Strength Cartel (Egremont)
Privacy Policy



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