Company: NRS Innovations Limited - Company Number 6839865.
DPA: Data Protection Act 2018 which implements the EU’s General Data Protection Regulation.
Systems Used To Keep Data: JTX Issue Tracker, LMX (in-house database systems), Xero, Magento, Amazon.
NRS Innovations is committed to processing data in accordance with its responsibilities under the DPA.
DPA requires that personal data shall be:
a. Processed lawfully, fairly and in a transparent manner in relation to individuals.
b. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be incompatible with the initial purposes.
c. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
d. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
e. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to the implementation of the appropriate technical and organisational measures required by the DPA in order to safeguard the rights and freedoms of individuals; and
f. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
a. This policy applies to all personal data processed by the Company, for both customers and employees/workers.
b. The Responsible Person, under the guidance of the Managing Director, is responsible for the Company’s ongoing compliance with this policy.
c. This policy will be reviewed at least annually.
d. The Company has registered with the Information Commissioner’s Office as a Company that processes personal data.
a. To ensure its processing of data is lawful, fair and transparent, the Company maintains databases to record all contact with our customers.
b. Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner. The relevant Privacy Notice gives guidance on how to do this.
a. All data processed by the Company is done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information). Further details are available in the relevant Privacy Notice.
b. Lawful bases include:
i. Contract: Processing is necessary due to the fulfilment of a contract.
ii. Legitimate Interests: Processing is necessary for the legitimate interests of or a third-party affiliate.
iii. Consent: The data subject has freely given consent for their information to be processed for a specific purpose.
iv. Vital Interest: Processing is necessary to save or protect an individual’s life.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent and guidance on how to request this is contained within the relevant Privacy Notice.
a. The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
b. If an individual requires the removal of data from NRS Innovations systems, they should contact the DPO via our contact form and mark for the attention of the DPO and they will get in touch with them.
a. The Company shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps are in place to ensure that personal data is kept up to date.
c. In processing customer requests NRS Innovation will ask for confirmation of details from the customer to ensure the details are correct and accurate.
Personal data will be kept for as long as it is needed, to process complaints/issues and future purchases. If a customer wishes to remove their data, they should contact the DPO - please use our contact form and mark for the attention of the DPO and they will get in touch with you. They will delete the information where it is possible to do so. If the information is still required to meet contractual or legitimate interests, the data will be retained until the time limit for retaining that data is reached.
a. The Company stores all personal data securely using modern software that is kept up-to-date. Where personal data is stored in hard copy, it is kept in secured storage.
b. Access to personal data is limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information.
c. When personal data is deleted, this is such that the data is irrecoverable.
d. Appropriate backup and disaster recovery solutions are in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, or unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.
In the event of a data breach inform your direct manager immediately, no matter how small you believe the breach to be and contact the Data Processing Officer.
It is essential that appropriate working practices are followed so that this data protection policy is practically applied across the Company. Anyone who processes personal data on the Company’s behalf is therefore required to:
a. Be aware of the data protection policy and issues relating to data protection and to work towards continuous improvement of the proper processing of personal data.
b. Evaluate whether the personal data you hold is being processed in accordance with this policy, particularly with regard to ensuring that inaccurate, excessive or out of date data is disposed of in accordance with the information security section of this policy.
c. Notify your line manager immediately you become aware of an actual or potential data breach, no matter how small the data breach may be perceived to be.
d. Record any data breaches as instructed by your manager and make suggestions with regard to improvements that you believe can be made to prevent recurrences.
e. Make sure that passwords are used where appropriate and not shared with anyone else unless it is necessary for the processing of personal data.
f. Make sure your computer or laptop is password protected and log-off from your computer whenever you leave it so that it is secure and cannot be accessed by anyone else (this is especially important where you are working remotely from the main office).
g. Make sure that any physical documents containing personal data are secured in a locked drawer or filing cabinet and not left on your desk or workstation when you are not processing that data.
h. Take extra care of special categories of personal data to ensure this data is kept securely.
i. Carefully and securely delete or destroy personal data that is no longer required i.e. by shredder for written records and to include back-ups of electronic data that are deleted.
The Company will ensure that anyone who handles personal data on behalf of the Company is properly trained in the legislation and their responsibilities for that data.
Last updated 15/1/2024
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that this web page contains a lot of information, and we are keen that you are fully informed about your rights, and how we use your data. For example, we will explain things like, what data we collect about you and any companies we share your data with.
We hope the following information will answer any questions you have but if not, please do get in touch with us.
JTX Fitness is a company selling home gym equipment and accessories. Based in the UK, JTX Fitness is a brand name of NRS Innovations. This Privacy Notice applies to international orders. For simplicity throughout this notice, ‘we’ and ‘us’ mean JTX Fitness.
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase and pass them to our warehouse and courier company.
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to request a review of your experience with our products and services. We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
If you have purchased with us: your name, billing/delivery address, orders and receipts, email address and telephone number.
Details of your interactions with us through our contact centre, showroom or online. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made and how and when you contacted us.
Your comments and product reviews.
Your image may be recorded on video footage or audio files you send to us to diagnose an issue with your machine.
We want to give you the best possible customer experience. One way to achieve that is to get the fullest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
It’s worth bearing in mind that if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
To process any orders that you make by using our websites, in the showroom or over the phone. Collecting your personal data during checkout enables us to process your order and comply with our legal obligations.
For example, your details may need to be passed to a third party to deliver the product or service that you ordered. We keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, warranties and so on.
To respond to your queries, request for a refund and warranty requests. Handling the information you supply to us enables us to respond. We may also keep a record of these to help inform any future communication with you and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To help us understand any quality or performance issues with our products. By analysing the information you provide to us about any issues you have experienced, we can improve the quality of the product.
To process payments we do this on the basis of our contractual obligations with you.
If you are an existing customer, we will use your personal data, preferences and details of your transactions to keep you informed about relevant products and services – such as special offers, discounts and promotions. We will communicate with you by email, web, text, telephone and through our contact centre.
Of course, you are free to opt out of hearing from us at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Policy, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we will be unable to comply with our legal obligations.
To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
To comply with our contractual or legal obligations to share data with law enforcement.
For example, if a court order is submitted to share data with law enforcement agencies or a court of law.
To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest in doing so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by opting out.
Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers or an engineer visiting your home). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
We know how much data security matters to all our customers. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment information) is secured by SSL encryption.
We regularly monitor our system for possible vulnerabilities and attacks.
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
An example of a retention period is warranties: If your order included a warranty, the associated personal data will be kept until the end of the warranty period.
There are a number of ways you can stop direct marketing communications from us:
Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails.
Write to: Customer Services – JTX Fitness, Unit 3, Harbour Way, Shoreham-By-Sea, West Sussex, BN43 5HZ.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
We may share your personal data with trusted third parties.
For example, delivery couriers, engineers visiting your home, for fraud management, to help diagnose issues with your equipment, to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
We aim to provide only the information they need to perform their specific services. They may only use your data for the exact purposes we specify in our contract/data processing agreement with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
We will only do this in very specific circumstances, for example:
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
We may expand, reduce or sell the business and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
For further information please contact our Data Protection Officer.
To help personalise your journey through the JTX Fitness website and improve the services we offer you, we currently use the following companies who will process your personal data as part of their contracts with us:
Sometimes we might need to share your personal data with third parties and suppliers outside the UK.
Protecting your data outside the UK.
The UK has adequacy regulations about the following countries and territories:
For example, this might be required in order to fulfil your order, process your payment details or provide supportive services.
If on the rare occasion we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the UK. If you wish for more information about these contracts please contact our Data Protection Officer.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
An overview of your different rights.
You have the right to request:
You can contact us to request to exercise these rights at any time as follows: To ask for your information please contact The Data Protection Officer, please use our contact form and mark for the attention of the DPO and they will get in touch with you.
JTX Fitness, Unit 3, Harbour Way, Shoreham-By-Sea, West Sussex, BN43 5HZ.
If we choose not to action your request we will explain to you the reasons for our refusal.
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels. We must always comply with your request.
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites) If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence from using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
We’ll ensure that any third parties process your personal data only in accordance with their legitimate interests. These third parties may be subject to different laws from those which apply in your country of residence. Please note that we do not take active steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you: Please use our contact form and mark for the attention of the DPO and they will get in touch with you.
Or write to us at:
Data Protection Officer, JTX Fitness, Unit 3, Harbour Way, Shoreham-By-Sea, West Sussex, BN43 5HZ.
Last updated 17/1/2024
