Privacy Policy

1. Important Notice

a) This is the Privacy Notice of Frame which is the trading name of Endorphin Dealers Ltd. (company number 13840526) whose registered office is at 29 New Inn Yard, Shoreditch, London, Greater London, EC2A 3EY (“we”, “us” or “our”) and sets out how we collect and process your personal data. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data.

b) This Privacy Notice relates to personal data that identifies “you” meaning our customers or individuals who browse our website and other individuals outside our organisation with whom we interact. However if you are an employee or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead.

c) We refer to this information throughout this Privacy Notice as “personal data” and paragraph 3 sets out further detail of what this includes.

d) Please read this Privacy Notice to understand how we may use your personal data. e) This Privacy Notice may vary from time to time so please check it regularly. This original version was published on 4th of Feb 2022.

2. How to contact us

a) Data controller and contact details
‍
For the purposes of relevant data protection legislation, we are the controller of the personal data you provide to us and as a controller we use the personal data we hold on you in accordance with this Privacy Notice.

If you wish to access or correct your personal data held by us or if you need to contact us in connection with our use of your personal data, then these should be directed to the Data Privacy Manager (see below) using the following details:

By Email:
‍data@moveyourframe.com

‍b) Data Privacy Manager
‍
Our Data Privacy Manager is Pip Black and you can contact her at:
data@moveyourframe.com

3. Categories of personal data we collect

a) The categories of personal data about you that we may collect are:

• Individual Data which includes personal data you provide to us in person, via our website or by telephone, including the personal and contact details (such as your first name, middle name, last name, username or similar identifier, title, date of birth and gender, billing address, delivery address, email address and telephone numbers, family and associate details, and physical or mental health details) you supply when booking a class, signing up to our newsletter or contacting us to let us know we are doing well or to make a complaint or ask a membership / press / brand collaboration / marketing / shop / recruitment / general enquiry;
• Audio and Visual Data which includes personal data which is gathered using our CCTV or other recording systems in the form of images or video footage that is taken at one of our studios or otherwise by us for promotional purposes;
• Account and Profile Data which includes personal data which relates to your account or profile on our website, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
• Advertising and Marketing Data which includes personal data which relates to your marketing preferences, such as information about your preferences in receiving marketing materials from us and our third parties and your communication preferences as well as your personal interests;
• Sales Data which includes personal data which relates to the transactions you have conducted with us, such as details about payments to and from you, details of the products, services, classes and memberships you have purchased from us;
• Economic and Financial Data which includes personal data which relates to your finances, such as your bank account and payment card details and information which we collect from you for the purposes of the prevention of fraud;
• Market Research Data which includes personal data which is gathered for the purposes of market research, such as price comparison information;
• Information Technology Data which includes personal data which relates to your use of our website, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication 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 website; and
• Health Data which includes personal data which is gathered for health and safety purposes including any accident report or claim log.

b) We may also create personal data about you, for example, if you contact us by telephone to make a complaint, such as about our services or products, then we may make a written record of key details of the conversation so that we can take steps to address the complaint.

c) We also obtain and use certain aggregated data such as statistical or demographic data for any purpose (“aggregated data”). Aggregated data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your operational data to calculate the percentage of users accessing a specific feature on our website. However, if we re-combine or re-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 Notice.

d) In addition, we may obtain certain special categories of your data (“special categories of data”), and this Privacy Notice specifically sets out how we may process these types of personal data.

The special categories of data are:
(i) data concerning health.

e) We do not collect information about criminal convictions and offences.

4. The sources from which we obtain your personal data

We obtain your personal data from the following sources:

(a) Directly from you, either in person (at our studios or otherwise), via our website or by telephone. This could include personal data which you provide when you:

• purchase our products or services;
• create an account on our website;
• subscribe to our newsletter;
• request information on our services or products or for other marketing to be sent to you;
• enter into a competition or promotion;
• complete a survey from us or give us feedback; and
• when you visit any of our studios;

(b) Automated technologies, such as CCTV or other recording systems, cookies, server logs and other similar technologies. We may automatically collect Information technology data about your equipment, browsing actions and patterns by using cookies, server logs and other similar technologies. [We may also receive information technology data about you if you visit other websites employing our cookies.] Please see our cookie policy for further details. Audio and visual data may be collected on you if you attend any of our studios for security purposes.

(c) Third parties, such as:

• analytics providers (such as Google Analytics, Segmentum);
• advertising networks (such as Google and Facebook based [inside]/[outside] the EU);
• search information providers (such as Google);
• providers of technical, payment and delivery services (such as Elavon, Realex / GlobalPayments, Stripe, Shopify Plus);
• refer-a-friend providers (such as Mention Me);

(d) Publicly available sources, such as Companies House.

5. How we use your personal data and the basis for using it

a) We may rely on one or more of the following legal bases when processing your personal data. We have set out below the purposes for which we may process your personal data: