Privacy Policy

1. Who we are

Harry Thorn Coaching is an online fitness coaching business based in the United Kingdom. We provide personalised fat loss, muscle building, and overall health coaching services to clients via our online programmes.

Trading name: Harry Thorn Coaching
Website: harrythorncoaching.com
Contact email: harry@harrythorncoaching.com

2. What data we collect

We collect the following personal data from you:

When you fill in an enquiry or lead form (including via Meta/Instagram ads):

• Your full name
• Email address
• Phone number (where provided)
• Your responses to our qualifying questions (e.g. fitness goals, current training habits, intent to invest in coaching, preferred contact method)

When you message us on Instagram or via our automated chat (Manychat):

• Your Instagram handle
• Any messages or content you send us
• Conversation history with our automated and live chat

When you become a paying client:

• Billing details (processed by our payment provider — we do not store full card details ourselves)
• Health and fitness information you choose to share for the purpose of programme design (training history, dietary preferences, lifestyle, body measurements, photos)
• Ongoing communications throughout the coaching relationship

When you use our website:

• Standard analytics data (IP address, browser type, pages visited) via cookies — see section 8 below

3. Why we collect it (lawful basis)

Purpose	Lawful basis
Responding to your coaching enquiry	Legitimate interests / Consent
Assessing fit for our coaching programmes	Legitimate interests
Booking and conducting discovery calls	Consent
Delivering coaching services to paying clients	Performance of contract
Sending you marketing communications	Consent (you can unsubscribe anytime)
Improving our services and content	Legitimate interests
Meeting legal obligations (tax, accounting)	Legal obligation

4. Who we share your data with

We share your data with the following third-party processors, each bound by appropriate data processing agreements:

• Manychat (US-based) — for managing automated and live conversations on Instagram Direct
• Email service provider (Flodesk or equivalent) — for sending email communications
• Calendar / scheduling provider — for booking discovery calls
• Our appointment-setting team — UK-based contractors who help schedule calls with qualified leads
• Meta Platforms (Instagram, Facebook) — when you interact with our ads or Instant Lead Forms
• Payment processor (Stripe or equivalent) — for processing payments from paying clients
• HMRC and our accountants — for legal and tax compliance

We do not sell your data to third parties.

5. International transfers

Some of our processors (notably Manychat and Meta) are based outside the UK, primarily in the United States. Where your data is transferred internationally, we rely on the UK addendum to the EU Standard Contractual Clauses, or other appropriate safeguards required by UK GDPR, to ensure your data remains protected to UK standards.

6. How long we keep your data

• Lead enquiries that do not convert to clients: 24 months, after which we delete or anonymise the data
• Active and former coaching clients: for the duration of the coaching relationship + 7 years thereafter (required for legal, tax, and accounting purposes)
• Marketing email subscribers: until you unsubscribe, after which we delete your data within 90 days

7. Your rights under UK GDPR

You have the right to:

• Access the personal data we hold about you
• Rectify inaccurate or incomplete data
• Erase your data ("right to be forgotten") in certain circumstances
• Object to, or restrict, the processing of your data
• Withdraw consent at any time where we rely on consent as the lawful basis
• Data portability — receive your data in a machine-readable format
• Lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk

To exercise any of these rights, email us at the address in section 11. We will respond within one calendar month.

8. Cookies

Our website uses essential cookies for basic functionality and may use analytics cookies (such as Google Analytics or the Meta Pixel) to understand visitor behaviour and improve our content. You can control or block cookies through your browser settings at any time.

9. Children

Our services and marketing are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18.

10. Changes to this policy

We may update this policy from time to time. The "Last updated" date at the top reflects the most recent version. Significant changes will be communicated to subscribers by email.