Privacy Notice
Issued under the Personal Information Protection Act 2016 (Bermuda) · Version 1.0 · June 2026
1. Who We Are
Renewal Fitness is a private personal training studio located in Paget, Bermuda, owned and operated by Anita Lightbourne. We provide one-to-one and duo personal training services to clients in Bermuda.
For the purposes of Bermuda's Personal Information Protection Act 2016 (PIPA), Renewal Fitness is the organisation responsible for the personal information we collect and use. We are committed to handling your personal information lawfully, fairly, and transparently.
2. What Information We Collect
2.1 General Personal Information
We collect the following when you become a client or make an inquiry:
- Full name and contact details (email, phone, home address)
- Referral source (e.g. physiotherapist or another client)
- Scheduling preferences and available session times
- Communication history relating to your training or billing
2.2 Sensitive Information — Health & Fitness Data
Classified as sensitive personal information under PIPA and subject to higher standards of protection:
- Health history and any known medical conditions
- Physical limitations, injuries, or rehabilitation requirements
- Completed Physical Activity Readiness Questionnaire (PAR-Q) forms
- Movement assessment findings and initial strength evaluations
- Fitness goals and training progress notes
We always obtain your explicit written consent before collecting or using sensitive personal information.
3. Why We Collect Your Information
We collect and use your personal information only for the following purposes:
- To design, deliver, and adjust personalised training programmes tailored to your health history and goals
- To assess your suitability for physical activity through the PAR-Q process
- To communicate about session scheduling, rescheduling, and changes
- To issue monthly invoices and record payments
- To comply with legal obligations, including health and safety requirements
- To respond to inquiries from prospective clients
We do not use your personal information for any other purpose, including advertising or marketing to third parties.
4. Our Legal Basis for Using Your Information
Under PIPA, we rely on the following conditions:
- Consent — you have provided explicit written consent, including for sensitive health data.
- Contract performance — processing is necessary to deliver the training services you engaged us for.
- Legal obligation — where we are required to retain records by law.
You may withdraw consent at any time; this does not affect the lawfulness of prior processing, though it may mean we can no longer provide training services to you.
5. Who We Share Your Information With
5.1 Contracted Trainers
Where sessions are delivered or supported by a contracted trainer, that trainer accesses the information necessary to provide your training — including health history, PAR-Q data, and training programme. All contracted trainers handle your information in accordance with PIPA and are bound by confidentiality obligations.
5.2 Third-Party Service Providers
We use the following platforms to operate our business, each governed by its own privacy policy:
| Platform | Purpose | Data Stored |
|---|---|---|
| Gmail (Google LLC) | Client communication | Correspondence, scheduling, invoices |
| Google Calendar (Google LLC) | Session scheduling | Appointment dates, times, attendance |
| Google Sheets (Google LLC) | Training programmes | Session data, programming notes |
| Acuity Scheduling (Squarespace Inc.) | Client booking | Contact details, appointment history |
| QuickBooks Desktop (Intuit Inc.) | Billing & accounting | Financial records, invoices |
| Intuit E-Commerce (Intuit Inc.) | Invoice delivery | Contact details, invoice data |
| Notion (Notion Labs Inc.) | Business operations | Internal records (no client-facing use) |
| WhatsApp (Meta Platforms Inc.) | Ad hoc client messaging | Messages sent via this platform |
5.3 What We Do Not Do
We do not sell, rent, or trade your personal information to any third party, and do not share it for advertising or marketing purposes.
6. Overseas Transfers
Several platforms above are operated by US-based companies; your information may be transferred to and stored on servers outside Bermuda. We take reasonable steps to ensure overseas providers apply data protection standards consistent with PIPA. By consenting to this notice, you acknowledge your information may be processed and stored overseas for the purposes described.
7. How Long We Keep Your Information
We retain personal information only as long as necessary, or as required by law:
| Category | Retention Period |
|---|---|
| Client personal & contact information | Relationship + 3 years |
| Health history, PAR-Q & medical information | Relationship + 7 years |
| Training session records & programming | Relationship + 5 years |
| Financial & billing records | 7 years from transaction |
| Signed consent & waiver forms | Relationship + 7 years |
| Inquiry records (non-clients) | 2 years from first contact |
| Email correspondence | Relationship + 3 years |
At the end of the applicable period, information is securely deleted or anonymised; paper records are securely destroyed.
8. Security Safeguards
We implement appropriate technical and organisational measures to protect your information, including:
- Password-protected access to all digital platforms and devices used in the business
- Limiting access to client health information to the trainer(s) directly working with you
- Secure storage of any paper-based records containing personal or health information
- Use of established, reputable service platforms for storing client data
No method of transmission or storage is completely secure. In the unlikely event of a breach that may adversely affect you, we will notify you and the Bermuda Privacy Commissioner without undue delay, in accordance with PIPA.
9. Your Rights Under PIPA
| Right | What It Means |
|---|---|
| Access | Request a copy of the personal information we hold about you. |
| Correction | Request correction of information that is inaccurate or incomplete. |
| Withdraw Consent | Withdraw consent at any time; does not affect prior processing. |
| Object | Object to a particular use of your information, including direct marketing. |
| Blocking | Request we cease using your information in certain circumstances, e.g. disputed accuracy. |
To exercise these rights, contact our Privacy Officer (Section 11). We respond to all rights requests within 30 days.
10. Complaints
If you are not satisfied with how we've handled your personal information, you may complain to the Office of the Privacy Commissioner for Bermuda (www.privacy.bm), which has authority to investigate complaints and take action where a breach of PIPA has occurred.
11. Our Privacy Officer
Renewal Fitness has appointed the following individual as Privacy Officer, responsible for PIPA compliance:
Anita Lightbourne — Privacy Officer, Renewal Fitness Email: renewalfitnessbda@gmail.com · Website: www.renewalfitnessbda.com
All access requests, corrections, consent withdrawals, or privacy concerns should be directed to the Privacy Officer in writing. We acknowledge receipt within 5 business days and respond in full within 30 days.
12. Changes to This Privacy Notice
We may update this notice to reflect changes in our operations, the platforms we use, or legal requirements. Material changes are notified to existing clients by email, with the version number and date updated above. The current version is always available at www.renewalfitnessbda.com.
This notice was last reviewed and issued in June 2026, and is subject to annual review — next scheduled review: June 2027.
Renewal Fitness · Paget, Bermuda · renewalfitnessbda@gmail.com · www.renewalfitnessbda.com