Effective February 16, 2021
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis, and using or handling information in any way, including, but not limited to: collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
Information Collection and Use
Our primary goals in collecting information are to provide and improve our Site, services, features, and content, to administer memberships (together, our “Services”) and to enable users to enjoy and easily navigate the Site.
Information You Provide
If you seek information about membership in The Bath Club or seek to book an event through the Site, we may ask you for information that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to, your name and email address.
Unless we specifically request or invite it, we ask that you not send or otherwise disclose to us your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership. In those cases where we may request or invite you to provide the foregoing information, we will only do so with your express consent, in accordance with applicable data protection law requirements. Where you provide us with such information without request from us, we reserve the right (but do not have any obligation) to erase any such information at our discretion.
When you visit the Site, our servers may record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as the pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and our Services and for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. We also use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other information that would not enable an individual’s identification (“Non-Identifying Information”).
How We Use Personal Information
We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide our Services and administer your inquiries.
We may also use your Personal Information to contact you with information about membership or events, marketing or promotional materials, and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or update your preferences via the “Settings” section of the Site. (See “Changing or Deleting Information,” below.)
We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of our Services, and to analyze and understand how our Site and Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
Information Sharing and Disclosure
Please note that The Bath Club does not sell, rent, or trade Personal Information with third parties for such third parties’ promotional or marketing purposes.
Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for enhancement of features of our Services, industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
Service Providers. We may employ third party companies and individuals to facilitate our Service, to provide our Services on our behalf, to perform Site-related Services (e.g., without limitation, maintenance services, database management, web analytics, and improvement of the Site’s features) or to assist us in analyzing how our Site and Service are used. In some instances, these service providers may have access to Personal Information, but will only access or use Personal Information to provide services to us as described herein.
Compliance with Laws and Law Enforcement. The Bath Club cooperates with government and law enforcement officials and private parties as necessary to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including, but not limited to, subpoenas), to protect the property and rights of The Bath Club or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable.
Business Transfers. The Bath Club may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
Your Data Rights and Choices
We will retain your information, including Personal Information, for as long as your Account is active or as needed to provide you with our Services. If you would like us to delete your record in our system, please contact us at TBCservices@thebathclub.com with a request that we delete your Personal Information. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
The Bath Club is committed to safeguarding your information. We will take reasonable steps to protect the information collected and provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. The security of your Personal Information is important to us, but be advised that no method of transmission over the Internet, or method of electronic storage, is 100% secure.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted, electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Offers and Links to Other Websites
Our Site may contain links to other websites and offers for third party products or services that may be complementary to your use of the Site. If you click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
Our Policy Toward Minors
This Site is not directed to individuals under 18. We do not knowingly collect Personal Information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at TBCservices@thebathclub.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.
“Do Not Track” Signals
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard or legal requirement governing what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals.