Privacy Policy – Jetts Fitness India

This document sets out the policy of Jetts Fitness India Private Limited and its related franchisee-operated clubs (collectively, "Jetts India") in relation to the collection, use, disclosure, storage, and protection of your personal information (Privacy Policy). Jetts India is committed to protecting the privacy and confidentiality of your personal information and adheres to the applicable provisions of the Information Technology Act, 2000 and its allied rules, as well as the principles under the Digital Personal Data Protection Act, 2023 (DPDP Act).

This Privacy Policy applies to all your interactions with Jetts India, whether through its clubs, franchise locations, mobile applications, official website (www.jetts.in), or through other communication means. It explains:

• The kinds of personal information Jetts India collects and holds;

• How Jetts India collects and stores your personal information;

• The purposes for which Jetts India uses and discloses your personal information;

• How you may access and correct your personal information;

• How you can raise a complaint about Jetts India’s handling of your personal data;

• Whether Jetts India discloses your personal information to third parties, including international data transfers.

By using Jetts India’s services, visiting www.jetts.in, submitting membership or trainer forms, entering contests, or engaging with the franchisee recruitment process, you agree to the terms of this Privacy Policy and explicitly consent to Jetts India’s use of your personal information as detailed below.

Your Personal Information

Jetts India collects personal information only when it is reasonably necessary for delivering our services, fulfilling legal obligations, or managing business functions. This includes:

• Processing and managing membership and franchisee applications;

• Facilitating members & casual members gym access;

• Conducting marketing activities, research & special offers;

• Accurately identifying who is using Jetts’ services;

• Communicating with members, franchisees & website visitors to Jetts’ website and online enquiries;

• Profiling our members & their interests;

• Operating Jetts’ business; and / or

• Transferring memberships between clubs as per Jetts transfer policy. The types of information Jetts collects include:

  • Name, date of birth, gender, and emergency contact details;

  • Contact details such as address, phone number, and email;

  • Identity proof (e.g., Aadhaar, PAN, passport, etc.);

  • Health and fitness-related information;

  • Goals, preferences, and feedback;

  • Banking and payment details;

  • Information provided through surveys, forms, or website interaction.

Your Sensitive Information

Sensitive personal information under Indian law includes medical history, biometric data, financial data, and identifiers issued by the government (e.g., Aadhaar, PAN). Jetts India collects such information only:

• When it is necessary for health and fitness services;

• With your explicit and informed consent;

• Or where required by applicable Indian laws.

How Jetts Collects Your Personal Information

Jetts India collects your personal information directly from you where feasible, including via:

• Telephone, SMS, or WhatsApp;

• Email and physical forms;

• In-person communication at clubs;

• Online forms and website interactions;

• Club access systems, biometric scans (if used), or CCTV surveillance.

Jetts India may also receive data from:

• Your assigned personal trainer;

• Third-party service providers;

• Referrals from members (e.g., “refer a friend” campaigns);

• Public sources such as directories or regulatory filings.

Using Your Personal Information

Jetts India uses your personal information to:

• Process memberships and franchisee onboarding;

• Facilitate gym access and member services;

• Communicate offers, updates, or schedule changes;

• Customise training and wellness plans;

• Monitor safety, security, and service quality;

• Improve our website, customer support, and operations;

• Meet legal and regulatory requirements.

We only use the information for purposes reasonably connected to your engagement with Jetts India.

Purpose of Collection

Jetts India collects your data for primary purposes such as membership management and service delivery. We will not use your data for unrelated (secondary) purposes unless:

• You have consented; you would have consented to the use or disclosure of your personal information; or

• In relation to the use or disclosure of your personal information:

• You would reasonably expect Jetts to use or disclose your information for the secondary purpose, and the secondary purpose is directly related to the primary purpose;

• use or disclosure is required or authorised under Indian law, court order, or regulatory directive;

• Necessary for legal proceedings or enforcement matters.

• a permitted situation exists in relation to Jetts’ use or disclosure of the information;

• a permitted health situation exists in relation to the use or disclosure of the information; or

• Jetts reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

• If Jetts uses or discloses your information because Jetts reasonably believes that the use or disclosure of your information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body, Jetts will make a written note of the use or disclosure.

All such uses will be documented for transparency.

Do You Have to Provide Personal Information?

Providing your personal information is voluntary. However, refusal to provide required data may restrict Jetts India from offering services, processing memberships, or addressing requests.

Sharing Your Personal Information

Jetts India may share your personal information with third parties such as:

• Regulatory authorities, if requested or required under the Indian Law

• Various law enforcement agencies and governments for security, customs and immigration purposes;

• Banks, payment gateways, and accounting firms;

• Service vendors (marketing, logistics, IT infrastructure, printing);

• Personal trainers and health consultants;

• Auditors, legal counsel, and insurers.

• Professional or government organisations; and

• External advisers (recruiters, auditors & lawyers).

• Jetts does not rent, sell or exchange your personal information with third parties without your prior approval.

Government Identifiers

Jetts India does not use your Aadhaar number, PAN, or other government-issued identifiers as our own internal identifiers. We only use such data:

• When required by Indian law (e.g., for verification, tax compliance);

• For KYC documentation in banking or franchisee contracts.

• It’s reasonably necessary to fulfil Jetts’ obligations; or

• Jetts reasonably believes it is reasonably necessary for one or more enforcement-related activities.

Cookies

Jetts India may use cookies and similar technologies to improve your digital experience. Information collected may include:

• IP address;

• Device/browser type;

• Session time and pages visited.

This data helps us monitor usage patterns, improve website content, and enhance functionality. You can disable cookies via browser settings.

Links to Other Websites

Jetts India is not responsible for privacy practices of third-party websites linked from our platforms. Users are encouraged to read the privacy policies of external websites before providing personal data.

Direct Marketing

We may use your contact information for promotional campaigns, fitness updates, or third-party wellness offers, if:

• Jetts collected the information from you; and

• You would reasonably expect Jetts to use or disclose the information for that purpose; and

• Jetts provided you with a simple way to opt out of receiving direct marketing from Jetts; and

• You have not made such an opt out request to Jetts. Jetts may also use or disclose your information (other than sensitive information) for direct marketing if:

• Jetts collected the information from you and you would not reasonably expect Jetts to use or disclose the information for that purpose or someone other than you; and

• either:

• You have consented to the use or disclosure of the information for that purpose; or

• It is impracticable to obtain that consent; and

• Jetts provided you with a simple way to opt out of receiving direct marketing from Jetts; and

• In each direct marketing communication with you:

• Jetts includes a prominent statement that you can request to opt out; or

• Jetts otherwise draws your attention to the fact that you can request to opt out; and

• You have not made such a request to Jetts.

Jetts can use or disclose your sensitive information for the purpose of direct marketing if you have consented to the use or disclosure of that information for direct marketing. Jetts may also use or disclose your personal information for direct marketing if:

• Jetts are a contracted service provider for a Commonwealth contract; and

• Jetts collected your information in order to meet an obligation under that contract; and

• The use or disclosure is necessary to meet (directly or indirectly) such an obligation.

If Jetts has collected the personal information that Jetts used to send you direct marketing material from a third party, you can ask Jetts to notify you of its source of information. It is Jetts’ policy is to do so unless it is unreasonable or impracticable.

How to Opt Out of Direct Marketing

You may opt out from Jetts India’s direct marketing emails, SMS, or WhatsApp by:

• Clicking “unsubscribe” in emails;

• Write to us at privacy@jetts.in;

• Notifying club staff or franchisee personnel.

Requests are processed within 7 working days.

Protecting Your Personal Information

We follow industry-standard security practices, including:

• Password-protected internal databases;

• Physical access controls at our offices and gyms;

• Encrypted storage of sensitive data;

• Access controls and audit trails;

• Staff confidentiality agreements;

• Secure firewalls and data backup systems.

Jetts cannot guarantee that personal information will be protected against unauthorized access or misuse and Jetts does not accept any liability for the improper actions of unauthorised third parties.

Jetts will retain your personal information for as long as necessary to fulfil Jetts’ obligations to you, to protect its legal interests, to comply with laws or as otherwise stated to you when Jetts collects your personal information.

Once Jetts is no longer required to retain your personal information, Jetts will take reasonable steps to destroy your personal information or to ensure that your personal information is de-identified.

Disclosing Your Personal Information Overseas

Your personal information may be processed or stored on cloud platforms or systems outside India. Before such transfer, Jetts India ensures:

• The overseas recipient complies with similar or higher privacy standards;

• Your data remains protected under applicable Indian and contractual safeguards.

By interacting with us, you agree to this international transfer. Personal information may be disclosed by Jetts to other Jetts entities and third parties in jurisdictions including: Australia, New Zealand, United States of America and the Netherlands. The European Commission has recognized each of these countries as providing adequate protection of personal information.

To make it easy for you to deal with Jetts and other Jetts entities and provide you with a more personal and consistent experience, Jetts may exchange and combine personal information with other Jetts entities for the purposes described in this Privacy Policy.

If your personal information is collected using a document that references this Privacy Policy, you are taken to consent to the disclosure, transfer, storing or processing of your personal information outside of Australia.

You acknowledge and understand that by providing such consent:

• Jetts will not be required to take steps as are reasonable in the circumstances to ensure that such third parties comply with the APPs;

• If the overseas recipient handles your personal information in breach of the APPs:

• Jetts will not be liable under the Act; and

• You will not be able to seek redress under Act.

• The overseas recipient may not be subject to any privacy law or principles similar to the APPs;

• You may be unable to seek redress overseas;

• The overseas recipient is subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.

If you withdraw consent, Jetts will not rely on this consent when dealing with your personal information going forward.

Anonymity

You have the option of not identifying yourself or using a pseudonym when dealing with Jetts provided that is it lawful and practicable.

Jetts will try to accommodate a request for anonymity if possible. However, your right to anonymity does not apply in relation to a matter if:

• Jetts is required/authorised by law or court/tribunal order to deal with identified individuals; or

• It is impracticable for Jetts to deal with individuals who have not identified themselves.

It is Jetts’ policy to enable you to access Jetts’ website and make general phone queries without having to identify yourself and to enable you to respond to Jetts’ surveys anonymously.

In some cases however, if you don’t provide Jetts with your personal information when requested, Jetts may not be able to respond to your request or provide you with our service. For example, you must identify yourself to become a Jetts member or franchisee.

Access to Your Personal Information

You have the right, upon request, to access any of Jetts’ records containing your personal information. To request access to your personal information, please contact the Privacy Officer/Club Manager, set out at the end of this Policy.

Jetts will respond to your request to access your personal information within a reasonable period of time.

On the basis that it is reasonable and practicable to do so, Jetts will give you access to the information requested.

If Jetts refuses your request to access personal information, Jetts will provide a written notice setting out the reasons for the refusal & how you can complain about the refusal.

Reasons for a refusal may include if it:

• Poses a serious threat to the life, health or safety;

• Would have an unreasonable impact on the privacy of others;

• Is frivolous or vexatious;

• Relates to legal proceedings;

• Reveals Jetts’ intentions or prejudices any negotiations;

• Would be unlawful;

• Is required or authorised by law or a court/tribunal order;

• Is likely to prejudice enforcement-related activities; or

• Relates to a commercially sensitive decision process.

When you make a request to access personal information, Jetts will require you to provide some form of identification (such as a driver’s licence or passport) so Jetts can verify that you are the person to whom the information relates.

Help Jetts Keep Your Personal Information Accurate

Jetts will take reasonable steps to ensure Jetts’ records of personal information are accurate, up to date and complete.

However, the accuracy of information depends to a large extent on the information you provide. If you do not give Jetts all the personal information Jetts may require, or the personal information provided is inaccurate or incomplete, then the products, services and information Jetts provide may be affected.

If you think there is something wrong with the information Jetts holds about you please contact the Privacy Officer/ Club Manager to:

• Let Jetts know if there are any errors; and

• Keep Jetts up-to-date with any changes, and Jetts will try to correct your personal information.

Jetts will respond to your request to correct your personal information in a reasonable period of time. If Jetts refuses your request, Jetts will provide you with a written notice setting out the reasons for the refusal and mechanisms available to complain about the refusal.

If Jetts refuses to correct your personal information, you may request that Jetts associate your information with a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. Jetts will take reasonable steps to make the statement visible to users of your personal information.

If Jetts does correct your personal information and Jetts has previously disclosed your personal information to a third party, upon your request, Jetts will notify that third party of the correction unless it is impracticable or unlawful to do so.

Resolving Your Privacy Issues

For complaints, data correction, or any data privacy concern, please contact our Grievance Officer:

Email: privacy@jetts.in
Address: Registered Address, Jetts India HQ

Unresolved complaints can be escalated to the Data Protection Board of India (once functional).

Changes and Access to This Privacy Policy

Jetts India may revise this Privacy Policy to comply with future Indian privacy regulations or operational changes. Any revisions will be posted on www.jetts.in and be effective upon publication. You are encouraged to review this Policy periodically.

If you have any questions about this statement, please contact Jetts’ Privacy Office by emailing privacy@jetts.in