Pure Health is committed to complying with the General Data Protection Regulation and the Data Protection Act 2018. Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you a better and more personalised experience.
We have published this notice to help you understand:
- how and why Pure Health collect information from you
- who Pure Health share your information with, why and on what basis
- what your rights are
Should you have any questions about this policy please write to us at support@PureHealth.ie
This policy was last updated on August 1st, 2018.
Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
Includes: Online channels: http://purehealth.ie, the Pure Health App, the Pure Health Mind Body booking portal at https://clients.mindbodyonline.com/home/?studioid=40410
Offline channels: our Pure Health studio and therapy rooms
“Our Site” Refers to http://purehealth.ie
“Account” means a Pure Health or Mind Body account required to access and/or use certain areas and features of Our Locations
“Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via any of Our Locations. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
“We, Us ,Our” means Pure Health Therapies Limited, registered in Ireland under company number 529845, whose registered address is 2-3 The Mall, Ongar, Dublin 15
When do we collect your personal data?
- When you create an account at any of our Locations
- When you purchase a product at any of our Locations or apply for concession pricing which requires proof of age.
- When you book a service at any of our Locations
- When you visit our centre to attend a class or therapy
- When you redeem a gift card at any of Our Locations
- When you engage with us on social media
- When you download or install our apps
- When you contact us by any means with queries, complaints or to send us your CV for a job application
- When you enter prize draws or competitions
- When you choose to complete any feedback requests or surveys we send you
- When you’ve given a third party permission to share with us the information they hold about you
- When you use our studios which may have CCTV systems operated for the security of both customers and partners. These systems may record your image during your visit
What data do we collect and how do we use it?
Depending upon your use of our Locations, We may collect some or all of the following personal and non-personal data
Data Protection says that we are allowed to collect and use your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons:
- Contract – your personal information is processed in order to fulfil a contractual arrangement e.g. to place an order or book a class.
- Consent – where you agree to us using your information in this way e.g. for storing your payment card details.
- Legitimate Interests – this means the interests of Pure Health in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way
- Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.
|What we store||Our Reasons (Legal Basis)||What we use the data for|
|Name, date of birth, email, telephone number, For your security, we’ll also keep an encrypted record of your login password.||Fulfilling a contract||We need this information as a minimum in order to process your orders and bookings|
|Email / Mobile No.||Consent||Supplying you with email/sms Marketing communications that you have opted into to keep you informed of special offers, promotions and new events.|
|Email / Mobile No.||Legitimate Interests||Notifying you about enhancements to our services, such as changes to pricing and schedules or new services, and reminders.|
Contacting you to request feedback and undertake customer satisfaction surveys, and reminders for classes and appointment.
|Email / Mobile No.||Fulfilling a contract||Sending you payment invoices by email|
|Date of Birth||Legitimate interest||For health and safety reasons under 14s cannot practice yoga, (unless in a child specific class), Between the ages of 14 and 16 you can practice if accompanied by an adult|
How you heard about Pure Health
|Legitimate interest||Personalising and tailoring your experience with Pure Health. Developing products and services, that attract and retain customers. Improving customer interaction with our sites.|
|Preferred Pure Health location||Legitimate interest||To personalise your experience when using our online Locations|
|Your photo||Legitimate interest||This helps us ensure that your pre-paid class passes are not being used fraudulently by someone else|
|Payment card number, expiry date and billing address||Consent (we will only store these details if you ask us to)|
|If you purchase one of our services or make a booking: your purchased / booked services, receipts||Fulfilling a contract||We also use information about services bought and volumes, to help us with planning, demand forecasting, management information and research|
|Time and date of your check-ins for any bookings||Legitimate interests||To help us with planning and handling our customer contact efficiently and effectively|
|Details of your interactions with us through Our Locations. For example, we collect notes from our conversations with you, details of any feedback or comments you make, and how and when you contact us.||Legitimate interests||Keeping our records up to date, handling our customer contact efficiently and effectively|
|Health information and emergency contact||Legitimate interests||To enable us to assess your suitability for the services and safeguard your health|
|Details of your visits to our websites or apps, including IP address, web browser and version, operating system, and which website referred you to ours.||Legitimate interests||Improving customer experience and interaction with our sites.|
Third party services and how we share your data
We contract with third parties to supply products and services to you on Our behalf. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. In certain circumstances, We may be legally required to share certain data held by us, which may include your personal data, for example, where We are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
We use the following third party data processors who are based inside the EU
SnedinBlue, EU – following your first visit to Pure Health you may be contacted via email to provide feedback on your experience. We will also keep you up to date with class and therapy news and information. You can opt-out of these emails at any time by clicking the unsubscribe link at the bottom of every emaill
We use the following third party data processors who are based outside the EU, but who are protected by the Privacy Shield, which allows them to store EU data on US soil with the GDPR.
MINDBODY Online, California USA – we use MindBody online for web scheduling, registration, order processing and online payments
Google, California USA – We may compile statistics about the use of our Locations using Google Analytics including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law
Where do we store your data?
Your data will be stored in the Ireland, the EU and all MINDBODY Online data for its Pure Health platform, and data with third party service providers, are stored in the US, protected by the Privacy Shield that allows MINDBODY Online, to store EU data on US soil with the GDPR.
How long we keep your information
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed here.
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
- we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
- in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
You have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
right to access – You have the right to request information about the personal data we hold on you at any time.
right to portability – Whenever We process your personal data, by automated means based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal data you have submitted to us.
right to rectification – You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed. If you have Pure Health or Mind Body account you can edit your personal data under your account and membership pages.
right to erasure – You have the right to erase any personal data processed by Us at any time except for the following situations:
- you have an ongoing matter with Customer Service
- you have an unsettled debt with Us, regardless of the payment method
- if you are suspected or have misused our services within the last four years
- your debt has been sold to a third party within the last three years or one year for deceased customers
- if you have made any purchase, we will keep your personal data in connection to your transaction for book-keeping purposes
- we bring or defend a legal claim or other proceedings during the period we retain
- your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible
- in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
Your right to object to processing based on legitimate interest
You have the right to object to processing of your personal data that is based on our legitimate interest. We will not continue to process the personal data unless we can demonstrate legitimate grounds for the process which overrides your interest and rights or due to legal claims.
If you have any cause for complaint about Our use of your personal data, please contact us at support@PureHealth.ie in the first instance in order that we can investigate thoroughly. Should you find the response unsatisfactory, you also have the right to lodge a complaint.
For further information about your rights, please contact the Data Protection Office.
By continuing to browse our site, you consent to our placing cookies on your computer (unless you have chosen to disable them via your browser). Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings but please be aware that Our Site may not work properly if you do so.
The following first party Cookies may be placed on your computer or device:
Name of Cookie
_ga, _gat, _gid These cookies enable the function of Google Analytics. This software helps us collect and analyse visitor information such as browser usage, new visitor numbers, response to marketing activity and shopping times. That information helps us to improve the website and your shopping experience, and to make our marketing campaigns relevant.
The data stored by these cookies can be seen only by the relevant teams at Pure Health and Google and never shows any confidential information.
Third party Cookies may be placed on your computer or device by the following companies however these are not within our control:
Doubleclick is used for placing adverts and marketing on third party websites
Youtube is used to provide video social media and content
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. If you’d like to learn more about cookies in general and how to manage them please visit aboutcookies.org.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours.
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
If you have any queries or concerns about your data usage please contact us.
Under the Data Protection Act, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).
Contacting us, exercising your information rights and complaints
Promotions and competitions
When you submit your information to a promotion or competition to one of our locations (including social media) you are consenting to allow us to send you a return message to notify you of the results of that promotion or competition.