DRAFT for review by an Italian privacy lawyer before launch. Replace every [bracket].

Privacy notice

Who we are

[Company name], [registered address], VAT [number], is the data controller. Contact: [email].

What we collect

Contact details, date of birth, sex, height, weight, goals, answers to four yes/no safety questions, weekly check-in data, body measurements, optional progress photos, and blood-test values you choose to share.

Why, and on what basis

To run your coaching membership (contract, Art. 6(1)(b) GDPR). Health data (weight, measurements, photos, blood values, safety answers) only with your explicit consent (Art. 9(2)(a) GDPR), which you can withdraw at any time. Marketing emails only if you opt in.

Blood results

We compare your values only with the reference ranges printed by your laboratory. If a value is outside range, we ask you to see your GP or a specialist physician. We do not diagnose or give medical advice.

Who processes it

Google (Workspace: storage and email), Cloudflare (website hosting), Anthropic (AI assistance drafting coaching replies). Each acts under a data processing agreement. [Confirm data locations and transfer safeguards.]

How long

Applications not accepted: deleted after 6 months. Members: deleted [12] months after membership ends (including maintenance), except accounting records kept as required by Italian law.

Your rights

Access, correction, deletion, restriction, portability, objection, and withdrawal of consent: email [email]. You can complain to the Garante per la protezione dei dati personali (garanteprivacy.it).