In an effort to keep our Studio 22 community safe in light of the COVID-19 pandemic, we are collecting additional information from our students, employees, and other studio visitors. Our transparency is key to maintaining your trust, and during these unprecedented times, we are especially mindful of striking the right balance between ensuring the health and safety of our students, employees, and the public and respecting your privacy. Accordingly, effective as of May 18, 2020, the following privacy notice (the "Privacy Notice") shall apply, set forth below, which will continue to otherwise govern our collection, use and other processing of your information.
As the current circumstances and the needs of our community evolve, this Privacy Notice may be modified or updated in Studio 22's sole discretion. If we make any changes to our Privacy Notice, we will post the revised document here and such changes will be effective immediately upon posting. Please review this Privacy Notice periodically to ensure you are aware of any changes.
What Information We're Collecting:
We may collect certain information about your potential exposure to COVID-19 and health through periodic health declarations we ask you to complete. We may also collect measurements of your body temperature when you are at the studio. We will not record or store your body temperature measurement, but if your body temperature registers higher than our permitted threshold for studio access, we reserve the right to record and indicate in our system that you were denied entrance and are not eligible to return for 3 days. In addition, we may collect information provided by you, or a public health authority or other government agency, if you test positive for COVID-19, including information about how you interacted with Studio 22 during the time in which you may have been infected with COVID-19. Should you exhibit symptoms of COVID-19 or test positive for COVID-19 within 48 hours of visiting Studio 22, you should notify Studio 22 so that your interactions at Studio 22 may be reviewed and appropriate steps taken. All of the foregoing is referred to in this Privacy Notice as "Screening Information".
What We're Doing With Screening Information:
We collect and use Screening Information to help provide a safe environment for our employees, students, and other studio visitors and to administer your access to our studio. We will use Screening Information in furtherance of those legitimate interests and business purposes. We will not use your Screening Information for any marketing or promotional purposes.
How We May Share Screening Information:
While we generally will not share your Screening Information without your consent, we reserve the right to disclose this information, and other related information, to government and regulatory authorities, such as the Centers for Disease Control and Prevention and state and local health authorities, or as otherwise necessary or appropriate in furtherance of public health or safety. If we are notified that you tested positive for COVID-19 within 14 days after your last visit to Studio 22, or if we otherwise determine that you may pose a risk to our community, we reserve the right to disclose to our employees, students, and other studio visitors that an individual who tested positive, or otherwise poses a risk to our community, was in our facilities and while we will won't disclose your name unless legally required to do so, we may disclose information such as the date and time of your visit, your gender, and the studio areas you used. We share this information to help ensure our studio remains safe for our employees and other students. We may also share your Screening Information and other related information with service provider, advisors or consultants who are performing services on our behalf and for other reasons in accordance with applicable law. Please note we may disclose aggregated, de-identified information for any other lawful purpose.
How We Retain Screening Information:
Your Screening Information will be protected, and will be retained only as long as we determine reasonably necessary to ensure the health and safety for our students, employees, and other studio visitors and in accordance with applicable law. As noted above, your body temperature measurement will not be stored unless required by applicable law, but we will retain your acknowledgements of the health declaration, as well as any records (if any) that you were denied entrance and not permitted to return for 3 days. Any information that we retain will be stored for a reasonable period of time, including as we determine necessary to comply with applicable law or to establish or defend our legal rights.
At this time, Studio 22 requires you to provide Screening Information as a condition of entry to its studios. However, if you are uncomfortable with providing any requested Screening Information or do not wish to consent to this Privacy Notice, we may refund, exchange, or extend the expiration date of your purchase, in our sole discretion. Please contact firstname.lastname@example.org if you have any questions regarding our screening procedures or would like to discuss a refund, exchange, or expiration extension of your purchase.
EFFECTIVE DATE: May 18, 2020