HAUS OF MOVEMENT
PRIVACY POLICY & PRIVACY NOTICE
Trading name: Haus of Movement
Business owner / Data Controller: Martynas Striska, sole trader
Business address: 4–6 Irving Street, Dumfries, Scotland, DG1 1EL
Effective date: 1 September 2026
Last updated: 1 September 2026
⸻
1. INTRODUCTION
Haus of Movement (“Haus”, “we”, “us” or “our”) is committed to protecting the privacy and personal information of our members, customers, visitors and other individuals who interact with our business.
This Privacy Policy explains how Haus of Movement collects, uses, stores, protects and shares personal information when you:
• Visit our premises;
• Become a member;
• Purchase a membership or other service;
• Attend classes;
• Use our gym facilities;
• Participate in personal training;
• Make or manage bookings;
• Use our gym application;
• Communicate with us through WhatsApp;
• Contact us by email, telephone or social media;
• Visit or use our website;
• Participate in events or competitions; or
• Otherwise interact with Haus.
This Privacy Policy is intended to provide 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 2003 (PECR) and other applicable legislation as amended from time to time.
⸻
2. WHO IS RESPONSIBLE FOR YOUR INFORMATION?
The data controller responsible for your personal information is:
Martynas Striska, sole trader trading as Haus of Movement
Business address:
4–6 Irving Street
Dumfries
Scotland
DG1 1EL
Email:
[PRIVACY EMAIL TO BE ADDED]
Until a dedicated privacy email address is established, privacy-related requests may be submitted through Haus of Movement’s normal business contact channels.
As a sole trader, Martynas Striska is responsible for ensuring that personal information processed by Haus is handled in accordance with applicable data protection law.
⸻
3. WHAT PERSONAL INFORMATION DO WE COLLECT?
The information we collect depends on how you interact with Haus.
3.1 Personal and contact information
We may collect:
• Full name;
• Date of birth;
• Telephone number;
• Email address;
• Postal address;
• Emergency contact name and contact details;
• Profile photograph where provided;
• Information contained within communications with us.
⸻
3.2 Membership and account information
When you become a member, we may collect and maintain:
• Membership type;
• Membership start date;
• Membership status;
• Membership renewal information;
• Class bookings;
• Personal training bookings;
• Attendance information;
• Gym access information;
• Membership payment status;
• Cancellation information;
• Customer account information;
• Communications relating to your membership.
Membership and booking information may be processed through ClubRight, our membership and gym-management platform.
⸻
4. PAYMENT INFORMATION
Memberships and other services may be paid for using card payments and other payment methods supported by our payment systems.
We use ClubRight’s payment facilities for relevant card-payment processing.
Depending on the payment method, we may receive information such as:
• Payment status;
• Transaction amount;
• Transaction date;
• Payment reference;
• Subscription information;
• Refund information;
• Limited payment information.
We do not intend to store full payment-card details ourselves where those details are processed securely by the relevant payment provider.
Payment and financial information may be retained where necessary to comply with accounting, tax, legal and insurance obligations.
⸻
5. HEALTH, FITNESS AND PAR-Q INFORMATION
Because Haus provides exercise, fitness, personal training and physical activity services, we may ask you to provide information relating to your health and ability to exercise safely.
This may include information contained within:
• PAR-Q questionnaires;
• Health screening;
• Injury information;
• Medical conditions relevant to exercise;
• Physical limitations;
• Exercise history;
• Training goals;
• Relevant medication information voluntarily provided;
• Information provided to coaches or trainers regarding your ability to participate safely.
Some health information constitutes special category personal data under the UK GDPR.
We will only collect and process health information that is reasonably relevant and necessary for the provision and safe management of our services.
We will not use health information for unrelated marketing purposes.
Where required, we will rely on an appropriate lawful basis under Article 6 UK GDPR and an appropriate condition for processing special category data under Article 9 UK GDPR.
Where explicit consent is the appropriate legal basis or condition, we will obtain it.
You should provide accurate information and notify us if information relevant to your ability to train safely materially changes.
⸻
6. TRAINING AND PERFORMANCE INFORMATION
Where relevant to the services you receive, we may collect:
• Training programmes;
• Exercise records;
• Strength and performance information;
• Fitness assessments;
• Training history;
• Bodyweight or measurements where voluntarily provided;
• Personal training notes;
• Progress information;
• Competition or event results;
• Running or conditioning information;
• Coaching notes.
This information may be used to provide, monitor and improve your training and coaching.
⸻
7. COMMUNICATIONS
Haus may communicate with you using:
• WhatsApp;
• Email;
• Telephone;
• SMS;
• ClubRight;
• The Haus internal gym application;
• Instagram or other social-media platforms;
• Website contact forms;
• Other communication channels used by Haus from time to time.
We may retain relevant communications where necessary to:
• Respond to enquiries;
• Manage your membership;
• Manage bookings;
• Provide customer service;
• Resolve disputes;
• Maintain business records;
• Protect our legal interests.
Please be aware that third-party communication platforms, such as WhatsApp and social-media platforms, may independently process your information under their own privacy policies.
⸻
8. GYM APP AND CLUBRIGHT
Haus uses ClubRight to help manage memberships, bookings, communication and other gym-management functions.
Information entered into or generated through ClubRight may include:
• Your name;
• Contact details;
• Membership information;
• Booking information;
• Attendance;
• Payment status;
• Account information;
• Relevant fitness or health information where entered for the provision of services.
ClubRight may process information on our behalf as a third-party service provider.
The processing of your information by ClubRight may also be subject to ClubRight’s own privacy terms and policies.
⸻
9. CCTV
CCTV operates at Haus of Movement.
CCTV is used for legitimate purposes including:
• Protecting members, visitors and staff;
• Protecting property and equipment;
• Preventing and detecting crime;
• Investigating incidents;
• Supporting health and safety;
• Assisting with insurance or legal matters where necessary.
CCTV footage is not used for general monitoring of members’ fitness performance.
Appropriate CCTV signage will be displayed at relevant locations.
Access to CCTV footage will be restricted to authorised individuals and will only be accessed where reasonably necessary.
CCTV retention
Our standard CCTV retention period is 14 days.
Footage may be retained for longer where it is reasonably necessary because of:
• An incident;
• An accident;
• A complaint;
• Suspected criminal activity;
• An insurance claim;
• A legal dispute;
• A request from law enforcement; or
• Another legitimate investigation.
Where footage is retained for one of these reasons, it will be securely preserved only for as long as necessary for that specific purpose.
The ICO states that CCTV should be retained for the shortest period necessary for its purpose and gives a two-week retention period as an example for a small business. (Information Commissioner’s Office)
⸻
10. PHOTOGRAPHY, VIDEO AND SOCIAL MEDIA
Haus may take photographs and video recordings at the gym, during classes, events, competitions and other activities.
We may use suitable photographs and video for:
• Instagram;
• Facebook;
• TikTok;
• Our website;
• Advertising;
• Promotional campaigns;
• Gym announcements;
• Marketing materials;
• Community content;
• Haus promotional content.
Where identifiable individuals are intentionally featured in promotional content and consent is required, we will seek appropriate consent.
We will not use health information or private medical information in promotional content without an appropriate legal basis and, where required, explicit consent.
If you do not wish to appear in promotional content, please notify Haus.
Where reasonably practicable, we will take appropriate steps to respect such requests.
⸻
11. WHY WE USE YOUR INFORMATION
We may use your information for the following purposes.
Providing our services
To:
• Provide gym membership;
• Provide gym access;
• Process bookings;
• Manage classes;
• Provide personal training;
• Provide coaching;
• Create and manage training programmes;
• Monitor training progress;
• Manage events and competitions.
Health and safety
To:
• Assess whether you can safely participate;
• Identify relevant limitations;
• Adapt training where appropriate;
• Respond to emergencies;
• Protect members, visitors and staff.
Administration
To:
• Manage memberships;
• Process payments;
• Manage subscriptions;
• Handle refunds;
• Maintain financial records;
• Manage bookings;
• Maintain customer accounts.
Security
To:
• Operate CCTV;
• Protect our premises;
• Protect equipment;
• Prevent and investigate crime;
• Investigate incidents;
• Protect members and staff.
Communication
To:
• Respond to enquiries;
• Send booking information;
• Send membership information;
• Notify you of changes;
• Provide important operational information;
• Provide customer support.
Marketing
Where permitted by law, we may send information about:
• Haus memberships;
• Classes;
• Personal training;
• Events;
• Promotions;
• New services;
• Products;
• Community activities.
⸻
12. LAWFUL BASES FOR PROCESSING
We will only process personal information where we have a lawful basis under applicable data protection law.
Depending on the circumstances, these may include:
Contract
Where processing is necessary to provide services that you have purchased or requested.
Examples include:
• Managing your membership;
• Processing bookings;
• Providing personal training;
• Providing gym access;
• Managing payments.
Legal obligation
Where processing is necessary to comply with a legal obligation.
Examples include:
• Tax records;
• Accounting records;
• Legal requests;
• Regulatory requirements.
Legitimate interests
We may process information where it is necessary for our legitimate interests, provided that your interests, rights and freedoms do not override those interests.
Examples may include:
• Managing our business;
• Improving our services;
• Maintaining gym security;
• Preventing membership misuse;
• Protecting our property;
• Managing disputes;
• Maintaining appropriate business records.
Consent
Where appropriate, we may rely on your consent.
Examples may include:
• Certain marketing communications;
• Certain photography or video uses;
• Certain optional information.
Where processing is based on consent, you may withdraw your consent at any time.
Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
⸻
13. MARKETING
We may send marketing communications where legally permitted.
Marketing communications may relate to:
• Memberships;
• Classes;
• Personal training;
• Events;
• Promotions;
• New services;
• Products;
• Haus community activities.
You can unsubscribe from marketing communications at any time.
You may also contact us and request that your information is removed from our marketing list.
Important service communications will still be sent where necessary.
These may include:
• Booking confirmations;
• Membership notices;
• Payment information;
• Operational changes;
• Safety announcements.
⸻
14. WHO WE SHARE YOUR INFORMATION WITH
We may share personal information with third parties where reasonably necessary to operate Haus and provide our services.
These may include:
• ClubRight;
• Payment-processing providers;
• Website providers;
• Email providers;
• Cloud-storage providers;
• IT providers;
• Professional advisers;
• Accountants;
• Solicitors;
• Insurers;
• Emergency services;
• Police;
• Courts;
• Government authorities;
• Regulators.
We will only share information where we have an appropriate lawful basis to do so.
We do not sell personal information to third parties.
⸻
15. THIRD-PARTY SERVICE PROVIDERS
Some services used by Haus are provided by third-party organisations.
These may include providers of:
• Membership management;
• Gym booking;
• Payment processing;
• Website hosting;
• Email;
• Cloud storage;
• Messaging;
• Analytics;
• Marketing;
• Access control;
• IT services.
Where a third party processes information on our behalf, we will take reasonable steps to ensure that appropriate data protection and security arrangements are in place.
Some third parties may act as independent data controllers rather than processors. Their own privacy policies may therefore apply to information they process independently.
⸻
16. INTERNATIONAL DATA TRANSFERS
Some third-party service providers used by Haus may process or store information outside the United Kingdom.
Where personal information is transferred outside the UK, we will take appropriate steps to ensure that the transfer is lawful under applicable UK data protection legislation.
This may include the use of:
• UK adequacy regulations;
• International Data Transfer Agreements;
• UK Addendums;
• Other legally recognised safeguards.
⸻
17. HOW LONG WE KEEP YOUR INFORMATION
We will not retain personal information indefinitely.
We have adopted the following standard retention periods, subject to legal requirements and legitimate exceptions.
Membership and customer records
7 years after the end of the customer relationship.
This allows us to maintain appropriate business, contractual, insurance and legal records.
PAR-Q and health/fitness information
3 years after the end of membership or the relevant service, unless a longer period is reasonably required because of an ongoing matter, legal claim, insurance matter or other legitimate requirement.
Health information will be reviewed and securely deleted when it is no longer necessary.
Payment and financial records
7 years, or for the period required by applicable tax and accounting obligations, whichever is applicable.
Marketing information
Until you unsubscribe or the information is otherwise no longer reasonably required for marketing purposes.
CCTV
14 days, unless footage is required for an incident, investigation, insurance matter, legal claim or law-enforcement request.
Communications
Relevant business communications may generally be retained for up to 3 years after the relevant matter has ended, unless a longer period is reasonably necessary for legal, insurance, contractual or other legitimate purposes.
Photography and promotional content
Promotional photographs and video may be retained for as long as reasonably necessary for the relevant promotional purpose, unless you withdraw consent where consent is the applicable legal basis.
Where information is no longer required, we will securely delete, destroy or anonymise it where appropriate.
Retention periods will be reviewed periodically.
⸻
18. DATA SECURITY
We take reasonable technical and organisational measures to protect personal information.
These may include:
• Password protection;
• Access controls;
• Restricted access to sensitive information;
• Secure third-party platforms;
• Secure payment processing;
• Device security;
• Staff and contractor confidentiality;
• Limiting access to information to those who need it.
No electronic system can be guaranteed to be completely secure.
If we identify a personal data breach, we will assess the incident and take appropriate action in accordance with applicable law.
⸻
19. YOUR DATA PROTECTION RIGHTS
Subject to applicable legal conditions and exemptions, you may have the right to:
Access
Request a copy of the personal information we hold about you.
Rectification
Ask us to correct inaccurate or incomplete information.
Erasure
Ask us to delete personal information in certain circumstances.
Restriction
Ask us to restrict processing in certain circumstances.
Objection
Object to certain processing, including processing based on legitimate interests.
You have an absolute right to object to direct marketing.
Data portability
In certain circumstances, request personal information you have provided to us in a structured, commonly used and machine-readable format.
Withdraw consent
Where we rely on consent, you can withdraw that consent at any time.
⸻
20. HOW TO EXERCISE YOUR RIGHTS
To exercise a data protection right, contact:
Martynas Striska
Haus of Movement
4–6 Irving Street
Dumfries
Scotland
DG1 1EL
Email: [PRIVACY EMAIL TO BE ADDED]
Until a dedicated privacy email address is established, requests may be submitted through Haus of Movement’s usual contact channels.
We may need to verify your identity before responding.
We will normally respond to valid requests within the timeframe required by applicable data protection law.
⸻
21. CHILDREN
Haus of Movement does not currently offer memberships or services to individuals under the age of 18.
We therefore do not intentionally collect personal information from children under 18 for the purpose of providing gym membership.
If we introduce services for individuals under 18 in the future, this Privacy Policy will be reviewed and updated accordingly.
⸻
22. AUTOMATED DECISION-MAKING
Haus does not currently make decisions about members based solely on automated processing that produce legal or similarly significant effects.
⸻
23. DATA ACCURACY
We aim to ensure that personal information we hold is accurate and up to date.
You should notify us if:
• Your contact details change;
• Your emergency contact changes;
• Relevant health circumstances change;
• Information you have provided becomes inaccurate.
You can request that inaccurate information is corrected at any time.
⸻
24. CONFIDENTIALITY
Haus expects individuals who have access to personal information as part of providing services to handle that information appropriately and confidentially.
Access to personal information will be limited to information reasonably required for legitimate business purposes or the provision of services.
⸻
25. DATA BREACHES
If Haus becomes aware of a personal data breach, we will assess:
• What information has been affected;
• How many individuals may be affected;
• The potential risk to individuals;
• What caused the breach;
• What steps can be taken to contain it.
Where legally required, we will notify the Information Commissioner’s Office and affected individuals within the applicable statutory timeframe.
⸻
26. COOKIES AND WEBSITE TECHNOLOGIES
Our website may use cookies and similar technologies.
These may be used for:
• Essential website functionality;
• Security;
• Remembering preferences;
• Website analytics;
• Understanding website usage;
• Marketing, where applicable.
Where consent is required for non-essential cookies, we will obtain appropriate consent.
A separate Cookie Policy may be provided where necessary.
⸻
27. SOCIAL MEDIA
Haus may operate social-media accounts including Instagram and other platforms.
Information you voluntarily provide through social-media platforms may be processed by both Haus and the relevant platform.
Social-media companies operate their own privacy policies and terms.
We encourage you to review the privacy settings and policies of the platforms you use.
⸻
28. COMPLAINTS
If you have concerns about how Haus has handled your personal information, please contact us first so that we can investigate and attempt to resolve your concern.
You may contact:
Martynas Striska
Haus of Movement
4–6 Irving Street
Dumfries
Scotland
DG1 1EL
Email: [PRIVACY EMAIL TO BE ADDED]
You also have the right to complain to the UK’s data protection regulator:
Information Commissioner’s Office (ICO)
You can find information about making a complaint on the ICO’s website.
Information Commissioner’s Office
⸻
29. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time.
This may be necessary where:
• Our services change;
• We introduce new technology;
• We introduce new third-party providers;
• Our data-processing activities change;
• The law changes;
• Regulatory guidance changes.
The latest version will be made available through our website.
Where a change is significant, we may notify members through an appropriate communication channel.
⸻
30. GOVERNING LAW
This Privacy Policy is governed by the laws applicable in Scotland and is intended to operate in accordance with applicable UK data protection legislation.
Nothing in this Privacy Policy removes or limits any statutory rights you have under applicable data protection law.
⸻
31. CONTACT DETAILS
Haus of Movement
Owner / Data Controller:
Martynas Striska, sole trader
Address:
4–6 Irving Street
Dumfries
Scotland
DG1 1EL
Privacy email:
[TO BE ADDED]
Website
www.hausofmovement.co.uk
⸻
DOCUMENT CONTROL
Document: Haus of Movement Privacy Policy & Privacy Notice
Business: Martynas Striska trading as Haus of Movement
Version: 1.0
Effective date: 1 September 2026
Last reviewed: 1 September 2026
Next scheduled review: 1 September 2027