Freedom Fit Pass Inc. (“FFP”) is committed to safeguarding the personal information entrusted to us by our members. We manage your personal information in accordance with Alberta’s Personal Information Protection Act and other applicable laws. This policy outlines the principles and practices we follow in protecting the personal information about members through the FFP website and the services we provide through FFP membership.
This policy applies to FFP and to any individual providing services on our behalf. For clarity, this policy does not apply to the third-party gyms or fitness studios listed on the FFP website and accessed through FFP. A copy of our policy is provided to any FFP member on request. For information concerning the privacy policies of any third-party gyms or fitness studios, please contact the gyms or fitness studios directly.
Personal information means information about an identifiable individual. This includes an individual’s name, home address and phone number, age, sex, marital or family status, an identifying number, financial information, educational history, etc.
We collect only the personal information that we need for the purposes of providing services to our members, including personal information needed to:
We normally collect client personal information directly from our clients. We may collect your information from other persons with your consent or as authorized by law.
We inform our clients, before or at the time of collecting personal information, of the purposes for which we are collecting the information. The only time we don’t provide this notification is when a client volunteers information for an obvious purpose (for example, producing a credit card to pay a membership fee when the information will be used only to process the payment).
We ask for consent to collect, use or disclose client personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.
We assume your consent to continue to use and, where applicable, disclose personal information that we have already collected, for the purpose for which the information was collected.
We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), or in writing (by signing a consent form).
We hereby ask for your express consent to provide the necessary personal information you provide to us to the applicable third-party gyms or fitness studios so that they can set up your account and allow you to reserve classes.
In cases that do not involve sensitive personal information, we may rely on “opt-out” consent. For example, we may disclose your contact information to other organizations that we believe may be of interest to you, unless you request that we do not disclose your information. You can do this by emailing us directly at firstname.lastname@example.org.
A client may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.
We may collect, use or disclose member personal information without consent only as authorized by law. For example, we may not request consent when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to FFP, in an emergency that threatens life, health or safety, or when the personal information is from a public telephone directory.
We use and disclose members personal information only for the purpose for which the information was collected (to provide you with the benefits of FFP membership), except as authorized by law. For example, we may use client contact information to enable members to book fitness classes at third-party gyms or fitness studios through FFP.
In order to fulfill our service obligations to you, we have contractual arrangements with third-party service providers for website hosting, website improvement, cloud service, booking / scheduling functionality, and payment processing. These third parties may have limited access to databases of member information solely for the purpose of helping us to improve our services and they will be subject to confidentiality restrictions which prohibit them from using the personal information for any other purpose.
If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent.
We make every reasonable effort to ensure that personal information is accurate and complete. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with FFP. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases we may ask for a written request for correction.
We protect personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information. We take all reasonable steps to limit the dissemination of your personal information to only such designated persons as are reasonably necessary to fulfill the services provided through the FFP Platform. We protect the security of your payment information using industry standard encryption technology.
You are also responsible for helping us keep your personal information up to date and secure. This would include not giving your log- in credentials or information or password to third parties.
We use appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records.
We retain personal information only as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes which may extend beyond the termination of your relationship with FFP. We may retain certain data for legitimate business purposes, including analysis of aggregated, non-identifiable data or account recovery or if required by law.
FFP members have the right to access their own personal information that we have collected about you and is in our custody or under our control, subject to some exceptions. For example, we can refuse to provide access to information that would reveal personal information about another member, would reveal confidential business information of FFP or is subject to legal privilege.
If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.
You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. In addition, you may request a correction of an error or omission in your personal information.
Please keep us informed of any changes in your personal or contact information. You may contact Miryah J. Scott at FFP regarding errors in or changes to your personal information, access to your personal information or any questions or comments you have [provide a specific FFP privacy email address]. You must provide sufficient information in your request to allow us to identify the information you are seeking.
If you are not satisfied with the response you receive, you should contact the Information and Privacy Commissioner of Alberta:
Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 – 6 Avenue, SW
Calgary, Alberta T2P 3W2
Toll Free: 1-888-878-4044
Last Updated: September 30, 2017
Copyright © 2017 Freedom Fit Pass Inc. All rights reserved.