Privacy Policy

Privacy Policy 


This Privacy Policy (“Policy”) relates to our website at, and all related downloadable software, [mobile  application] and other services provided by us and in or on which a link to this  Privacy Policy is displayed, and all other communications with individuals by written  or oral means, such as email or phone (collectively, together with the Site, (our “Service”). 

This Policy describes the information that 1StepFitness (“we” or “us”) gathers on or  through the Service, how we use and disclose such information, and the steps we  take to protect such information. By visiting the Site, or by purchasing or using any  Services, you consent to the privacy practices described in this Policy. 

This Policy is incorporated into, and is subject to, our [Acceptable Terms of Use Policy] and our [Terms of Business]. Capitalised terms used but not defined in this  Policy have the meaning given to them in [our Terms of Business and our  [Acceptable Terms of Use Policy] 


“Client” means a customer of ours. 

“Client Data“ means personal data, reports, addresses, and other files, folders or  documents in electronic form that a User of any of our Services stores within the  Service which would include but not be limited to sessions, personal training,  newsletter uploaded by a Client to our Site]. 

“Personal Data” means information that specifically identifies an individual or that is  linked to information that identifies a specific individual. 

“Public Area” means the area of the Site that can be accessed both by Users and  Visitors, without needing to use a login ID and a password. 

“Restricted Area” means the area of the Site that can be accessed only by Users, and  where access requires the use of a login ID and a password. 

“User” means a Client or an employee, agent, or representative of a Client, who  primarily uses the restricted areas of the Site for the purpose of accessing the  Service in such capacity. 

“Visitor” means an individual other than a User, who uses the public area, but has  no access to the restricted areas of the Site or Service. 

The Information We Collect on the Service: 

We collect different types of information from or through the Service:

User-provided Information. When you use the Service, as a User or as a  Visitor, you may provide, and we may collect Personal Data. Examples of  Personal Data include name, email address, mailing address, mobile phone  number, and credit card or other billing information. Personal Data also  includes other information, such as geographic area or preferences, when  any such information is linked to information that identifies a specific  individual. You may provide us with Personal Data in various ways on the  Service. For example, when you register for an Account, use the Service, post  Client Data, interact with other users of the Service through communication  or messaging capabilities, or send us customer service -related requests. 

[Information Collected by Clients. A Client or User may store or upload into  the Service Client Data. Each Client is responsible for providing notice to third  persons concerning the purpose for which the Client collects their Personal  Data and how this Personal Data is processed in or through the Service as  part of Client Data]. 

“Automatically Collected” Information. When a User or Visitor uses the  Service, we may automatically record certain information from the User’s or  Visitor’s device by using various types of technology, including cookies, “clear  gifs” or “web beacons.” This “automatically collected” information may  include IP address or other device address or ID, web browser and/or device  type, the web pages or sites visited just before or just after using the Service,  the pages or other content the User or Visitor views or interacts with on the  Service, and the dates and times of the visit, access, or use of the Service. We  also may use these technologies to collect information regarding a Visitor or  User’s interaction with email messages, such as whether the Visitor or User  opens, clicks on, or forwards a message. This information is gathered from all  Users and Visitors. 

[Integrated Services. You may be given the option to access or register for  the Service through the use of your user name and passwords for certain  services provided by third parties (each, an “Integrated Service”), such as  through the use of your Google account, or otherwise have the option to  authorise an Integrated Service to provide Personal Data or other  information to us. By authorising us to connect with an Integrated Service,  you authorise us to access and store your name, email address(es), date of  birth, gender, current city, profile picture URL, and other information that the  Integrated Service makes available to us, and to use and disclose it in  accordance with this Policy. You should check your privacy settings on each  Integrated Service to understand what information that Integrated Service  makes available to us, and make changes as appropriate. Please review each  Integrated Service’s terms of use and privacy policies carefully before using  their services and connecting to our Service.] 

Information from Other Sources.

We may obtain information, including Personal Data, from third parties and sources  other than the Service, such as [our partners, advertisers, credit rating agencies, and  Integrated Services]. If we combine or associate information from other sources with 

Personal Data that we collect through the Service, we will treat the combined  information as Personal Data in accordance with this Policy. 

How We Use the Information We Collect 

We use the information that we collect in a variety of ways in providing the Service  and operating our business, including the following: 


We use the information – other than Client Data – to operate, maintain, enhance and  provide all features of the Service, to provide the services and information that you  request, to respond to comments and questions and to provide support to users of  the Service. We process Client Data solely in accordance with the directions provided  by the applicable Client or User. 


We use the information – other than Client Data – to understand and analyze the  usage trends and preferences of our Visitors and Users, to improve the Service, and  to develop new products, services, features, and functionality. 


We may use a Visitor’s or User’s email address or other information – other than  Client Data – to contact that Visitor or User (i) for administrative purposes such as  customer service, to address intellectual property infringement, right of privacy  violations or other issues related to the Client Data or Personal Data posted on the  Service or (ii) with updates on promotions and events, relating to services offered by  us and by third parties we work with. You have the ability to opt-out of receiving any  promotional communications as described below under “Your Choices.” 

Cookies and Tracking Technologies 

“Cookies” are text-only pieces of information that a website transfers to an  individual’s hard drive or other website-browsing equipment for record-keeping  purposes. Cookies allow the Site to remember important information that will make  your use of the Site more convenient. Please see our Cookie Policy for more  information 

To Whom We Disclose Information 

Except as described in this Policy, we will not intentionally disclose the Personal Data 

or Client Data that we collect or store on the Service to third parties without the  consent of the applicable Visitor, User or Client. We may disclose information to  third parties if you consent to us doing so, as well as in the following circumstances: Unrestricted Information 

Any information that you voluntarily choose to include in a Public Area of the  Service, such as a chat forum or a banner advertisement or our social media page &  groups will be available to any Visitor or User who has access to that content. 

Service Providers 

[We work with third party service providers who provide website, application  development, hosting, maintenance, and other services for us. These third parties  may have access to, or process Personal Data or Client Data as part of providing  those services for us. We limit the information provided to these service providers to  that which is reasonably necessary for them to perform their functions, and our  contracts with them require them to maintain the confidentiality of such  information] 

Non Personally Identifiable Information 

We may make certain automatically-collected, aggregated, or otherwise non personally-identifiable information available to third parties for various purposes,  including (i) compliance with various reporting obligations; (ii) for business or  marketing purposes; or (iii) to assist such parties in understanding our Clients’,  Users’ and Visitors’ interests, habits, and usage patterns for certain programs,  content, services, and/or functionality available through the Service. Law Enforcement, Legal Process and Compliance 

We may disclose Personal Data or other information if required to do so by law or in  the good-faith belief that such action is necessary to comply with applicable laws, in  response to a court order, judicial or other government subpoena or warrant, or to  

otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose Personal Data or other information that we  believe, in good faith, is appropriate or necessary to (i) take precautions against  liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or  activity, (iii) investigate and defend ourselves against any third-party claims or  allegations, (iv) protect the security or integrity of the Service and any facilities or  equipment used to make the Service available, or (v) protect our property or other  legal rights, enforce our contracts, or protect the rights, property, or safety of  others. 

Transfer of Ownership 

Information about Users and Visitors, including Personal Data, may be disclosed and  otherwise transferred to an acquirer, successor or assignee as part of any merger,  acquisition, debt financing, sale of assets, or similar transaction, as well as in the  event of an insolvency, bankruptcy, or receivership in which information is  transferred to one or more third parties as one of our business assets and only if the 

recipient of the User or Visitor Data commits to a Privacy Policy that has terms  substantially consistent with this Privacy Policy. 

Client Data may be physically or electronically transferred to an acquirer, or  successor or assignee as part of any merger, acquisition, debt financing, sale of  assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or  receivership in which information is transferred to one or more third parties as one  of our business assets, for the sole purpose of continuing the operation of the  Service, and only if the recipient of the Client Data commits to a Privacy Policy that  has terms substantially consistent with this Privacy Policy. 

Your Options 

Access, Correction, Deletion 

We respect your privacy rights and provide you with reasonable access to the  Personal Data that you may have provided through your use of the Services. If you  wish to access or amend any other Personal Data we hold about you, or to request  that we delete any information about you that we have obtained from an Integrated  Service, you may contact us as set forth in the “How to Contact Us” section. At your  request, we will have any reference to you deleted or blocked in our database. 

You may update, correct, or delete your Account and or Account information and  preferences at any time by [accessing your Account settings page on the  Service].[contacting us at 1StepFitness]. Please note that while any changes you  make will be reflected in active user databases instantly or within a reasonable  period of time, we may retain all information you submit for backups, archiving,  prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where  we otherwise reasonably believe that we have a legitimate reason to do so. 

You may decline to share certain Personal Data with us, in which case we may not be  able to provide to you some of the features and functionality of the Service. At any time, you may object to the processing of your Personal Data, on legitimate  grounds, except if otherwise permitted by applicable law. 

This provision does not apply to Personal Data that is part of Client Data. In this case,  the management of the Client Data is subject to the Client’s own Privacy Policy, and  any request for access, correction or deletion should be made to the Client  responsible for the uploading and storage of such data into the Service. 

Navigation Information 

Opting out from Commercial Communications 

If you receive commercial emails from us, you may unsubscribe at any time by  following the instructions contained within the email or by sending an email to the  address provided in the [“How to Contact Us” section]. 

Users are able to view and modify settings relating to the nature and frequency of  promotional communications that they receive from us by [contacting us using the  unsubscribe option link contained within the email].

Please be aware that if you opt-out of receiving commercial emails from us or  otherwise modify the nature or frequency of promotional communications you  receive from us, it may take up to [ten (10)] business days for us to process your  request. Additionally, even after you opt-out from receiving commercial messages  from us, you will continue to receive administrative messages from us regarding the  Service. 

If a Client requests us to remove any data, we will respond to its request within  [fifteen (15) days. We will delete, amend or block access to any Personal Data that  we are storing only if we receive a written request to do so from the Client who is  responsible for such Personal Data, unless we have a legal right to retain such  Personal Data. We reserve the right to retain a copy of such data for archiving  purposes, or to defend our rights in litigation. Any such request regarding Client Data  should be addressed as indicated in the [“How to Contact Us”] section, and include  sufficient information for us to identify the Client and the information to delete or  amend. 

Third-Party Services 

The Services we provide may contain features or links to websites and services  provided by third parties. Any information you provide on third-party sites or  services is provided directly to the operators of such services and is subject to those  operators’ policies, if any, governing privacy and security, even if accessed through  the Service. We are not responsible for the content or privacy and security practices  and policies of third-party sites or services to which links or access are provided  through the Service. We encourage you to learn about third parties’ privacy and  security policies before providing them with information]. 

Your Privacy Rights 

We will not share any Personal Data with third-parties for their direct marketing  purposes to the extent prohibited by law. If our practices change, we will do so in  accordance with applicable laws and will notify you in advance. 

Interest Based Advertising 

Interest based advertising is the collection of data from different sources and across  different platforms in order to predict an individual’s preferences or interest and to  deliver to that individual, or his/her computer, smart phone or tablet, advertising  based on his/her assumed preference or interest inferred from the collection of data  pertaining to that individual or others who may have a similar profile or similar  interests. 

[We work with a variety of third parties to attempt to understand the profiles of the  individuals who are most likely to be interested in our Services so that we can send  them promotional emails, or serve our advertisements to them on the websites and  mobile apps of other entities.

These third parties include: (a) advertising networks, which collect information about  a person’s interests when that person views or interacts with one of their  advertisements; (b) attribution partners, which measure the effectiveness of certain  advertisements; and (c) business partners, which collect information when a person  views or interacts with one of their advertisements. 

In collaboration with these third parties, we may collect information about our  customers, prospects and other individuals over time and across different platforms  when they use these platforms or interact with them. [Individuals may submit  information directly on our Sites or on platforms run by third parties, or by  interacting with us, our advertisements, or emails they receive from us or from third  parties. We may use special tools that are commonly used for this purpose, such as  cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar  technologies. We may have access to databases of information collected by our  business partners]. 

The information we or third party collect enables us to learn what purchases the  person made, what ads or content the person sees, on which ads or links the person  clicks, and other actions that the person takes on our Sites, or in response to our  emails, or when visiting or using third parties’ platforms. 

We, or the third parties with which we work, use the information collected as  described above to understand the various activities and behaviors of our  customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognise new or past visitors to our Sites; to present more  personalised content; to provide more useful and relevant ads – for example, if we  know what ads you are shown we can try not to show you the same ones  repeatedly; to identify visitors across devices, third party websites and sites, or to  display or send personalized or targeted ads and other custom content that is more  focused on a person’s perceived interest in products or services similar to those that  we offer. 

Our interest-based ads may be served to you in emails or on third-party platforms.  We may serve these ads about our products or services or send commercial  communications directly ourselves or through these third parties. Visitors may opt out of receiving interest based advertising by advertising networks  that may be delivered to them on our platform and other websites by visiting the  following websites: N/A 

These features will opt a Visitor out of many – but not all – of the interest-based  advertising activities in which we or third parties engage.] 

Third Party Cookies 

We are legally required to disclose whether other third parties may collect  personally identifiable information about an individual’s online activities from our  Site or Service. Please see our Cookie Policy for more information 

The information gathered by these third parties is used to make predictions about  your interests or preferences so that they can display advertisements or promotional  material on this Site and on other sites across the Internet tailored to your apparent  interests. 

The business partners and advertising networks that serve interest-based  

advertisements on the Services have limited access to a small amount of information  about your profile and your device, which is necessary to serve you advertisements  that are tailored to your apparent interests. It is possible that they may reuse this  small amount of information on other sites or services. 

We do not share with these third parties any information that would readily identify  you (such as email address); however, these third parties may have access to  information about your device (such as IP or MAC address). We do not have access  to, or control over, the technologies that these third parties may use to collect  information about your interests, and the information practices of these third  parties are not covered by this Privacy Policy. Other than as discussed in this  document, we have no control over these third parties. 

Minors’ Privacy 

Protecting the privacy of minors is especially important. Our Service is not directed to minors under  the age of 16, and we do not knowingly collect Personal Data from persons under the age of 16 without obtaining parental consent. If you are under 18 years of age, then please do not use or  access the Service at any time or in any manner. If we learn that Personal Data has been collected on  the Service from persons under 16 years of age and without verifiable parental consent, then we will  take the appropriate steps to delete this information. If you are a parent or guardian and discover  that your child under 18 years of age has obtained an Account on the Service, then you may alert us  at 1StepFitness and request that we delete that child’s Personal Data from our systems. The Service is not intended to be used by minors, and is not intended to be used to post content to  share publicly or with friends. To the extent that a minor has posted such content on the Service, the  minor has the right to have this content deleted or removed using the deletion or removal options  detailed in this Privacy Policy. If you have any question regarding this topic, please contact us as  indicated in the [“How to Contact Us”] section. Please be aware that, although we offer this deletion  capability, the removal of content may not ensure complete or comprehensive removal of  that content or information. 

Data Security 

We follow generally accepted industry standards to protect the information  submitted to us, both during transmission and once we receive it. We use ISO  certified cloud services and applications. We maintain appropriate administrative,  technical and physical safeguards to protect Personal Data against accidental or  unlawful destruction, accidental loss, unauthorised alteration, unauthorised  disclosure or access, misuse, and any other unlawful form of processing of the  Personal Data in our possession. This includes, for example, firewalls, password 

protection and other access and authentication controls. We use TLS technology to  encrypt data during transmission through public internet and ISO certified cloud  services and applications, [and we also employ application-layer security features to  further anonymise Personal Data.] 

However, no method of transmission over the Internet, or method of electronic  storage, is 100% secure. We cannot ensure or warrant the security of any  information you transmit to us or store on the Service, and you do so at your own  risk. We also cannot guarantee that such information may not be accessed,  disclosed, altered, or destroyed by breach of any of our physical, technical, or  managerial safeguards. If you believe your Personal Data has been compromised,  please contact us as set forth in the [“How to Contact Us”] section. If we learn of a security systems breach, we will inform you of the occurrence of the  breach in accordance with applicable law. 

Data Retention 

We only retain the Personal Data collected from a User for as long as the User’s  account is active or otherwise for a limited period of time as long as we need it to  fulfill the purposes for which we have initially collected it, unless otherwise required  by law. We will only retain and use information as necessary to comply with our legal  obligations, resolve disputes, and enforce our agreements. 

Privacy Settings 

Although we may allow you to adjust your privacy settings to limit access to certain  Personal Data, please be aware that no security measures are perfect or  impenetrable. We are not responsible for circumvention of any privacy settings or  security measures on the Service. Additionally, we cannot control the actions of  other users with whom you may choose to share your information. Further, even  after information posted on the Service is removed, caching and archiving services  may have saved that information, and other users or third parties may have copied  or stored the information available on the Service. We cannot and do not guarantee  that information you post on or transmit to the Service will not be viewed by  unauthorised persons. 

Data Transfer 

International transfers 

[The Company will not transfer personal information outside the European Economic  Area (EEA), which comprises the countries in the European Union and Iceland,  Liechtenstein and Norway. 


The Company may transfer personal information outside the European Economic  Area (EEA) (which comprises the countries in the European Union and Iceland, 

Liechtenstein and Norway) to [England] on the basis [that that country, territory or  organisation is designated as having an adequate level of protection OR that the  organisation receiving the information has provided adequate safeguards by way of  [binding corporate rules OR standard data protection clauses OR of compliance with an approved code of conduct]. 


The Company will ensure that staff are adequately trained regarding their data  protection responsibilities. Individuals whose roles require regular access to personal  information, or who are responsible for implementing this policy or responding to  subject access requests under this policy, will receive additional training to help  them understand their duties and how to comply with them. 

Foreign Visitors 

The Service is hosted in the UK. If you choose to use the Service from regions of the  world with laws governing data collection and use that may differ from EU and UK law, then please note that you are transferring your Client Data and Personal Data  outside of those regions to the UK for storage and processing. Also, we may transfer  your data to other countries or regions in connection with storage and processing of  data, fulfilling your requests, and operating the Service. By providing any  information, including Client Data and Personal Data, on or to the Service, you  consent to such transfer, storage, and processing. 

Data Controller and Data Processor 

We do not own, control or direct the use of any of the Client Data stored or  processed by a Client or User via the Service. Only the Client or Users are entitled to  access, retrieve and direct the use of such Client Data. We are largely unaware of  what Client Data is actually being stored or made available by a Client or User to the  Service and do not directly access such Client Data except as authorised by the  Client, or as necessary to provide Services to the Client and its Users

Because we do not collect or determine the use of any Personal Data contained in  the Client Data and because it does not determine the purposes for which such  Personal Data is collected, the means of collecting such Personal Data, or the uses of  such Personal Data, we are not acting in the capacity of data controller in terms of  the European Union’s Directive 95/46/EC on data privacy or the European Data  Protection Regulation (“GDPR”) and do not have the associated responsibilities  under GDPR.  

We should be considered only as a processor on behalf of our Clients and Users as to  any Client Data containing Personal Data that is subject to the requirements of  GDPR. Except as provided in this Privacy Policy, We do not independently cause  Client Data containing Personal Data stored in connection with the Services to be  transferred or otherwise made available to third parties, except to third party 

subcontractors who may process such data on our behalf in connection with our provision of Services to Clients. Such actions are performed or authorised only by the  applicable Client or User. 

The Client or the User is the data controller under the Directive for any Client Data  containing Personal Data, meaning that such party controls the manner such  Personal Data is collected and used as well as the determination of the purposes and  means of the processing of such Personal Data. 

We are not responsible for the content of the Personal Data contained in the Client  Data or other information stored on our servers (or our subcontractors’ servers) at  the discretion of the Client or User nor are we responsible for the manner in which  the Client or User collects, handles disclosure, distributes or otherwise processes  

such information. 

Changes and Updates to this Policy 

Please revisit this page periodically to stay aware of any changes to this Policy, which  we may update from time to time. If we modify the Policy, we will make it available  through the Service, and indicate the date of the latest revision, and will comply with  applicable law. Your continued use of the Service after the revised Policy has become  effective indicates that you have read, understood and agreed to the current version  of the Policy. 

How to Contact Us 

Please contact us with any questions or comments about this Policy, your Personal  Data, our use and disclosure practices, or your consent choices by email at 

Changes to this privacy policy 

This privacy policy was published on 15/05/2018 and last updated on 15/05/2018.

You can download a copy of our Privacy Policy by clicking here