PRIVACY POLICY Last updated: [23/09/26] This policy explains how The No Gym Method collects, uses and protects your personal information when you visit our website and landing pages, fill in our forms, book a call, message us, or join one of our coaching programmes. Put simply: we only collect what we need to coach you well, we never sell your data, and you can ask us to see, change or delete it at any time. 1. WHO WE ARE The No Gym Method is run by Kyle Reain, a sole trader based in Northern Ireland, United Kingdom. Kyle Reain is the data controller for the personal information described in this policy. Business name: The No Gym Method (Kyle Reain) Address: [71 Magheraconluce Road Hillsborough bt266pr] Email: [[email protected]] ICO registration number: [ICO NUMBER] If you have any questions about this policy or your data, email us at [[email protected]]. 2. WHAT INFORMATION WE COLLECT Information you give us: - Contact details, such as your name, email address, phone number, country and Instagram handle. - Form and application answers covering your goals, lifestyle, routine, schedule, training history, what you've tried before, and whether you are the decision-maker for joining a programme. - Health and body information, such as your weight, measurements, body shape goals, injuries, medical conditions (for example PCOS, endometriosis or diastasis recti), pregnancy or postpartum status, menopause stage, sleep, eating habits and any medication that affects your training or nutrition. - Progress photos and videos, including exercise form videos you send for review. - Messages you send us by Instagram DM, email, WhatsApp, the coaching app or our website forms. - Call and workshop recordings, if a session is recorded. We always tell you before recording. - Payment information. Payments are handled by our payment provider, [STRIPE]. We see your name, amount and payment status, but we never see or store your full card details after onboarding. - Testimonials and feedback you choose to give us. Information collected automatically: - Device and usage data, such as your IP address, browser type, pages visited, time on page and how you arrived at our site. - Cookies and tracking pixels, including the Meta (Facebook/Instagram) Pixel and analytics tools. See section 8. 3. HOW WE USE YOUR INFORMATION AND OUR LEGAL BASIS Under UK data protection law (UK GDPR and the Data Protection Act 2018), we must have a lawful reason for each use of your data. Here's what we do and why: - Replying to your enquiry, form or DM, and booking your call. Legal basis: legitimate interests / steps before entering a contract. - Delivering your coaching programme, building your training and nutrition plan, and reviewing your form and check-ins. Legal basis: contract. - Using your health and body information to tailor your programme safely. Legal basis: explicit consent (see section 4). - Taking payments and keeping financial records. Legal basis: contract / legal obligation. - Sending you workshop invites, tips, offers and updates by email. Legal basis: consent (you can unsubscribe at any time). - Sharing your results, photos or testimonial publicly. Legal basis: consent only, given separately (see section 6). - Measuring and improving our website and adverts (analytics and Meta Pixel). Legal basis: consent (via our cookie banner). - Keeping our business secure, preventing fraud and handling disputes. Legal basis: legitimate interests. 4. YOUR HEALTH INFORMATION Health information is treated as "special category" data under the law, and we handle it with extra care. - We only ask for health information that we need to coach you safely and effectively. - We only use it with your explicit consent, which you give by ticking the consent box on our forms or onboarding questionnaire. - It is only seen by your coach and the small team supporting your programme. - You can withdraw consent at any time. If you do, we may not be able to keep coaching you safely, and we'll talk that through with you. - We are not medical professionals. Our coaching is not medical advice. If you have a medical condition, are pregnant or are unsure whether exercise is safe for you, please speak to your GP or doctor first. 5. WHO WE SHARE YOUR INFORMATION WITH We never sell your personal information. We only share it with trusted service providers who help us run the business. They may only use it to provide their service to us: - Kajabi: website, landing pages, forms, members' area and email - TrueCoach: delivering your training programme and tracking progress - Calendly: booking calls - Zoom: coaching calls and workshops - Meta (Instagram / Facebook): messaging, advertising and ad measurement - Google: email, file storage and analytics - [STRIPE]: payments - We may also share information if the law requires it, or to protect our rights in a legal dispute. 6. TESTIMONIALS, PHOTOS AND YOUR STORY We will never share your photos, results, name or story publicly without your clear, separate permission. - We ask for permission in writing, usually in your terms and conditions on your onboarding form that you will sign and checkmark as a requirement for coaching on your questionnaire, and tell you exactly how your story may be used (for example on Instagram, our website or in adverts). - You can choose to stay anonymous (first name only, or no face shown). - You have 7 days after giving permission to change your mind, no questions asked. - After that, you can still ask us to stop using your content at any time. We'll remove it from our own website and channels and stop using it in new content. We can't always pull back content that has already been shared or reposted by others. 7. INTERNATIONAL TRANSFERS We coach women worldwide, and some of our service providers (such as Kajabi, Calendly, Zoom, Meta and Google) store data outside the UK, mainly in the United States. When this happens, we make sure appropriate safeguards are in place, such as the UK-US Data Bridge, the UK International Data Transfer Agreement or Addendum, or Standard Contractual Clauses. 8. COOKIES AND TRACKING Our website and landing pages use cookies and similar technology: - Essential cookies keep the site and your members' login working. These can't be switched off. - Analytics cookies help us understand which pages are useful so we can improve them. - Advertising cookies (Meta Pixel) help us measure how our Instagram and Facebook adverts perform and show relevant adverts to people who've visited our site. Non-essential cookies are only used if you agree to them in our cookie banner. You can change your choice at any time through the cookie settings link on our site or in your browser settings. 9. HOW LONG WE KEEP YOUR INFORMATION - Enquiries and leads who don't join: up to 36 months after our last contact, then deleted. - Client records, including health information, check-ins and progress photos: for as long as you're a client, plus 2 years, so we can support you if you return. After that they are deleted or anonymised. - Payment and financial records: 6 years, as required by UK tax law. - Email marketing list: until you unsubscribe. - Testimonials you've approved: until you ask us to stop using them. You can ask us to delete your information sooner. See section 10. 10. YOUR RIGHTS You have the right to: - Access the personal information we hold about you - Correct anything that's wrong or incomplete - Delete your information ("right to be forgotten") - Restrict or object to how we use it, including all direct marketing - Withdraw consent at any time, including for health information, marketing, cookies and testimonials - Data portability: receive your information in a usable format To use any of these rights, email [PRIVACY EMAIL]. We'll respond within one month. It's free, unless a request is clearly excessive. If you live in the EU, you have the same rights under the EU GDPR. If you live in California or another US state with a privacy law, you also have the right to know what we collect, request deletion and not be discriminated against for using your rights. We do not sell or "share" your personal information for cross-context behavioural advertising except through the Meta Pixel described above, which you can refuse via our cookie banner. 11. KEEPING YOUR INFORMATION SAFE We use reputable, secure platforms, strong passwords and two-factor authentication, and we limit access to your information to the people who need it to coach you. No system is 100% secure, but if a data breach ever put you at risk, we would tell you and the Information Commissioner's Office as the law requires. 12. AGE Our programmes are for adults aged 18 and over. We don't knowingly collect information from anyone under 18. If you think we have, contact us and we'll delete it. 13. LINKS TO OTHER SITES Our pages may link to other websites and platforms such as Instagram, YouTube or our podcast hosts. We're not responsible for their privacy practices, so please check their policies. 14. COMPLAINTS If you're unhappy with how we've handled your information, please contact us first at [PRIVACY EMAIL] and we'll do our best to put it right. You also have the right to complain to the UK Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint or on 0303 123 1113. If you live in the EU, you can also complain to the data protection authority in your country. 15. CHANGES TO THIS POLICY We may update this policy from time to time. The latest version will always be on this page, with the date at the top. If we make a significant change, we'll let current clients know. Thank you for trusting us with your information. We take that trust seriously. Kyle Reain The No Gym Method