STRENGTH CARTEL LIMITED – PRIVACY POLICY
Last updated: 09/12/2025
Company: Strength Cartel Limited
Address: Ennerdale Mill, Egremont, Cumbria, United Kingdom, CA22 2PN
Email: info@strengthcartel.co.uk
Strength Cartel Limited (“we”, “us”, “our”) is committed to protecting your privacy and ensuring that your personal data is handled lawfully, securely, and transparently. This Privacy Policy explains how we collect, use, store, and share your personal information when you become a member, use our website, interact with our mobile applications, or visit our facilities.
1. DEFINITIONS
“Personal Data” means any information relating to an identifiable individual.
“Processing” means any operation performed on personal data, including storing, using, or sharing it.
“Data Controller” refers to Strength Cartel Limited, which determines how and why your personal data is processed.
“Data Processor” refers to Clubright Software Ltd and other approved third parties who process personal data on our behalf.
2. HOW WE COLLECT PERSONAL DATA
We collect personal data directly from you when you:
Sign up for a membership
Create a Clubright account
Complete a PAR-Q or health declaration
Contact us by email, phone or through social media
Use our gym turnstiles, access systems, or CCTV-protected facilities
Use our website or mobile applications
Participate in promotions, competitions, or events
We may also collect limited data automatically through cookies when you use our website (see section 10).
3. TYPES OF PERSONAL DATA WE PROCESS
We may collect and process the following categories of personal data:
3.1 Identity & Contact Details
Name
Address
Email
Phone number
Date of birth
Gender
3.2 Membership & Attendance Information
Membership type and status
Clubright account information
Check-in and attendance history
Direct Debit or billing reference details
3.3 Health & Safety Information
PAR-Q responses
Information relevant to safe participation in gym activities
Incident reports
Notes regarding medical exemptions or freeze requests
3.4 Technical & Usage Data
IP address
Device information
Website behaviour and cookies
App usage information
3.5 CCTV Footage
We operate CCTV for safety, security, and crime prevention. Images are retained for a limited period unless required for investigation.
3.6 Marketing Preferences
Opt-in consent
Email and SMS communication preferences
We do not collect special category data unless you voluntarily provide it for safety or health reasons. Where applicable, we process such data under Article 9(2)(a) UK GDPR (explicit consent).
4. LEGAL BASIS FOR PROCESSING
We process your data only where lawful. The lawful bases include:
4.1 Contractual Necessity
To manage your membership and provide the services you have purchased.
4.2 Legitimate Interests
To:
Ensure facility security
Improve our services
Protect health & safety
Prevent misuse or fraud
These interests never override your fundamental rights.
4.3 Consent
We rely on your explicit consent for:
Marketing communications (email/SMS)
Processing optional health information
App integrations with social media accounts
Consent can be withdrawn at any time.
4.4 Legal Obligations
We may process data to comply with:
HMRC requirements
Health & safety regulations
Law enforcement requests
5. HOW WE USE YOUR PERSONAL DATA
We may use your data to:
Administer your membership
Manage billing, payments, and arrears
Provide access to our facilities via Clubright
Communicate important membership updates
Deliver customer support
Ensure safety through CCTV and access logs
Improve gym services and member experience
Send marketing communications (where consent is given)
Manage competitions, promotions, or events
Detect and prevent illicit or unauthorised access to the facility
We do not sell your personal data.
6. SHARING YOUR DATA
We may share your personal data with:
6.1 Clubright Software Ltd
Our membership management system and designated Data Processor, operating under strict GDPR compliance.
6.2 Payment Partners
For Direct Debit processing and payment management.
6.3 Professional Service Providers
Such as:
IT support
Security and CCTV providers
Legal and accounting professionals
6.4 Law Enforcement or Regulatory Authorities
Where required by law or to protect the safety of members and staff.
No third party may use your data for their own purposes. All processors are contractually bound to maintain confidentiality and GDPR compliance.
7. INTERNATIONAL TRANSFERS
We store all membership data within the UK or EEA where possible.
If transfers outside the UK occur (e.g., via third-party digital tools), such transfers will comply with UK GDPR safeguards such as:
Adequacy regulations
Standard Contractual Clauses
Supplementary security measures
8. DATA RETENTION
We retain personal data only for as long as necessary:
Prospective members: up to 12 months
Active members: for the duration of membership
After cancellation: up to 6 years for legal, financial, and indemnity purposes
CCTV footage: typically 30 days unless required for investigation
After retention periods expire, personal data is anonymised or securely deleted.
9. YOUR RIGHTS
Under UK GDPR, you have the following rights:
Right to be informed – to understand how your data is used
Right of access – to request a copy of your personal data
Right to rectification – to correct inaccurate data
Right to erasure – to request deletion in certain circumstances
Right to restrict processing – to limit how your data is used
Right to data portability – to transfer your data to another provider
Right to object – particularly to marketing
Rights relating to automated decision-making and profiling
To exercise your rights, contact us at info@strengthcartel.com.
We may require proof of identity to process requests.
10. COOKIES
Our website uses cookies to:
Manage sessions and secure log-ins
Improve user experience
Analyse website performance through Google Analytics
You may adjust your browser settings to refuse cookies, but this may reduce functionality.
11. SECURITY MEASURES
We take appropriate security steps to protect your data, including:
Encryption and secure server hosting
Password protection and access controls
Staff training and confidentiality agreements
CCTV monitoring for premises security
Despite these measures, no system is 100% secure. You share data with us at your own risk.
12. CHILDREN’S DATA
We do not collect data from individuals under 16 unless parental consent is provided for junior memberships or supervised sessions.
13. LINKS TO THIRD-PARTY WEBSITES
Our website may contain links to external sites.
We are not responsible for their privacy practices.
14. CHANGES TO THIS POLICY
We may update this Privacy Policy periodically.
The updated version will be posted online and within Clubright.
Continued use of our services after changes indicates acceptance of the updated policy.
15. COMPLAINTS
If you believe your data has been mishandled, you may complain directly to:
Information Commissioner’s Office (ICO)
Website: www.ico.org.uk
We encourage you to contact us first at info@strengthcartel.co.uk so we can resolve your concerns promptly.
16. CONTACT US
If you have questions about this Privacy Policy or wish to exercise your data protection rights:
📧 Email: info@strengthcartel.co.uk
📮 Address: Strength Cartel Limited, Ennerdale Mill, Egremont, Cumbria, CA22 2PN