Top Gym Privacy Policy
1. Purpose and Scope of this Privacy Policy
This Privacy Policy explains how Top Gym collects, receives, uses, stores, processes, shares and protects personal data relating to prospective members, members, guests, class participants, personal-training clients, website visitors, users of the Top Gym mobile application (the "App") and other individuals who interact with Top Gym.
This Privacy Policy applies to personal data processed through or in connection with:
- Top Gym memberships and membership applications;
- the Top Gym App;
- Top Gym's website;
- Top Gym's customer relationship management ("CRM") and member-management systems;
- InBody assessments;
- classes and personal-training services;
- access-control and attendance systems;
- communications with Top Gym;
- Top Gym premises and CCTV systems;
- member benefits and partner offers; and
- other services operated or provided by Top Gym.
We process personal data in accordance with applicable data-protection law in the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL"), where applicable.
This Privacy Policy should be read together with any applicable Top Gym membership terms, facility rules, App terms or other notices provided in connection with a particular service.
2. Personal Data We Collect
The personal data we collect depends on how you interact with Top Gym and which services you choose to use.
2.1 Identity and Contact Information
We may collect:
- full name;
- date of birth;
- nationality;
- gender;
- telephone number;
- email address;
- residential address;
- emergency-contact details; and
- other information reasonably required to administer your membership or requested service.
2.2 Emirates ID and Identity Verification
Where required for membership application, identity verification, fraud prevention or access-control purposes, Top Gym may request a temporary image of your Emirates ID and may view the information visible on it.
We do not retain a copy of the Emirates ID image once verification has been completed.
Where an Emirates ID image is received through WhatsApp Business or another approved communication channel, it is deleted from Top Gym's relevant account and any local downloads as soon as practicable after verification and no later than the end of the same business day.
Top Gym may retain a limited verification record confirming matters such as:
- that identity verification was completed;
- the date of verification; and
- the authorised staff member who completed the verification.
2.3 Membership and Service Information
We may collect and process:
- membership applications;
- membership type and duration;
- membership status;
- membership start and expiry dates;
- membership agreements and contract records;
- unique membership numbers or identifiers;
- digital membership cards;
- unique membership QR codes;
- access credentials;
- class bookings;
- personal-training sessions;
- attendance records;
- facility-access records;
- membership freezes where applicable; and
- other records relating to your use of Top Gym services.
2.4 Body Composition, Fitness and Wellness Information
Where you choose to use relevant Top Gym fitness or assessment services, we may process fitness, wellness and body-composition information.
Top Gym currently uses an InBody 270S body-composition assessment system.
Information generated by an InBody assessment may include:
- weight;
- Body Mass Index (BMI);
- body-fat percentage;
- muscle mass;
- visceral-fat information;
- other body-composition metrics generated by the InBody 270S; and
- historical InBody scan results.
The Top Gym App does not itself perform the body-composition assessment. The information is generated through the relevant assessment system and may be transferred through Top Gym's connected systems and displayed within the App.
Historical results may be retained and displayed so that members can review changes and progress over time.
We may also process:
- fitness goals;
- exercise programmes;
- exercises and workout information;
- personal-training information;
- trainer notes; and
- relevant health or wellness information that you voluntarily provide in connection with a requested service.
Health, fitness and body-composition information is treated with enhanced care.
Please do not provide medical information that is not reasonably relevant to a service you have requested.
3. The Top Gym App
The App is intended to provide Top Gym members with access to certain membership, fitness and member-benefit functionality.
Depending on the features available to you, the App may display or process:
- your name;
- date of birth;
- telephone number;
- membership details and membership status;
- digital membership card;
- unique membership number;
- membership QR code;
- InBody results and historical scans;
- class bookings;
- personal-training sessions;
- attendance;
- exercises and workout information;
- trainer notes;
- membership-related notifications; and
- participating partner offers and benefits.
The App may receive information from Top Gym's CRM and other connected systems and may send information back to those systems where required for the operation of the relevant function.
4. Sources of Personal Data
We may collect personal data:
- directly from you;
- when you enquire about Top Gym;
- when you apply for or purchase a membership;
- when you enter into a membership or service agreement;
- when you attend Top Gym;
- when you use the App;
- when you access our website;
- when you book a class or personal-training session;
- when you undergo an InBody assessment;
- when you communicate with us;
- when you use membership access systems; or
- when you participate in another Top Gym service.
We may also receive limited personal data from:
- an authorised family member;
- a corporate account holder;
- an authorised trainer;
- payment or accounting service providers;
- our CRM or technical service providers;
- connected fitness systems;
- a partner where necessary to resolve a member-benefit issue; or
- another person acting with your authority or as otherwise permitted by law.
5. Why We Use Personal Data
We may process personal data where reasonably necessary to:
- consider and process membership applications;
- verify identity;
- prevent membership, payment or access fraud;
- enter into, perform and administer membership agreements;
- provide classes, personal-training and other requested services;
- create and maintain your membership profile;
- manage membership status and access credentials;
- administer bookings and attendance;
- provide and display InBody assessments and fitness information;
- display historical fitness progress;
- administer personal-training programmes;
- maintain exercise and trainer records;
- provide App functionality;
- verify eligibility for member benefits;
- communicate with you regarding your membership;
- provide membership-expiry or other operational notifications;
- record payments and transactions;
- administer refunds or outstanding balances where applicable;
- manage enquiries, feedback and complaints;
- resolve disputes;
- establish, exercise or defend legal claims;
- maintain safety and security;
- operate CCTV and access-control systems;
- prevent misuse or unauthorised access;
- maintain the cleanliness and proper operation of our facilities;
- operate, maintain, secure, troubleshoot and improve our CRM, App, website and other systems;
- maintain accounting and business records;
- comply with applicable legal, regulatory and record-keeping obligations; and
- respond to lawful requests from courts, regulators, governmental authorities or law-enforcement authorities.
We do not currently use members' health, body-composition or training information for targeted advertising.
We do not currently use personal data for direct marketing based on member profiling.
If our direct-marketing practices materially change, we will provide any notice and obtain any consent required by applicable law.
6. Legal Basis for Processing
Where applicable under the PDPL or other applicable law, Top Gym may process personal data:
- with your consent;
- where necessary to take steps at your request before entering into an agreement;
- where necessary to enter into, perform or administer an agreement with you;
- where necessary to comply with a legal obligation;
- where necessary to protect Top Gym's lawful rights and interests;
- where necessary to protect a person's vital interests;
- where necessary to establish, exercise or defend legal claims; or
- under another lawful basis permitted by applicable law.
Where we rely on consent, you may withdraw that consent subject to applicable law. Withdrawal of consent does not affect processing that was lawfully carried out before withdrawal.
Where particular processing is necessary to provide or administer a membership or service, withdrawal may mean that Top Gym can no longer provide or continue that service.
Emirates ID Consent
Where an Emirates ID image is requested, its purpose is limited to identity verification, fraud prevention and the assessment or administration of your membership.
Before providing the image, you will be provided with notice of the purpose for which it will be used.
By voluntarily sending the image after receiving that notice, you acknowledge and authorise Top Gym to receive, view and use the image for that verification purpose.
The image itself is not retained after verification.
7. Health, Fitness and InBody Data
Health, fitness and body-composition information may be sensitive personal data and is handled with enhanced care.
We use this information only in connection with services you choose to use and for relevant fitness, membership, wellness, administration and record-keeping purposes.
Top Gym does not sell this information.
Top Gym does not provide members' InBody results, fitness information, training history or trainer notes to partner businesses merely because the member uses a partner offer.
Fitness and Medical Disclaimer
InBody results, fitness information, exercise programmes, trainer notes and information displayed through the App are provided for general fitness, wellness and informational purposes.
They are not intended to constitute medical advice, medical diagnosis, medical treatment or a substitute for advice from a qualified healthcare professional.
Measurements produced by body-composition equipment may be affected by hydration, food intake, exercise, measurement conditions and other factors.
Members should seek appropriate professional medical advice where they have concerns regarding their health, medical conditions, symptoms, pregnancy, medications, injuries or ability to participate in physical exercise.
8. CRM, App Infrastructure and Connected Systems
Top Gym uses a CRM and member-management system supplied by Simplar and may use other authorised technology providers to operate the App and related services.
Information may flow between Top Gym's:
- App;
- CRM;
- membership-management systems;
- attendance and access systems;
- InBody or body-composition systems; and
- other authorised connected systems.
This enables relevant membership and fitness information to remain consistent across Top Gym services.
Service providers may process personal data only to the extent reasonably necessary to provide their contracted services and are expected to maintain appropriate confidentiality, security and data-protection safeguards.
9. Technical, Device and App Information
When you use the App, website or other digital systems, limited technical information may be automatically generated or processed as part of normal application, server, network, security or diagnostic operations.
Depending on the technology actually used, this may include:
- IP address;
- device type;
- operating system;
- App version;
- server logs;
- security logs;
- diagnostic information;
- crash or error information; and
- similar technical information.
Such information may be used where reasonably necessary to:
- provide the digital service;
- maintain system security;
- diagnose technical problems;
- prevent unauthorised activity;
- maintain reliability;
- investigate faults; and
- protect Top Gym's systems.
Top Gym does not use this provision as authority to access device functions or information that are not reasonably connected with the App or service.
10. Location Information
The Top Gym App does not currently request or collect the precise or approximate location of your device for the purpose of providing its services.
If location-based functionality is introduced in the future, we will update this Privacy Policy where required and request any device permission or consent required by applicable law or platform rules.
11. Push Notifications
The App may send push notifications relating to Top Gym services or the administration of your membership.
These may include operational communications such as:
- membership-status information;
- membership-expiry reminders;
- class or service information; and
- other important service-related notifications.
Top Gym does not currently use members' body-composition or training information to provide personalised advertising.
Where supported by your device, push-notification permissions can be managed through your device settings.
Disabling notifications may prevent you from receiving certain reminders but does not itself cancel or alter your Top Gym membership.
12. Partner Offers and Member Benefits
The App may contain a section displaying offers, discounts, privileges or benefits made available by participating third-party businesses.
Where required to use an offer, a member may present their:
- digital membership card;
- membership number; or
- unique membership QR code.
A partner may scan or verify the relevant membership credential for the limited purpose of determining whether the individual is eligible for the relevant Top Gym member benefit.
Such verification does not provide the partner with general access to the member's:
- Top Gym profile;
- InBody results;
- body-composition data;
- fitness information;
- trainer notes;
- attendance history;
- class history;
- personal-training history; or
- other information held in Top Gym's CRM.
A verification response may confirm that the relevant membership or benefit is valid or eligible where necessary for redemption.
Participating partners are independent businesses.
If you separately provide personal data directly to a participating partner—for example to purchase a product, make a booking or obtain a service—that processing is governed by the partner's own privacy practices and is outside Top Gym's control.
Top Gym is not responsible for the privacy practices, availability, quality, acts, omissions, products or services of independently operated partner businesses, except to the extent required by applicable law.
13. Independence of Membership Price and App Benefits
The price and value of a Top Gym membership are independent of the Top Gym App and any benefits, features, offers, discounts, partner privileges or other services made available through the App.
All App features and benefits are supplementary to the Top Gym membership and do not form part of the calculation or determination of the membership price or value.
The modification, suspension, withdrawal or unavailability of any App feature, benefit, offer, discount, partner privilege or other App-based service shall not, to the extent permitted by applicable law, entitle a member to any refund, reduction, credit or adjustment to the price of their Top Gym membership.
Nothing in this section excludes any right that cannot lawfully be excluded under applicable law.
14. Payments and Transaction Information
Top Gym may maintain payment and transaction records relating to:
- memberships;
- classes;
- personal-training services;
- refunds;
- credits;
- outstanding balances; and
- other Top Gym services.
The Top Gym App does not currently process card payments and Top Gym does not currently collect or store payment-card information through the App.
Where payments are processed outside the App, relevant transaction records may nevertheless be maintained as part of Top Gym's membership, accounting or CRM records.
If payment functionality is introduced into the App in the future, payments may be processed through an authorised third-party payment service provider.
Where applicable, payment-card details may be provided directly to the relevant payment provider rather than stored by Top Gym.
This Privacy Policy will be updated where required to reflect material changes to payment processing.
15. Communications
We may process communications between you and Top Gym, including:
- emails;
- WhatsApp messages;
- telephone communications;
- enquiries;
- feedback;
- requests;
- complaints; and
- other correspondence.
Top Gym may use WhatsApp Business for member communications.
Where you choose to communicate with us using WhatsApp, relevant information may also be processed by WhatsApp, its group companies and infrastructure providers in accordance with their own terms and privacy practices.
Members should avoid sending unnecessary sensitive or medical information through messaging services.
16. Who May Receive Personal Data
Where reasonably necessary and permitted by law, personal data may be disclosed on a need-to-know basis to:
- authorised Top Gym personnel;
- membership and operations personnel;
- authorised management personnel;
- finance and accounting personnel;
- authorised customer-service personnel;
- authorised trainers where access is necessary for a requested service;
- authorised technical or administrative personnel;
- Simplar, our CRM provider;
- App developers and authorised technical subcontractors;
- hosting, cybersecurity and infrastructure providers;
- WhatsApp Business and its relevant service providers;
- payment and accounting providers;
- legal advisers;
- insurers;
- auditors;
- IT and communications providers;
- security providers;
- other professional service providers;
- courts;
- regulators;
- governmental authorities;
- law-enforcement authorities; or
- another person where you direct us to make the disclosure or where the disclosure is otherwise permitted by law.
Third-party service providers acting on Top Gym's behalf are expected to process personal data only as necessary to provide the relevant service and to apply confidentiality, security and data-protection safeguards appropriate to the information concerned.
Top Gym does not sell personal data.
17. Staff and Trainer Access
Access to personal information is restricted according to operational requirements, role and system permissions.
Top Gym trainers and ordinary staff members do not receive unrestricted access through the App to members' private profiles or body-composition information merely because they are employees, contractors or trainers.
Where a particular staff member, trainer, manager, system administrator or technical service provider needs access to particular information in order to provide, administer, secure, investigate or support a requested service, access may be provided on an appropriately restricted basis.
18. International Transfers
Top Gym uses technology and communications service providers, including Simplar and WhatsApp Business.
The infrastructure, systems, servers or authorised personnel used by some service providers may be located outside the United Arab Emirates.
Where personal data is transferred outside the UAE, Top Gym will take the steps required under applicable law to provide an appropriate level of protection, which may include contractual, organisational, technical or other safeguards.
Further information may be provided on request where required by law.
19. Data Retention
Top Gym retains personal data only for as long as reasonably necessary for the purposes for which it was collected or for other lawful purposes, including:
- membership administration;
- provision of services;
- accounting;
- taxation;
- record keeping;
- security;
- fraud prevention;
- complaints;
- dispute resolution;
- regulatory requirements; and
- establishment, exercise or defence of legal claims.
Emirates ID Images
Top Gym does not retain the image of an Emirates ID after identity verification has been completed.
Any image received through Top Gym's WhatsApp Business account or downloaded locally for verification will be deleted as soon as practicable following verification and no later than the end of the same business day.
Only the limited verification record described above may be retained.
Membership Records
As a general rule, Top Gym retains membership records and limited identity-verification records for the membership period and for six years after the membership ends.
Information may be retained for a longer period where required or permitted because of:
- a legal or regulatory obligation;
- an ongoing complaint;
- a dispute;
- a legal claim;
- an investigation;
- fraud prevention;
- security concerns; or
- another lawful reason.
After the applicable retention period, information will be securely deleted, anonymised or archived as appropriate.
20. Membership Expiry and App Access
Access to member-only areas of the Top Gym App is linked to an active Top Gym membership.
When a membership expires, access to member-only functionality may be deactivated.
Expiry or deactivation of App access does not necessarily require immediate deletion of all underlying membership records where Top Gym is entitled or required to retain those records in accordance with the retention provisions of this Privacy Policy or applicable law.
21. Account and Data Deletion Requests
Members may contact Top Gym at info@topgym-dxb.com to request deletion of personal data.
Deletion requests will be assessed in accordance with applicable law and Top Gym's legal and record-retention obligations.
Where Top Gym is legally entitled or required to retain particular information—for example for accounting, fraud prevention, dispute resolution, security, regulatory or legal-claim purposes—that information may be retained for the applicable period even where other information is deleted.
Where the Top Gym App enables users to create an App account, Top Gym will provide any account-deletion mechanism required by the applicable App Store or Google Play requirements.
Deletion of an App account, where applicable, does not override lawful obligations to retain separate membership, transaction, security or legal records.
22. Data Security
Top Gym uses reasonable technical, organisational and physical safeguards designed to protect personal data against:
- unauthorised access;
- unauthorised disclosure;
- accidental or unlawful loss;
- misuse;
- alteration; and
- destruction.
Measures may include, where appropriate:
- access controls;
- role-based permissions;
- authentication;
- secure systems;
- appropriate network protection;
- restricted administrative access;
- confidentiality obligations;
- vendor controls; and
- staff procedures and training.
Emirates ID images received for verification are available only to authorised personnel during the limited verification period and are promptly deleted following verification.
No electronic system, network, application, transmission method or storage system can be guaranteed to be completely secure.
Members are responsible for keeping passwords, login credentials, device access and other authentication information secure and should notify Top Gym if they believe their account or information has been compromised.
23. CCTV, Premises Security and Visitor Information
Top Gym uses CCTV in and around appropriate areas of its premises for:
- safety;
- security;
- access control;
- incident prevention;
- investigation;
- protection of members, staff, visitors and property; and
- establishment or defence of legal claims.
CCTV is not used in changing rooms, toilets, showers or sauna areas.
We may also maintain incident reports, visitor records and other premises-security information where reasonably necessary.
24. Website, Wi-Fi, Cookies and Similar Technologies
Top Gym's website and, where offered, Wi-Fi services may use essential cookies, server logs and similar technologies to:
- operate securely;
- maintain functionality;
- remember relevant settings;
- diagnose technical issues;
- prevent misuse; and
- understand general usage.
Where consent is required for non-essential cookies or similar technologies, we will request that consent separately.
The website may also provide additional cookie notices or controls where appropriate.
25. Children and Young People
Top Gym may provide memberships or services to individuals under the age of 18 where permitted by Top Gym's rules and applicable law.
Where an individual is below the age at which they can lawfully provide the relevant consent or enter into the relevant arrangement independently, Top Gym may require the involvement, consent or authorisation of a parent or legal guardian.
Parents and guardians are responsible for:
- providing accurate information;
- providing any consent or authorisation required by law; and
- appropriately supervising the young person's use of Top Gym services and the App.
Top Gym does not knowingly use children's personal or fitness information for targeted advertising.
26. Your Privacy Rights
Subject to the PDPL, other applicable law and any relevant exceptions, you may have rights to request:
- information about personal data Top Gym processes;
- information regarding the purposes of processing;
- access to personal data;
- a copy of personal data;
- correction of inaccurate or incomplete personal data;
- deletion of personal data where applicable;
- restriction or cessation of certain processing where applicable;
- transfer of personal data where applicable and technically feasible;
- withdrawal of consent where processing is based on consent; and
- review of certain decisions based solely on automated processing where applicable.
To exercise a privacy right or raise a privacy concern, contact: info@topgym-dxb.com
Top Gym may need to verify your identity before acting upon a request in order to prevent unauthorised access to personal information.
Where applicable, you may also have the right to raise a complaint with the UAE Data Office or another competent authority.
27. Third-Party Services and External Businesses
The App, website or other Top Gym services may contain information concerning, or links to, independently operated third-party businesses and services.
Where you independently interact with a third party, the third party may collect personal information directly from you.
Top Gym does not control the independent privacy practices of such third parties.
You should review the applicable privacy policy or terms of the relevant third party before providing personal information directly to it.
Nothing in this section limits any responsibility Top Gym has under applicable law for service providers processing personal data on Top Gym's behalf.
28. No Sale of Personal Data and No Advertising Use of Fitness Data
Top Gym does not sell personal data.
Top Gym does not sell members' body-composition, InBody, fitness or training information.
Top Gym does not provide such information to advertisers or participating partner businesses for targeted advertising or behavioural profiling.
If these practices materially change in the future, Top Gym will update this Privacy Policy and obtain any consent required by applicable law before implementing the relevant processing.
29. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect:
- changes in applicable law;
- changes to Top Gym services;
- changes to the App;
- changes to our website;
- new technologies;
- new service providers;
- changes to data-processing practices; or
- regulatory requirements.
The latest version will be made available through the Top Gym website and, where applicable, through the App or another accessible location.
Where required by law, material changes will be brought to your attention through appropriate means.
The "Last Updated" date at the beginning of this Privacy Policy indicates the date of the most recent revision.
30. Contact Us
For questions concerning this Privacy Policy, Top Gym's processing of personal data or a privacy-rights request, contact: