Privacy notice
How I handle your personal data under UK GDPR and the Data Protection Act 2018.
DRAFT for legal review: this page has not been checked by a solicitor and may change.
Who is responsible for your data
Lean Horizon Online is run by John. The data controller is [JOHN TO CONFIRM: legal name or trading name, and business address if required]. You can contact me at hello@leanhorizononline.com.
[JOHN TO CONFIRM: ICO registration number, if you are registered with the Information Commissioner's Office.]
What I collect
When you message me: your name, email address, the plan you ask about (if you say) and your message.
When you buy: your name, email address and the details of your order. Payment is taken by Stripe, which collects your card and billing details. I do not see or store your full card number.
The health questionnaire: information about your health, injuries, medication, training history and goals. Some of this is health data, which is special category data under UK GDPR and gets extra protection. [JOHN TO CONFIRM: the questions asked, and which tool hosts the questionnaire.]
During your programme: your training and progress information, and messages between us, including your weekly check-ins if you choose Premium.
Website analytics: I use Vercel Web Analytics, which is cookieless. It records page views without setting cookies on your device or tracking you across other sites. I do not use Google Analytics, advertising pixels or tracking cookies.
Why I use it, and my lawful basis
To take your order, build your plan and deliver the service, including Premium check-ins and Lean for Life billing: this is necessary to carry out the contract with you.
To use your health information: I ask for your explicit consent. You give it when you complete the questionnaire, and I use the information only to build and adjust your plan safely. You can withdraw your consent at any time by emailing me, but I may then be unable to provide a safe plan.
To keep financial records and meet tax and accounting rules: this is a legal obligation.
To reply to your messages, keep my systems secure and understand how the site is used: these are my legitimate interests.
I will only send you emails about your order and your plan. [JOHN TO CONFIRM: if you want to send marketing emails, add a separate opt-in.]
Who I share it with
I do not sell your data. I use a small number of providers to run the business: Stripe (payments), Vercel (website hosting and analytics) and Zoho (email). [JOHN TO CONFIRM: the provider that hosts the health questionnaire, and any app or other provider that holds plan or progress data.]
Some providers may handle data outside the UK. Where they do, I rely on appropriate safeguards. [JOHN TO CONFIRM: details of international transfers.]
How long I keep it
Financial records: for the period the law requires, usually six years. [JOHN TO CONFIRM.]
Health questionnaire answers and progress data: [JOHN TO CONFIRM: for example, deleted a set time after your programme or membership ends].
Messages: [JOHN TO CONFIRM: retention period].
Your rights and deletion
You can ask to see the data I hold about you, correct it, delete it, restrict or object to how I use it, and receive a copy in a portable format. You can withdraw consent at any time. Email me at hello@leanhorizononline.com and I will deal with it. If you ask me to delete your data, I will do so unless I need to keep something to meet a legal obligation, such as financial records.
You can also complain to the Information Commissioner's Office at ico.org.uk.
Security
I take reasonable steps to keep your data safe, and I limit who can see your health information. [JOHN TO CONFIRM: the security measures you use for the questionnaire and plan data.]
Changes
I may update this notice. The latest version will always be on this page.