This policy sets out how your personal information will be used by Virgin Active and applies to any information, including personal and special personal information, you give to Virgin Active, or which Virgin Active may collect from third parties.

It is important that you read this policy carefully before submitting any personal information to Virgin Active.

By submitting any personal information to Virgin Active you provide consent to the processing of your personal information as set out in this policy.

The provisions of this policy are subject to mandatory, unalterable provisions of applicable laws.

Please do not submit any personal information to Virgin Active if you do not agree to any of the provisions of this policy. If you do not consent to the provisions of this policy, or parts of the policy, Virgin Active may not be able to (i) provide its products and services to you, and/or (ii) provide third party products and services to you (i.e. points awarded to you by a medical scheme partner)).

1. Related Documents
Where appropriate under the applicable circumstances, this document links to, or should be read in conjunction with, the following documents also available on our website:

The Rule Book
The Website Terms and Conditions
The Data Privacy Notice for Employees, Tenants and Independent Contractors, if applicable
The Data Privacy and Security Addendum (in instances of Independent Contractors who process information on behalf of Virgin Active)

2. The Policy
Virgin Active knows that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly. This policy describes the types of personal information that we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy.

As used throughout this policy, the term “Virgin Active”, “us” or “we” refers to Virgin Active South Africa (Pty) Limited and/or Virgin Active Botswana (Pty) Ltd and its affiliates in South Africa, Namibia, Botswana and worldwide. By engaging with us, you are accepting and consenting to the practices described in this privacy policy.

1. Personal Information:

Any personal information provided to or gathered by Virgin Active is controlled by Virgin Active South Africa (Pty) Limited, whose registered office is at 3rd Floor, MontClare Place, Cnr Main & Campground Rd, Claremont 7708, Cape Town, South Africa and/or Virgin Active Botswana, whose registered office is at Plot 67978, Mokolwane House, Fairgrounds, Gaborone Botswana. A number of suppliers act as data processors on behalf of us from time to time.

2. What personal information does Virgin Active collect?

Special personal information: The term “special personal information” in this context refers to information relating to your religious or philosophical beliefs, race or ethnic origin, trade union membership, political opinions, health, sexual life or criminal behaviour. Whilst we do not generally collect special personal information unless it is volunteered by you, we do specifically collect (i) health data, to the extent that it is required to assess your readiness for physical exercise or to provide you with a specific service that requires that we process your health data in order to provide you with that specific service, and/or (ii) your access information to the extent that you are part of a medical scheme rewards or a retention/rewards programme. We will use health data or health information and/or access information provided by you (or retrieved from you each time you access our facilities or use our services inside our facilities or on our online platforms), exclusively to (i) share with the medical scheme rewards partner (if applicable) that you have joined Virgin Active through, or (ii) serve you better and meet your particular needs. We also collect photographs (as discussed below) and may collect fingerprints for identification and fraud prevention. In limited circumstances (such as for membership demographic analysis purposes) we may collect information about your race and mental health. By providing this information to us, you are consenting to our using it in the manner set out in this policy.
Personal information about children: We do not knowingly collect personal information from children (under 18 years of age) without the permission of their parent or guardian. As a parent or guardian, please do not allow your children to submit personal information without your permission.
Photographs for your Virgin Active membership card: In the interests of security and the prevention of crime, or for purposes of enabling the enforcement of our Rules, we take a digital photograph of each member to whom a membership card is issued. By providing the digital photograph to us, you are consenting to our using it in the manner set out in this policy.
Contacting us via our Website or otherwise: When you use the www.virginactive.co.za website (our “Site”) or any Virgin Active mobile application, online platform or contact us by post, telephone, email, SMS or WhatsApp, we collect, store and use certain personal information that you disclose to us. This includes details such as your name, address, telephone, email and mobile phone number as well as traffic data, location data, web logs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access. If you contact us, we may keep a record of that correspondence.
CCTV: We use CCTV in our facilities for health, safety and security reasons, or for purposes of enabling the enforcement of our Rules. If you have any queries in relation to the use of CCTV operating in and around our clubs please contact us.
Surveys: We may ask you to complete surveys for research purposes from time to time, although you do not have to respond to them.
We ordinarily collect personal information directly from you. In certain circumstances where, for example, you have elected and consent to participate in a business partner’s offerings, such partner may share information about you with us (which we will process accordingly as part of the chosen offering), which may include information relating to your health. You are generally required to make your personal information available and the supply of the information is accordingly mandatory. In instances where it is voluntary, you will be informed accordingly.
3. What do we do with personal information collected from you?
We use personal information for the following or related purposes:

To provide the services you request from Virgin Active such as to facilitate operational appointments (in the case of independent contractors), administration of your membership, facilitate bookings of classes and appointments with our own or third party service providers and other transactions;
To advertise (including by means of direct marketing) products and services;
To process payments (including by means of debit orders), such as membership fees, vendor or supplier payments and any other payments that may be due to us from you or the other way around;
To process member benefits;
To run or manage (i) rewards programmes, (ii) loyalty programmes, or (iii) to facilitate the interaction between us and any other third party you may have joined Virgin Active through;
To maintain accounts and records;
To prevent crime and aid in the prosecution of offenders;
To administer and maintain membership records;
To improve our membership and customer services platform;
To prevent or detect fraud or abuses of our website or services;
To enable third parties to carry out technical, logistical or other functions on our behalf;
To send you newsletters and promotions, and to conduct online surveys or surveys by telephone; prize draws; competitions and other promotions via email, telephone or post;
If you subsequently apply for employment at Virgin Active, to process your job application;
To continuously profile and assess our membership data base in order to improve the service offering provided to members and/or to better align ourselves with business partners;
To build a basic credit score of members;
To assess job applications;
To evaluate tenders, quotations and select suppliers and to load them on our systems;
To process purchase orders;
To manage debit order disputes;
To add data subjects to a “do not call list” if they opt out from receiving direct marketing from us;
To update personal information;
To assess membership demographics;
To run and manage various campaigns, such as collections, arrears notices and any communication which affects a member’s contract or access to a Virgin Active facility;
To conduct social media scans;
To share it with existing and potential business partners and third parties in order to identify mutual commercial opportunities with such business partner or third party, and/or improve the service offering to you. We operate an automatic opt-in policy which means that when you request information from us on one of our clubs or make an enquiry we add you to our database.
4. What about Cookies?
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to enable our systems to recognise your browser and to automatically collect information from your computer such as your IP address and other details about your computer which are automatically collected by our web server, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. The “Help” menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer. However, because cookies allow you to take advantage of some of Virgin Active’s essential features, we recommend that you leave them turned on. If you do leave cookies turned on, be sure to sign off when you finish using a shared computer. Please note that our advertisers may also use cookies, over which we have no control:

To estimate our audience size and usage pattern.
To store information about your preferences, and so allow us to customise our Site according to your individual interests.
To speed up your searches.
To recognise you when you return to our Site.
5. Does Virgin Active share the information it receives?
Information about our members is an important part of our business and we do not sell it to others. Virgin Active shares member information only as described below. If you have joined us via a Corporate Medical Aid rewards programme, you consent to us sharing your information with the relevant Corporate.

Third Party Service Providers: We employ other companies and individuals to perform functions on our behalf. Examples include sending postal mail and email, managing legal and financial communications, removing repetitive information from member lists, analysing data, storage and providing marketing assistance. Third party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this privacy policy and as permitted by South African data protection legislation.
Banks: We share personal information with banks to process debit orders or to do bank account verification of suppliers and to prevent fraud.
Pension Funds and Medical Aids and other Third Parties: We share information with these entities for employment related purposes.
Business Transfers: As we continue to develop our business, we might sell or buy health clubs or subsidiaries or business units. In such transactions, member information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing privacy policy (unless, of course, the member consents otherwise). Also, in the unlikely event that Virgin Active or substantially all of its assets are acquired, personal information will of course be one of the transferred assets.
Business partners: We may partner with other businesses from time to time, including other applications and healthcare providers. If you elect and consent to participate in such partner’s offerings, we may share information with the relevant partner relating to your membership, the fitness activities you engage in, and suggested fitness and health parameters. The business partner may, in turn, share information about you with us (which we will process accordingly as part of the chosen offering), which may include consultation metrics and details of your prescription (if any).
Regulators or State Departments: We share information with local or foreign regulators and/or State Departments, including tax authorities and the Department of Labour, if we are required or permitted to do so in terms of applicable laws.
Protection of Virgin Active and others. We release account and other personal information when we believe that such a release is appropriate to comply with the law; enforce or apply our membership or other agreements; or protect the rights, property or safety of Virgin Active, our users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction. Obviously, however, this does not include selling, sharing or otherwise disclosing personally identifiable information from members for commercial purposes in a way that is contrary to the commitments made in this policy.

Information is shared on a confidential basis, and unless you have consented otherwise, under no circumstances is the business partner or third party entitled to make any communication to you, or make any further transmission of the information, as a result of the personal information we share with them. Each transmission of the personal information with the business partner or third party differs, but is specific to the particular information share exercise being undertaken.

Other than as set out in this policy we will not share your personal information with third parties for marketing or any other purposes without your consent, unless we are required to do so by law. You will receive notice when information about you might go to third parties and you will have an opportunity to choose not to share the information.

6. Transborder transfers of personal information
We may transfer your personal information transborder for storage or operational purposes and other reasons, including to countries, such as Namibia and Botswana, that may not have data protection laws similar to your own country.

7. Your promise to give us accurate information
You agree to give us accurate personal information and to update it if it changes. You also indemnify us from any losses, damages or harm that may result in us relying on any inaccurate information provide by you to us or collected by us from third parties.

8. Storage of information
We may store your information indefinitely, unless you object in writing as set out in our manual in terms of the Promotion of Access to Information Act, 2002 (“PAIA Manual”). If you object, we will only store your information if we are legally entitled or obliged to do so.

9. Access to information
You may access your personal information which is under our control by following the procedure set out in our PAIA Manual.

10. How secure is information about me?
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

11. What about links to other websites?
Our site may include links to other websites. We do not provide any personally identifiable customer information to these advertisers or third-party websites. These third-party websites may use technology to send (or “serve”) the advertisements that appear on our website directly to your browser. They automatically receive your IP address when this happens. They may also use cookies, JavaScript, web beacons (also known as action tags or single-pixel gifs), and other technologies to measure the effectiveness of their ads and to personalise advertising content. We do not have access to or control over cookies or other features that they may use, and the information practices of these advertisers and third-party websites are not covered by this privacy policy. Please contact them directly for more information about their privacy practices.

12. What choices do I have (opt out)?
You can always choose not to provide information to us, but we may then not be able to provide our products or services to you. If you do not want to receive marketing or other communications from

us, tick the opt-out box in your terms and conditions or let us know in writing. We will then only send such communications to you if we are legally entitled or obliged to do so.

However, please note, if you do not want to receive legal notices from us, such as this policy, those notices will still govern your use of Virgin Active and it is your responsibility to review them for changes.

13. Notices and Revisions:
If you have any concern about privacy at Virgin Active, please e-mail us a thorough description and we will try to resolve the issue for you. Our business changes constantly and this policy and the website terms and conditions will also change from time to time. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our website frequently to see recent changes. Unless stated otherwise, our current privacy policy applies to all information that we have about you and your account. However, we stand behind the promises we make and will never materially change our policies and practices to make them less protective of member information collected in the past unless we are legally entitled or obliged to do so.

14. Contact:
Questions, comments, complaints and requests regarding this policy are welcomed and should be addressed to the Legal Department, Virgin Active South Africa (Pty) Limited, 3rd Floor, MontClare Place, Corner Main Road & Campground Road, Claremont 7708, Cape Town, South Africa.

If you believe that we have not processed your personal information in a lawful manner you can also contact the Information Regulator at https://justice.gov.za/inforeg/.

VIRGIN ACTIVE HEALTH ASSESSMENT PRIVACY NOTICE

For member use when taking part in an optional interactive ‘Longevity’ health assessment in a Virgin Active club.
This notice explains how Virgin Active South Africa processes your personal information when you choose to use Technogym Longevity equipment and body scan.1. About this notice
This notice applies only to the optional health assessment feature made available to members in South Africa through a Virgin Active club, a linked QR code flow, or the connected Virgin Active digital experience.
The assessment is designed to provide wellness and fitness-related insights. It is not a medical diagnosis and does not replace medical advice, treatment, or professional clinical assessment.

2. Who is responsible for your information
Virgin Active South Africa (Pty) Ltd is the responsible party for the personal information processed through this feature.
Registered office: 3rd Floor, MontClare Place, Corner Main Road and Campground Road, Claremont, Cape Town, 7708.
Virgin Active has appointed an Information Officer in line with POPIA and PAIA. Contact details are included in section 15 below.

3. What information we collect
If you choose to use this feature, we may collect information that identifies you or is linked to your membership profile, together with information generated from your participation in the assessment.
• membership or profile identifiers needed to link the assessment to you;
• device, session, club, and date / time information;
• measurements, inputs, and responses captured during the assessment;
• results and scores relating to body composition, mobility, balance, cognitive function, strength, and cardio fitness;
• health-related observations or recommendations generated from the assessment;
• supporting operational or audit information needed to administer, secure, and troubleshoot the feature.

4. Special personal information
Some of the information processed through this feature is health-related and is therefore treated as special personal information under POPIA.
Virgin Active will process this information only where permitted by law, including where you have given your consent for this optional feature.

5. Why we use your information
We use your information only for purposes that are relevant to the operation of this feature and the services linked to it.
• to verify and link the assessment to your member profile;
• to run the assessment and generate your results;
• to show your results to you during or after the assessment;
• to store your results in your Virgin Active member profile so that you can view them again later [if applicable];
• to support your wellbeing or fitness journey through related Virgin Active services that you choose to use [if applicable];
• to secure, support, maintain, and improve the safe operation of the feature;
• to comply with legal and regulatory requirements and to manage complaints, requests, or disputes.

6. Is this assessment optional?
Yes. Your participation is entirely voluntary.
If you choose not to use the assessment, your normal membership and access to Virgin Active clubs and services will not be affected.

7. How we obtain your consent
Before the assessment starts, you will be shown a short consent screen and this full privacy notice will be made available to you.
You give consent by taking an affirmative action in the consent flow, such as selecting the consent option and starting the assessment after reviewing the notice.
If the feature is made available to members under 18, Virgin Active may require consent from a parent or legal guardian before the assessment is used.

8. What happens if you do not provide the information
If you choose not to provide the information needed for the assessment, Virgin Active will not be able to run the assessment or provide the related results to you.
This will not affect your underlying gym membership or your access to ordinary club services.

9. Who we share your information with
Virgin Active may share your information only where this is necessary for the purposes described in this notice or where required by law.
• authorised Virgin Active employees, contractors, and support teams who need the information to operate or support the feature;
• approved service providers who host, maintain, support, or secure the technology used for the assessment;
• professional advisers, regulators, or authorities where disclosure is required or permitted by law;
• other recipients identified to you in relation to this feature, including [insert vendor / partner details if applicable].

10. Transfers outside South Africa
Your information may be stored in or accessed from countries outside South Africa where this is necessary to host, support, or operate the feature.
If this happens, Virgin Active will take steps to ensure that the transfer is permitted under POPIA and that your information continues to receive an appropriate level of protection.
Relevant transfer locations and service providers for this feature are: [insert countries / provider details or state that no foreign transfer is expected].

11. How long we keep your information
Virgin Active will keep your information only for as long as it is needed for the purposes described in this notice, or for a longer period where retention is required or permitted by law.
The retention period for assessment data and results for this feature is: [insert retention period or clear retention rule].
When the information is no longer needed, it will be deleted, destroyed, or de-identified in accordance with applicable law and Virgin Active retention standards.

12. Security
Virgin Active uses reasonable technical and organisational measures to help protect your personal information against loss, misuse, unauthorised access, disclosure, alteration, or destruction.
Access to assessment information is restricted to people and service providers who need it for legitimate operational purposes and who are subject to appropriate confidentiality and security obligations.

13. Your rights
Subject to POPIA and any applicable legal limitations, you may have the right to:
• ask whether Virgin Active holds personal information about you;
• request access to your personal information;
• request correction of inaccurate, incomplete, misleading, or outdated information;
• request deletion or destruction of information where Virgin Active is no longer authorised to keep it, or where POPIA otherwise allows this;
• object, on reasonable grounds, to certain processing in appropriate circumstances;
• withdraw your consent for this optional feature at any time, subject to lawful processing already carried out before the withdrawal.

14. How to withdraw consent
You can withdraw your consent for this feature at any time by using the withdrawal channel made available for the feature or by contacting Virgin Active using the details below.
The current withdrawal route for this feature is: [insert app setting / email / support path / club process].
Withdrawal of consent will not affect processing already carried out before the consent was withdrawn, but it may mean that we can no longer provide the feature or show you new results through it.

15. Contact Virgin Active
If you have questions, requests, comments, or complaints about this notice or this feature, you can contact Virgin Active using the details below:
Company (Responsible Party) Virgin Active South Africa (Pty) Ltd
Information Officer Phila Zulu (Legal Director), or the current designated Information Officer
Email webadmin@virginactive.co.za
Phone +27 21 684 3000
Address 3rd Floor, MontClare Place, Corner Main Road and Campground Road, Claremont, Cape Town, 7708

16. Complaints to the Information Regulator
If you believe that your personal information has not been processed lawfully, you can raise your concern with Virgin Active first. You also have the right to contact the Information Regulator of South Africa.
Information Regulator The Information Regulator (South Africa)
Complaints email POPIAComplaints@inforegulator.org.za
General email enquiries@inforegulator.org.za
Phone 010 023 5200 | Toll-free: 0800 017 160
Address Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191

17. Changes to this notice
Virgin Active may update this notice from time to time to reflect changes to the feature, our operations, or the law. The latest version will be made available through the relevant digital channel or on request.

App Privacy Policy