Notice of Privacy Practices – Fitness Centers
Premise Health Holding Corp, on behalf of its affiliates and professional associations, corporations, or similarly structured professional organizations with whom it has a managed services agreement, is required by law to maintain the privacy of Personally Identifiable Information (“PII”) and to provide you with notice of our legal duties and privacy practices with respect to PII. References to “Premise Health”, “we”, “us”, and “our” include the employees and workforce members of Premise Health Holding Corp who are involved in providing and coordinating services. We are all bound to follow the terms of this Notice of Privacy Practices for Fitness Centers (“Notice”).
The Notice is also being posted on our website and will be available at our fitness centers. We adopt this notice to comply with the state privacy laws.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or device (“personal information”). We have collected the following categories of personal information from consumers within the last twelve (12) months:
|Identifiers||Name, alias, postal address, unique personal identifier, online identifier, gender, email address, account name, employer name, physical activity readiness questionnaire or other similar identifiers.||YES|
|Personal information categories||Name, signature, physical characteristics or description, address, telephone number, employment, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.||YES|
|Protected classification characteristics||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||YES|
|Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|Geolocation data||Physical location or movements.||NO|
|Sensory data||Audio, electronic, visual, thermal, or similar information.||NO|
|Professional or employment-related information||Current employer.||YES|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Notice Excludes: Bluetooth and Connecting to 3rd Party Application
The fitness equipment may provide links to other websites, the ability to connect to an external site, or connect your Bluetooth device for your convenience. These websites and Bluetooth devices operate independently from Premise Health. Linked websites and your Bluetooth device may have their own privacy notices, which we strongly suggest you review. We are not responsible for content, any use, or the privacy practices of any website or Bluetooth device that you connect to through fitness equipment,
Personal Information Does Not Include
- Publicly available information from government records.
- De-identified or aggregated consumer information.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients. For example, from documents that our clients provide to us related to the services for which they engage us.
- Directly from our members. For example, through information we collect from our members in the course of providing services to them.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To provide you with information, products, or services that you request from us.
- To provide you with email alerts, event registrations, and other notices concerning our products or services or events or news that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collections.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party or our affiliates for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We do not share your personal information with nonaffiliated companies for their direct marketing purposes, unless we have your permission.
Your Rights and Choices
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting your personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to [email protected].
Only you or a representative that is authorized to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your rights. Unless permitted by state law, 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 services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
If you have questions or comments about this notice, our privacy statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under state law, please do not hesitate to contact us at:
Email: [email protected]
Postal Address: Premise Health
Attn: Compliance/Legal Department
5500 Maryland Way
Brentwood, TN 37027
Effective date: March 17, 2020