Privacy Policy

Bonsai is the data controller for the personal data described in this Policy. Its details are as follows:

• Company: BnsB SRL, trading as Bonsai
• Registered office: Avenue de Tervueren 207, 1150 Woluwe-Saint-Pierre, Belgium
• Enterprise number: 1031.846.012
• Email: hello@bonsai.brussels
• Website: www.bonsai.brussels

We have not appointed a Data Protection Officer. Any question or request relating to your personal data may be addressed to hello@bonsai.brussels.

The categories of personal data we process depend on the relationship you have with Bonsai.

Save for the optional training data described in section 2.2 — for which your explicit consent is obtained — Bonsai does not collect sensitive data such as data revealing racial or ethnic origin, religious beliefs, criminal records or sexual orientation. You may not provide personal data concerning another person unless that person has given their consent, save for the minimal data required to issue a gift voucher. Bonsai does not sell or rent your personal data.

Bonsai operates surveillance cameras on its premises, in accordance with the Belgian Act of 21 March 2007 regulating the installation and use of surveillance cameras.

• Purpose: to ensure the safety of members, visitors and staff, and to prevent and establish offences against persons and property, such as theft, damage or aggression.
• Areas covered: cameras are installed throughout the premises, with the exception of the changing rooms, where no camera is present.
• Access to images: recorded images may be viewed solely by the management of the club and, where legally required, by the competent authorities (such as the police or judicial authorities).
• Retention: images are kept for a maximum of one month, unless they are required as evidence of an offence or of damage, or to identify a person.

Pictograms indicating the presence of cameras are displayed at the entrance of the premises, in accordance with the law.

Access to the club is reserved for persons aged 18 and over. Minors are admitted only subject to the compulsory authorisation of a parent or legal guardian, who must consent to the registration and to the processing of the minor’s personal data. In addition, the wellness area — including the sauna, ice bath and Sun Shower — is not accessible to minors under any circumstances.

We do not sell your personal data. We share it only where necessary, and only with the following categories of recipients:

• Our staff and management, who process personal data to manage memberships and enquiries.
• Our service providers acting as processors on our behalf, in particular:
  • MyClubPlanner — club management and customer-relationship (CRM) software.
  • Technogym / Mywellness — the platform powering the Bonsai application and the connected equipment.
  • Mollie — our payment service provider.
  • Google (Gmail) — our e-mail service.
• Public authorities, where we are required to do so by law or where necessary to establish, exercise or defend legal rights.

We require our processors to comply with the GDPR and to provide appropriate safeguards for your personal data. If Bonsai is involved in a merger, acquisition, transfer of business or similar transaction, your personal data may be transferred to the party concerned; we will inform you of such a transfer where required.

Bonsai does not transfer your personal data outside the European Economic Area (EEA). Should any of our processors process personal data outside the EEA, such transfer would take place only subject to the appropriate safeguards required by the Applicable Data Protection Laws.

We retain your personal data for no longer than is necessary for the purposes for which it was collected, and in accordance with applicable legal obligations. In particular:

• Membership and client data: kept for the duration of your membership and deleted at the latest five (5) years after the end of the contractual relationship.
• Accounting and invoicing data: retained for seven (7) years, in accordance with Belgian accounting and tax legislation.
• Optional training and health data: kept within your client space while your membership is active, and deleted upon termination of your membership or at your request.
• Enquiries from prospective members: deleted twelve (12) months after our last contact.
• Newsletter data: retained until you withdraw your consent or unsubscribe.
• Video-surveillance images: kept for a maximum of one month, as set out above.

Under the Applicable Data Protection Laws, you have the following rights in respect of your personal data:

• the right to access your personal data;
• the right to rectify inaccurate, incomplete or outdated data;
• the right to erasure of your data, for instance where it is no longer needed;
• the right to restrict the processing in certain cases;
• the right to data portability;
• the right to object to the processing in certain cases;
• the right to withdraw your consent at any time, where the processing is based on consent, without affecting the lawfulness of processing carried out beforehand.

To exercise these rights, please contact us at hello@bonsai.brussels. We will respond without undue delay and in any event within one month of receipt of your request. That period may be extended by a further two months where necessary, taking into account the complexity and number of requests; we will inform you of any such extension. These rights are exercised free of charge, unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or decline to act.

The security of your personal data is important to us. Bonsai takes appropriate technical and organisational measures to protect the security, confidentiality and integrity of personal data, and to prevent its accidental or unlawful destruction, loss, alteration, or unauthorised disclosure or access. Personal data is stored on secure systems accessible only to authorised persons bound by an obligation of confidentiality.

Where you have been given, or have chosen, a password granting access to your client space, you are responsible for keeping it confidential and must not share it. Please note that the transmission of information over the internet is never entirely without risk; while we do our utmost to protect your personal data, any transmission is at your own risk.

You have the right to lodge a complaint with the Belgian Data Protection Authority if you consider that the processing of your personal data infringes the Applicable Data Protection Laws:

• Data Protection Authority — Rue de la Presse 35, 1000 Brussels
• Tel.: +32 (0)2 274 48 00 — Email: contact@apd-gba.be
• Website: www.dataprotectionauthority.be

We would nonetheless appreciate the opportunity to address your concern before you approach the Authority, and we invite you to contact us first at hello@bonsai.brussels.

Bonsai may amend this Privacy Policy from time to time. The current version is always available at www.bonsai.brussels, together with the date of its last update. Where changes are material, we will provide appropriate notice, for example by e-mail or by a notice on our website.