Level 3 Pilates Instructor Course

Introduction

Train Limited (collectively referred to as "Company", "we", "our" or "us" in this Privacy Policy) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This Privacy Policy is provided in a layered format so you can find the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

1.

Important Information and Who We Are

2.

The Data We Collect About You

3.

How is Your Personal Data Collected

4.

How We Use Your Personal Data

5.

Disclosures of Your Personal Data

6.

International Transfers

7.

Data Security

8.

Data Retention

9.

Your Legal Rights

10.

Glossary

1. Important Information and Who We Are

Purpose of This Privacy Policy

This Privacy Policy aims to give you information on how we collect, store, use, transfer and or share ("process" or "use") your personal data when you enquire with us, register with us, apply for a job with us, contact us (including by WhatsApp), purchase or make payments for any of our products or services, sign up to receive information from us, take part in one of our competitions, promotions or surveys, or visit our websites ("Sites") and mobile applications ("Apps") (regardless of where you visit them from). If you do not agree with the data practices described in this Privacy Policy, you should not use our Sites or Apps or engage with us as described above.

Our Sites and Apps are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Controller

Company is the controller and responsible for your personal data.

We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

You can write to us at: Train Limited, Attn: Data Protection Officer, 128 City Road, London EC1V 2NX.

You can email us at: [email protected]

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep this Privacy Policy under regular review. The version number and date of the last update are shown at the end of this page.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

Our Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Sites, we encourage you to read the privacy policy of every website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may process different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Sites and Apps.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Sites, Apps, products and services.
• Communications Data includes the content of the messages you send to us and we send to you by email, text message and WhatsApp (including photos and files), when they were sent, whether they were delivered and read, and the identifiers WhatsApp uses for you, such as your WhatsApp phone number and profile name.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, including the channels (email, text message or WhatsApp) you have agreed to or opted out of.

We also process Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site or App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

The only Special Categories of Personal Data about you that we process are details about your ethnicity and your health:

• Ethnicity data is processed to meet the requirement of awarding organisations to monitor that qualifications don’t unfairly advantage or disadvantage particular groups of learners. We process it because it is necessary for equality of opportunity or treatment monitoring (Article 9(2)(g) UK GDPR and Schedule 1, paragraph 8 of the Data Protection Act 2018), alongside our legitimate interests and legal obligations in meeting awarding organisation requirements.
• Health data is processed so that we can consider and, where applicable, make reasonable adjustments in line with our Equality Policy. We process it with your explicit consent when you tell us about a health condition or need (Article 9(2)(a) UK GDPR), and where it is necessary for equality of opportunity or treatment (Schedule 1, paragraph 8 of the Data Protection Act 2018). You can withdraw your consent at any time by contacting us.
• In an emergency, we may use health information where it is necessary to protect your vital interests or those of someone else, and you are not able to give consent (Article 9(2)(c) UK GDPR).

We do not ask for any Special Categories of Personal Data to be disclosed to us as part of your job application. If your application is successful and a position is offered to you we will ask you to conduct a Disclosure and Barring (“DBS”) check and at that time we will explain why we need that information and how we intend to use it.

We do not store credit card details.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions.
  You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, text message, WhatsApp or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our Sites or Apps;
• subscribe to our services or publications;
• request marketing to be sent to you;
• message us on WhatsApp or reply to a message we send you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions.
  As you interact with our Sites or Apps, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy.
• Third parties or publicly available sources.
  We may receive personal data about you from various third parties and public sources as set out below:
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly available sources.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

i.

Where we need to perform the contract we are about to enter into or have entered into with you.

ii.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

iii.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. The exceptions are: sending you marketing by WhatsApp; sharing your personal data with third parties for their own direct marketing (which we only do with your express opt-in consent); setting non-essential cookies; and health information you choose to tell us. You have the right to withdraw your consent at any time: by using the unsubscribe link in any marketing email, by replying STOP to a text message or WhatsApp message, by changing your cookie settings, or by contacting us.

Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will send you marketing communications where you have provided your consent (for example, when you indicate your agreement to receive such communications when accepting our Privacy Policy and Cookie Policy) or where otherwise permitted by applicable law.

Promotional Offers From Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us by email and text message if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

WhatsApp

We use the WhatsApp Business Platform, provided by Meta, to send you messages and to receive the messages you send us.

If you give us your mobile number when you enquire or enrol, we may contact you about your enquiry, course or account on WhatsApp. If you message us on WhatsApp first, we will reply to you there.

We will only send you marketing on WhatsApp if you have agreed to receive marketing from us, for example by ticking the marketing box on one of our forms. That agreement covers marketing by email, text message and WhatsApp, and you can opt out of any of them separately.

When we message you on WhatsApp we process your WhatsApp phone number, the identifier WhatsApp gives you for our business, your WhatsApp profile name, the messages, photos and files you send us, the messages we send you, and whether they were delivered and read.

You can stop WhatsApp marketing at any time by replying STOP. We will confirm and record your choice and will not send you WhatsApp marketing again. We may still send you messages about your enquiry, course or account on WhatsApp unless you ask us to stop those too.

Meta carries WhatsApp messages between you and us and processes them under its own terms and privacy policy. How long we keep WhatsApp messages is set out in Data Retention.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside the Company for direct marketing purposes, otherwise, we will not share it.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing email, by replying STOP to any marketing text message or WhatsApp message, or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies Policy

We collect information directly from you in a number of ways. One way is through our use of ‘cookies’. Most websites use cookies in order to make them work, or to work more efficiently, as well as to provide information to the owners of the website. They help us to understand how our customers and potential customers use our website so we can develop and improve the design, layout, content and function of the site.

Cookies are small text files that are placed on your computer’s hard drive by websites that you visit. They save and retrieve pieces of information about your visit to the website. For example, how you entered the site, how you navigated through the site and what information and documentation was of interest to you. This means that when you go back to a website, it can give you tailored options based on the information it has stored about you on your last visit. Some of our cookies are used to simply collect information about how visitors use our website and these types of cookies collect the information in an anonymous form.

Where there is a login process relating to buying products or services from us, we also use cookies to store personal registration information so that you do not have to provide it to us again on subsequent visits.

Cookies that are essential for our Sites to work are always set. We only set other cookies, such as analytics and advertising cookies, if you agree to them in the cookie banner shown when you first visit our Sites. You can change or withdraw your choice at any time: change your cookie settings.

You can also set your browser to reject or block cookies or to tell you when a website tries to put a cookie on your computer, and you can delete any cookies that are already stored on your computer’s hard drive. However, please be aware that if you block all cookies from our website, parts of the site will not then work, because some of the cookies we use are essential for parts of our Sites to operate. To find out more about cookies, including seeing what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

i.

External Third Parties as set out in the Glossary.

ii.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Some third parties, such as Meta (for WhatsApp), PayPal and finance lenders, act as separate controllers for the data they process and do so under their own privacy policies, as described in the Glossary.

6. International Transfers

Our learner records and messaging systems are hosted in the United Kingdom. Some of our service providers process personal data outside the UK. In particular, when we exchange WhatsApp messages with you, those messages are carried and processed by Meta, which may process them in the United States and other countries.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

i.

We transfer it to a country that the UK Government has found provides an adequate level of protection for personal data ("adequacy regulations"). This includes transfers to organisations in the United States that are certified under the UK Extension to the EU-US Data Privacy Framework (the "UK-US data bridge").

ii.

Where there are no adequacy regulations, we use contracts approved for use in the UK which give personal data the same protection it has in the UK: the International Data Transfer Agreement or the UK Addendum to the European Commission’s standard contractual clauses. For further details, see ICO: International transfers.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How Long Will You Use My Personal Data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

If you register for or complete a regulated qualification with us, we keep the records needed to confirm, verify or reissue that qualification (such as your identity details, the qualification, your assessment results and the dates of your registration and certification) for as long as our awarding organisations and the qualifications regulator require.

We delete the content of WhatsApp messages (the text, photos and files) 12 months after they were sent or received. We keep a record that a message was exchanged (when, and in which direction) as part of our record of our communications with you. We keep a record of your marketing opt-outs, including a WhatsApp STOP, so that your choice continues to be respected.

In some circumstances you can ask us to delete your data: see How to Ask Us to Delete Your Data below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under certain circumstances you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

How to Ask Us to Delete Your Data

To ask us to delete your personal data, email [email protected] with the subject “Delete my data”, or write to our Data Protection Officer at the address in section 1. Please include your name and the email address or phone number you used with us, so that we can find your records.

We will confirm your identity, then delete your personal data within one month of your request (or tell you within that month if we need longer and why). We will confirm to you when it has been done.

We cannot delete everything in every case. We will keep only what we must, and tell you what we have kept and why:

• if you registered for or completed a regulated qualification, the records needed to confirm, verify or reissue it, for as long as our awarding organisations and the qualifications regulator require;
• financial and transaction records we must keep for six years for tax purposes; and
• a record of your marketing opt-outs (including a WhatsApp STOP), so that we do not contact you again.

Deleting the data we hold does not delete messages stored on your own phone, or copies held by Meta under its own terms. You can delete a chat in WhatsApp and block our number at any time.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means your freely given, specific and informed agreement to a particular use of your personal data, such as receiving marketing from us. You can withdraw it at any time.

Third Parties

External Third Parties

• Service providers including but not limited to those who provide IT, hosting (including Microsoft, which hosts our systems in the United Kingdom), subcontracting, recruitment and system administration services.
• Meta Platforms, which provides the WhatsApp Business Platform and carries WhatsApp messages between you and us. Meta processes those messages under its own terms and privacy policy.
• Professional advisers including but not limited to lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities such as accreditation organisations who require reporting of processing activities in certain circumstances.
• Finance companies, financial institutions, credit reporting agencies, finance merchants (e.g. financial services providers), brokers, fraud prevention agencies and market researchers who facilitate or provide financial services and information or marketing services in certain circumstances.
• If you pay with PayPal, PayPal acts as a data controller in regards to your payment information. See their privacy policy for more information about the processing.
• If you apply to pay for a course with a payment plan, your application is handled by Vendigo (Koze Group Ltd), which passes it to one or more lenders (such as humm) to decide whether to offer you finance. Vendigo and the lenders act as data controllers for the information you give them and may carry out credit checks. See Vendigo’s privacy policy, and the privacy policy of the lender you are offered finance by, for more information.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. See How to Ask Us to Delete Your Data.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Version: PRI-27 | Rev: Oct 2026