Privacy policy
Primal training - Data & Privacy policy
Effective Date: 25th July 2015
Last Updated: 6th May 2026
At Primal Training (hereinafter referred to as "we", "us", or "our"), protecting your privacy and
ensuring the security of your personal information is our priority. This Data Protection and Privacy
Policy outlines how we collect, use, store, share, and protect your personal information in
compliance with the data protection act 2018.
1. Scope of the Policy
This policy applies to all individuals who interact with Primal Training and provide us with their
personal data, including but not limited to members, visitors, and website users (hereinafter referred
to as "you" or "your"). By accessing our services or facilities, you agree to the collection and use of
your personal information as described in this policy.
Where services involve participants under 18, personal data relating to minors will only be
processed with appropriate parent or guardian involvement where required.
2. Information We Collect
We collect various types of personal data for the purpose of providing you with a high-quality gym
experience. The information collected includes:
2.1 Personal Information
• Identity Data: Name, date of birth, gender, membership ID.
• Contact Data: Phone number, email address, physical address.
• Emergency Contact Information: Name, relationship, and contact details of your
emergency contact.
2.2 Payment Information
• We do not store your full credit card, debit card or bank account details on our systems.
Payments are processed securely by authorised third-party payment providers. We may
receive limited information relating to payment transactions, such as payment status, billing
history, transaction references and membership payment records, for the purposes of
managing your membership and providing our services. Any payment information processed
by our payment providers is handled in accordance with their own privacy policies and
security standards.
2.3 Health Information• Medical Data: Any health information you choose to provide, including injury or disability
details necessary for safe use of gym equipment and facilities.
• Health-related information is treated as special category personal data and processed with
additional safeguards in accordance with applicable data protection law.
2.4 Activity Information
• Gym Usage Data: Attendance records, workout history, and class registration.
2.5 Technical Data
• Online Data: IP address, device information, location data, browser type, and cookies
collected when using our website or mobile app.
3. How We Use Your Information
We collect and use your personal information to provide and improve our services. The purposes for
which we process your data include:
• Membership Management: To register you as a member, process your membership
payments, and maintain your account.
• Service Delivery: To provide access to gym facilities, fitness classes, and other services.
• Health and Safety: To ensure safe participation in activities, especially in cases where
medical information is necessary.
• Customer Support: To respond to your inquiries, requests, or complaints.
• Marketing Communications: With your consent, to send you promotions, updates, or
information about new products, classes, or services.
• Legal Compliance: To comply with legal obligations, such as tax regulations, fraud
prevention, or government requests.
4. Legal Basis for Processing
We process your personal data based on the following legal grounds:
• Consent: When you provide explicit consent for the processing of your personal
information (e.g., marketing communications).
• Contractual Necessity: When processing is necessary for the performance of a contract
(e.g., membership agreement).
• Legal Obligation: When we must process your data to comply with legal or regulatory
obligations.
• Legitimate Interests: When processing is in our legitimate interests, such as ensuring the
security of our facilities or improving our services, provided these do not infringe your
rights.
5. Data Sharing and Disclosure
We do not sell or rent your personal data to third parties. We may share your information with the
following parties:• Service Providers: We may share personal information with trusted third-party providers
who help us operate our business and deliver services to members. These may include
payment processors, membership management software providers, booking systems, email
communication platforms, website hosting providers, analytics providers and marketing
platforms. All providers are required to process personal data securely and in accordance
with applicable data protection laws.
• Legal Authorities: In response to legal processes, such as a court order or government
request, or to comply with applicable laws.
• Emergency Services: In case of an emergency where medical intervention is necessary.
6. Data Security
We take the security of your personal data seriously and implement appropriate technical and
organisational measures to protect it against unauthorised access, loss, misuse, alteration, or
destruction. These measures include:
• Encryption of sensitive data (e.g., payment information).
• Secure access controls to our systems and facilities.
• Regular audits of our data protection practices.
7. CCTV
CCTV may operate within and around our facilities for security, member safety, crime prevention
and incident investigation purposes.
CCTV footage is retained only for as long as reasonably necessary and processed in accordance
with applicable data protection law.
7. Data Retention
We retain personal data only for as long as reasonably necessary for:
• membership administration
• legal obligations
• accounting requirements
• dispute resolution
• health and safety obligations
Retention periods may vary depending on the type of data involved.
8. Data Deletion & DisposalPrimal Training is committed to ensuring that personal information is not retained for longer than
necessary.
Once personal data is no longer required for the purpose for which it was collected, and where there
is no legal or legitimate reason to retain it, we will securely delete, anonymise or destroy the
information using appropriate technical and organisational measures.
Certain records may be retained for longer periods where required for:
• legal or regulatory compliance
• accounting and tax obligations
• health and safety requirements
• safeguarding responsibilities
• dispute resolution and insurance purposes
Individuals may request the deletion of their personal data at any time. Requests will be reviewed
and processed in accordance with UK data protection legislation and any applicable exemptions.
9. Your Rights
You have the following rights in relation to your personal data:
• Right to Access: You can request access to the personal information we hold about you.
• Right to Rectification: You can request corrections to any inaccurate or incomplete data.
• Right to Erasure ("Right to be Forgotten"): You can request that we delete your personal
data under certain circumstances.
• Right to Restrict Processing: You can ask us to suspend the processing of your data in
certain cases.
• Right to Data Portability: You can request a copy of your data in a structured, commonly
used, and machine-readable format.
• Right to Object: You can object to the processing of your data in certain situations, such as
for direct marketing purposes.
To exercise your rights, please contact us using the details in Section 13 below.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if
you believe your personal data has been handled unlawfully or improperly.
Further information can be found at www.ico.org.uk.
10. Cookies and Online Tracking
Our website uses cookies and similar technologies to:
• maintain website functionality
• improve user experience
• analyse website traffic• support marketing and advertising activities
Where legally required, non-essential cookies are only activated after consent has been provided
through our cookie banner or preference settings.
11. Use of Images and Videos
At Primal Training, we occasionally take photographs and videos during group classes and other
gym activities to capture the energy and spirit of our community. These media may be shared across
our social media platforms, website, and other promotional materials. This section outlines how we
use such images and videos, and your rights regarding them.
11.1 Purpose of Use
We use images and videos to:
• Promote gym events, classes, and services.
• Celebrate member achievements and share community highlights.
• Engage with our community on social media platforms such as Instagram, Facebook, and
Twitter.
11.2 Consent for Photography & Video
We may occasionally capture photographs or videos during classes, events or gym activities for
promotional and community purposes.
Where individuals are clearly identifiable in featured content, we will seek appropriate consent
before using images or videos for marketing purposes.
Members may withdraw consent at any time by contacting our team.
• Direct Consent for Close-Ups: If we intend to take close-up images or videos that
specifically feature you, we will seek your explicit consent prior to capturing and sharing
these materials.
11.3 Opting Out
If you do not wish to be included in any photos or videos:
• Please notify the instructor before or during the class/event.
• Alternatively, you can contact us at any time to request that specific images or videos in
which you appear be removed from our social media platforms or marketing materials.
11.4 Usage Platforms
Photos and videos may be used on the following platforms:
• Social Media: Facebook, Instagram, Twitter, LinkedIn, TikTok, or other platforms where
we maintain an official presence.
• Website: Primal training's website, class schedules, blogs, and event pages.
• Promotional Materials: Printed brochures, posters, newsletters, and digital ads.11.5 Protection of Your Privacy
We are committed to respecting your privacy and ensuring that images and videos are used
appropriately. We will not share any images or videos that could cause harm, embarrassment, or
discomfort to any member.
11.6 Rights and Removal Requests
• Please note by terminating your membership/ online account with Primal training we do not
remove any information/ photos/ videos used from our website and/or social media sites.
You have the right to:
• Request Removal: If you see an image or video of yourself posted on our social media or
website and would like it removed, you can contact us at info@primaltraining.co.uk or
speak to a member of staff. We will promptly remove the requested media upon verification.
• Withdraw Consent: You may withdraw your consent for future photography or
videography by contacting us, and we will ensure you are not included in any future media.
• Please note by terminating your membership/ online account with Primal training.
Previously published promotional materials may continue to appear where lawful and
proportionate. However, we will always consider reasonable removal requests fairly and
promptly.
12. Changes to This Policy
We reserve the right to update this policy from time to time to reflect changes in our practices, legal
obligations, or industry standards. Any updates will be communicated via our website or directly to
members.
By using our services, you agree to the terms outlined in this Data Protection and Privacy Policy.
13. Contact Us
If you have any questions about this Data & Privacy Policy or how your personal data is handled, or
if you wish to exercise any of your rights, please contact us:
Primal Training
Shaw lodge Mills
Email: Hello@primaltraining.co.uk
Phone: +447805036614