PRIVACY POLICY
A. HOW WE COLLECT AND WHAT KIND OF INFORMATION WE COLLECT
To provide the Offerings, we need to process your Personal Data. Generally, we collect your information through the following ways:
We collect your Personal Data when you create, register, and maintain a user account with us, contact us, interact with our website, download and use our application, avail of our Offerings, reserve and take classes, or shop in our online store.
We also collect your Personal Data when we ask you to fill up certain forms and documents such as: application forms, data sheets, parental consent sheet, questionnaires, surveys, and the like.
The Personal Data collected depends on the particular Offerings availed of. Generally, we may be asking for your Personal Information such as your name, residential and/or billing address, email, cellphone number, telephone number, purchase history, and your personal preferences when availing of the services (such as your shoe size, bike height, etc.).
We may also be asking Sensitive Personal Information such as details about your health, nationality, birthday, marital status, gender, educational attainment, occupation, family background, government issued data such as your driver’s license, social security number, passport details and the like, and payment information (if any purchase was or is to be made).
There may also be instances when we may request for data that is not enumerated above, however we will specifically notify you what information we need, and why we need it.
If you avail of our Services, we may collect information concerning what classes you take, when and where you take them, and who you take them with. We also log and record your performance during the class. If you participate in the Digital Instruction, live classes are recorded and your video/image and name, may be processed. In addition to those previously mentioned, we also collect information such as: visited route logs, session cookies, and other anonymized data that is collected through your creation of an online account or through the use of our website and on-demand classes.
We may also require that you provide us with your picture, or that we take your picture. This is to ensure and verify the identity of those who avail of our Offerings.
Your Personal Data may also be collected by CCTV cameras operating at each of our locations. It may be possible that images and videos of you may be recorded when you visit any or our studios or when you participate in our online classes.
We may contract the services of third-parties to manage certain aspects of our Services (such as our website and our mobile app). Consequently, these third-parties may be given access to your Personal Data, but rest assured that they shall only process your Personal Data according to our instructions and as may be necessary.
We may also collect any information that does not identify you individually. This may include anonymous, aggregated, or analytical reports; statistical and analytical data; anonymized usage statistics and data; and other forms of anonymized data that we may get from your availment of our Offerings and accessing our Online Channels.
B. HOW WE USE THIS INFORMATION
We use the information we have on you: (i) as described below, (ii) to support our obligations under the Terms and Conditions, and (iii) as otherwise provided for and allowed by law.
We use your information for the following purposes, among others:
- To provide you with an optimal User Experience. We are committed to giving you the best experience that we can provide and this requires the use of your Personal Data. We may use your Personal Data to communicate any information that would be necessary or beneficial to your availment of our Services; updates, concerns, or changes to the Offerings (such as cancellation of classes, change of instructors, expected delivery date, and the like); and to respond to your queries.
- To keep you up to date with our latest products, promotions, and partnerships. We are constantly thinking of new, innovative, and engaging products and experiences – and we would like you to be the first to know about them.
- To ask feedback from you. From time to time, we may ask if you would want to participate in surveys, which are purely optional and do not affect the availment of our Offerings. These surveys give us the opportunity to get your opinion concerning our Offerings, and to make the necessary adjustments to keep you engaged. These surveys may also ask for your opinion on third-party goods or services which we partner with. Any information we receive form these surveys will only be used for the purposes stated in the survey.
- Events, Marketing and Promotions. We may partner with third parties for certain promotional or marketing campaigns, specialty events, and the like. We may use your Personal Data to inform you of events and marketing campaigns which we think may be of interest to you.
- To make the content we communicate more relevant to you. We may use your Personal Data such as your nationality, marital status, educational attainment, occupation, gender, and age, to provide you with tailor-made content, information, promotions, discounts, advertisements, and other marketing and promotional materials, that we believe would interest you.
- To make sure we keep you safe. Before you participate in any of our classes, we will require that you disclose certain health and medical information as it would be unadvisable for persons with certain medical conditions to participate in some aspects of our Offerings. As much as we would want you to be part of the Electric Studio family, we value your safety more than anything else.
- To make sure we can reach someone if something happens to you. Before you participate in our classes, we require the designation of an emergency contact who will be contacted if something happens to you. We may ask for the name, age, marital status, contact details, address, and your relation to your emergency contact.
- To make sure that you are you. As part of our safety and security measures we may require you to present competent evidence of identity (such as a government issued or company ID). We want to make sure that the people who avail of our services are who they say they are
- To help our subsidiaries, affiliates, and third-party service providers serve you better. We hire third party service providers to handle certain aspects of our business operations. Your personal information such as your name, contact details, payment information, address, nationality, and age are passed to these service providers. Rest assured, these service providers only process your Personal Data to the extent we instruct them to.
- To comply with law and regulation. There may be instances where we must process your data in order to comply with law, legal processes, or other regulations; to prevent imminent harm to public security, public safety, public order; to fulfill functions of public authority which necessarily includes the processing of Personal Data for the fulfillment of its mandate; or to prevent fraud and/or other criminal acts.
- To protect our lawful rights and interests in court proceedings. We may use your Personal Data when it becomes necessary or beneficial for the protection of our lawful rights and interest in any arbitration, court proceedings, or the establishment, exercise, or defense of any and all legal claims and defenses.
- Research. One way for us to serve you better is to conduct research. We collect and use anonymized, aggregated data and analytics which we may share with our affiliates, service providers, subsidiaries, business partners, and the like. These entities help us research, analyze, and evaluate the effectiveness our Offerings.
C. HOW YOUR INFORMATION IS SHARED AND TO WHOM DO WE SHARE YOUR DATA
In some instances, we may share your Personal Data to people and entities that we trust such as:
- Affiliates, Subsidiaries, and External Business Partners. We may from time to time use your Personal Data on behalf of our affiliates, subsidiaries, and external business partners concerning certain products and services that they would want you to know about, and what we think would interest you.
- To our Trusted Service Providers and Contractors. We may disclose the Personal Data that you provide us to our third-party service providers, contractors, vendors, and representatives, who perform functions, service, or activities for us, or directly for you, on our behalf (“Trusted 3rd Parties”).
- Digital Integration. There may be times where you will have option to integrate your social media accounts, or any other accounts maintained by any other providers (“Digital Services”) with us. If you choose to do so, your Personal Data with the Digital Services will be shared and can be used by us, and the Personal Data you have with us can be shared and used by the Digital Services.
- To those we merge with or those that acquire us. If Purefitness, Inc./Electric Studio is acquired by or is merged with another company, or by any other act or proceeding through which the ownership of Purefitness, Inc./Electric Studio changes, the Personal Data that we possess may be transferred to the acquiring or merged company.
- To comply with legal obligations. We may be required, ordered, or mandated by a competent public authority to disclose your Personal Data, whether it be to comply with law, court order, subpoena, or any other legal process; or pursuant to a judicial, administrative, or any other official proceeding.
- To protect our lawful rights and interests in court proceedings. We may disclose your Personal Data when it becomes necessary or beneficial to protect our lawful rights and interest in any arbitration, administrative or court proceeding; or to establish, exercise, or defend any and all legal claims.
D. WHERE WE KEEP YOUR INFORMATION AND HOW WE MAKE SURE IT’S SAFE.
Where we keep your data. We avail of the services of reputable and trusted service providers, such as those provided by Amazon Web Services, Inc.
How we keep your data safe. When it comes to data security, we look after both digital and physical data. ¬We try to secure your Personal Data from unauthorized access, use, disclosure, or processing. To further this goal, we have adopted certain technical and organizational measures necessary to ensure the security of your data.
However, while we cannot guarantee the absolute security and impenetrability of our database, we will take all the necessary measures, according to reasonable industry standards and practices to keep your data safe.
While we try to keep our systems safe, we cannot control external factors (such as the safety of your computer or mobile phone, the network you are using, the servers you are being routed through, and the like). When you transmit information to us via our website, mobile app, or any other online means, we cannot guarantee the security of your Personal Data. Your Personal Data passes through various channels where it may be intercepted, corrupted, disclosed, or misused. But rest assured, once we receive your information, we will use our implemented safety features and procedures to ensure that your data is kept safe from any unauthorized access.
When we provide you with our services, there may be times that you may come across links that will direct you to other websites. Unless we own, operate, and/or manage these other websites we cannot and do not take responsibility over how they collect, use, process, store, or protect the data which you provide.
In addition to the above, we may allow third parties to exhibit their goods or services in-studio or during our pop-up events; it’s up to you whether you want to share your Personal Data with these third parties. Unless we own and operate these third parties we cannot and do not take responsibility for how they collect, use, process, store, or protect the data which you provide.
E. HOW LONG WE KEEP YOUR DATA.
As may be necessary pursuant to law. Under the law there are different periods for which actions may be brought. For example, actions based on written contracts prescribe in ten (10) years. We may store Personal Data for an additional period of five (5) years after the prescriptive period lapses. We may also store and keep your data when and for the period required by laws, regulations, and legal obligations.
The periods as stated in this section may be extended if there is a legal obligation and/or requirement to do so.
F. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM
Under the Data Privacy Act of 2012, you as a data subject have rights. Below is a brief description of your rights and how you can enforce them.
- Submit a notarized written request addressed to our DPO, attaching the same identification card used in the notarization.
- State in your written request that you wish to exercise your Right to Access in accordance with the Data Privacy Act of 2012
- Specify in the written request
- What Personal Data you wish to inquire about;
- Through what means you wish us to send your Personal Data to you (email, courier service, etc. Note: We will not send Personal Data through fax); and
- Your contact information that we can use to communicate with you.
- Have this written request received by our DPO, his/her duly authorized representative.
- We will inform you of our decision on your request fifteen (15) days from our receipt of your written request.
- If we grant your data request, we will send an invoice representing the estimated reproduction costs. You will have fifteen (15) days from your receipt of the invoice to settle payment. We will release your data request within ten (10) days from receipt of payment. Furthermore, if the data request is sent through couriers, the reckoning point for our compliance with the ten-day period is date of delivery to the courier, and not your receipt of the data request.
- The release of the data request will only be made to the person whose Personal Data is subject of the data request. A notarized authorization letter shall be required if the data request will be released to a third-party/ courier.
- Send a notarized written request to our DPO along with a copy of any valid government issued ID with a picture and signature.
- State in your written request that you wish to exercise your Right to Object in accordance with the Data Privacy Act of 2012.
- State and specify ALL the following in the written request:
- A statement that you object or no longer want us to process your Personal Data;
- Indicate what data or class of data is covered by your objection or withdrawal of consent;
- Indicate for what particular purpose you object or withdraw your previously given consent.
- Have this written request received by our DPO, or his/her duly authorized representative.
- We will inform you of our action on your request fifteen (15) days from our receipt of your written request.
- We may reject your request if the procedures above are not followed, in which case, you would have to re-submit your request in a manner compliant with the above.
- If you object or withdraw your consent to our use of your data, and such objection or withdrawal results in our being unable to provide the Offerings according to our standards, we retain the right and prerogative to refuse you the Offerings.
- If you object and/or withdraw consent to the processing of your data which makes us unable to offer you our products and/or services, these may be reinstated by renewing your consent.
- We may require certain Personal Data to maintain a level of diligence in the conduct of our business. If you withdraw your consent or object to our processing of your data, and it hinders us from maintaining the level of diligence that we deem necessary, we retain the right and prerogative to refuse you our Offerings.
- If we ask for your consent to process your data in a new way, and you object to this new manner of processing, your objection is only related to the new purpose of processing, and it will not be considered as a revocation of consent previously given.
- If you withdraw your consent or object to our processing of your Personal Data for a particular purpose, you acknowledge that you only withdraw your consent or object to our processing as to that purpose, and we may still process your Personal Data further to other purposes you have consented to.
- If you consent to our processing of your Personal Data, subsequent your exercise of the Right to Object, you acknowledge that your previous written request shall be deemed abandoned.
- Under the IRR of the DPA, there are instances where we may process your personal information, notwithstanding your objection.
- Send a notarized written request to our DPO along with a copy of any valid government issued ID with a picture and signature.
- State in your written request that you wish to exercise your Right to Erasure or Blocking in accordance with the Data Privacy Act of 2012.
- Specify in the written request:
- The particular data or class of data you want erased or the particular data or class of data you no longer want processed;
- What circumstance under Section 34 (e)(1) of the Implementing Rules of the DPA you are invoking; and
- Indicate for what particular purpose (i.e. how we use your data) you want your data blocked and/or erased.
- Have this written request received our DPO, or his/her duly authorized representative
- We will inform you of our action on your request fifteen (15) days from our receipt or acknowledgement of our receipt of your request.
- We may reject your request if the procedures above are not followed. In which case, you would have to re-submit your request in a manner compliant with the above.
- If your request results in our inability to effectively provide our Offerings, according to our standards, we retain the right and prerogative to refuse you the Offerings.
- There may also be some Personal Data that we have to process to maintain a certain level of diligence in the conduct of our business. If your request hinders us from maintaining the level of diligence that we deem necessary, we retain the right and prerogative to refuse you the Offerings.
- We may still process Personal Data subject of the request for erasure or blocking for those purposes that are not enumerated in 3(c) of the above.
- If you consent to our processing of your Personal Data subsequent to your request for erasure and/or blocking, you acknowledge that your request shall be deemed abandoned.
- Send a notarized written request to our DPO along with a copy of any valid government issued ID with a picture and signature.
- State in your written request that you wish to exercise your Right of Rectification in accordance with the Data Privacy Act of 2012.
- Specify and attach the following to the written request:
- The erroneous data that you wish to have corrected;
- Summary of the correct data to be entered;
- Documentary proof supporting the correction; and
- A statement certifying that the documentary proof submitted is genuine and a true and correct copy of the original.
- Have this written request received our DPO, or his/her duly authorized representative.
- We may reject your request if the procedures above are not followed. In which case, you would have to re-submit your request in a manner compliant with the above.
- We reserve the right to refuse your request for rectification if it is vexatious or otherwise unreasonable.
- We may deny your right to rectification if the suggested corrections are not supported by or inconsistent with the documentary proof.
- Submit a notarized written request addressed to our DPO, attaching the identification card used in the notarization.
- Have this written request received by our DPO, or his/her duly authorized representative.
- State in your written request that you wish to exercise your Right to Data Portability in accordance with the Data Privacy Act of 2012.
- Specify in the written request:
- What Personal Data you wish to be made portable;
- Through what means you wish us to send your Personal Data to you; and
- Your contact information.
- From the time that you file your written request, we will respond within fifteen (15) days from our receipt of your written request.
- If we grant your request, we will send an invoice representing the anticipated costs for the collation, reproduction, duplication, and releasing of your Personal Data. You will have fifteen (15) days to settle payment from your receipt of the invoice, and we will release your data ten (10) days from our receipt of payment.
- The release of the data request will only be made to the person whose Personal Data is subject of the data request. A notarized authorization letter shall be required if the release of the data request will be made to a third-party/courier.
107 Valero St. Salcedo Village, Makati