At Aspria, your privacy and the security of your personal data is very important to us.
We want to transparently explain:
We endeavour to implement and maintain the highest standards with regard to Data Protection and adopt policies in line with the highest level of compliance – the EU GDPR & UK GDPR.
We do not sell your end users’ personal information and we do not share your end users’ information with third parties for those third parties’ own business interests.
Aspria Holdings BV are the Data Controller who operate across various European markets (Belgium, Germany & Italy) and are registered with:
Aspria Holdings BV
Luna ArenA, Herikerbergweg 238
1101 CM Amsterdam
PO BOX 23393
whose registered office is located at:
Hill Place House
55A High Street
Wimbledon
London, SW19 5BA
United Kingdom
Tel: +44 20 8944 4087
Mail: info@aspria.com
Website: www.aspria.com
CEO and Founder: Brian Morris
Legal form: Aspria Holdings BV
Registered office of the company: Amsterdam
Register court: Chamber of Commerce, Amsterdam, company number 33287052
VAT reg. No: GB 977120508
If you need to contact us you can chose to do that via our Data Protection Officer
Aspria Holdings BV
c/o Aspria Berlin GmbH
Karlsruher Str. 20
10711 Berlin
Germany
Attn: Data Protection Officer
Belgium
· Aspria Club SA, Rue Sombre 56, B-1200 Bruxelles
· Aspria City SA, Rue Sombre 56, B-1200 Bruxelles
· Aspria La Rasante S.A., Rue Sombre 56, B-1200 Bruxelles
Germany
· Aspria Alstertal GmbH, Rehagen 20, 22339 Amburgo
· Aspria Berlin GmbH, Karlsruher Straße 20, 10711 Berlino
· Aspria Hamburg City GmbH & Co. KG, Karlsruher Straße 20, 10711 Berlino
· Aspria Hannover GmbH, Karlsruher Straße 20, 10711 Berlino
Italy
· Aspria Club Milano S.P.A., Via Cascina Bellaria 19, 20153 Milano
· Aspresso Roma SRL., Via Marco Polo 127, 00154 Roma
· Tennis Club Ambrosiano SSDRL, Via Feltre 33, 20134 Milano
If you have any concerns regarding how we are processing your personal data we’d like the opportunity to address them – Please contact us via dataprotection@aspria.com
If you believe we have not addressed your concerns you can contact your local Data Protection Authority
We provide various services and offers based upon the relationship you have with us - Aspria Holdings BV.
For example, this could be:
The Personal Data we process will vary according to the services you subscribe to and the functionality you use. As in order to provide various services we process personal data.
The lawful basis we process data under GDPR is either:
There are two further grounds – vital interest & public interest, but we only process data under one of these lawful basis when required.
When we need to process what is classed as special category data e.g. data revealing racial or ethnic origin etc. we will only do so if we have a lawful exemption such as your explicit consent.
We aim to process data in line with the principles of fair and transparent processing. This Data Protection Notice is aimed at informing you of our purposes of processing Personal Data and your rights.
We aim to supplement this by highlighting to you at points where we request / collect personal data in a timely manner and appropriate format.
You have various rights to understand the processing of Personal Data we conduct and to control how we use your data dependent upon the lawful basis the including:
Belgium
Germany
Italy
The Netherlands
UK : the Information Commissioners Office
Please contact us at dataprotection@aspria.com or by post if you wish to make a request.
You are not required to pay any charge for exercising your rights.
If you make a request, the designated period to respond to you is one month but we aim try to respond to you as quickly as feasible.
We regularly review the methods we adopt to support and facilitate your data rights.
We process personal information when you use our products and services based upon the relationship you have with us.
When you communicate with us we process:
Purpose of processing | Category of Data | Examples of Data Types | Lawful Basis |
---|---|---|---|
To fulfil a query, request for services and/or to administer our services |
|
| Legitimate Interest - General business communication |
When you visit a website in addition to General communication data we also process:
Purpose of processing | Category of Data | Examples of Data Types | Lawful Basis |
---|---|---|---|
Marketing Data |
|
| Consent |
Website Analytics & email Effectiveness |
|
| Consent |
Guaranteeing effective customer service and technical support |
|
| Legitimate Interest |
We offer the ability to withdraw your consent / unsubscribe in all our emails but please contact us if you wish to withdraw your consentor exerciseyourrightto object to Direct Marketing.
When you join our one of our clubs or transact as with us we process:
Purpose of processing | Category of Data | Examples of Data Types | Lawful Basis |
---|---|---|---|
Activity Data |
|
| Contractual |
Financial Data |
|
| Contractual |
Service messages related to membership |
|
| Contractual |
Commercial Messages |
|
| Consent |
Insurance reasons, security measures for the benefit of members, guests, staff & visitors |
|
| Legitimate Interest |
Collecting Feedback |
|
| Legitimate Interest |
COVID-19 tracking regulations |
|
| Legal obligations |
Purpose of processing | Category of Data | Examples of Data Types | Lawful Basis |
---|---|---|---|
Activity Data |
|
| Contractual |
Technical messages and communications |
|
| Contractual |
Guardian(s) contacts |
|
| Contractual |
Medical Status |
|
| Legal Obligations |
Physical Health Status |
|
| Consent |
Insurance reasons, security measures for the benefit of our members, guests, staff & visitors |
|
| Legitimate Interest |
Collecting Feedback |
|
| Legitimate Interest |
Purpose of processing | Category of Data | Examples of Data Types | Lawful Basis |
---|---|---|---|
Physical Health Status |
|
| Consent |
Medical Status |
|
| Legal obligations |
COVID-19 regulations |
|
| Legal obligations |
When you contact us or are interest in any service of our clubs
Purpose of processing | Category of Data | Examples of Data Types | Lawful Basis |
---|---|---|---|
Commercial messages relating to our services & marketing measures |
|
| Consent |
We offer the ability to withdraw yourconsent / unsubscribein all our emails,but please contact us if you wish to withdraw your consent or exercise your right to object to Direct Marketing.
We process data based on two broad categories via the myAspria App for members:
We ask for certain Customer Account Data information, such as your contact details, when you sign up for an account with us through our application.
When you download our application various categories of data will be requested – Further detail regarding this is available at
We use App Usage Data to provide services to you and to carry out necessary functions of our business.
As a subscriber to, or when you visit our website, we collect some information automatically in order to help us analyse and report information on how you use our services in order to improve the functionality offered for users.
Summary of Data Processing purposes:
Purpose of processing | Category of Data | Examples of Data Types | Lawful Basis |
---|---|---|---|
To fulfil a query, request for services and/or to administer our services |
|
| Performance of a contract or agreement |
To fulfil a query, request for services and/or to administer our services |
|
| Legal Obligation |
Marketing messages about our products and services. |
|
| Consent |
Segmentation and analysis of app use and website performance |
|
| Our Legitimate interest e.g. Business Performance |
We are committed to protecting our users’ personal data and to help protect the security of your personal data.
In order to do this we:
We provide access for employees and contractors across the Aspria Group to Personal Data on the principle of least privilege (PoLP) - users are given the minimum levels of access – or permissions – needed to perform his/her job functions.
All Aspria Holdings staff receive regular awareness briefings regarding the importance of Data Protection.
In order to carry out the activities specified in this Notice and enable global access to our services we store and distribute content and data in systems and data centres that we use around the world.
For some activity personal data collected within the European Union and Switzerland is transferred to and processed by third parties located in an external country subject to privacy laws that are different from those in the country you live in.
Where we need to do this either directly or through third party data processors we contract with, we
In addition to the lawful transfer mechanism we conduct analysis of the effectiveness of the transfer mechanism to support your Rights and Freedoms with our processors.
To provide our services we use third party data processors to provide elements of services for us.
For our data processors we have contracts in place with them to ensure that they process the data provided to them only for the purposes we have instructed them to. We also specify that they implement specific data minimisation practices and that they will hold data securely and retain it for the period we instruct.
In selecting suppliers and during the contract we regularly review and assess the third parties we use to ensure that they abide with the principles of the GDPR.
We keep your personal data only as long as:
We will delete specific personal information you request unless we are legally allowed or required to maintain certain personal data – where it prevents us from carrying out necessary business functions, such as:
Cookies are pieces of information that are transferred from our web server to your web browser and are stored there for future visits to our site. Cookies serve to make our offer more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and are saved by your browser.
The cookies on our website do not collect any personal data. Our website can be viewed without cookies. The first time you visit our website, we ask if you agree to store cookies and provide the option to adjust the type collected.
Previously saved cookies can be deleted in your browser’s system settings. Cookies provide an optimum website experience and deactivating cookies may restrict the function of the website.
Company | Category | Description |
---|---|---|
De-Bug Bear | Website performance/optimisation | Used to identify opportunities for improved website performance and optimisations related to user device,speedand site experience. |
Lead generation/social networking | With its help, we can track users' actions after they've seen or clicked Facebook advertising in order to track the effectiveness of our Facebook advertising for statistical and market research purposes. The data collected in this way is anonymous for us, ie we do not see the personal data of individual users. | |
Website Analytics & Adwords advertising | Analytics: These cookies are used to collect information about how visitors use our Site. We use the information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where have come to the Site from and the pages they visited. If you do not allow these cookies we will not be able to include your visit in our statistics. Adwords: In the case of Google AdWords, each AdWords client receives a different cookie. Cookies cannot, therefore, be tracked across the websites of AdWord clients. The information obtained through conversion cookies serves to produce conversion statistics for AdWords clients who have opted for conversion tracking. AdWords clients see the total number of users who have clicked on their ad and been forwarded to a page with a conversion tracking tag. However, they do not receive any information enabling them to personally identify users. | |
HotJar | Website Analytics | Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular device'sIP address (captured and stored only in anonymised form), device screen size, device type (unique device identifiers), browser information, geographic location (country only). |
HubSpot | Lead Generation / Email Communication | Cookie: _hstc |
Lead generation /social networking | With its help, we can track users' actions after they've seen or clicked LinkedIn advertising in order to track the effectiveness of our LinkedIn advertising for statistical and market research purposes. The data collected in this way is anonymous for us, ie we do not see the personal data of individual users. | |
Supermetrics | Website analytics | Main purpose of Supermetrics is to provide a connection between different Digital data sources, mainly for Social Media. |
Vimeo | Video Hosting | We embed videos from our official Vimeo channel. When you press play Vimeo will drop third party cookies to enable the video to play and to collect analytics data such as number of views and how long a viewer has watched the video. These cookies do not track individuals. |
YouTube | Video Hosting | We embed videos from our official YouTube channel. When you press play YouTube will drop third party cookies to enable the video to play and to collect analytics data such as number of views and how long a viewer has watched the video. These cookies do not track individuals. |
Lead generation/social networking | With its help, we can track users' actions after they've seen or clicked Xing advertising in order to track the effectiveness of our Xing advertising for statistical and market research purposes. The data collected in this way is anonymous for us, ie we do not see the personal data of individual users. |
Through our app or our website links to third-party websites may be displayed.
If you click on a link external to our Service, please understand that you are leaving our Service and we do not control or be held responsible for the privacy practices and content of any third parties.
Any personal data you provide will not be covered by this Notice and we encourage you to their privacy notices to understand how they collect and process your personal data.
This Privacy Notice was last updated on 15.10.2021 and you can print a PDF copy of it for your Records.