Privacy Policy
Last updated: July 2026
Introduction
Welcome to Posilivity. I am committed to protecting your privacy and ensuring that your personal information is handled in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
This Privacy Policy explains how I collect, use, store, and protect your personal data when you visit my website or use my services. Please read this policy carefully to understand my practices regarding your personal data.
Data Controller
The data controller responsible for your personal data is:
If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact me using the details above.
Personal Data I Collect
I may collect and process the following categories of personal data:
Identity Data
Name, title, and other identifiers you provide when contacting me or booking a consultation.
Contact Data
Email address, telephone number, and postal address.
Health Data (Special Category)
Information about your health, fitness levels, medical conditions, and wellness goals that you voluntarily share during consultations. This is special category data under UK GDPR and is processed only with your explicit consent.
Technical Data
IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Usage Data
Information about how you use my website, including pages visited, time spent on pages, and navigation paths.
How I Collect Your Data
I collect personal data through the following methods:
- Direct interactions: When you contact me via email, book a consultation through Calendly, or communicate with me during coaching sessions.
- Automated technologies: As you interact with my website, I may automatically collect Technical Data about your equipment and browsing patterns through cookies and similar technologies. See my Cookie Policy for more details.
- Third parties: I may receive data from analytics providers such as Google Analytics (based outside the UK).
Legal Basis for Processing
Under UK GDPR, I must have a lawful basis for processing your personal data. The legal bases I rely on are:
| Purpose | Legal Basis |
|---|---|
| Providing wellness coaching services | Performance of a contract |
| Processing health data for coaching | Explicit consent (Article 9(2)(a)) |
| Responding to enquiries | Legitimate interests (to respond to your requests) |
| Sending marketing communications | Consent |
| Website analytics | Legitimate interests (to improve my website) |
| Legal compliance | Legal obligation |
How I Use Your Personal Data
I use your personal data for the following purposes:
- To provide personalised wellness coaching services tailored to your needs
- To schedule and manage consultation appointments
- To respond to your enquiries and provide customer support
- To send you service-related communications
- To send marketing communications about my services (only with your consent)
- To analyse website usage and improve user experience
- To comply with legal and regulatory obligations
Data Sharing and Disclosure
I do not sell, trade, or rent your personal data to third parties. I may share your data with:
- Service providers: Third-party companies that help me operate my business (e.g., Calendly for scheduling). These providers are bound by contractual obligations to keep your data confidential and secure.
- Legal requirements: If required by law, court order, or governmental authority.
- Professional advisers: Lawyers, accountants, or other professional advisers as necessary.
Third-Party Fonts
This website uses Google Fonts to display typography consistently across devices. When you visit a page, your browser automatically connects to Google servers (fonts.googleapis.com and fonts.gstatic.com) to load the font files.
As part of this connection, Google may receive your IP address. This processing is necessary for the technical delivery of the website and happens before any cookie consent is obtained, because the fonts are required for the page to render correctly.
International Data Transfers
Some of my third-party service providers are based outside the UK. When your data is transferred outside the UK, I ensure that appropriate safeguards are in place, including:
- Transfers to countries with an adequacy decision from the UK government
- Use of Standard Contractual Clauses approved by the UK ICO
- Transfers to organisations that have implemented binding corporate rules
Data Retention
I retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:
- Client records: Retained for 7 years after our last interaction, as required for tax and legal purposes.
- Health data: Retained for the duration of our coaching relationship plus 7 years, unless you request earlier deletion.
- Marketing preferences: Retained until you withdraw consent or unsubscribe.
- Website analytics: Typically retained for 26 months.
Data Security
I take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it, including:
- Encryption of data in transit using SSL/TLS
- Secure storage of electronic records
- Regular review and updating of security measures
- Limited access to personal data on a need-to-know basis
While I strive to protect your personal data, no method of transmission over the internet is 100% secure. I cannot guarantee absolute security but will notify you and the ICO of any data breach as required by law.
Your Data Protection Rights
Under UK GDPR, you have the following rights:
Right of Access
You can request a copy of the personal data I hold about you.
Right to Rectification
You can request correction of inaccurate or incomplete data.
Right to Erasure
You can request deletion of your data in certain circumstances (also known as the "right to be forgotten").
Right to Restrict Processing
You can request that I limit how I use your data.
Right to Data Portability
You can request your data in a structured, commonly used, machine-readable format.
Right to Object
You can object to processing based on legitimate interests or for direct marketing purposes.
Right to Withdraw Consent
Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact me. I will respond to your request within one month. There is no fee for making a request unless it is manifestly unfounded or excessive.
Right to Complain
If you are unhappy with how I have handled your personal data, you have the right to lodge a complaint with the UK's supervisory authority:
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
Website: ico.org.uk
I would appreciate the opportunity to address your concerns before you contact the ICO, so please reach out to me first.
Cookies
My website uses cookies to enhance your browsing experience. For detailed information about the cookies I use, their purposes, and how to manage them, please see my Cookie Policy.
Changes to This Policy
I may update this Privacy Policy from time to time to reflect changes in my practices or for legal, regulatory, or operational reasons. Any changes will be posted on this page with an updated revision date. I encourage you to review this policy periodically. Significant changes will be communicated to you directly where possible.
Contact Me
If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have concerns about how I handle your personal data, please contact me.
Sophie Tookey
sophie@posilivity.co.uk