Esporta Privacy Policy

At Esporta we strive to deliver an outstanding service to all our members and guests. We value your business and, more importantly, your loyalty. We recognise that privacy is an important issue. We have developed this Privacy Policy (this "Policy"), which has been approved by the Esporta Board, to explain our practices regarding the personal information we collect when you register as a member of one of our clubs, when you give us your personal information by other written or verbal communications or when you visit our website.

Please read this Policy carefully before submitting personal information about yourself to us.

Personal Information We Collect

At every touch point or interaction, we may collect personal information. In addition to any other information you may choose to provide to us, this personal information may include: your name and contact information; date of birth; preferred communication methods; business name (in the case of a corporate membership) and business address; bank details and credit card details, including the three-digit code that appears on the back of your credit card. We also create information that becomes part of the personal information we hold about you, such as your membership number and your usage of the club. We may also collect and create details on associate members and other family members, where applicable, including, where necessary, family members under the age of 18.

In addition we collect other personal information when you interact with Esporta in various ways such as:

• When you register on the Members' section of the website, we also ask you to select a username and password.
• When you enroll in our OnTrack or BeneFIT programmes.
• From your membership card, when you enter an Esporta club.
• From time to time, this site may offer features that allow you to send an electronic postcard or otherwise share a message with a friend. If you choose to do so, we will ask you for the recipient's name and email address, along with the text of any message you choose to include. By using this feature, you warrant that you are entitled to use and provide us with the recipient's name and email address for this purpose.

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 we do not generally collect sensitive information unless it is volunteered by you, we do specifically collect health data to the extent that it is required to assess your readiness for physical exercise. We will use health information provided by you exclusively to serve you better and meet your particular needs. By providing the sensitive information to us, you and your Associate or family members, as applicable, are consenting to our using it in the manner set out in this Policy.

Personal Information from Children

We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.

Photographs for Membership Card

In the interests of security and the prevention of crime, we may take a digital photograph of each member to whom a membership card is issued. By providing the digital photograph to us, you and your Associate or family members, as applicable, are consenting to our using it in the manner set out in this Policy.

Use of Personal Information Collected About You

We use your personal information to provide the services you request from Esporta such as to facilitate: administration of your membership of the club; facilitate bookings of classes and appointments with our own or third party Onsite Service Providers; membership in the BeneFIT, OnTrack and similar programmes; to ensure you can make smooth use of the Freeway programme, and other transactions. We also use the personal information to provide you with information about meeting and event planning and access to specific account information for administrative purposes. In addition, we may use the information to: improve Esporta's services; provide you with the expected level of hospitality and service; and ensure the website is of interest to you. We also use details to send you newsletters and promotions, and to conduct online surveys, prize draws, competitions and other promotions via email, telephone or post. We will also use the information in the course of collecting your membership fees and any other payments that may be due to us from you. If you apply for employment with Esporta, we use the personal information you supply to process your job application.

How We Share Personal Information

As a national company, we endeavour to provide you with the same level of service that you have come to expect at Esporta at all our clubs. To provide this service, we may share your personal information with other members of the Esporta group of companies or with our service providers. Esporta will take appropriate steps to ensure that your personal information is handled as described in this Policy.

• Esporta group of companies: We may share personal information within the Esporta group of companies that may jointly use the personal information for the purposes described above.
• Events or Meetings: If you visit Esporta as part of an event or meeting, information collected for the event or meeting planning may be shared with the organisers of those meetings and events, and, where appropriate, guests who organise or participate in the meeting or event.
• Business Partners: From time to time we may partner with other companies to provide co-sponsored or co-branded promotions, products and services and may share your information with our co-sponsor. For example, we may co-sponsor some prize draws, competitions or other promotions on our site with other companies or we may provide prizes for draws, competitions or other promotions sponsored by other companies. If you enter one of these draws, competitions or other promotions, we may share your information with our co-sponsor or the third party sponsor.
• Onsite Services: We may share personal information with providers of onsite services that provide services such as spa treatments, physiotherapy, pilates, classes, or other lifestyle experiences at a club.
• Service Providers: We rely on service providers to provide certain products and services, such as credit card billing, providing services in connection with our websites, communicating news and delivering promotional and transactional materials via email and direct mail, processing credit card transactions, debt collection, data hygiene and enhancement services and administering prize draws, competitions and customer surveys for which it is necessary to provide personal information. Esporta will disclose personal information to service providers as appropriate.
• Business Transactions: As we develop our business, we might sell, buy, restructure or reorganise businesses or assets. In the event of a merger, consolidation, sale, liquidation or transfer of assets, Esporta may, in its sole and absolute discretion, transfer, sell or assign information collected, including without limitation, non-personal information and personal information, to one or more affiliated or unaffiliated third parties.
• Other: In addition Esporta may disclose personal information, with or without prior notice to you, in order to: (i) comply with applicable laws; (ii ) respond to governmental inquiries or requests from public authorities; (iii) comply with valid legal process; (iv) protect the rights, privacy, safety or property of Esporta, site visitors, guests, employees or the public; (v) permit us to pursue available remedies or limit the damages that we may sustain; and (vii) respond to an emergency.

Non-Personal Information

When you visit and interact with this site, Esporta and third parties with whom Esporta has contracted to provide services to Esporta, may collect non-personal information (for example, a catalogue of the site pages you visit).

As with many other sites, our site may use "cookies" or other technologies to help us deliver content specific to your interests, to process your reservations or requests, and/or to analyse your visiting patterns. Cookies, by themselves, cannot be used to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit our site. If you want to remove cookies at any time from your computer, you can delete them using your browser (consult your browser's "help" menu to learn how to delete cookies).

We also may collect data by using "pixel tags", "web beacons", "clear GIFs" or similar means (collectively, "pixel tags") that allow us to know when you visit our site. Through pixel tags, we obtain non-personal information or aggregate information (i.e., the domain name, the areas of the site you visit, your operating system, your browser version, and the URL you came from) which can be used to enhance your online experience and understand traffic patterns.

[In addition, we may use third party advertisers to serve advertisements on the Sites. Please note that these third party advertisers also may use cookies, pixel tags and other technologies, among other things, to enable such third party advertisers to record which ads your browser has seen and which site pages you may have been viewing when the ads were delivered. Esporta does not control the use of this technology or the resulting information and is not responsible for any actions or policies of such third parties.]

Because non-personal information does not personally identify you, we may use or disclose such information for any purpose. In some instances, we may combine non-personal information with personal information (such as embedding e-mail addresses in cookies). If we do combine any non-personal information with personal information, the combined information will be treated by us as personal information in accordance with this Policy.

Links to Third-Party Websites

Our site may contain links to third parties' websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on third party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

Protecting Personal Information

Esporta will take appropriate measures to: (i) protect personal information collected against unauthorised access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date where necessary. We also seek to require our affiliates and service providers to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use technology to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.

For your own privacy protection, we encourage you not to include sensitive personal information in any emails you may send to us. Please do not send credit card numbers or any sensitive personal information to us via email.

Changing Personal Information

Your personal information may change from time to time, for example if you move house. In the interests of maintaining accurate and up-to-date records, we will make the changes you request as soon as practicable after you tell us about them but we reserve the right to request appropriate evidence of the change before we do so.

You may request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct, and/or suppress personal information about you that we maintain in our active databases. We will make all required disclosure, updates and changes within the time specified by the applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request. Such requests must be submitted in writing to the following address: The Data Protection Officer, New Esporta Holding Limited, Trinity Court, Molly Millar's Lane, Wokingham, Berkshire, RG41 2PY. To protect your confidentiality, we can only respond to requests that are from you and our response will be addressed to you at the address that you have registered or otherwise provided to us.

In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or that Esporta cease the use of personal information. Your written request must be sent to to The Data Protection Officer, New Esporta Holding Limited, Trinity Court, Molly Millar's Lane, Wokingham, Berkshire, RG41 2PY. We will seek to honour your request but reserve the right not to honour a request that materially affects our own rights. For example, in the collection of debt.

Retaining Personal Information

We retain personal information about you for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

Choices - Marketing Lists

If you have given us your contact information (postal address, fax number, email address or phone number), we may want to inform you about our services or invite you to events by email, SMS, telephone or post. We will only do so if we have, where relevant, obtained your consent.

If you prefer not to receive marketing materials from us, you may change your preferences at any time by: (i) writing to us (and include your email address) at The Data Protection Officer, New Esporta Holding Limited, Trinity Court, Molly Millar's Lane, Wokingham, Berkshire, RG41 2PY; or (ii) using the unsubscribe function in the email you receive from us. We will update your preferences as soon as reasonably practical.

Please note, however, that if you "opt out" as described above, we will not be able to remove your personal information from the databases of affiliates, franchisees or business partners with which we have already shared your personal information (i.e. to which we have already provided your personal information as of the date of your opt-out request).

Other Information

• If you are interested in obtaining more information about our Onsite Service Providers we will also collect information about your interests and requirements.
• If you choose to apply online for employment with Esporta, you will also have the opportunity to send your CV in electronic form, information on education and employment history, desired salary scale, working permits, and any other information you feel is relevant to your application. If you apply for employment online, any information about you which is obtained by us during the application process may be retained by us for purposes of considering your application for employment, as well as for more general management and research purposes. Please see our Online Recruiting Policy for further detail.

Policy Modifications

We may modify this Policy from time to time. When we make material changes to this policy we will post the revised policy on the homepage of our site. You can tell when this Policy was last updated by looking at the date at the top of the Policy. Any changes to our Policy will become effective upon posting of the revised Policy on the site. Use of the site following such changes constitutes your acceptance of the revised Policy then in effect.

Questions

If you have any questions about this Policy or how Esporta processes your personal information, please contact us by post to The Data Protection Officer, New Esporta Holding Limited, Trinity Court, Molly Millar's Lane, Wokingham, Berkshire, RG41 2PY.