Privacy Policy

Valid from 13 December 2023 to 19th January 2024.

Introduction

Welcome to Lattice Training Limited’s privacy policy.

Lattice respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit them from), when you use Lattice Training (‘our app’) and/or when you receive services or products from us. It also tells you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Lattice collects and processes your personal data including any data you may provide through our websites (which includes latticetraining.com and my.latticetraining.com), through our app, or to our company through other means (such as when you sign up to our newsletter, purchase a product or service, attend any in-person services or activities, or take part in a competition).

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Children

Our websites and our app are not intended for children and we do not knowingly collect data relating to children or any individual below the age of 16 via our websites or our app.  

However we do offer some products and services to children below the age of 16, including in-person training.  Where a Lattice product or service is being used for the benefit of a child aged 12 or under, we will require confirmation from whomever has parental responsibility for the child that they consent to Lattice collecting and processing the child’s personal data as set out in this privacy policy.  We may also request, collect and process personal data relating to the person with parental responsibility and their relationship to the child for the purpose of verifying this consent and parental responsibility.  We reserve the right to suspend or decline to provide the Lattice products or services if we have any concern regarding the validity of this consent.

If you have parental responsibility and would like to exercise any of the data subject rights on behalf of the child (e.g. to review, correct, delete the personal data) or if you have any questions about this privacy policy please contact us at [email protected].  Following ICO guidance, you will only be able to exercise these rights on behalf of a child if the child authorises you to do so, if the child does not have sufficient understanding to exercise the rights themselves, or when it is evident that this is in the best interests of the child.  

Where you are reviewing this privacy policy in relation to a child’s personal data the words “you” and “your” may refer to the child and the child’s personal data as well as to you and your own personal data.

Controller

Lattice Training Limited is the controller and responsible for your personal data (collectively referred to as “Lattice “, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Lattice Training Limited

Email address: [email protected]

Postal address: Lattice Training Ltd, Unit 11 Clarence Industrial Estate, Eastside Road, Chesterfield, S41 9AT, UK

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you are based in the EU and you have any questions about this privacy policy or our privacy practices, you may contact our DPO in the ways set out above, and in the alternative you may contact our EU Representative using the details set out below:

Full name of EU Representative: Data Priva Limited T/A GDPREP.ORG

Email address: [email protected]

Postal address: Suite 10357, 5 Fitzwilliam Square, Dublin 2, Ireland, D02 R744

Full name of Swiss GDPR Representative: Data Priva Limited T/A GDPREP.ORG

Email address: [email protected]

Postal address: Andreaspark, Hagenholzstrasse 56, 7th Floor, Zurich, 8050

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

Our websites or our app may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites or our app, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Basic Identity Data includes first name, last name, username or similar identifier, title.
• Detailed Identity Data includes date of birth, gender and sex.
• Tax Identity Data includes any identification information required by a country for tax and customs purposes (e.g. a Tax Identification Number is needed for orders being shipped to Spain).
• Social Media Data includes Instagram handle and bio/posts/stories/reels and any direct messages, Facebook profile name and public profile information/posts/stories/reactions and any direct messages, Youtube subscriber name and public profile information/posts/reactions.
• Contact Data includes billing address, delivery address, email address, country location.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform, a unique device identifier (when using our app) and other technology on the devices you use to access our websites and our app.
• Profile Data includes your username(s) and password(s) for our websites or our app (for our products or services only), purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our websites, our app and our products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Assessment Data includes (not all of these will apply to every service): your training and climbing history including perceived strengths/weaknesses; links to your public climbing logbooks (such as 8a.nu or UKClimbing.com); climbing aims and goals; physical metrics including weight, height, arm span, date of birth, gender; physical testing data including strength (fingers, core, upper and lower body), mobility and flexibility, endurance, and technique; and feedback relating to assessment & testing process.
• Nutrition Data includes information relating to nutritional intake, timing and quality, and perceptions around food.
• Training/Coaching Data includes (not all of these will apply to every service): your training and climbing history including perceived strengths/weaknesses; links to your public climbing logbooks (such as 8a.nu or UKClimbing.com); climbing aims and goals; session/training logs, feedback relating to nutrition/training plan services and climbing performance; basic athlete monitoring information including sleep, energy, and stress levels; and information relating to nutritional intake, timing and quality, and perceptions around food.
• Parental Responsibility Data includes first name, last name, address, email address, telephone number and relationship to the child for any person claiming parental responsibility (“Person(s) with Parental Responsibility”).

We also collect Special Categories of Personal Data about you which we have grouped together as follows:

• Health Data includes injury history, current and future injuries, and relevant medical conditions or other medical information (including information related to your menstrual cycle/status and contraception where relevant) that might impact upon services we provide; and
• Gender Identity Data includes
  your current gender status and if needed, which sex you would prefer us to use
  for the purpose of comparing your assessment data against our models.

We will only process Special Categories of Personal Data if you give us consent to do so.

We do not collect any information about criminal convictions and offences. Please see https://latticetraining.com/policy/special-category-data/ our policy document relating to the processing of Special Categories of Personal Data listed above.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Basic Identity, Detailed Identity, Social Media Data, Contact, Financial Data, Assessment Data, Nutrition Data, Training/Coaching Data, Health Data and Gender Identity Data by filling in forms or by corresponding with us by email, via the chat function in our app, or otherwise (including via our app, direct messages, posts or reactions/likes on our social media platforms). This includes personal data you provide when you:
  • order our products or services;
  • are using our services and/or providing feedback in order to continue using our services;
  • create an account on our websites or our app;
  • subscribe to our services or publications (including logging in to our app or joining our Facebook groups or following our Instagram/Youtube accounts);
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us (including by email, using our app, or using our social media platforms).
• Automated technologies or interactions. As you interact with our websites and/or app, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Instagram, Youtube, Facebook, Google, and Google Adsense based inside and outside the UK (Aggregated Data only);
  • Social Media Data from advertising networks such as Instagram, Facebook, Tiktok, and YouTube based inside and outside the UK.
  • Assessment Data from affiliate assessors based inside and outside the UK who have been trained to provide some of our assessment services and who may give us Assessment Data whilst conducting one of our assessments with you.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe Inc, Royal Mail, and UPS and its/their affiliates based inside or outside the UK.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Click here https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/ to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will always obtain your explicit consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile, and Social Media Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who we share your data with

We may share your personal data with our partner company Crimpd Inc (“Crimpd”) in circumstances where you are a subscriber and/or purchase certain training plans (for example Training Plans, Home Plans and Fingerboard Plans) which are hosted on the Crimpd App, which is different to our app. This is so you may enjoy the full services Lattice and Crimpd provide and may include sharing the following information:

• Your identity data including name, age and gender (you provide this to both Lattice and Crimpd);
• Your Crimpd ID and email address used to create an account with Crimpd (Crimpd shares this with Lattice);
• Training plans and plan notes (Lattice shares this with Crimpd);

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Whenever we transfer your personal data out of the UK we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government.
• Where we use certain service providers, we may use specific contracts approved by the European Commission and adopted by the UK Government which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we ensure that adequate safeguards are in place to protect your personal data.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

You can request details of retention periods for different aspects of your personal data by contacting us.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/
• https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-rectification/
• https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
• https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-object/
• https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-restrict-processing/
• https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-data-portability/

If you wish to exercise any of the rights set out above, please contact [email protected].

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers acting as processors based in the United Kingdom, USA and/or other third countries who provide IT, social media, and system administration/payment services.
• Crimpd Inc acting as a separate data controller based in the USA (see section 5 above).
• Affiliate assessors acting as separate data controllers based in the United Kingdom, USA or other third countries who conduct our assessments at your request.
• Physiotherapists or other medically qualified individuals acting as separate data controllers who may be based anywhere in the world and who you have engaged to provide medical support and who you have consented to contacting us directly to provide information to help us provide relevant services taking in to account any rehab process or other adjustments which may be required.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom or third countries who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.