Apex Gymnastics – Privacy Policy
1. Introduction
Apex Gymnastics ("we," "us," "our," "the Club") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect,1 use, store, and share personal data for our members (Participants), their parents or legal guardians (Guardians), staff, volunteers, and visitors.
We are the data controller responsible for your personal data. Our registered activities take place primarily at the Aspire Centre, Earlsfield, London.
This policy applies to information collected through our registration forms (online or paper), website (Apex-gymnastics.co.uk), email, telephone, in-person interactions, and any other means through which you provide us with personal data.
We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. What Personal Information Do We Collect?
We may collect, store, and use the following categories of personal information:
For Participants (Children):
Full name, date of birth, gender.
Relevant medical information, including physical or mental health conditions, allergies, medications, and disability information necessary for safe participation (this is special category data).
Emergency contact details (usually Guardian details).
Attendance records, progress reports, competition results.
Photographs and videos taken during Club activities (only where consent is provided).
Details of any incidents or accidents.
Information required by British Gymnastics for membership.
For Parents/Guardians:
Full name, home address, email address, telephone numbers.
Emergency contact details (if different from main contact).
Payment information (note: financial transaction details like full card numbers are typically processed securely by third-party payment providers and not stored by us).
Records of communications (emails, correspondence).
Information provided when making enquiries or complaints.
For Staff/Volunteers:
Information necessary for recruitment, employment, or volunteering, including contact details, qualifications, experience, DBS checks, bank details (for payroll), and emergency contacts. (Specific details provided during onboarding).
3. How We Use Your Personal Information (and our Legal Basis)
We use personal information for the following purposes, relying on these legal bases under UK GDPR:
To manage registration, membership, and participation: (Legal Basis: Contract)
Processing applications and renewals.
Administering classes, squads, camps, and events.
Collecting fees and managing payments.
To communicate with you: (Legal Basis: Contract, Legitimate Interests)
Sending essential information about classes, schedules, venue changes, fees, and events.
Responding to your enquiries or complaints.
Providing updates on Participant progress.
To ensure health, safety, and welfare: (Legal Basis: Vital Interests, Legal Obligation, Legitimate Interests, Explicit Consent for health data)
Ensuring the Participant is medically fit to participate safely.
Managing medical conditions or allergies effectively during sessions.
Providing first aid and contacting emergency services/contacts if necessary.
Recording and investigating accidents or incidents.
Complying with safeguarding procedures and legal requirements.
To comply with governing body requirements: (Legal Basis: Legal Obligation, Contract)
Registering Participants with British Gymnastics for membership and insurance.
Submitting information for competitions or events.
For marketing and promotion (with consent): (Legal Basis: Consent)
Using photographs or videos of Participants in promotional materials (website, social media, flyers) where explicit consent has been given.
Sending newsletters or information about optional Club events, offers, or fundraising activities (where you have opted-in or based on Legitimate Interests for existing members regarding similar services, with an easy opt-out).
For Club administration and improvement: (Legal Basis: Legitimate Interests)
Monitoring attendance and class suitability.
Analysing participation for service improvement.
Maintaining financial records.
Equality monitoring (using anonymised or consented data).
To manage staff and volunteers: (Legal Basis: Contract, Legal Obligation, Legitimate Interests)
Recruitment, payroll, training, and ensuring appropriate qualifications and checks (e.g., DBS).
We only use special category data (like health information) where necessary for safety, with explicit consent, or where required by law (e.g., safeguarding, vital interests).
4. Who We Share Your Information With
We may share your personal information with the following third parties where necessary and legally permitted:
British Gymnastics: For mandatory membership registration, insurance purposes, and event entries.
Coaches and Authorised Staff/Volunteers: On a need-to-know basis to manage classes, ensure safety, and track progress.
Payment Processors: To securely process fee payments.
Software Providers: Including class management systems, communication platforms (e.g., email providers), or cloud storage, under strict data processing agreements.
Emergency Services: In the event of an emergency requiring medical attention.
Local Authorities, Safeguarding Boards, Police: If required by law for safeguarding purposes or criminal investigations.
Insurance Providers: In the event of an insurance claim.
Venue Management (Aspire Centre): Limited information if necessary for safety, security, or emergency procedures at the venue.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process it for specified purposes and in accordance with our instructions.
5. Data Security
We have put in place appropriate technical and organisational security measures to prevent your personal information from being accidentally lost, used, accessed in an unauthorised way, altered, or disclosed. These include:
Restricting access to personal data to those staff/volunteers who need it for their roles.
Using secure servers and password protection for electronic data.
Storing physical records securely.
Providing data protection training to relevant staff/volunteers.
Having procedures to deal with any suspected data security breach and notifying you and applicable regulators where legally required.
6. Data Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, insurance, or reporting requirements.
Membership and participation records are generally kept while the individual is an active member and for a reasonable period afterwards (e.g., up to 3 years) to handle queries or returning members, unless longer retention is required.
Financial records are kept for 6 years plus the current year as required by HMRC.
Accident and safeguarding records may be kept for longer periods in accordance with legal and insurance guidelines (often until the child reaches age 21 or longer for safeguarding concerns).
Data collected solely based on consent (e.g., marketing photos) will be deleted if consent is withdrawn or when no longer needed for the consented purpose.
We will securely delete or anonymise your personal information when it is no longer required.
7. International Data Transfers
Most of your data is stored and processed within the UK or European Economic Area (EEA). Where we use third-party services (e.g., cloud software providers) that may transfer data outside the UK/EEA, we ensure appropriate safeguards are in place, such as UK adequacy regulations or approved contractual clauses (like the UK Addendum to the EU Standard Contractual Clauses), to ensure your data protection rights are maintained.
8. Your Data Protection Rights
Under UK data protection law, you have rights including:
Right of Access: To request copies of the personal data we hold about you.
Right to Rectification: To request correction of inaccurate or incomplete data.
Right to Erasure ('Right to be Forgotten'): To request deletion of your personal data where there is no compelling reason for us to keep holding it.
Right to Restrict Processing: To request suspension of processing under certain circumstances.
Right to Data Portability: To request transfer of your data to another organisation in a structured, commonly used format (where applicable).
Right to Object: To object to processing based on legitimate interests or for direct marketing.
Right to Withdraw Consent: Where we rely on consent (e.g., for photos, marketing), you can withdraw it at any time.
Rights related to automated decision making: We do not currently conduct automated decision-making or profiling with legal or significant effects.
To exercise any of these rights, please contact us using the details below. We may need to verify your identity first.
9. Cookies
Our website (Apex-gymnastics.co.uk) uses cookies. Cookies are small text files placed on your device. Some are essential for the website to function, while others may help us improve the user experience or provide analytics. You can usually manage your cookie preferences through your web browser settings or potentially via settings on our website.
10. Changes to This Privacy Policy
We may update this policy from time to time. The latest version will always be available on our website (Apex-gymnastics.co.uk) and we will notify you of significant changes where appropriate (e.g., via email or notice board). This policy was last updated on the effective date shown above.
11. How to Contact Us & Complaints
If you have any questions about this Privacy Policy, how we handle your personal data, or wish to exercise your rights, please contact us at:
Apex Gymnastics
Email: [email address removed]
Phone: 07714296676
Address: c/o Aspire Centre, 337 Merton Road, London, SW18 5JU
You also have the right to make a complaint at any time to the Information Commissioner's Office10 (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns first.