if you have given us specific and explicit consent to use your health data in connection with the provision of the services.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
  • Medical Emergencies: In the event of a medical emergency at a UBX club, information may be shared with officials. Please refer to your individual club's policy for details.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

4. WILL YOUR INFORMATION BE SHARED WITH ANYONE

We may need to process your data or share your personal information in the following situations:

  • Vendors, Consultants, Manufacturers and Other Third-Party Service Providers. We may share your data with third party vendors, product manufacturers, product providers, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, address (to the extent you have ordered physical products for delivery), hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. WHO WILL YOUR INFORMATION BE SHARED WITH?

In short: We only share information with the following third parties to provide you with the best user experience.

We only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

  • Cloud Computing & Platform SaaS Suppliers
  • Marketing Communications & Chat with Users Suppliers
  • Invoice and Billing Suppliers
  • User Account Registration and Authentication Suppliers
  • Web and Mobile Analytics Providers
  • Advertising, Tracking & Targeting Providers and Partners
  • Website & App Testing Providers
  • UBX gyms (franchisees and licensees), where needed to provide gym-linked app benefits or competitions

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy: ubxtraining.com/legal/cookie-policy

7. DO WE USE GOOGLE MAPS?

In short: Yes, we use Google Maps for the purpose of providing better service.

This website, mobile application, or Facebook application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link.

By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. You agree to allow us to obtain or cache your location. You may revoke your consent at any time. We use information about location in conjunction with data from other data providers.

8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Apps offer you the ability to register and login using your third party social media account details (like your Facebook or Google logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this policy or that are otherwise made clear to you on the Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

9. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In short: We may transfer, store, and process your information in countries other than your own.

Location of Servers:

Our servers are located in the United Kingdom, Australia, and United States. If you are accessing our Apps from outside Australia, and United States, for example, in the United Kingdom, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in New Zealand, Singapore, Australia, United Kingdom, and other countries. Your gym membership records are held by your gym in ABC Glofox and, depending on your gym's set-up, in other technology systems your gym uses; please see your gym's privacy notice for where they are stored and processed.

Transfers outside the European Economic Area and the United Kingdom:

If you are a resident in the European Economic Area or the United Kingdom, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take appropriate supplementary measures (namely, the implementation of Standard Contractual Clauses or approved data transferring clauses) to protect your personal information in accordance with this policy and applicable law. Further information regarding these supplementary measures can be requested from support@ubxtraining.com with the subject line: [ATTN: UBX COMPLIANCE].

10. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We keep your information for as long as necessary to fulfil the purposes outlined in this policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). Under applicable laws, we may need to keep certain information for up to seven years after you cease being a customer of UBX to defend against potential future legal claims.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

11. HOW DO WE KEEP YOUR INFORMATION SAFE?

In short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In short: In some regions, such as the European Economic Area and the United Kingdom, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area and the United Kingdom), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure of your personal information; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

In the United Kingdom, the data protection supervisory authority is theInformation Commissioner’s Office whose contact details are availablehere: https://ico.org.uk/make-a-complaint/.

California privacy laws, including the California Consumer Privacy Act ("CCPA") require that we provide California residents information about how we use their personal information, and this section is intended to satisfy that requirement.

Under the CCPA, "personal information" is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

Right to Opt-out/in. California residents have the right to opt-out of our sale of their personal information and personal information about California residents who we know are younger than 16 years old cannot be sold without opt-in consent. We do not sell your personal information.

Right to Opt-In. We do not sell personal information about residents who we know are younger than 16 years old without opt-in consent.

Right to Non-Discrimination, and Incentives. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information. We do not currently offer any financial incentive programs.

Notice at Collection. We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

Verifiable Requests to Delete, and Requests to Know. Subject to certain exceptions, California residents have the right to make the following requests, at no charge, up to twice every 12 months: (a) California residents have the right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary for any of a list of exempt purposes; (b) California residents have the right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (i) by mail or (ii) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance; (c) California residents have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months.

If you are a resident in California and wish to exercise any of these rights, you may email us at support@ubxtraining.com. if you wish to unsubscribe from our marketing channels such as SMS or email, you may do so by following the instructions in the Account Information below.

The categories and sources of personal information we have collected in the past 12 months can be found in  WHAT INFORMATION DO WE COLLECT and in our Cookie Policy. Who we disclose your personal information with can be found in  WILL YOUR INFORMATION BE SHARED WITH ANYONE?  and WHO WILL YOUR INFORMATION BE SHARED WITH?.

If you have questions or comments about your privacy rights, you may email us at support@ubxtraining.com with the subject line: [ATTN: UBXCOMPLIANCE].

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Contact us at support@ubxtraining.com with the subject line: [ATTN: UBX COMPLIANCE]
  • For your gym membership records, please contact your gym directly.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies:Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Apps. To opt-out ofinterest-based advertising by advertisers on our Apps visit http://www.aboutads.info/choices/. For further information, please see our Cookie Policy: ubxtraining.com/legal/cookie-policy.

Opting out of email marketing: You can unsubscribe from our marketing email lists at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. UBX newsletters and Head Office communications are sent by UBX Global Limited and every newsletter contains an unsubscribe link. Unsubscribing from UBX newsletters does not unsubscribe you from messages sent by your gym. To otherwise opt-out, you may:

Opting out of SMS marketing: You may unsubscribe from SMS messages sent from us at any time by following the instructions at the end of the SMS message delivered to you. As some notifications and messages may not contain any unsubscribe instructions, you may also unsubscribe using our SMS Unsubscribe tool. Note you may still receive service-related emails that are necessary for the administration and use of your account, reminders for your bookings, and other transactional non-marketing notifications, such as order tracking, and feedback requests.

  • You may still receive SMS and emails directly from your gym, which sends its own messages. To stop them, follow the opt-out instructions in the message or contact your gym.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

14. CCTV POLICY

This section sets out the appropriate actions and procedures which we follow in respect of the use of CCTV (closed circuit television) surveillance systems (“CCTV Systems”) at our premises.

Sound recording is disabled on all cameras.

Please note that UBX gyms may be monitored by CCTV 24 hours a day. CCTV at each gym is managed by the franchisee, licensee or master franchisee that runs that gym, which is responsible for its footage and may allow its employees and contractors to review footage as required. Gyms may use CCTV systems supplied by Performance Hub and, depending on how a gym has configured them, these may include automated features such as tailgating detection linked to gym access records. Recorded CCTV footage will be stored securely and retained in compliance with applicable laws.

In drawing up this policy, due account has been taken of the GDPR and any other relevant data protection legislation, the CCTV guidance produced by the Information Commissioner and the Human Rights Act 1998.

  • Our Policy. This policy will cover all employees and persons providing a service to us, visitors and all other persons whose image(s) may be captured by our CCTV Systems. We will also ensure that the personal data captured by our CCTV Systems is only processed in accordance with the following requirements:

    • It will be processed fairly, lawfully and in a transparent manner;
    • It will only be collected for specified, explicit and legitimate purposes and not further processed in any manner incompatible with those purposes;
    • It will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
    • It will be accurate and, where necessary, kept up to date;
    • It will not be kept for longer than is necessary for the purposes for which the personal data are processed; and
    • It will be processed in a manner that ensures appropriate security of the personal data.

    Depending on the location of your gym, the operator of your gym has the legal responsibility for the day-to-day compliance with the requirements of this policy. Please refer to section 16 as to how to enquire about this policy to the extent your local gym operator is unable to assist you.

    The purpose of the use of the CCTV Systems and the collection and processing of CCTV images is for the prevention or detection of crime or disorder, apprehension and prosecution of offenders (including use of images as evidence in criminal proceedings), interest of public and employee health and safety, protection of public health and the protection of our property and assets and to ensure compliance with our policies and procedures. This may include automatically identifying individual member attendance and time spent by members interacting with staff of the relevant gym, all with a vie to providing a better quality experience for members.

    Prior to any camera installation the CCTV Officer will ensure that the installation complies with this policy and that the use of any camera is justified, necessary and proportionate. The CCTV Officer will regularly assess whether the use of any camera and the CCTV System as a whole continues to be justified, necessary and proportionate.

    The location of the equipment is carefully considered because the way in which images are captured needs to comply with the Regulation.

    All cameras are located in prominent positions within public and staff view and do not infringe on sensitive areas. All CCTV surveillance is automatically recorded, and any breach of this siting policy will be detected via periodic auditing of the CCTV System.

    The images produced by the equipment will as far as possible be of a quality that is effective for the purpose(s) for which they are intended. Upon installation, all equipment is tested to ensure that only the designated areas are monitored, and suitable quality pictures are available in live and play back mode. All CCTV equipment is maintained under contract.

    Images which are not required for the purpose(s) for which the equipment is being used will not be retained for longer than is necessary. While images are retained, it is essential that their integrity be maintained, whether it is to ensure their evidential value or to protect the rights of people whose images may have been recorded. Access to and security of the images is controlled in accordance with GDPR requirements.

    All images are digitally recorded and stored securely within the system's hard drives. Images are, unless manually stored by the operator of the relevant gym, automatically stored for a minimum of 7 days and typical for no more than 6 months.

    Where the images are required for any other purpose, for example system testing, evidential purposes or disciplinary proceedings, a copy file will be moved to an access controlled confidential location on the network and held until completion of the investigation. Viewing of images within the system is controlled by the CCTV Officer or a person nominated to act on their behalf. Only persons trained in the use of the equipment and authorised by the CCTV Officer can access data.

  • Access to and disclosure of images to third parties. Access to, and disclosure of, the images recorded by our CCTV System and similar surveillance equipment is restricted and carefully controlled. This ensures that the rights of individuals are preserved, and the continuity of evidence remains intact should the images be required for evidential purposes e.g. a police enquiry or an investigation being undertaken as part of an internal procedure. Access to the medium on which the images are displayed and recorded is restricted to the CCTV Officer, staff authorised by them and third parties as authorised from time to time for specific purposes. Access to and disclosure of images is permitted only if it supports the purpose for which such images were collected.

  • Access to images by individuals. The GDPR gives any individual the right to request access to CCTV images which contain their personal data. CCTV is managed and maintained by the operator of each gym, using CCTV systems supplied to it. Individuals who request access to images should contact their gym operator first. Requests may also be submitted formally in writing to us, or via a CCTV Access Request. This will provide us with sufficient details to identify the section of footage they are concerned with and to enable us to satisfy itself that the person making the request is the data subject of that specific recording. Upon receipt of the request, the CCTV Officer, or another member of staff authorised by them, will determine whether disclosure is appropriate and whether there is a duty of care to protect the images of any third parties. If the duty of care cannot be discharged, then the request can be refused. A written response will be made to the individual, giving the decision (and if the request has been refused, giving reasons) within 31 days of receipt of the request.

  • Management by franchise clubs. While this policy governs how we manage the CCTVs, it should be noted that physical control of the CCTV equipment is in the sole control of the franchisee, licensee or master franchisee that operates each gym and that they are solely responsible for ensuring compliance with the local laws and regulations applicable to their physical site and this policy. Should you have any queries about a specific gym, please contact your gym's operator at the first instance and to the extent they are unable to provide you with the information you are entitled to, we will use all reasonable endeavours to obtain such information for you.

15. DATA REMOVAL REQUEST

As a part of the relevant privacy laws and regulations you have the right to request removal of data that a company holds on you.

To request removal of your Data from UBX you may:

16. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at support@ubxtraining.com with the subject line: [ATTN: UBX COMPLIANCE], or by post to:

UBX GLOBAL LIMITED (company number 12350456)
Registered office: c/o RPGCC, 40 Gracechurch Street, London EC3V 0BT, United Kingdom
Brisbane office: Central Plaza One, Level 38, 345 Queen Street, Brisbane, QLD 4000, Australia

UBX Global Limited is registered with the UK Information Commissioner's Office (registration number ZB327261).

For your gym membership records, please contact your gym directly.

17. DO WE MAKE UPDATES TO THIS POLICY?

In short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.