Privacy Policy

Who we are

http://activestepsworkouts.com.

Terms used in Privacy Policy.

In this policy:

“you” means you, the person using our services, or visiting the site.
“Group Companies” means Active Steps Workouts and all subsidiaries and affiliate companies; from time to time owned by Active Steps Workouts(other than us) providing fitness-related goods and services. If you require a full list of entities comprising the Group Companies, please contact us as described in the “Contact” section below.
“Active steps Workouts” means us and the Group Companies.
“Services” means the Active Steps Workouts+ subscription service. The Services may be provided to you on our desktop site.

Information We Collect About You

We will collect and process the following information about you:

Information you give us

This is information about you that you give us when you browse or use the site, correspond with us by phone, SMS, email, social media or otherwise. It includes information you provide when:

you register to use our site;
subscribe to our Services;
place an order on our site;
participate in discussion boards or other social media functions on our site;
enter a competition; and
you contact us or report a problem with our site.

The information you give us includes your name, address, country, date of birth, e-mail address and phone number, credit card information (which is captured for payment but not stored) if you subscribe to our Services or place an order on our site, personal description and photographs, videos, images or comments, your fitness interests and preferences such as your marketing preferences.

This information is required to provide the Services to you. If you do not provide such information, it may delay or prevent us from providing the Services.

Information we collect about you

With regard to each of your visits to our site we will automatically collect the following information:

technical information, including the IP address used to connect your computer or device to the Internet, your login information, browser type and version, time zone setting, location data, browser plug-in types and versions, operating system and platform;
information about your visit, including the full URL, clickstream to, through and from our site (including date and time), pages or products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page; and
information about how you use the Services, including but not limited to your video consumption and playback, sign-in and sign-out and playback error.

Our site may also contain social media features, such as the Facebook Like button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are also governed by the privacy policy of the company providing it.

For detailed information on the cookies we use and the purposes for which we use them, please refer to our Cookie Policy here and Cookie Declaration here.

Information we receive from other sources

Other Active Steps Workouts websites: We may receive information about you if you use any of the other websites operated by Active Steps Workouts Companies or the other services the Active Steps Workoutsprovide.

Third parties: We also work closely with third parties (including, for example, business partners, authorised distributors, health and/or fitness clubs and facilities or any other organization that Active Steps Workouts has licensed to conduct Active Steps Workouts programs (“Licensed Clubs”), sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, advertisers, search information providers, credit reference agencies, third parties that enable sign on functionality and social network integration) and may receive information about you from them.

Social Media: If you connect with us via certain social media platforms, or you choose to use features on this site or the websites of other Active Steps Workout Companies that connect to your online profiles or social media accounts (“Social Media Accounts”), we may collect any information that you permit through your settings on those Social Media Accounts. For example, if you log in to our site using your Facebook account and you have allowed Facebook to share your profile information with us, we may collect that information. Information we receive from your Social Media Accounts includes email address, first and last name, location (hometown and country), gender, date of birth, likes, interests, number of connections, occupation, posts or other social activity. The information that your social media platform may provide to us via your Social Media Account may change from time to time. Please review your Social Media Account privacy settings to control what information is shared with us.

How Your Information Will Be Used

We use information held about you in the following ways:

A. To the extent permitted under applicable law, we process data for the following purposes based on our legitimate interests:

to administer our site and for internal operations, including troubleshooting, data analysis, security, testing, research, statistical and survey purposes;
to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
to provide you with the latest information and offers relating to health and fitness if you live outside the European Economic Area (the “EEA”), the United Kingdom or Brazil, unless you opt out (see Marketing Opt-Out);
to tailor your experience on the site;
to provide (or permit third parties to provide) targeted advertising via websites you visit about goods or services that you may find interesting (see more on this below in the section on “Disclosure of your Information” and in our Cookie Policy here and Cookie Declaration here) and to measure or understand the effectiveness of that advertising. Similarly we may also use your information to exclude you from some targeted advertising groups e.g. if we already know you subscribe to Les Mills we may not include you in some advertisements encouraging new joiners; or
to track the progress and number of entries in competitions and promotions.

B. To the extent permitted under applicable law, we will process data where it is necessary to fulfil our contract with you:

We collect, store and use your personal information including your name, e-mail address, login details and payment information and information about how you use and access the Services because it is necessary in order to provide the Services requested by you pursuant to the contract made between you and us when you agreed to our Terms of Use. This includes:

making the Services available to you;
providing any Services that you request and respond to your enquiries;
administering the Services and processing your payment where you are purchasing Services from us (including but not limited to using third party service providers to process such payment);
notifying you about changes to our services; and
service and account administration requirements such as where we need to contact you for reasons related to the Services (for example, where we need to send you a password reminder, to notify you about Services updates or amendments to our Terms of Use, or this Privacy Policy).

C. We will process data for the following purposes based on your consent:

to participate in interactive features of our service, when you choose to do so. This includes any ‘contact us’ forms or public forum features we provide on our site such as community forums, comments positing or chat features;
to provide you with the latest information and offers relating to health and fitness if you live in the European Economic Area (the “EEA”), the United Kingdom or Brazil, ; and

D. We will process data where necessary to comply with all legal requirements.

For example:
o if you have a paid subscription to use the Services and live in the EEA, we are legally required to allow you, and you are legally entitled, to watch the Services when you’re visiting another country in the EEA.
o if we receive a request for information from a regulator, we may also need to process your personal information to respond to that request.

Disclosure Of The Information

Service Providers

For some of the purposes for which we use personal data (see above), we will engage a third party. If such third party needs access to personal data to carry out its task, to the extent permitted by applicable laws, we will share the data with them, we will ensure that the third party will only use the data based on our instructions. Those third parties are data processors acting on our behalf and we remain responsible for your data.

We will engage organisations that provide services to us (including Active Steps Workouts Companies) such as vendors, service providers, and other partners who globally support our business. These third parties provide services such as providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of ads and services, providing customer service, facilitating payments, or conducting academic research and surveys. These partners must adhere to strict confidentiality obligations in a way that is consistent with this policy and the agreements we enter into with them.

Analytics and advertisers

We will, when we have the right to do so according to applicable personal data regulations, share your personal information with:

Analytics and search engine providers such as AWS and Google Analytics that assist us in the improvement and optimisation of our site. We want our site and advertising to be as relevant and interesting to you as it can be.
advertisers and advertising networks that require the data to select and serve relevant advertising to you and others, including to a targeted audience. These third-party advertising companies collect, store and use data by integrating cookies and other tracking software on our Services. In some cases these third parties will also use the data that they collect for their own purposes, for example, they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients and work with other advertising companies and share collected information with such companies as part of the process.. Please see our Cookie Policy here and Cookie Declaration here for more information on the third-party advertising companies which collect, use, process and store data about you, and the use of cookies and other tracking technologies on our Services;
social media or other similar platforms so that we can serve relevant content to you via that platform, or exclude you from receiving content that is inapplicable to you. For example, we may share your email address with Facebook so that we can include you within (or exclude you from) a custom audience that we (or a third party on our behalf) will serve content to on Facebook, or we may create an audience of other Facebook users based on the information in your Facebook profile.

Other third parties

We will also, when we have the right to do so according to applicable personal data regulations, share your personal information with:

Active Steps Companies;
the following selected third parties:
o business partners, authorised distributors, Active Steps Workouts licensed clubs who provide us with services which allow us to perform the contract we enter into with you and/ or to provide you with information about promotions and offers, or for any of the other purposes described the “How your information will be used” section above;
o credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

Disclosure under certain circumstances

We will, when we have the right to do so according to applicable personal data regulations, also disclose your personal information to third parties in the following circumstances:

In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets subject to appropriate confidentiality arrangements;
If LMM or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets;
If we are under a duty to disclose or share your personal information in order to comply with any legal obligation,
In order to enforce or apply our website terms of use (www.Activestepsworkouts.com/terms) including the Active Steps Workouts+ Terms of Use or purchase terms and other agreements; or to protect the rights, property, or safety of any Active Steps Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
Where you have otherwise consented that we may do so.

Where We Store Your Information

Individuals (especially within the EEA or UK) should be aware that we and other third-party recipients of their personal information, such as the Active Steps Companies or our service providers will not be located within your jurisdiction or within the EEA or UK and we may transfer your data to those locations.

For instance, personal data may be transferred to the Active Steps Companies in New Zealand in connection with the purposes stated above. Our video platform provider (Vimeo) and ecommerce platform (Magento) are based in the United States, therefore your personal data may be transferred to the United States. Where we transfer your data to a third party in another country, steps will be taken to protect your personal information in a way that is consistent with applicable privacy laws including (as applicable) EU Regulation 2016/679 (the “GDPR“), the GDPR as retained in law in the UK and the UK Data Protection Act 2018. These steps might include:

ensuring that there is an adequacy decision by the European Commission in the case of transfers out of the EEA, or by the UK Government in the case of transfers out of the UK, which means that the recipient country is deemed to provide adequate protection for such personal data;
putting in place standard model contractual arrangements with the recipient which have been approved by the European Commission (or the UK government for transfers out of the UK). These model contractual clauses include certain safeguards to protect the personal data; and
taking all reasonable precautions to ensure that your personal information is treated securely and in accordance with this Privacy Policy.

Data Retention

We retain the personal information we collect only if we need it to support justifiable business requirements or when our lawful purposes for using the information requires retention. When we no longer require personal information we or our third party suppliers will securely delete and/or archive the information. For more information on where and how long your personal information is stored, and for more information on your rights of erasure and portability, see below under “Your Rights”.

Security Of Your Information

To help protect the privacy of data and personally identifiable information you transmit through use of our site and portals, we maintain physical, technical and administrative safeguards. All information you provide to us is stored on our secure servers or on the secure servers or secure services controlled by third parties on our behalf (see ‘Disclosure of Information’ above). Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential.

We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at Admin@activestepsworkouts.com at any time.

Linked Sites

The site may contain links to other websites. We are not responsible for the reliability of the content or privacy practices of such other websites.

Public Forums

We may provide you with chat features, instant messaging, message boards, community forums and/or news groups through the site or otherwise. Please remember that any information that you disclose in public areas of the site will become public information, and be accessible to the public. We do not intend (but reserve the right) to monitor, moderate or screen the contents of user postings. We bear no responsibility for any such content and you should be cautious when considering whether to disclose your personal information in the on the site through public or private forums.

Lost Or Stolen Information

You must not share your user same or password with anybody and you should keep these secure. Please notify us promptly email Admin@activestepsworkouts.com if your user name or password is lost, stolen or used without permission. Upon notice, we will cancel that user name or password and update our records accordingly. We recommend that different passwords are used for all of your online accounts.

Marketing Opt Out

Where you don’t live in the UK or EEA, you have the right to decline our use of your personal information for (or opt-out of) marketing communications. If you do so, your name will be marked in our records so you will be excluded from any contact of that type in the future unless you later request or agree to future contact.

If you do live in the UK, Brazil or EEA, you must opt in (or consent) to marketing communications from us, and you can withdraw that consent in the same way as opting out below, as well as via the method set out under ‘withdrawing consent’ below.

You can “opt-out” by:

using the contact details provided for this purpose in our mailing to you;
using the “unsubscribe” option at the foot of any electronic communication we send to you; or
by emailing us at any time at Admin@activestepsworkouts.com.

Your Rights

Depending on your country of residence, you may have specific rights over your personal data.

Right of access

You may have the right to request access to certain personal data that we hold about you including any information we have shared to our Group Companies for direct marketing purposes, subject to certain conditions and limited exceptions set out in relevant data privacy laws.

If you wish to do so, please email your request to Admin@activestepsworkouts.com, and to the extent that we are required to do so under applicable law, we will process your request.

We will be as open as we can with you in relation to your request, but sometimes, to the extent permitted by applicable laws, we might not hold any personal information about you or may have to withhold personal information from you. These circumstances may include where the information is not personal information about you, is commercially sensitive, is legally privileged, relates to the personal information of another person, or may impact on the safety or security of our employees or customers to release it. In these circumstances, we will withhold the information but we’ll tell you why.

Right of correction

You can request that we correct (rectify) the record of your personal data maintained by us if it is inaccurate or out of date.

Withdrawing Consent

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at Admin@activestepsworkouts.com and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide you with our services (for example, we may not be able to provide marketing information to you).

Other rights

Residents of the EEA, Switzerland, the UK and Brazil may also have special additional rights under data protection legislation in the EEA/European Union, Switzerland, the United Kingdom and Brazil respectively, including the right to:

If you wish to exercise your right of erasure click here. If you wish to exercise any of your other rights, please send your request to admin@activestepsworkouts.com.

request information about the existence and purpose of the processing; the categories of personal data concerned; who else outside the Active Steps Companies might have received the data from us; what the source of the information was (if you didn’t provide it directly to us); and how long it will be stored;
obtain information about the possibility of denying processing which relies on your consent (and the consequences of doing that) as well as delete personal information that you had previously consented to us using (assuming we only need it for those purposes);
request that we erase that data or cease processing it, subject to certain exceptions;
request that we anonymise, block or delete unnecessary or excessive personal information, including personal information processed in non-compliance with the law. Of course we intend to never over-collect personal information and to comply with the law;
review decisions we may have made based on automatic data processing;
ask us not to process your personal information for the legitimate interests that we have set out above. In certain circumstances we may not be able to stop using your personal information but, if that is the case, we’ll let you know and tell you why;
receive the personal information that you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another data controller; and
lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal data. The local authority differs depending on the country. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

Notice to California Residents

This section only applies to individuals who are residents of California under the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws (together “California Laws”).

Below is a summary of the personal information, as that term is defined in the CCPA, that Active Steps Workouts+ may have collected in the preceding twelve months, the reason we collect your personal information, where we obtain the personal information we collect about you, and the third parties that we share your personal information categorized as defined and outlined in California Law.

Category of Information: Identifiers (such as Account Name, Device ID, Email Address, IP Address, etc.)

Sources of Information: We collect Identifiers when you register to use our site and subscribe to our services.
Purpose of Information Collection: We collect Identifiers in order to communicate with you, provide you with information about other goods and services we offer, enforce our Terms and Conditions.
How We Share Your Personal Information: We share Identifiers with Service Providers and other third parties in order to perform the contract we enter into with you and to provide you with our services and provide you with information about other goods and services.

Category of Information: California Customer Records (such as Address, Name, Telephone Number)

Sources of Information: We collect personal information when you register to use our site and subscribe to our services.
Purpose of Information Collection: We collect personal information in order to communicate with you, provide you with information about other goods and services we offer, enforce our Terms and Conditions.
How We Share Your Personal Information: We share Personal Information with Service Providers and other third parties to perform the contract we enter into with you, to provide you with our services and to provide you with information about other goods and services.

Category of Information: Commercial Information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Sources of Information: We collect Commercial Information through your registering to use our site and subscribe to our services from other Les Mills websites, other third parties, our App (if you download it) and social media as stated above.
Purpose of Information Collection: We collect Commercial Information in order to provide you our services, perform the contract we enter into with you, and for data analysis, and to tailor your experience to the site.
How We Share Your Personal Information: We share Commercial Information with Service Providers and other third parties in order to perform the contract we enter into with you and to provide you with our services and provide you with information about other goods and service as stated above.

Category of Information: Internet/ Network Activity Information (such as website or application or advertisement browsing history)

Sources of Information: We collect Electronic Network Activity Information automatically through your use of our site, from other Les Mills websites, other third parties, and social media as stated above.
Purpose of Information Collection: We collect Electronic Network Activity Information in order to communicate with you, provide you with information about other goods and services we offer, enforce our Terms and conditions.
How We Share Your Personal Information: We share Electronic Network Activity Information with Service Providers and other Third Parties in order to perform the contract we enter into with you and in compliance with legal process.

Category of Information: Geolocation Data

Sources of Information: We collect Geolocation Data through your registering to use our site and subscribe to our services.
Purpose of Information Collection: We collect Geolocation Data to provide you our services, perform the contract we enter into with you.
How We Share Your Personal Information: We share Geolocation Data with Service Providers and other third parties as outlined above in order to comply with legal process, perform the contract we enter into with you, to provide you with our services, provide you with information about other goods and services, any other purpose as stated above with your consent.

Under California Laws, California residents have the rights listed below. Californians can exercise their privacy rights by contacting us at Admin@activestepsworkouts.com. We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and the right to deletion, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.

Your right to access and to deletion are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us or the security of the business’s systems or networks.

California residents have the right to request that we disclose to them (i) the categories of personal information we have collected about them, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual.
California residents have the right to have their personal information deleted, unless the personal information is necessary for the business or service provider to:
o    complete a transaction for which the personal information was collected, provide a good or service requested by the consumer or otherwise perform a contract between the business and the consumer;
o    detect security incidents;
o    protect against malicious, deceptive, fraudulent or illegal activity (or prosecute those responsible);
o    debug to identify and repair functionality errors;
o    exercise or ensure the right of another to exercise free speech or another legal right;
o    comply with the California Electronic Communications Privacy Act, which compels the production of or access to electronic communication information or electronic device information with a search warrant;
o    engage in research in the public interest (if the consumer has provided informed consent);
o    to enable solely internal uses aligned with the consumer’s expectations given their relationship with the business;
o    comply with a legal obligation; or
o    otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided it.
Californian residents have the right to opt-out of having their personal information sold to third parties. Under California Law, Active Steps Workouts sharing of personal information relating to the marketing and access of our Online Services to certain third parties may constitute a “sale” under the CCPA’s definition of that term. You can opt-out of such information sharing on your browser by clicking on the Do Not Sell My Info link in the footer of our homepage.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, provide you a different level or quality of goods or service, or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods and services.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

Under California Civil Code sections 1798.83-1798.84, also known as the “Shine the Light Law,” any of our users who are California residents are entitled to request and receive once a year, free of charge, a notice from us describing what categories of personal customer information (if any) we shared with third parties or corporate affiliates for their direct marketing purposes during the preceding calendar year. If applicable, the notice will identify the categories of information shared, the names and addresses of the third parties and affiliates with which information was shared. If you are a California resident and would like to request a copy of this notice, please submit a written request to the following address Admin@activestepsworkouts.com. In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least thirty days for a response.

Contact Us

To exercise your opt-out privileges, access your user information, obtain more information about this Privacy Policy or advise us of other matters regarding your experiences with Active Steps Workouts or the site, please contact us by email at:
Email: admin@activestepsworkouts.com

Changes To The Policies

We may update or change this Privacy Policy at any time. We will tell you about any changes by posting an updated policy on our site and (where appropriate) notifying you by post or email. Any such modification will be effective immediately upon posting on the site. Where applicable law requires us to do so, we will seek your consent for such changes and give you an opportunity to cancel your subscription.

Language

This policy may be translated into other languages. You agree where there is any inconsistency between the translation and this policy, the English language will prevail.