1. Object of the treatment

The joint Holders process personal identification data, such as e.g. images, name, email,
telephone number, postal address, fiscal data, (hereinafter "Data") and particular data
("health status") provided by you, on the occasion of the purchase and in general in relation
to the contractual relationship in place with the Holder.

2. Purpose of the processing and legal basis of the processing

Your personal data are processed, without your prior consent (Article 6 paragraph 1 letter
b), c) GDPR), for the sole purpose of managing and executing pre-contractual and
contractual relationships; the obligations related to administrative and accounting
management; the obligations established by laws, regulations or EU legislation or otherwise
imposed by law; for the protection of the rights of the Holder in court and management of
any disputes; for the prevention and repression of illegal acts.

2.1. Additional purposes of the processing

The data collected, with your prior free and explicit consent (Article 6 letter a) GDPR), may
also be used for the additional purposes indicated below under the terms and conditions
specified therein:
(a) to send you newsletters, through the references you have provided.
(b) to manage your request for information.
(c) to manage job applications.

3. Cookies and similar website tools

In compliance with the EU Directive 2009/136/EC of 25/11/2009, the Holder informs you
that our website www.vitaboutiquefitness.com and the subdomains
www.it.vitaboutiquefitness.com and www.en.vitaboutiquefitness.com use cookies or similar
tools to allow us to improve our service and offer the user some useful features. This may
include cookies from business partners that are stored by your computer or device when
you visit our site (https: //www.vitaboutiquefitness/cookie-policy). Please visit the websites
of our business partners for information on their cookie and privacy policy.
Cookies are small text files that are transferred to your computer or device via the web
browser to allow us to recognize your browser and help us to monitor visitors to our site,
thus allowing us to better understand the products and services that will be more suitable
for users. A cookie contains contact information and useful information allowing to identify
your computer or device when you visit our sites www.vitaboutiquefitness.com
www.it.vitaboutiquefitness.com www.en.vitaboutiquefitness.com with the aim of helping
the user to get a better user experience. Most web browsers automatically accept cookies,
but if you wish, you can change these browser settings by accepting, rejecting and deleting

cookies. If you choose to change these settings, certain features and functionality may not
work as expected. The cookies used do not detect the information contained on the
computer or device.
For more information about cookies and how to prevent your browser from accepting them,
visit the following website: http://www.allaboutcookies.org.

4. Methods of processing and storage

The processing will be carried out by means of the operations indicated in art. 4 GDPR and
may take place both through IT systems (cloud, internet, intranet, computers and mobile
devices) and automated processes, and in paper form (archives).
For the purposes in point 2.1a) the data will be kept until the consent is revoked in
accordance with the law and as specified above, except in cases where current legislation
does not require the retention of your data for longer periods. For purposes 2.1b) and 2.1c)
your data will be stored in the Holder’s databases only for the time strictly necessary to
achieve the purposes for which they were collected and processed. If you decide to close
your account, the Holder will keep personal data provided only for administrative purposes
from the termination of the contractual relationship (for 7 years up to a maximum of 10
years), without prejudice to any further needs for which the Holder is allowed or required
by specific provisions of the law to keep the data. The Holder will keep the personal data
provided only for administrative and statistical purposes, except for any further needs for
which the Holder is allowed or required by specific provisions of the law to keep the data.

5. Additional methods of processing and storage

We may use surveillance cameras at our locations that may record you and your activities.
We display notices to clarify which areas are subject to video surveillance. We release
footage of surveillance recordings only following a formal warrant or request from law
enforcement, or as needed in connection with disputes. Recordings can be kept for a
maximum period of 48 hours.

6. Nature of the provision of data and consequences of refusal

The provision of personal identification data is necessary for the execution of the
contractual relationship and the obligations deriving from the fulfilment of the law,
regulations or EU legislation and any refusal will make it impossible to provide total or
partial services or services requested.
It is understood that, if you do not want to give your consent to the processing of your data
for the purposes referred to in point 2.1a) this will not prevent you from accessing our
available services.

7. Data Security

We have put in place adequate internal security measures to prevent your personal
information from being accidentally lost, used or accessed in an unauthorized manner,
altered or disclosed.

8. Access to Data

Your Data will be processed for the aforementioned purposes by employees and / or
collaborators of the Holder in their capacity as persons in charge of processing and / or
internal data processors and / or system administrators; by third parties (for example,
suppliers, professionals, banks, affiliates) where they carry out outsourced activities on
behalf of the Holder, in their capacity as external data processors.

9. Communication of Data

Without your express consent (pursuant to Article 6 letter b), c) GDPR), the Holder may
communicate your data to public bodies to comply with the obligations established by laws,
regulations or EU legislation or imposed by the Authorities, which will process them in their
capacity as independent data controllers.
They may also be communicated to Third Parties (for example, partners and client
companies), who will process the data for the performance of activities instrumental to the
services requested and the aforementioned purposes.
Generally, the selected service providers operate through data centres located in the
European Union. If your data will be transferred to non-EU countries, also for the purpose of
technical management of the data collected, this will take place exclusively in full
compliance with the European GDPR legislation, to companies adhering to the Privacy Shield
(USA) or to third countries for which there are adequate guarantees for the protection of
the transfer or specific undersigned contractual clauses for the protection of personal data.

10. Rights of the interested party and Holder of the treatment

At any time, you can exercise your rights towards the Holder, pursuant to articles 15-22 of
EU Regulation 2016/679, and in particular the rights of access, rectification, integration and,
in the cases permitted, the portability of the data provided, in addition to obtaining the
cancellation, limitation or opposition to the processing of data for legitimate reasons and to
oppose the automated decision-making process, including profiling. As well as the right to
complain to the Data Protection Authority, by contacting the joint controllers by sending an
email to info@vita-london.com or to info@vita-milano.com. In order to guarantee the
protection of the personal information of the interested party, we may need to request
further specific information, which confirms the identity of the subject requesting the data
and thus guarantees the right to access information (or to exercise any of the other rights)
only to persons entitled to receive such communications. This is another security measure
suitable for protecting personal data.
The request to access your personal information (or to exercise one of the above rights) is
free. However, if the request is clearly unfounded or excessive, we may charge a reasonable
fee taking into account the administrative costs incurred to provide the information or
refuse to comply with the request in such circumstances.

Joint data controllers are:
Vita Health & Fitness Limited with registered office in flat 80 Durrels House, 28-46 Warwick
Gardens, London W14 8QB - United Kingdom contactable at info@vita-london.com and Vita
S.R.L. based in Piazza Castello, 22 - 20122 Milan, Italy contactable at info@vita-milano.com.

11. Mobile Application

Vita Health & Fitness Limited mobile application is owned and operated by Vita Cafe,
who are the controller of all stored data.
PepperHQ Ltd operate as a processor of data for Vita Health & Fitness Limited App.

This policy, together with our MOBILE APP TERMS OF USE, explain how we may use information
we collect about you, as well as your rights over any personal information we hold about you.
Please read this policy and our MOBILE TERMS OF USE carefully.

11.1 Information we collect about you through Vita Health & Fitness Limited App.

We collect information about you when you:

- register to use Vita Health & Fitness Limited App;
- attempt to check in to our stores;
- register your debit or credit card details;
- upload a profile photo, and
- use the payments facility in Vita Health & Fitness Limited App to pay for your purchase.

This information is collected, stored and processed under Article 6(1)(b) of the GDPR,
- “processing is necessary for the performance of a contract to which the data subject
is party or in order to take steps at the request of the data subject prior to entering into a contract"
i.e. We need this data for you to be able to use the App for it's primary purposes.

11.2 Using your information

Collecting personal information in Vita Health & Fitness Limited App
(name, email address, date of birth) helps us to better understand what you need from us.

We use your information to:

- improve the functionality and performance of Vita Health & Fitness Limited App;
- personalize our services to you;
- tell you about important changes to Vita Health & Fitness Limited App and related services, and
- manage promotions, competitions, customer surveys and questionnaires.

Your personal information is safe with us and will never be released to third party companies
for marketing purposes.

Vita Health & Fitness Limited App captures your geographic location when you attempt to
"check in" to one of our stores. We do this to identify which store you are in or near to allow you
to pay using Vita Health & Fitness Limited App, and to provide an enhanced visitor experience
(for example, through digital loyalty cards). We will only capture this information with your consent.
Vita Health & Fitness Limited App also captures basic usage metrics to help us identify any problems
and to make improvements in the future. These metrics also help us understand how people use
Vita Health & Fitness Limited App and how many people use the different functions within
Vita Health & Fitness Limited App.

Your contact details and personal information may be used to send direct marketing messages
to you via your contact details provided. This is done only with your explicit consent, which can be
withdrawn at any time from the 'MyAccount' options within the app. You may refuse consent for
marketing messages without detriment to any other areas of functionality within the app.

11.3 Information We Capture

11.3.1 Geographic location

We provide enhanced store visit experiences when you choose to pay using Vita Health & Fitness
Limited App. You may prevent Vita Health & Fitness Limited App from accessing your devices
location services, or turn off the location services of your Mobile Device. Doing so will impact the
capability of Vita Health & Fitness Limited App and prevent you from enjoying an enhanced experience.


11.3.2 Data you share with us (Including information you give us when signing up, and information which
is shared automatically, such as Device ID, and IP address)

We use this data to log you in to Vita Health & Fitness Limited App and it helps us understand our
customers better and present you with appropriate offers and promotions. Your data is stored in an
encrypted database and transferred over a secure network connection. You decide which data you do
and do not share with us. If you ask us to, we will update, correct or delete any data which you give to us.


11.3.3 Your Card details

Your card details are not stored on Vita Health & Fitness Limited App and they are only used in accordance
with your payment instructions. Your card details are stored with our payment gateway partner - Square -
who are a Level 1 certified PCI-DSS Service Provider. You have to use the payments facility within Vita Health &
Fitness Limited App to pay for your purchase through the app.


11.3.4 Your profile photo

Your profile photo is used in store to verify your identity. If you ask us to, we will update, correct or delete your
profile photo. However, you must have a profile photo if you wish to use Vita Health & Fitness Limited App to pay
for your purchases in-store.

11.3.5 Your purchase history

We use your purchase history to provide personalized offers and analyse which products and rewards are
most likely to interest you.



1.4 Data storage, protection and your right to access and erasure

Your data is stored in an encrypted database and transferred over secure network connections.
We will store your information for as long as your account exists in Vita Health & Fitness Limited App.
If your user account is entirely inactive for a period of 12 months or more, we will delete your account.
If you ask us to, or if you delete your account, we will delete the information linked to your account which
can identify you personally, including your profile photo and personal details.

You may ask us, at any time, to provide to you confirmation that your data is being processed and
access to your personal data. This will generally be provided within 7-21 working days.


11.5 Marketing and research

If you agree, we may contact you:

- with offers and information about Vita Health & Fitness Limited products or services.
- for customer research, e.g. to help improve our service.

You can ask us to stop contacting you for marketing and/or research purposes by following the
instructions in any such communication or by emailing us at info@vita-london.com

11.6 Disclosing your information

We will never disclose your information to anyone outside of Vita Cafe except:

- Where we have your consent
- Where we are required or permitted to do so by law
- To other companies who provide a service to us as a processor under the terms of this privacy policy
- To any successors in title to our business.

If we ever transfer your personal information to countries outside the European Economic Area
we will ensure that appropriate security measures are taken.


11.7 Accessing your information

To obtain a copy of the information we hold about you, email us at info@vita-london.com.
Please confirm any details to help us identify and locate your information.
If any of the details are incorrect, let us know and we will amend them.

11.8 Changes to our policy

This policy replaces all previous versions and is correct as of November 2019.
We reserve the right to change the policy at any time.

11.9 Contacting us

If you have any queries, please contact us at info@vita-london.com