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PRIVACY POLICY

KILOS.PH FITNESS CENTER – PRIVACY POLICY

Effective Date: June 1, 2025

Last Updated: June 3, 2025

1. INTRODUCTION

Welcome to KILOS.PH Fitness Center ("KILOS.PH," "we," "us," or "our"). We are located at Unit - 3 Mercedes Warehouse, Mercedes Plaza, Mercedes Ave cor Luis St., Brgy. San Miguel, Pasig City, Metro Manila, Philippines, 1600.

Your privacy is important to us. This Privacy Policy outlines how we collect, use, disclose, retain, and protect your personal information in compliance with the Data Privacy Act of 2012 (R.A. 10173) of the Philippines.

This policy applies to all personal information we process in relation to your interactions with KILOS.PH, including your use of our facilities, products, services, website https://kilos.ph, and other engagement channels.

By becoming a member, using our services, visiting our facility, or providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and processing of your personal information as described herein.

2. WHAT PERSONAL INFORMATION WE COLLECT

We collect personal information that is necessary for our business operations and to provide you with our services. The types of personal information we may collect include:

  • Personal Identification Information: Full name, date of birth, gender, and government-issued identification details (e.g., for verification purposes where legally required or with explicit consent).
  • Contact Information: Residential address, email address, telephone or mobile number.
  • Membership Information: Membership ID, start and end dates, membership type, records of your visits and use of facilities.
  • Health and Fitness Information (Sensitive Personal Information):
    • Physical Activity Readiness Questionnaire (PAR-Q) responses.
    • Health declarations, medical conditions, or physical limitations you voluntarily disclose to us for the purpose of ensuring your safety and tailoring appropriate fitness programs (collected with your explicit consent).
    • Information related to personal training sessions or fitness assessments.
  • Emergency Contact Information: Name and contact number of a person you designate for emergencies.
  • Financial and Transaction Information: Payment card details (processed securely through our payment gateway providers), bank account details (for direct debit arrangements), transaction history for fees and purchases.
  • Visual Information: CCTV footage recorded for security and safety purposes within our premises. Photographs may be taken during events or for membership identification with your consent.
  • Communication Records: Records of your communications with us, including emails, messages, or feedback forms.
  • Website and Online Services Information (if applicable): IP address, browser type, Browse activity, and information collected through cookies if you visit our website. [If you use cookies, consider a separate Cookie Policy or a detailed section here].

How We Collect Personal Information:

  • Directly from you: When you fill out membership application forms, health questionnaires (PAR-Q), consent forms, communicate with our staff, make payments, or participate in surveys or promotions.
  • Automatically: Through CCTV surveillance in common areas of our facility for security. If you use our website, some data may be collected automatically through cookies and similar technologies.
  • From Third Parties: In some instances, we may receive information from third parties, such as when a membership is purchased for you by someone else, or from publicly available sources where permissible.

3. HOW WE USE YOUR PERSONAL INFORMATION (PURPOSE OF PROCESSING)

We use your personal information for the following legitimate purposes:

  • To Provide and Manage Services:
    • To process your membership application and manage your account.
    • To grant you access to our facilities and services.
    • To schedule classes, personal training sessions, and other services.
    • To tailor fitness programs, where you provide health information for this purpose.
  • Communication:
    • To send you important notices regarding your membership, service updates, changes to our terms or policies.
    • To respond to your inquiries, requests, and feedback.
    • To send you marketing communications (e.g., newsletters, promotions, event invitations) with your explicit consent. You can opt-out of marketing communications at any time.
  • Payment Processing:
    • To process membership fees, payments for products, and other transactions.
  • Health, Safety, and Security:
    • To ensure a safe environment for all members and staff.
    • To respond to emergencies and provide assistance if needed.
    • To monitor for, prevent, and investigate security incidents, fraud, or misconduct using CCTV footage and other relevant information.
  • Service Improvement:
    • To understand our members' needs and preferences.
    • To analyze usage of our facilities and services for improvement and development of new offerings (often using aggregated or anonymized data).
  • Legal and Regulatory Compliance:
    • To comply with applicable laws, regulations, court orders, or government requests.
    • To establish, exercise, or defend legal claims.

4. LAWFUL BASIS FOR PROCESSING

We process your personal information based on the following lawful bases under the Data Privacy Act:

    • Consent: We will obtain your consent before collecting and processing your sensitive personal information (e.g., health data) and for sending direct marketing communications. You can withdraw your consent at any time, subject to legal or contractual restrictions.
    • Contract: Processing is necessary for the performance of our membership agreement with you.
    • Legitimate Interests: We process information for our legitimate interests, such as ensuring the security of our premises and improving our services, provided that such interests are not overridden by your fundamental rights and freedoms.
  • Legal Obligation: Processing is necessary for compliance with a legal obligation to which KILOS.PH is subject.

5. SHARING AND DISCLOSURE OF YOUR PERSONAL INFORMATION

We do not sell your personal information. We may share or disclose your personal information in the following circumstances:

  • Within KILOS.PH: To our authorized staff who require access to the information to perform their duties (e.g., membership services, trainers, finance).
  • Third-Party Service Providers: We may engage third-party companies and individuals to perform services on our behalf (e.g., payment processors, IT and system administration, cloud storage providers, marketing platforms, maintenance services). These providers are contractually bound to protect your personal information and use it only for the purposes for which we disclose it to them.
  • Emergency Services: In case of a medical emergency, we may share necessary information with medical personnel or your emergency contact.
  • Legal and Regulatory Authorities: If required by law, regulation, legal process, or government request, we may disclose your information to law enforcement, courts, or other public authorities.
  • Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of the transaction, subject to appropriate confidentiality and data protection safeguards.
  • With Your Consent: We may share your information with other third parties if you have given us your explicit consent to do so.

6. DATA SECURITY

We are committed to protecting the security of your personal information. We implement appropriate organizational, physical, and technical security measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, and destruction. These measures include:

  • Secure storage of physical and electronic records.
  • Access controls and restrictions.
  • Use of secure payment gateways for financial transactions.
  • Staff training on data privacy and security.
  • Regular review of our security practices.
  • [Mention specific measures like encryption or pseudonymization if applicable].

In the event of a data breach that is likely to result in a real risk of serious harm, we will notify you and the National Privacy Commission in accordance with the Data Privacy Act.

7. DATA RETENTION

We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the duration of your membership, and for a reasonable period thereafter to satisfy any legal, accounting, or reporting requirements, or to resolve disputes.

Once your personal information is no longer needed, we will securely dispose of it in a manner that prevents unauthorized access or use.

8. YOUR RIGHTS AS A DATA SUBJECT

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

    • The Right to be Informed: You have the right to be informed whether your personal information shall be, is being, or has been processed.
    • The Right to Access: You have the right to reasonable access to your personal information upon demand.
    • The Right to Object: You have the right to object to the processing of your personal information, including processing for direct marketing, automated processing, or profiling.
    • The Right to Erasure or Blocking: You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your personal information from our filing system under certain circumstances.
    • The Right to Rectify: You have the right to dispute the inaccuracy or error in your personal information and have us correct it immediately and accordingly.
  • The Right to Data Portability: You have the right to obtain a copy of your personal information in an electronic or structured format that is commonly used and allows for further use by you (where processing is based on consent or contract and is carried out by automated means).
  • The Right to Damages: You have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal information.
  • The Right to File a Complaint: You have the right to file a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 11 of this policy. We will respond to your request in accordance with the Data Privacy Act.

9. USE OF COOKIES (IF APPLICABLE)

Our website https://kilos.ph may use "cookies" and similar tracking technologies to enhance your browsing experience, analyze site traffic, and for other purposes. Cookies are small text files stored on your device. [You can provide more detail here: e.g., types of cookies used (essential, performance, functionality, targeting), and how users can manage their cookie preferences through their browser settings or a cookie consent tool on your website. If you don't have a website or don't use cookies, you can omit this section or state that it's not applicable.]

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. We will notify you of any significant changes by posting the new Privacy Policy on our website, displaying a notice in our facility, or by other means of communication. We encourage you to review this Privacy Policy periodically. The date of the last update will be indicated at the top of the policy.

11. CONTACT US / DATA PROTECTION OFFICER (DPO)

If you have any questions, concerns, or complaints about this Privacy Policy, our data protection practices, or if you wish to exercise your rights as a data subject, please contact our Data Protection Officer (DPO) at:

Data Protection Officer

KILOS.PH Fitness Center Unit - 3 Mercedes Warehouse, Mercedes Plaza, Mercedes Ave cor Luis St., Brgy. San Miguel, Pasig City, Metro Manila, Philippines, 1600

Email: site-admin@kilos.ph

Phone: (02) 8573-8308

We are committed to resolving any privacy concerns you may have.