DATA PROTECTION POLICY

In this policy on the processing of personal data, you can read about how SATS Danmark A/S ("SATS" or "we") process the personal data we, among other things, obtain when you are a member of SATS, communicate with us, visit our website and/or otherwise use the various services and functions we offer.

1.                Data controller responsibility

SATS is the data controller for the processing of your personal data. Our legal information is as follows:

SATS Danmark A/S

CVR no. 20 37 05 99

Kanalvej 1

2800 Kongens Lyngby

Denmark

2.                How we use personal data

Visiting the SATS website

See more under the Cookie Policy.

Visiting the SATS social media pages

If you visit our social media pages, currently Facebook, Instagram, TikTok, LinedIn and Youtube, we will process the information you have made available via the settings on the social media. In addition, we will be able to see your reactions (uploads, shares, likes, comments, etc.). We will also have access to anonymised statistics to gain insight into the use of our social media pages.

When processing such information we act as joint data controller together with the social media in question. The joint data controller agreements may be found using the following links:

Facebook/ Instagram (Meta): https://www.facebook.com/legal/terms/page_controller_addendum

TikTok: https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms

Linkedin: https://legal.linkedin.com/pages-joint-controller-addendum

Youtube

Please note that even if you delete your account or stop following us on social media, you reactions will still be available on our page, unless you delete them yourself.

The purpose of our processing of your personal data is to market and optimise the marketing of SATS, disseminate relevant content and respond to your inquiries via the social media communication tools.

The legal basis for the process of your personal data is:

The GDPR's article 6 (1) litra f (SATS' legitimate interest in being able to market SATS on social media, communicate with you and compile statistics)

Using the SATS App (the "App")

The personal data that are principally processed are your membership information, information about social functions (e.g. commenting on friends' exercise), your exercise, your preferences and group fitness class registrations. We collect and may also automatically process technical information such as information about mobile devices, unique device identifiers (e.g. EMEI and MAC numbers), operating system, network information, IP address, search words, time of use of the App and location (if you have consented to it).

In addition, we collection information about what you give the App access to through the settings on your device as well as the information that this access enables.

The App contains various functions that you may voluntarily choose to use, which may result in the processing of personal data. In this connection, both general personal data and sensitive personal data may be collected, e.g. when using Google Fit and/or Apple Health Kit. Another function is participation in challenges or other competitions in the App. It will be specifically stated in connection with the various functions, which information is processed.

The overall purpose is to make the App and the desired services available, to optimise the App and the user experience, including by compiling statistics on your use and to carry out targeted marketing, including retargeting via Facebook, Snapchat and Google.

The purpose of collecting information in connection with a group fitness class registration is to be able to reserve a place in the desired class and to compile statistics at an aggregated level on registrations, non-attendance, etc.

The legal basis for the processing of your personal data is:

The GDPR article 6(1) litra a (consent in connection with your use of optional functions in the App, including via settings on your device)

The GDPR article 6(1) litra b (performance of an agreement with you)

The GDPR article 6(1) litra f (legitimate interest in being able to improve the user experience and the App's functions as well as compile statistics on an aggregated level on group fitness class registrations, adapt communication and exercise, etc.)

The GDPR article 9(2) litra a and article 6(1) litra a (consent to any sensitive data in connection with your use of optional functions in the App)

Direct marketing and other communication regarding SATS

We collect information such as your name, e-mail address, mobile telephone number as well as any preferences.

The overall purpose is to be able to send direct marketing, including newsletters, as well as other relevant communication such as marketing of similar products, etc.

The purpose of sending out customer satisfaction surveys and analysing aggregated statistics on members' use of our exercise offerings is to improve and optimise our exercise offerings in order to understand our members' needs and preferences.

The legal basis for the processing of your personal information is

The Danish Marketing Act section 10-1 (consent to direct marketing)

The Danish Marketing Act section 10-2 (right to use personal data provided in connection with the purchase of a product to market own similar products)

The GDPR article 6(1) litra f (legitimate interest in sending out customer satisfaction surveys or other studies)

If you no longer wish to receive marketing, you may use the unsubscribe link in the marketing messages you receive, or go to "My page" on our website or in the App. Note that you cannot opt out of non-marketing information.

Persons who contact SATS or otherwise communicate with SATS, e.g. via the website or the App

We collect the information you provide, e.g. name, address, telephone number, e-mail address, the content of your/our communication.

The purpose is to be able to provide membership services and/or answer your requests and otherwise communicate with you.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra b (performance of an agreement with you or discussions prior to entering into an agreement with you)

The GDPR article 6(1) litra f (SATS has a legitimate interest in processing your data for the purpose of communicating with you)

The holding of competitions

We collect the data you provide in connection with participation in competitions, e.g. name, e-mail address, competition response, etc.

The purpose is to be able to complete the competition and notify you if you win. If necessary for the specific competition and prize, we will forward your contact details and prize information to the relevant prize provider for the purpose of delivery of the prize in question.

If we are subject to a legal obligation, e.g. a reporting requirement, your contact details and any prize information in connection with the holding or end of the competition will be forwarded to the appropriate authority.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra b (performance of an agreement with you)

The GDPR article 6(1) litra c (legal obligation in connection with a possible reporting obligation)

Membership registration and the administration thereof

In order to register you as a member with us, and order for us to be able to invoice and manage your membership, we process your name, national ID number, contact information, photo, membership type and your communication with us. Depending on which membership you buy, and where and how you make the payment, registration and card numbers, the last 4 digits of the card number on the payment card, the card type and the card's expiry date as well as details related to your current payments and purchases are collected.

If you have a membership via a company agreement or via a partner, we will also process information regarding your employer / the partner through which you have your membership. If you have a student membership, we will also process information regarding your place of sturdy.

If someone else pays for the membership, the same information is collected as when registering a membership about both the payer and the member. However, payment information about the member is not collected, just as information such as photo and membership number is not processed as far as the payer is concerned.

We will also register information about the use of a personal trainer and your other use of our exercise offers. If you choose to share information with us about your health, such as physical injuries or illnesses, we will also process this.

If you are banned/excluded from exercising at SATS, we will process your full name, national ID number, membership number, quarantine period, reason and the letter you received from SATS in connection with the ban/exclusion from SATS.

The purpose of collecting information is to perform the agreement with you, including continuously managing your membership and your rights, among other things, by sending information relating to your membership and other communication with you in general. Photos are collected and processed for verification in connection with access control. The national ID number is collected partly for the purpose of registering with a payment service, partly for the purpose of publication in our internal list of persons who have been banned from exercising at SATS, and partly for the purpose of publication in the Register of sanctions for doping cf. "Doping control and registration in Register of sanctions for doping".

The purpose of processing your data in connection with banning/exclusion is – for a specified period – to refuse previously banned/excluded members from signing up for a new SATS membership.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra b (performance of an agreement with you)

The Danish Accounting Act section 12 (storage of accounting records)

The GDPR article 6(1) litra f (SATS' legitimate interest in preventing fraud and abuse of memberships, safeguarding the interests of the staff and other members as well as SATS' legitimate interest in being able to decide when a banned member may regain membership)

The Danish Data Protection Act section 11-2 no. 2 (consent to the processing of national ID number)

The GDPR article 9(2) litra a and article 6(1) litra a (consent in relation to the processing of health data)

Online exercise

If you use online exercise, we will register your user name, your searches, your history and the favourites you save.

The purpose of collecting the data is to manage your use of online exercise and to improve the experience of our services.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra b (performance of an agreement with you)

The GDPR article 6(1) litra f (SATS' legitimate interest in being able to improve the user experience as well as compile statistics at an aggregated level on the exercise videos used)

Exercise-related services

If you use our exercise-related services such as personal training ("PT"), Bootcamps, physiotherapy, massage, dietary guidance or lifestyle courses, we will process data about you that are necessary for these services, such as health, weight, habits, needs and preferences.

The purpose of collecting the data is to perform the agreement with you, including documenting your purchases.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra b (performance of an agreement with you)

The Danish Accounting Act section 12 (storage of accounting records)

The GDPR article 6(1) litra a and article 9(2) litra a (consent, including in relation to the processing of health data)

Purchases online or at a SATS centre

If you make purchases in our online shop, or if you make purchases at one of our fitness centres which you link to your membership, we will, for bookkeeping purposes, process information regarding your purchases, i.e., what you purchased, the time of the purchase and the amount.

The purpose of collecting the data is to perform the agreement with you, including documenting your purchases.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra b (performance of an agreement with you)

The Danish Accounting Act section 12 (storage of accounting records)

Visiting SATS centres in connection with exercise

We automatically collect information about check-in (date, time, centre and membership number), information about your attendance at group fitness classes, PT and Bootcamps (date, time, centre, membership number and name of group fitness class) as well as information about lack of non-attendance of group fitness classes, PT and Bootcamps (date, time, centre, membership number and name of group fitness class).

The purpose is to perform the agreement with you, organise group fitness classes, charge payment for non-attendance and to use general statistics at an aggregated level on visitors to our centres, including non-attendance.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra b (performance of an agreement with you)

The GDPR article 6(1) litra f (SATS has a legitimate interest in you showing up for group fitness classes and in processing aggregated information for statistical purposes)

Studies

Occasionally, we recruit members for studies, surveys or other research conducted by third parties. There may be collection of both general and sensitive data. Participation is always voluntary. Unless you consent thereto, we will not gain access to information from such studies at the individual level, but we may gain access to the results at an aggregated level.

The purpose is to improve the exercise offerings, including collecting feedback, wishes and exercise preferences.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra a and article 9(2) litra a (consent, including in relation to the processing of health data)

The GDPR article 6(1) litra F (SATS has a legitimate interest in processing aggregated general data for statistical purposes)

Video surveillance

Recordings from video surveillance of the SATS centres, including of entrance areas, reception areas, fitness areas and exercise areas. Video surveillance is carried out around the clock.

The purpose of the video surveillance is to prevent crime in the form of burglary and shrinkage and gross violations of SATS' internal rules, as well as to ensure security for the staff, members and other guests and to be able to apply to the Danish Data Protection Authority for permission to disclose. The recordings will be reviewed in random checks, in the event of specific suspicion or other irregularities.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra f (legitimate interest in being able to control and enforce the above-mentioned purpose) as well as article 10 cf. the Danish Data Protection Act sections 6 and 8

The Danish Video Surveillance Act section 4C-1 no. 3 (disclosure of recordings to the police) as well as section 4C-2 (disclosure internally in SATS or to other businesses according to a permit from the Danish Data Protection Authority.

Body analysis

If you purchase a body analysis, for which the InBody meter is used, SATS will collect information such as your telephone number, your weight, your BMI, your fat percentage, your muscle mass and where and when the measurement was taken. Depending on your choices, the InBody meter may also collect information on resting metabolism, waist/hip ratio, fat mass, fat-free mass and body water.

The purpose is to be able to deliver the body analyses you have purchased as well as to optimise your user experience.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra a (consent)

The GDPR article 6(1) litra b (performance of an agreement with you)

The GDPR article 9(2) litra a and article 6(1) litra a (consent to the extent that sensitive data are processed)

Debt to SATS

We process information such as your full name, address, e-mail address, telephone number, national ID number, payment method, registration and account number. In addition, we process information about which membership, product or service the debt relates to, correspondence in the matter, as well as other information that is necessary for the collection of our receivables.

The purpose is to collect our receivables from you.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra f (SATS' legitimate interest in being able to collect its receivables)

The Danish Data Protection Act section 11-2 no. 3 (processing of national ID number to ensure unambiguous identification)

Doping control and registration in the Register of sanctions for doping

SATS cooperates with Anti-Doping Danmark ("ADD") cf. SATS' general terms and conditions. SATS processes information such as name and membership number as well as members' positive tests for the purpose of terminating memberships and temporary banning. SATS also processes national ID numbers for the purpose of looking up persons the Register of sanctions for doping in order to obtain information as to whether a potential member has been sanctioned for doping and, if so, the duration of the sanction.

The purpose is to prevent the use of doping in sports, including at SATS' centres, as well as compliance with SATS' cooperation agreement with ADD.

The legal basis for the processing of your personal data is

The GDPR article 6(1) litra f (SATS' legitimate interest in being able to prevent the use of doping, including at SATS' centres)

The Danish Act relating to the promotion of integrity in sports section 9 and executive order relating to the promotion of integrity in sports sections 3 and 6 (cooperation agreement with ADD on combating doping)

The Danish Data Protection Act section 11-2 no. 2 (consent to the processing of national ID numbers)

3.                With whom do we share personal data

We only share personal data with others when permitted or required by law.

The Group Our organisation is part of a group of companies, in which personal data is shared between the group companies for use for internal administrative purposes or otherwise depending on the specific circumstances.

Advisers We may also share your data with our advisers, such as auditors, lawyers, collection agencies, etc.

Third parties In relation to certain processing, it may be necessary to share your personal data with third parties. If you enter into a payment service agreement with us, we will forward your personal data to the relevant provider. We will also forward your data to the extent we are required, e.g. as a consequence of reporting requirements to public authorities, such as the Danish tax administration. We collect various personal data via cookies in connection with your use of the website or the App cf. in more detail above under the section "Visiting the SATS website", which is forwarded to Google Ireland Limited, Snap Inc., LinkedIn Ireland Unlimited Company and Meta Platforms Ireland (Facebook) for the purpose of targeting marketing. You may read more about the respective providers' processing of your personal data on their websites.

External data processors We use external data processors to process data on our behalf, among other things, for hosting and support, for technical operations and for improvements to the website and the App, distribution of newsletters and targeted marketing, including retargeting, as well as to obtain your rating of our company and products. We have entered into data processing agreements with our data processors to ensure that the data are processed properly and not used for other purposes.

We do not transfer personal data to countries or international organisations outside the EU/EEA, unless we have a transfer basis according to the GDPR.

4.                How long do we retain the personal data

We retain your personal data as long as it is necessary for the purposes mentioned above. Then we delete them.

Unless you consent otherwise, this generally means that:

Information about "Using the SATS App", "Membership registration and administration thereof", "Online exercise" and "Exercise-related services", "Visiting SATS centres in connection with exercise" and "Body analysis" will be deleted no later than six months after the membership has ended. However, this does not apply to information about banning/exclusion, which is deleted at the earliest when the quarantine period expires, unless it is a matter of a permanent ban. In addition, information is retained which, according to the Danish Accounting Act, shall be retained for 5 years. "Debt to SATS" and "Doping control and registration in the Register of sanctions for doping" are deleted when the case is closed, or when a possible quarantine period expires.

Information for the use in "Direct marketing and other communication regarding SATS" is deleted when you withdraw your consent, but in any case no later than 6 months after the membership has ended. Information used for customer satisfaction surveys is deleted or anonymised immediately after the survey has been completed.

Information about "Purchases online or at a SATS centre" is deleted after 5 years in accordance with the Danish Accounting Act.

Information from "Video surveillance" is deleted no later than one week after the recordings were made, unless it is likely that the recordings will be used by or disclosed to the police.

Information about "Persons who contact SATS or otherwise communicate with SATS" is deleted on an ongoing basis

Information about "Visiting the SATS website" and "Visiting the SATS social media pages" depends on the specific information and functions to which you have consented, but information about this will always be deleted or anonymised in accordance with applicable legislation, and when it no longer serves a purpose.

5.                Security

We have high security standards, also when it comes to the protection of your personal data. Therefore, we have a number of internal procedures and policies that ensure that we live up to our high security standards and thus meet the requirement to implement appropriate technical and organisational security measures. Thus, we do our best to ensure the quality and integrity of your personal data.

6.                Your rights in connection with the protection of personal data

You have the right to access to the personal data we process about you, with certain exceptions provided for in the legislation. In addition, you may object to the collection and further processing of your personal data. Furthermore, you have the right to have your personal data corrected, or you may ask us to limit the processing of your personal data.

If you ask for it, we will delete the personal data that we have registered about you without undue delay, unless we may continue the processing on another basis, e.g. if the processing is necessary for us to establish a legal claim, if it is necessary to answer an inquiry from you, or if we are required by law to retain the information.

In certain circumstances, you may also request that we provide you with a copy of your personal data in a structured, commonly used and machine-readable format, and request that we transmit the information to another data controller (data portability).

If we process your personal data on the basis of your consent, you may withdraw your consent at any time. If you withdraw your consent, we will cease to process your personal data, unless we are entitled or required to continue processing or retaining your personal data on another basis, including according to law. The withdrawal of your consent does not affect the lawfulness of the processing that took place before the withdrawal of the consent.

If you wish to exercise your rights as described above, you are welcome to contact us at any time. We ask that, in connection with requests regarding your rights, you provide us with sufficient information for us to process your request, including your full name and your e-mail address, so that we can identify you and respond to your request. We will respond to your request as soon as possible.

If you disagree with the manner in which we process your personal data, you may submit a complaint to the Danish Data Protection Authority. We would appreciate that your contact us first, so that we may clear up any misunderstandings.

7.                Possible consequences of not providing personal data

If you are required to provide information about yourself to us, this will be stated where we collect the information.

In some cases, it may be a statutory requirement or a requirement according to a contract cf. the GDPR article 13(2) litra e.

If you do not want to provide the personal data we ask for, then this may have the consequence that we cannot register you as a member, provide you with the services you request, complete your orders, etc.

8.                Contact details

You may contact us at privace@sats.no if you wish to exercise your rights or if you have other questions, comments or want more information about our processing of personal data.

9.                Updates of the personal data policy

We reserve the right to update this personal data policy due to significant changes in legislation, new technical solutions, new or improved functions.