Equipment Privacy Policy (LMME)
Last updated 16 May 2023
LES MILLS PRIVACY POLICY
Les Mills is committed to protecting and respecting your privacy.
This policy (together with our website terms of use and any other policy developed on this website from time to time and notified on any part of the site) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
This policy may change from time to time and, if it does, the latest version will be available on our website or our app (and, where appropriate, brought to your attention).
Please note that this privacy policy only deals with equipment purchases and your use of our shop website. There are separate privacy policies for lesmills.com which can be found here as well as lesmillsondemand.com and the LES MILLS+ App which can be found here.
KEY POINTS:
- Les Mills Middle East Fitness LLC is the data controller of personal data processed through your purchase of equipment and use of our website.
- The type of the personal data processed by us includes information that you provide when purchasing equipment, using our website, technical information about your device, settings and website use, information that we receive from third parties, such as other website providers, ad networks.
- We use your data, amongst other things, to provide you with our site and allow you to purchase equipment, fulfil and track your order of equipment, attend to after-sales activities such as refunds and returns, analyse our site and equipment sales, and provide (or allow others to provide) targeted ads.
- We may send you marketing materials relating to the Les Mills Companies, which you can opt out of at any time.
- We share data with our service providers and other third parties to receive and fulfil your equipment order, to provide you with information and to serve advertising.
- You have a number of rights that you may exercise in relation to our use of your personal data, and you may exercise these by contacting us through the communication methods set out in the 'Your rights' section below.
WHO WE ARE
This website (the “site”) is controlled by Les Mills Middle East Fitness LLC. (“we”, “us”, “our”) whose registered office is at Bay Square, Al Abraj Street, Business Bay, Dubai. We are a wholly owned subsidiary of Les Mills International Limited (“LMI”).
In this Privacy Policy the “Les Mills Companies” means all subsidiaries and affiliate companies from time to time owned by LMI. If you require a full list of entities comprising the Les Mills Companies, please contact us as described in the “Contact” section below.
INFORMATION WE COLLECT FROM YOU
We will collect and process the following information about you:
INFORMATION YOU GIVE US
This is information about you that you give us when you browse or use the site, correspond with us by phone, SMS, email, or otherwise. It includes information you provide when:
- you use a ‘Contact Us’ form on our site;
- place an order for our equipment with our reseller (or very rarely, directly with us); or
- you report a problem with our site.
Normally equipment orders are placed directly with our reseller, and your personal data will be held and dealt with by them under their own privacy policy. You must create an account and you give personal data directly to our reseller. We don’t receive any of it, only aggregated sales reports. On the rare occasion you place an order directly with us, the information you give us includes your name, address, date of birth, e-mail address, billing address and phone number, payment information such as credit card number.
INFORMATION WE COLLECT ABOUT YOU
With regard to each of your visits to our site we will collect the following information with your consent where required under applicable privacy laws:
- technical information, including the IP address used to connect your computer or device to the Internet, your login information, browser type and version, time zone setting, anonymised location data, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full URL, clickstream to, through and from our site (including date and time), pages or products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
HOW YOUR INFORMATION WILL BE USED
We use information held about you in the following ways:
A. We process data for the following purposes based on your consent:
- to provide you with information about other services we offer;
- to ensure that content from our site is presented in the most effective manner for you and for your computer;
- to tailor your experience on the site;
- to administer our site and for internal operations, including for data analysis, testing, research, statistical, editorial, feedback and survey purposes;
- to provide (or permit third parties to provide) targeted advertising via websites you visit about goods or services that you may find interesting (see more on this below in the section on "Disclosure of your Information" and in our Cookie Notice and Cookie Declaration) and to measure or understand the effectiveness of that advertising.
B. On the rare occasion you place an order directly with us, we will process data for the following purposes based on our performance of a contract:
- to fulfil any equipment order or discuss delayed or incomplete equipment orders with you;
- to process your payment and follow up with any failed payments;
- to respond to your queries; and
- to attend to after-sales activities such as refunds and returns.
C. We will process data where necessary to comply with legal and regulatory requirements.
DISCLOSURE OF YOUR INFORMATION
SERVICE PROVIDERS
For some of the purposes for which we use personal data (see above), we will engage a third party. If that third party provider needs access to personal data to carry out its task, we will share the data with them and we will ensure that the third party will only use the data based on our instructions. Any such third parties are processors acting on our behalf and we remain responsible for your data. We will engage companies that provide technical services to us (including Les Mills Companies), such as vendors, service providers, and other partners who globally support our business. These third parties provide services such as providing secure payment mechanisms, technical infrastructure services, analyzing how our site is used, measuring the effectiveness of ads and services, or conducting surveys. Where we transfer your data to service providers in another country, we will take steps to protect your personal data consistent with applicable privacy laws, including the UAE Federal Data Protection Law No 45 (2021). These partners must also adhere to strict confidentiality obligations in a way that is consistent with this policy and the agreements we enter into with them.
ANALYTICS AND ADVERTISERS
We will, when we have the right to do so according to applicable personal data regulations, share your personal data with advertisers and advertising networks that require the data to select and serve relevant advertising to you and others. These third-party advertising companies collect, store and use data by integrating cookies and other tracking software on our Services. In some cases these third parties will also use the data that they collect for their own purposes, for example, they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients and work with other advertising companies and share collected information with such companies as part of the process. Please see our Cookie Notice and Cookie Declaration for more information on the third-party advertising companies which may collect, use, process and store data about you, and the use of cookies and other tracking technologies on our services with your consent.
DISCLOSURE UNDER CERTAIN CIRCUMSTANCES
We will when we have the right to do so according to applicable personal data regulations also disclose your personal data to third parties in the following circumstances:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to appropriate confidentiality arrangements;
- If Les Mills Middle East Fitness LLC or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms of use (https://www.lesmills.com/ae/terms-of-use/) and other agreements; or to protect the rights, property, or safety of any Les Mills Company, or others.
- Where you have otherwise consented that we may do so.
DATA RETENTION
We retain the personal data we collect only if we need it to only for as long as is necessary to respond to any queries or complaints, improve the services that we offer to you, comply with any legal obligations to which we may be subject and for other internal business requirements or when our lawful purposes for using the information requires retention. When we no longer require personal data we or our third party suppliers will securely delete and/or archive the information. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at privacy@lesmills.com.
SECURITY OF YOUR INFORMATION
To help protect the privacy of data and personal data you transmit through use of our site and portals, we maintain physical, technical and administrative safeguards.
We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Further details on the steps we take to protect your personal data, in these cases is available from us on request by contacting us by email at privacy@lesmills.com at any time.
LINKED SITES
This site, our newsletters and other communications will from time to time contain links and/or banners that take you to other websites. We are not responsible for the reliability of the content or privacy practices of such other websites.
CHILDREN
We do not knowingly collect information from children under the age of majority as determined by the laws of the applicable jurisdiction in which we are operating and the site and any associated apps are not targeted to such children. We encourage parents and guardians to take an active role in their children’s online activities and interests. Please contact us at privacy@lesmills.com if you are aware that we may have inadvertently collected personal data from a child.
YOUR RIGHTS
Right of access
You may have the right to request certain information from us about processing we perform using your personal data such as the categories and purposes of processing your personal data, any automated decision-making, target sectors or enterprises with whom we share information, and other information as set out in relevant data privacy laws.
Portability
You have the right to receive the personal data that you have provided to us in a structured and machine-readable format, and to transmit that data to another data controller. This right is limited to personal data where we rely on your consent or performance of a contractual obligation to obtain it, and the processing is performed by automated means.
Right of correction
You can request that we correct (rectify) the record of your personal data maintained by us if it is inaccurate, incomplete or out of date.
Right of erasure
You have the right to request that we erase your personal data or cease processing it in certain situations, such as if we rely on your consent to use it and you withdraw it or it is no longer necessary to continue to hold the personal data for the reasons it was collected. There are some exceptions to this right set out in the law.
Right to restrict or stop processing
You have the right to require us to restrict and/or stop using your personal data including where you think it is not accurate, it’s for direct marketing purposes (see ‘Marketing opt-out option’ below), you think our use of it is contrary to agreed purposes or where personal data processed in non-compliance with the law. Of course, we intend to never over-collect personal data and to comply with the law. There are some exceptions to this right set out in the law.
Right to require retention
You have the right to require us to keep the personal data where it is necessary to pursue or defend legal proceedings.
Right to object to automated decision-making
You have the right to object to review decisions we may have made based on automatic decision-making using your personal data that have legal implications or seriously affect you, including profiling, subject to certain exceptions set out in law. We don’t currently perform any automatic decision-making using your personal data for your equipment purchases.
Withdrawing Consent
If we rely on your consent to use your personal data in a particular way, but you later change your mind, you may withdraw your consent by contacting us at privacy@lesmills.com and we will stop doing so. However, if you withdraw your consent, this may impact our ability to be able to provide you with some services (for example, we may not be able to provide marketing information to you).
Marketing opt out option
You have the right to decline our use of your personal data for (or opt-out of) marketing communications. If you do so, your name will be excluded from any contact of that type in the future unless you later request or agree to future contact. You can “opt-out” by:
- using the contact details provided for this purpose in our mailing to you;
- using the “unsubscribe” option at the foot of any electronic communication we send to you; or
- by emailing us at any time at info@lesmills.com.
If you wish to exercise any of the above rights other than marketing opt-out, please send your request to privacy@lesmills.com.
CHANGES TO OUR PRIVACY POLICY
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@lesmills.com.
Our registered office is at Bay Square, Al Abraj Street, Business Bay, Dubai.