1. Introduction
This Privacy Policy explains how NEW CHEER ROAD LIMITED collects, uses, stores and discloses personal information in the course of running its training floor systems. It applies to the company website, to the studio counter, to the digital records used by coaching staff and to every sitting, class and test window operated from the Wan Chai studio. The policy is written by the team led by our developer CheerRoad, and it is kept under review so that it reflects both the services we actually offer and the expectations of the people who use them.
We ask that you read this policy before you attend the studio, submit a form or contact the floor team. It is written in plain English because we think a privacy policy should be usable by the member at the counter as well as by a lawyer. Where a term is technical, we explain it rather than leaving it to a glossary at the end.
If you have any question about this policy, or about how we handle a specific record, you can write to our contact address listed in the final section. We answer privacy questions in the same way we answer training questions: directly, with reference to the record, and without hiding behind a template.
2. Who We Are
NEW CHEER ROAD LIMITED is a computer systems design business working in the professional, scientific and technical services sector. Our studio and office are located at Rm 2107, 382 Lockhart Rd, Wan Chai, Hong Kong (HK). The company designs, implements and operates the systems behind a working training floor, including class rosters, member passes, coaching notes, fitness test windows, equipment reviews and supervised open gym sittings.
For the purposes of applicable data protection law, NEW CHEER ROAD LIMITED is the controller of the personal information described in this policy, except where we act on the instruction of a studio client as a processor. When we act as a processor, the client studio remains the controller and sets the purpose for which member records are held, while we provide the systems and follow the written instruction of that studio.
Rm 2107, 382 Lockhart Rd, Wan Chai, Hong Kong (HK)
Email: inbox@risefitness.lat
Phone: +16282915012
3. Scope of This Policy
This policy covers personal information we collect through the website, through the contact form, through direct correspondence by email or telephone, through attendance at the studio, and through the operating systems that support the six services described on the services page. It does not cover information held by other businesses, even where those businesses operate from the same building or work with the same members.
We do not sell personal information. We do not rent member lists. We do not use member records to build advertising audiences. The operating records we keep exist to run a training floor safely and consistently, and this policy sets out the limits we apply to that purpose.
Some records are created at the direction of a client studio. If you are a member of a studio that uses our systems, the studio will normally be the first point of contact for a privacy request, and we will work with that studio to answer it. If you are unsure which party holds your record, write to us and we will help you work it out.
4. Information We Collect
We collect information in three broad ways: information you give us, information created when you interact with the studio or the website, and information we receive from a studio client when we are engaged to operate its floor systems.
Information you give us
- Name, email address, telephone number and any message you send through the contact form or by email.
- Details you provide when booking a walkthrough, including the name of your studio, the size of the floor and the complaints your front desk hears most often.
- Any information you choose to include in a coaching note request, a data request or a complaint.
Information created during attendance
- Attendance records showing which class, sitting or test window you joined and when.
- Pass usage records showing credits consumed, guest slots used and freeze periods applied.
- Coaching notes filed by a coach after a session, including load, observation and cue.
- Fitness test results recorded in a test window, such as a measured figure and the date of measurement.
Information about equipment and incidents
- Incident notes recorded by a floor lead during a supervised sitting, including the time and the item involved.
- Equipment review findings, which usually concern the item rather than a person, but may reference a member if a member reported the issue.
We do not collect payment card numbers directly on this website. Where a pass purchase requires payment, it is handled by a payment provider under its own terms, and we receive only a confirmation reference rather than full card details.
5. Member and Roster Records
Roster records tell the floor who is expected and when. They include a member name, a pass reference, the class or sitting joined and the date. We keep these records because a training floor cannot be run safely or fairly without knowing how many people are coming and who has already been served.
Roster bays are rebuilt each week from the previous week attendance rather than from the original booking sheet. This means attendance history is used to improve the accuracy of future capacity planning. The history is used in aggregate wherever possible, and individual attendance is visible only to the staff who need it to run the floor.
Members can ask for a copy of their own roster history, and can ask for the correction of any attendance record that looks wrong. A correction request is reviewed against the door record and the coach note, and we will explain the outcome whether or not the record is changed.
6. Coaching Notes
Coaching notes are short records filed by a coach after a session. Each note has a fixed shape: a load or intensity figure, one observation about movement and one cue to repeat. The note is attached to the member record and is used to prepare for the next session and the next fitness test window.
We treat coaching notes as sensitive within our own system even though they are not a special category of personal data in the strict legal sense. They are visible only to coaching staff who work with the member and to the studio management that reviews the monthly test sheet. They are never shared with a third party for marketing and never used to build a profile for sale.
A member may request a copy of the notes attached to their own record. A member may also ask for a note to be corrected if it contains a factual mistake, for example a load recorded against the wrong member. Requests are handled by the studio manager and are answered in writing.
7. Fitness Test Data
Fitness test windows produce measured figures that show how a member is progressing. We record the figure, the date and the window reference. The purpose is to support the coaching conversation, not to rank members against each other.
Test results are stored with the member record and are reviewed monthly in a short trend sheet. The trend sheet is used to decide which program changes deserve another month and which should be dropped. It does not feed any automated decision that has a legal or similarly significant effect on the member.
If a member provides health information in connection with a test, that information is treated with extra care, stored only where it is needed to keep training safe, and is not shared beyond the coaching team without the explicit consent of the member.
8. How We Use Information
We use personal information for the following purposes, each of which is connected to a service we actually provide:
- To answer enquiries sent through the contact form, by email or by telephone.
- To arrange and run a floor walkthrough for a studio client.
- To build and maintain class roster bays and member pass runs.
- To record coaching notes and make them available before the next session or test window.
- To schedule fitness test windows and review results with the coaching team.
- To maintain an equipment review schedule with findings, dates and named owners.
- To supervise open gym sittings and keep a brief log of incidents or equipment issues.
- To meet our legal, accounting and safety obligations, and to respond to lawful requests from a competent authority.
We do not use member information for profiling that produces legal effects, and we do not make automated decisions about a member solely on the basis of a test result or a coaching note. Any decision that affects a member is made by a person who can explain it.
9. Lawful Basis for Processing
Where applicable law requires us to identify a lawful basis, we rely on the following grounds. Performance of a contract applies where we hold information in order to deliver a service you or your studio has asked for. Legitimate interests applies where we use information to run the floor safely, to improve roster accuracy and to maintain equipment records, balanced against your rights and expectations. Consent applies where we send marketing messages or where a member chooses to share health information for a specific purpose. Legal obligation applies where we must retain records for accounting, tax or safety reasons.
Where we rely on consent, it can be withdrawn at any time by writing to the contact address. Withdrawal does not affect the lawfulness of processing that happened before the withdrawal, and it does not remove a record that we are required to keep by law.
12. Service Providers
Our service providers are limited to what the work actually requires. A hosting provider keeps the website online. An email provider delivers correspondence to and from our contact address. A scheduling or record platform may hold roster, pass and note data where a studio client has asked us to run its floor through that platform. Each provider is chosen for reliability and for a clear security posture, not for the size of its advertising network.
We review our providers at least once a year and whenever a provider changes its terms in a way that affects privacy. If a provider can no longer meet our standards, we migrate the data and remove the old copy rather than leaving a duplicate behind.
13. International Transfers
Our studio is in Hong Kong (HK), and some service providers may process information in another country. Where that happens, we take steps to ensure the information continues to receive protection comparable to what this policy describes. Those steps may include contractual clauses approved for the purpose, an assessment of the provider security practices and a review of the legal environment in the destination country.
We keep a record of where our principal systems are hosted and who can access them. That record is reviewed with the rest of our privacy documentation, and it is available to a member or a client studio on request where it helps answer a specific question.
14. Retention of Records
We keep records only for as long as they are needed. Roster and attendance records are kept for the current season and the following season so that capacity planning and pass reconciliation remain accurate. Coaching notes are kept while a member is active and for a short period afterwards so that a returning member is not met with a blank sheet. Fitness test results follow the same principle. Equipment review records are kept for longer because a maintenance history is most valuable when it spans several years.
When a retention period ends, we delete the record or anonymise it so that it can no longer be linked to a person. Backups are purged on a rolling schedule, and we take care that a deletion request is also applied to the backup copy within a reasonable period.
A member can ask us to delete their record earlier than the standard retention period. We will do so unless we are required to keep some part of it for a legal, safety or accounting reason, and we will explain clearly which part was kept and why.
15. Security Measures
We protect information with a layered approach. Access to roster, pass and note systems is limited to staff who need it for their role, and access is removed when a role ends. Accounts use strong passwords and are reviewed periodically. Devices used on the floor are kept up to date, and the studio network is separated from guest access.
Written findings from equipment reviews and incident logs include a named owner so that a security or safety gap cannot quietly fade out of view. If a breach occurs that is likely to result in a risk to the rights of a person, we will notify the affected party and the relevant authority in line with applicable law, and we will explain what happened in plain language.
No system is perfectly secure, and we do not pretend otherwise. What we can promise is that we will tell you promptly and honestly if something goes wrong, and that we will fix the cause rather than only the symptom.
16. Your Rights
Depending on where you live, you may have the right to access the information we hold about you, to ask for a correction, to ask for deletion, to restrict processing, to object to processing and to receive a portable copy of the information you provided. You may also have the right to withdraw consent where consent is the basis for processing.
To exercise a right, write to inbox@risefitness.lat or call +16282915012. We will confirm your identity before we release a record, because we do not want to hand a member record to someone who is not the member. We aim to respond within thirty days and will tell you if a complex request needs more time.
There is no charge for a reasonable request. Where a request is clearly unfounded or repetitive, we may refuse it and explain the reason. We will not use a refusal to discourage a genuine question.
17. Privacy for Children
The systems we operate are intended for adults and for supervised young athletes whose attendance is arranged by a parent or guardian. We do not knowingly collect information from a child without the involvement of a responsible adult. Where a studio client runs a youth program, the client is responsible for obtaining the necessary consent, and we support that process by keeping the record structure clear.
If you believe that a child has provided information to us without appropriate consent, write to the contact address and we will investigate promptly and delete the record where that is the right outcome.
18. Marketing Communications
We send marketing messages only where we have a lawful basis and, in most cases, only where you have asked to hear from us. Messages are infrequent and are usually about a service change, a new training window or a studio event. Every message includes a way to opt out, and an opt out is applied without asking you for a reason.
Opting out of marketing does not affect service messages, such as a confirmation of a walkthrough time or a notice that a sitting has moved. Those messages are part of the service and are connected to a request you made.
19. Third Party Links
Our pages may link to a third party site where that link is useful to the reader. We do not control those sites and we are not responsible for their privacy practices. When you follow a link away from our site, you should read the privacy policy of the site you land on before sharing information with it.
We do not embed advertising networks, social sharing scripts or third party video players that track you before you act. Where a link leads to a platform with its own account system, the decision to sign in is yours and is not required to use our site.
20. Changes to This Policy
We update this policy when our services change, when we adopt a new provider or when the law requires it. The date at the top of the page shows when the current version took effect. Where a change is material, we will give notice on this page and, where we hold your contact details, we will tell you directly.
We keep earlier versions of this policy on file so that a reader can understand what applied at the time a record was collected. A request for an earlier version can be made through the contact address.
21. Complaints and Contact
If you are unhappy with how we have handled your information, please tell us first. Most concerns can be resolved quickly once the specific record is identified. Write to inbox@risefitness.lat with the subject line Privacy Concern, include the name under which your record is held and describe what you think went wrong.
We will acknowledge your concern within five working days and aim to give a substantive response within thirty days. If you are not satisfied with our response, you may complain to the data protection authority in your jurisdiction. We will cooperate with that authority and will not penalise you for raising a concern in good faith.
Rm 2107, 382 Lockhart Rd, Wan Chai, Hong Kong (HK)
Email: inbox@risefitness.lat
Phone: +16282915012
This policy is published by the team led by CheerRoad for NEW CHEER ROAD LIMITED and applies to every service listed on the services page of this website.