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SG GYM LTD PRIVACY POLICY

​Last updated: 12 August 2026

​

1. INTRODUCTION

SG Gym Ltd ("SG Gym", "we", "us" or "our") is committed to protecting the privacy and personal information of our members, visitors and customers.

This Privacy Policy explains how we collect, use, store and protect personal information when you:

  • Become a member of SG Gym;

  • Use our gym facilities;

  • Use the Gymflow app;

  • Access the gym using our Kisi access-control system;

  • Make payments to us;

  • Visit or use our website;

  • Contact us;

  • Purchase products from the SG Shop; or

  • Otherwise interact with SG Gym.

We process personal information in accordance with applicable UK data-protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR) and applicable provisions of the Data (Use and Access) Act 2025.

We aim to be transparent about what information we collect, why we collect it, who we share it with and how long we keep it.

 

2. WHO WE ARE

The organisation responsible for your personal information is:

SG Gym Ltd
Unit 10 Salisbury Road Business Park,
Pewsey
Wilsthire
SN9 5PZ
United Kingdom

Email: sg.gym@hotmail.com

SG Gym Ltd is the data controller for the personal information we collect and process in connection with our business.

As the data controller, SG Gym determines the purposes for which member information is collected and how it is used.

 

3. WHAT PERSONAL INFORMATION WE COLLECT

The information we collect depends on how you interact with SG Gym.

Personal and contact information may include:

  • Full name

  • Date of birth

  • Home address

  • Email address

  • Telephone number

  • Membership details

  • Membership start and end dates

  • Membership status

  • Information relating to your account

Identification information:
We require members to provide a simple photograph of themselves when joining SG Gym. The photograph is used for identifying members, confirming that the correct person is using the membership, preventing membership sharing and unauthorised access, and general gym security. The photograph is stored within Gymflow. SG Gym does not use this photograph for automated facial-recognition technology.

Emergency contact information may include:

  • Emergency contact name

  • Telephone number

  • Relationship to the member

Membership and usage information may include:

  • Membership information

  • Membership payments

  • Check-ins

  • Bookings where applicable

  • Access to the gym

  • Communications with SG Gym

  • Membership breaches

  • Incidents

  • Complaints or enquiries

Payment information may include details relating to membership payments, recurring payments, purchases, refunds, failed payments, payment disputes and amounts owed to SG Gym. Card payment information is processed through Stripe. SG Gym does not routinely store complete payment-card details such as your full card number or security code on our own systems.

Website information may include IP address, browser type, device information, website usage information, information submitted through forms, technical information and cookie/similar technology information.

 

4. HOW WE COLLECT YOUR INFORMATION

We may collect personal information directly from you when you:

  • Apply for membership;

  • Complete your member profile;

  • Provide identification information;

  • Provide an emergency contact;

  • Make a payment;

  • Use our website;

  • Contact us;

  • Use Gymflow;

  • Use the gym;

  • Enter or leave the gym;

  • Make a purchase from the SG Shop; or

  • Report an incident or issue.

We may also collect information automatically through:

  • Kisi access-control systems;

  • CCTV;

  • Gymflow;

  • Our website; and

  • Other technology used to operate and secure the gym.

 

5. WHY WE COLLECT AND USE YOUR INFORMATION

We collect and use personal information where necessary to operate SG Gym, provide your membership and protect our members, staff, property and business.

Managing your membership:

  • Set up your membership;

  • Manage your account;

  • Confirm your identity;

  • Provide access to the gym;

  • Manage membership payments;

  • Manage bookings and services;

  • Communicate with you;

  • Provide customer support; and

  • Deal with membership enquiries.

Gym security:

  • Ensure that only authorised members access the gym;

  • Confirm that the correct person is using a membership;

  • Prevent membership sharing;

  • Investigate unauthorised access;

  • Monitor access to the premises;

  • Protect members and visitors;

  • Protect SG Gym property; and

  • Investigate incidents.

Safety and emergencies:

  • Respond to emergencies;

  • Contact your nominated emergency contact where appropriate;

  • Investigate accidents and incidents;

  • Protect the safety of members and visitors; and

  • Cooperate with emergency services where necessary.

Preventing theft, fraud and misuse:

  • Investigate suspected theft;

  • Investigate unpaid purchases;

  • Identify members involved in incidents;

  • Investigate membership misuse;

  • Recover amounts owed to SG Gym;

  • Protect our business and property; and

  • Enforce our membership terms and conditions.

Legal and regulatory purposes:

  • Comply with legal obligations;

  • Maintain financial and accounting records;

  • Respond to lawful requests from authorities;

  • Establish, exercise or defend legal claims; and

  • Protect our legal rights and interests.

 

6. OUR LAWFUL BASES FOR PROCESSING

UK data-protection law requires us to have a lawful basis for processing personal information.

Contract
We process information where it is necessary to provide your membership and fulfil our contractual obligations. For example, we need your name, contact details and other relevant information to create and administer your membership.

Legal obligation
We may process personal information where necessary to comply with a legal obligation, including tax, accounting, legal and regulatory requirements.

Legitimate interests
We may process information where it is necessary for our legitimate interests, provided those interests do not override your fundamental rights and freedoms. These interests may include operating SG Gym, providing a safe and secure gym, preventing unauthorised access, preventing theft and fraud, protecting members and visitors, protecting our property, investigating incidents, enforcing membership terms, managing disputes, recovering money owed to us and protecting our legal interests.

Vital interests
In limited circumstances, we may process information where necessary to protect someone's vital interests, for example during a serious emergency.

 

7. MEMBER PHOTOGRAPHS

As part of our membership process, members are required to provide a simple photograph of themselves.

This photograph is used to help SG Gym:

  • Confirm the identity of members;

  • Ensure the correct person is using a membership;

  • Prevent membership sharing;

  • Prevent unauthorised access; and

  • Maintain gym security.

The photograph is stored within Gymflow and is not routinely shared with unrelated third parties.

SG Gym does not use automated facial-recognition technology to identify members.

A normal photograph is personal information but is not automatically classified as biometric special-category data under UK data-protection law.

 

8. EMERGENCY CONTACTS

Members may be asked to provide an emergency contact.

Emergency contact information is stored within Gymflow and is used only where reasonably necessary, including where there is an emergency, a serious incident occurs, or it is reasonably necessary to contact the nominated person for the member's safety.

Members should ensure that their nominated emergency contact is aware that their information has been provided to SG Gym.

 

9. HEALTH AND FITNESS

SG Gym does not routinely require members to provide detailed medical records, diagnoses, medication information or medical histories.

Members are responsible for ensuring that they are physically and medically fit and able to participate in exercise and gym activities.

By joining and using SG Gym, members acknowledge that they are responsible for determining whether exercise is suitable for them and should obtain appropriate medical advice where necessary.

If a member voluntarily provides health information to SG Gym, for example following an injury or incident, we will only use that information where reasonably necessary.

Where health information constitutes special category personal data, we will only process it where an appropriate lawful basis and special-category condition applies.

 

10. CCTV AND VIDEO SURVEILLANCE

SG Gym operates CCTV for security, safety, crime prevention and incident investigation.

CCTV operates 24 hours a day, 7 days a week.

Cameras cover areas including:

  • External areas;

  • Gym entrance;

  • Reception;

  • SG Shop;

  • Hallways;

  • Main gym; and

  • Cardio room.

There are no CCTV cameras inside toilets or shower facilities.

​

CCTV is used to:

  • Protect members and visitors;

  • Protect SG Gym property;

  • Prevent and investigate theft;

  • Prevent unauthorised access;

  • Investigate membership misuse;

  • Investigate accidents and incidents;

  • Assist with security;

  • Establish, exercise or defend legal claims; and

  • Provide information to the police, emergency services or other lawful authorities where appropriate.

​

CCTV recordings are stored remotely and are accessible only to authorised persons who have a legitimate reason to access them.

CCTV recordings are normally retained for 14 days and then automatically deleted.

Where a recording is relevant to an ongoing incident, complaint, insurance matter, investigation or legal claim, SG Gym may retain the relevant footage for longer where reasonably necessary.

SG Gym will not retain CCTV recordings indefinitely.

Our use of CCTV is primarily based on our legitimate interests in protecting our members, visitors, property and business and preventing and investigating crime and other incidents.

 

11. KISI ACCESS CONTROL

SG Gym uses Kisi electronic access-control technology to provide secure access to the gym.

When you access the gym, Kisi may record information such as:

  • Your identity or member identifier;

  • Date and time of access;

  • Access events; and

  • Information relating to the access-control system.

Access information is used to:

  • Provide authorised access;

  • Maintain gym security;

  • Confirm appropriate use of memberships;

  • Investigate unauthorised access;

  • Investigate membership sharing;

  • Investigate incidents; and

  • Protect members and SG Gym property.

Access records are normally retained for 12 months.

Specific access records may be retained for longer where necessary to investigate an incident, resolve a dispute, establish or defend a legal claim or comply with a legal obligation.

 

12. GYMFLOW

SG Gym uses Gymflow to manage memberships and member information.

Gymflow may process information including:

  • Name;

  • Address;

  • Date of birth;

  • Email address;

  • Telephone number;

  • Membership information;

  • Membership status;

  • Member photograph;

  • Payment-related information;

  • Check-in information;

  • Booking information where applicable;

  • Emergency contact information;

  • Communications; and

  • Information relating to membership incidents.

Gymflow provides the software infrastructure used by SG Gym to manage these services.

SG Gym remains responsible for determining why member information is processed.

 

13. PAYMENTS AND STRIPE

SG Gym uses Stripe to process payments.

Stripe may process payment information required to:

  • Take membership payments;

  • Process recurring payments;

  • Process purchases;

  • Process refunds;

  • Deal with failed payments;

  • Handle payment disputes; and

  • Maintain appropriate payment records.

SG Gym does not routinely store complete payment-card details on its own systems.

Payment information is processed through Stripe's payment infrastructure.

 

14. WEBSITE AND WIX

Our website is hosted and operated using Wix.

Wix and technologies used on our website may collect information including:

  • IP address;

  • Device information;

  • Browser information;

  • Website usage information;

  • Information submitted through contact forms;

  • Technical information; and

  • Cookie information.

The information collected will depend on the functions and technologies enabled on our website.

We do not deliberately use website analytics to identify individual visitors unless the visitor voluntarily provides identifying information.

 

15. EMAIL AND COMMUNICATIONS

SG Gym uses email to communicate with members and customers.

We may send communications relating to:

  • Memberships;

  • Payments;

  • Account information;

  • Important gym announcements;

  • Changes to services;

  • Safety information;

  • Facility updates;

  • Operational information;

  • Membership terms;

  • Responses to enquiries; and

  • Incidents involving your membership.

These communications are necessary service or administrative communications where they relate to your membership or our operation of the gym.

We use Gmail and related email services to manage communications.

We do not sell your email address or routinely provide it to unrelated third parties for their own marketing purposes.

 

16. MARKETING

SG Gym may send promotional communications about our services, offers, products or other activities where permitted by applicable law.

We will comply with applicable requirements under PECR and UK data-protection legislation.

You can object to direct marketing at any time.

Where you object to marketing, we will stop sending promotional communications, subject to any limited information we need to retain to ensure your marketing preference is respected.

Important membership and service communications will continue where they are necessary for your membership or our contractual relationship with you.

 

17. WHO WE SHARE YOUR INFORMATION WITH

SG Gym does not sell, rent or trade personal information.

We may share information with trusted organisations where reasonably necessary to operate our business.

These may include:

  • Gymflow – membership management and member information;

  • Kisi – gym access control and access records;

  • Stripe – payment processing;

  • Wix – website hosting and website services;

  • Gmail/email providers – communications;

  • Professional advisers such as accountants, solicitors and insurers where reasonably necessary; and

  • Police, emergency services, courts, regulators or other authorities where required or permitted by law.

We may also share information where necessary to protect SG Gym, protect members, protect staff or contractors, prevent crime, investigate incidents, recover money owed, establish legal rights or defend legal claims.

 

18. PERSONAL TRAINERS AND CONTRACTORS

Certain authorised personal trainers, contractors or other individuals working with SG Gym may have limited access to information where necessary to perform their role.

Access will be limited to information that is reasonably necessary.

Personal trainers and contractors must not use member information for their own purposes or contact members using information obtained through SG Gym unless authorised to do so.

Information may be used to contact a member in an emergency where reasonably necessary.

 

19. SG SHOP

SG Gym operates a self-service shop.

Where a product is taken without payment, we may use relevant information to investigate the incident, including:

  • CCTV;

  • Membership information;

  • Access records; and

  • Transaction information.

Where we reasonably identify the member responsible, we may contact them and, where permitted under the applicable membership terms, charge the relevant amount to their account.

We may also restrict or suspend membership access where permitted under our membership terms and take further appropriate action where necessary.

CCTV relating to an incident will normally be deleted after 14 days unless it needs to be retained for an ongoing investigation, complaint, insurance matter or legal claim.

 

20. DATA SECURITY

We take reasonable technical and organisational measures to protect personal information against:

  • Unauthorised access;

  • Unauthorised disclosure;

  • Accidental loss;

  • Destruction;

  • Damage;

  • Unauthorised alteration; and

  • Other unlawful processing.

Access to personal information is restricted to people who have a legitimate reason to access it.

Where we use third-party service providers, we take reasonable steps to ensure appropriate data-protection and security arrangements are in place.

However, no electronic system can be guaranteed to be completely secure.

 

21. HOW LONG WE KEEP YOUR INFORMATION

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, unless we are required or permitted by law to retain it for longer.

Our current retention periods include:

Active membership information — While membership is active.
Former member information — Retained where reasonably necessary, including where a member may reactivate.
CCTV — 14 days.
Kisi access records — 12 months.
Emergency contact information — While reasonably required.
Incident records — As long as reasonably necessary.
Payment/accounting information — As required by applicable legal and accounting requirements.
Marketing records — Until withdrawal of consent or objection, where applicable.

Where an incident, complaint, dispute, insurance matter or legal claim requires information to be retained for longer, we may retain the relevant information for as long as reasonably necessary.

 

22. YOUR DATA PROTECTION RIGHTS

Subject to applicable legal exemptions and restrictions, you may have the right to:

Access your information — You can ask us for a copy of the personal information we hold about you.

Correct your information — You can ask us to correct inaccurate or incomplete information.

Request deletion — You may ask us to delete your personal information in certain circumstances.

Restrict processing — You may ask us to restrict how we use your personal information in certain circumstances.

Object to processing — You may have the right to object to certain processing, particularly where we rely on legitimate interests. You have an absolute right to object to direct marketing.

Data portability — In certain circumstances, you may have the right to receive certain personal information in a structured, commonly used and machine-readable format.

Withdraw consent — Where we rely on consent as our lawful basis, you can withdraw your consent at any time. Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

 

23. CCTV ACCESS REQUESTS

You may have the right to request a copy of CCTV footage containing your personal information.

If you wish to make a CCTV access request, please contact us as soon as possible and provide:

  • The date;

  • Approximate time;

  • Location; and

  • Any other information that may help us identify the relevant recording.

CCTV recordings are normally automatically deleted after 14 days.

CCTV footage may contain images of other people. Where appropriate, we may need to redact or otherwise protect information relating to other individuals.

We may also be entitled to refuse or restrict a request where a legal exemption applies.

 

24. YOUR RIGHT TO COMPLAIN

If you have concerns about how SG Gym has handled your personal information, please contact us first.

We will investigate your concern and seek to resolve it.

Email: sg.gym@hotmail.com

Post:
SG Gym Ltd

Unit 10 Salisbury Road Business Park
Pewsey
Wiltshire
SN9 5PZ

​

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data-protection regulator.

ICO website: https://ico.org.uk/make-a-complaint/

 

25. INTERNATIONAL DATA TRANSFERS

Some of the third-party service providers used by SG Gym may process personal information outside the United Kingdom.

Where personal information is transferred outside the UK, SG Gym will ensure that the transfer is made in accordance with applicable UK data-protection law.

Where required, appropriate safeguards will be used, which may include adequacy regulations, appropriate contractual safeguards or another lawful transfer mechanism.

 

26. COOKIES

Our website may use cookies and similar technologies.

Cookies may be used for purposes including:

  • Website functionality;

  • Security;

  • Website performance;

  • Analytics; and

  • Other website functions.

Some cookies are necessary for the website to operate.

Where required by law, we will seek consent before using non-essential cookies or similar technologies.

You can manage available cookie preferences through the cookie controls provided on our website.

Our use of cookies will comply with applicable requirements under PECR and UK data-protection law.

 

27. CHILDREN

SG Gym memberships are available only to individuals aged 18 years and over.

We do not knowingly provide gym memberships to anyone under the age of 18.

 

28. AUTOMATED DECISION-MAKING

SG Gym does not currently use personal information to make decisions about members based solely on automated processing which produce legal or similarly significant effects.

If this changes, we will update this Privacy Policy and provide any information required by applicable law.

 

29. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our services, technology, suppliers, processing activities, applicable legislation or regulatory guidance.

The latest version will be made available on our website.

Last updated: 12 August 2026.

 

30. CONTACT DETAILS

If you have any questions about this Privacy Policy or how SG Gym processes your personal information, please contact us:
SG Gym Ltd

Unit 10 Salisbury Road Business Park
Pewsey
Wiltshire
SN9 5PZ

Email: sg.gym@hotmail.com

​

We will deal with privacy requests in accordance with applicable UK data-protection legislation.

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