Privacy Policy

1. Who We Are

This Privacy Policy applies to the personal data processing activities of Mark Bryce Executive Performance Coaching, trading as The Body Transformation Coach ("we", "us", "our").

Data Controller: Mark Bryce
Email: mark@executive-performance-coaching.com
Website: executive-performance-coaching.com

We are established in the United Kingdom and are subject to the UK General Data Protection Regulation (UK GDPR) as retained in UK law by the Data Protection Act 2018, and — where applicable — the EU GDPR for processing data of individuals located in the European Economic Area (EEA).

2. Data We Collect

We may collect and process the following categories of personal data:

• Identity data: first name, last name.
• Contact data: email address, telephone number.
• Health and lifestyle data: information you voluntarily provide through our health questionnaire, quiz, or coaching consultations (e.g. age, height, weight, sleep quality, stress levels, medical history, medications). This constitutes special category data under UK/EU GDPR.
• Professional data: job title, company, work environment, travel frequency.
• Financial data: payment details processed via our third-party payment processor (Stripe). We do not store full card numbers.
• Usage data: IP address, browser type, pages visited, time on site, referral source — collected via standard analytics tools.
• Communications data: records of correspondence, consultation notes, and programme feedback.

3. How We Collect Your Data

• Directly from you when you complete a contact form, health quiz, onboarding questionnaire, or book a consultation.
• Via email or telephone during consultations.
• Automatically through cookies and similar tracking technologies on our website.
• From third-party services such as Stripe (payments) and Calendly (scheduling).

4. Legal Bases for Processing

We rely on the following legal bases under UK/EU GDPR:

5. Special Category Data (Health Information)

Because we provide health and fitness coaching, we necessarily process special category data relating to your physical health and lifestyle. We will only do so with your explicit consent, which you provide by completing our health questionnaire or onboarding forms. You may withdraw this consent at any time by contacting us, though this may affect our ability to provide coaching services.

We implement appropriate technical and organisational safeguards to protect this data, including encrypted storage and restricted access.

6. How We Use Your Data

• To deliver, personalise and manage your coaching programme.
• To communicate with you about your programme, progress and appointments.
• To process payments securely.
• To send you relevant health, fitness and performance content (with your consent).
• To improve our website and services through analytics.
• To comply with legal and regulatory obligations.

7. Sharing Your Data

We do not sell your personal data. We may share it with:

• Stripe Inc. — payment processing (PCI DSS compliant). Data may be processed in the USA under Standard Contractual Clauses.
• Calendly LLC — appointment scheduling. Data may be processed in the USA under Standard Contractual Clauses.
• Base44 / cloud hosting providers — secure data storage and application infrastructure.
• Professional advisers — lawyers, accountants, or insurers where legally necessary.
• Regulatory authorities — if required by law (e.g. HMRC, ICO).

All third-party processors are contractually bound to handle your data in compliance with UK/EU GDPR.

8. International Data Transfers

Some of our third-party service providers are based outside the UK and EEA, including in the United States. Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• UK International Data Transfer Agreements (IDTAs) or EU Standard Contractual Clauses (SCCs).
• Transfers to countries with UK adequacy decisions.
• Data Protection Framework certification (where applicable).

9. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes set out in this policy, including:

• Client records (including health data): 7 years from the end of the coaching relationship, to meet legal, regulatory and insurance requirements.
• Financial records: 6 years from the relevant tax year, as required by HMRC.
• Marketing opt-ins: Until you withdraw consent.
• Website enquiries: 2 years from the date of enquiry if no contract is entered.

10. Your Rights

Under UK GDPR (and EU GDPR where applicable), you have the right to:

• Access — request a copy of the personal data we hold about you.
• Rectification — ask us to correct inaccurate or incomplete data.
• Erasure — request deletion of your data ("right to be forgotten"), subject to legal retention obligations.
• Restriction — ask us to limit how we process your data.
• Data portability — receive your data in a structured, commonly used, machine-readable format.
• Objection — object to processing based on legitimate interests or for direct marketing.
• Withdraw consent — at any time where processing is based on consent, without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at mark@executive-performance-coaching.com. We will respond within 30 days. You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at any time.

11. Cookies

Our website uses cookies and similar technologies to improve user experience and analyse site traffic. You may control cookie preferences through your browser settings. By continuing to use our website, you consent to our use of essential cookies.

12. Children's Privacy

Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from children under 18. If you believe a child has provided us with personal data, please contact us immediately.

13. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure, including encryption in transit and at rest, and access controls limited to authorised personnel only.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page with a revised "Last updated" date. We encourage you to review this policy periodically.

15. Contact Us

For any questions, concerns or requests relating to this Privacy Policy or your personal data, please contact: