Privacy Policy
Effective 01/SEP/2026 · version 1.0
In case of conflict, the Arabic version prevails.
Read the signed bilingual original (PDF)HEROS JOURNEY FITNESS CLUB L.L.C ("Hero's Journey", "we") is the controller of your personal data. Commercial Licence No. 1549553. TRN 105333116900001. Registered address Warehouse 9, Kunooz 12 Street (7B Street), Al Quoz Industrial 1, Dubai, UAE. Contact: dubai@hj.fit.
This policy explains what we collect, why, who receives it, where it goes and what you can do about it. It follows UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the PDPL).
1. What we collect and why
| Data | Purpose | Lawful basis |
|---|---|---|
| Name, date of birth, Emirates ID or passport number, nationality | Identifying you, verifying age, membership administration | Performance of contract |
| Mobile, email, address | Bookings, notices, confirmations, service messages | Performance of contract |
| Emergency contact details | Contacting someone if you are injured or unwell | Vital interests |
| Payment card details (held by our processor) | Collecting fees | Performance of contract |
| Health information you declare | Admission decisions and your safety | Explicit consent and vital interests |
| Bookings, attendance, Class history, weights lifted | Running your membership and programming | Performance of contract |
| Heart rate during Classes | Training intensity and progress tracking | Separate explicit consent |
| Body composition assessments | Progress tracking | Separate explicit consent |
| CCTV footage | Security, incident investigation, safety | Legitimate interests |
| App usage data, device identifiers, IP address | Running the app, security, fixing faults | Contract and legitimate interests |
| Marketing preferences | Sending offers if you asked for them | Consent |
2. Heart rate and body composition — your choice
Heart rate and body composition tell us things about your body. We treat them as sensitive data and handle them separately from everything else.
- Collection requires your separate, explicit consent, given as its own tick at sign-up.
- You can refuse, and you can withdraw consent at any time, through the app or by emailing dubai@hj.fit. Your membership, price and access are unaffected either way.
- Wearing a heart rate monitor is optional. You can attend any Class without one.
- This data is not diagnostic. It is not reviewed by a clinician and we give no medical opinion on it. Do not rely on it to make decisions about your health. If something concerns you, see a doctor.
- We keep granular heart rate data for [24] months, after which it is deleted or irreversibly aggregated.
3. Who receives your data
| Category of recipient | Purpose | Location |
|---|---|---|
| Payment processing | Collecting membership fees and issuing refunds | UAE and abroad |
| Membership app, bookings and access control | Running your membership, class bookings and entry | Stored in the UAE |
| Performance-tracking provider | Processing heart rate and body composition data | Stored in the UAE, processed in the EU/EEA |
| Member communications | Service messages and, where you have opted in, marketing | UAE and abroad |
| Hero's Journey Fitness Inc. and its master franchisee | Brand standards and aggregate reporting | USA and Kazakhstan |
| Professional advisers, auditors and insurers | Advice, claims and audit | UAE |
| Government and regulatory authorities | Where required by law | UAE |
We do not sell your personal data.
A current list of our service providers, naming each one and where it operates, is published at [hj.fit/processors] and is available on request from dubai@hj.fit. We update that list when a provider changes. This policy tells you the categories of recipient and the safeguards that apply to each; the list tells you who they are at any given time.
4. Transfers outside the UAE
Some of the recipients above are outside the UAE. Where that is the case we transfer data only where the PDPL permits it — because the destination provides an adequate level of protection, because appropriate contractual safeguards are in place, or because the transfer is necessary to perform your contract with us.
You can ask us for details of the safeguards applying to any specific transfer by emailing dubai@hj.fit.
4A. Where your data is stored, and where it is processed
Your membership records, bookings, attendance and performance data are stored on servers located in the United Arab Emirates.
Some processing of that data is carried out by service providers outside the UAE, who access it remotely rather than holding their own copy. In particular, your heart rate and body composition data is processed by a performance-tracking provider located in the European Economic Area.
Because performance data is sensitive, we apply additional safeguards to it: every provider that processes it does so under a written data processing agreement which permits processing only on our instructions and only for the purposes described in section 2; the provider may not use the data for its own purposes, disclose it to anyone else, or retain it after our instruction to delete; and providers in the European Economic Area are additionally bound by the European General Data Protection Regulation.
We rely on your separate explicit consent for this processing. If you withdraw that consent, the processing stops and we instruct the provider to delete the data it holds. Withdrawing does not affect your membership, your price or your access.
5. How long we keep it
| Data | Retention |
|---|---|
| Membership records and contracts | Duration of membership + [5] years |
| Health declarations | Duration of membership + [5] years |
| Financial and tax records | [5] years as required by law |
| Granular heart rate data | [24] months |
| Body composition assessments | Duration of membership + [12] months |
| CCTV footage | [30] days unless retained for an incident |
| Marketing preferences | Until you withdraw consent |
6. Your rights
Under the PDPL you can:
- Access the personal data we hold about you
- Correct anything inaccurate or incomplete
- Delete your data, where we have no overriding legal obligation to keep it
- Restrict or object to how we process it
- Receive a copy in a portable format, or have it transferred
- Withdraw consent at any time, for anything based on consent — including performance data and marketing
- Object to automated decision-making that significantly affects you
To exercise any of these, email dubai@hj.fit. We respond within [30] days. If you are not satisfied, you may complain to the UAE Data Office.
Withdrawing consent does not affect processing carried out before you withdrew it.
7. Marketing
We only send marketing if you have opted in. Every message carries an unsubscribe link, and you can opt out at any time through the app or by emailing us. Opting out does not affect service messages — booking confirmations, payment notices, schedule changes and cancellation confirmations are part of your membership.
8. Photography at the Club
We sometimes photograph or film the facilities for promotional use, and Members may appear incidentally. We display notice when filming is taking place, and you can ask not to be included. We will not use a photograph or video that identifies you individually for marketing without your separate written consent.
9. Security
We apply technical and organisational measures to protect your data, including access controls, encryption in transit and restricted staff access. No system is completely secure, and we cannot guarantee the security of data transmitted over the internet.
If a breach occurs that poses a risk to your data, we will notify the UAE Data Office and, where required, you.
10. Children
We do not knowingly process the data of anyone under 13. Members aged 16–17 are registered with the consent of a parent or legal guardian, who countersigns the application.
11. Changes
We may update this policy. The current version is always available at the Club and in the app. We will notify you of material changes by email.
12. Contact
Questions, requests or complaints: dubai@hj.fit, or write to us at the address above.
