Types of Personal Data Collected:
For the purpose of carrying on the Company's business, including registration and administration of the Company's related products and services (including relevant online services), you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:
- Your name;
- Correspondence address, and/or billing address;
- Payment details, including credit card and banking information;
- Contact details, including contact name and telephone number or email address
- Your image taken at our premises with a web cam (or like equipment ) for visual identification
Fitness First may employ other companies or individuals to assist us in providing our services, or to provide certain services such as analysing customer lists, providing marketing assistance or consulting services. These third parties may have access to information needed to perform their function but cannot use that information for other purposes.
In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependant on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:
- Your age;
- Gender;
- Salary range and employment details;
- Education and Profession;
- Hobbies and leisure activities;
- Other related products and services subscribed to; and
- Family and household demographics.
Some of the Company's Websites may place a "cookie" on your machine; for example to provide personalised services and/or maintain your identity across multiple pages within or across one or more sessions. This information may include, but is not limited to, relevant login and authentication details as well as information relating to your activities and preferences across our Websites.
Under certain circumstances, telephone calls made to our order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. Unless expressly indicated at the time of calling, such recordings are NOT personal data of the caller and therefore, in respect of the caller, are not subject to the various provisions of the Ordinance and the caller has no rights and/or claims; either statutory, contractual or tortuous, over or to such data. At all times, every care is taken to protect such recordings from inadvertent and/or unauthorized access.
Purposes for collection, use, disclosure and processing of personal data
We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
1. considering and/or processing your membership application with us, including to require you to fill in relevant forms which sets out your health and lifestyle to ascertain your fitness level at the point of application with us;
2. Facilitating and managing your membership with us, including, without limitation;
a) Granting you access into the Fitness First facilities and clubs according to the terms of your membership;
b) Providing and arranging your personal training programmes and other fitness lessons provided by Fitness First;
c) Providing you with service or club/facilities status updates;
d) Administering your personal training and other training/fitness packages;
e) Processing the payment of your membership fees and / or any other relevant charges that may be incurred by you;
f) Operating Fitness First’s members’ database;
g) Providing you with any benefits as indicated by the terms of your membership, including to administer the relevant referral programs applicable to your membership;
h) Providing you with our Class Booker application for you to making booking(s) for Group Exercise classes;
i) Tracking your fitness levels with systems provided by us or our service providers
j) Providing you with a fitness evaluation where requested by you;
k) Facilitating the payment and provision of private locker rentals;
l) Managing your access to online services provided by Fitness First;
m) Managing your access to our mobile apps (including the Fitness First app) and online services provided by the Company;
n) Where your image is captured on any Fitness First club/facilities, to be used for publicity purposes;
3. Carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
4 Contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your membership with us such as but not limited to communicating information to you related to:
a) The status of your membership;
b) Any service or club/facilities status updates;
c) Reminders for appointments and / or sessions that you have booked with Fitness First, whether through email or a notification through our Class Booker application;
d) Outstanding payments or membership fees; or
e) Any of the purposes as indicated in paragraphs 1 and 2 above;
5. Carrying out due diligence or other screening in accordance with any legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
6. To prevent or investigate any fraud, unlawful activity or omission or misconduct, whether relating to your membership with us or any other matter arising from your membership with us, and whether or not there is any suspicion of the aforementioned;
7. Complying with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding on us and/or for the purposes of any guidelines issued by regulatory or other authorities, whether in Malaysia or elsewhere, with which we are expected to comply;
8. Complying with or as required by any request or direction of any governmental authority; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that we may/will disclosure your personal data to the aforementioned parties upon their request or direction;
9. Conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities in order to enhance your membership with us or for your benefit, or to improve any of our products or services for your benefit;
10. Storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Malaysia;
11. Providing and sending you marketing, advertising and promotional information, materials and/or documents relating to your membership with us which we think may be of benefit or interest to you, via (i) postal mail to your postal address(es) and/or electronic transmission to your email address(es), and via telephone calls, SMS/MMS and/or facsimile to your telephone number(s);
12. If you have used our clubs as a guest or trial pass user, or have signed up with us during our promotional events, providing and sending you marketing, advertising and promotional information, materials and/or documents relating to our membership and clubs, via (i) postal mail to your postal address(es) and/or electronic transmission to your email address(es), and (ii) if so consented by you, via telephone calls, SMS/MMS and/or facsimile to your telephone number(s) provided by you;
(collectively, the “Purposes”)
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Malaysia or outside of Malaysia, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Examples of service providers include companies that provide web hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, debt recovery and other services.
Where possible, we will validate data provided using generally accepted practices and guidelines. This includes the use of checksum verification on some numeric fields such as account numbers or credit card numbers. In some instances, we are able to validate the data provided against pre-existing data held by the Company. In some cases, the Company is required to see original documentation before we may use the personal data such as with Personal Identifiers and/or proof of address.