Privacy Policy

Last updated: 4 October 2026Effective: 4 October 2026

1 Who we are

1.1 Coachflow is operated by Coachflow Ltd, registered in England and Wales, company number 17111426, registered office 66 Paul Street, London, England, EC2A 4NA. We are registered with the Information Commissioner's Office (ICO) under registration number ZC194076. 1.2 For the data described in this policy, Coachflow Ltd is the data controller. Contact us about privacy at admin@coachflow.io. 1.3 This policy covers our platform (on the web and on your phone, including when you add it to your home screen), our website, and our own marketing.

2 If you are a client or lead of a coach: read this first

2.1 Coaches use Coachflow to run their coaching businesses. If you are a client of a coach (you check in, view programmes or join a community through Coachflow) or a lead (you gave your details through a coach's form, lead magnet or booking page), then for that data your coach is the data controller and we are their processor. Your coach decides what is collected and why; we store and process it on their instructions, under our Data Processing Agreement with them. 2.2 That means for questions, access requests, corrections or deletion of your coaching data, contact your coach first. Their privacy notice governs that data. If you contact us instead, we will pass your request to your coach and help them respond. Your use of the platform itself is governed by our Client Terms, which you accept at signup. 2.3 We handle a small amount of data about clients and leads as a controller in our own right, limited to what we need to keep the platform secure and working: your login details, the date of birth check described in Section 13, security logs, abuse detection, app performance measurements, and aggregated, de-identified product analytics - including aggregate statistics we may publish (for example, average results across coaches on the platform), which never identify anyone. The rest of this policy covers that, plus everything about coaches' own accounts, our website visitors and our marketing.

3 The data we collect

3.1 Account data (coaches): name, business name, email, phone, date of birth (to confirm you are 18 or over), password (hashed), profile photo, plan, preferences, and, if you sign in with Google, your Google account's email address and ID. Signing in with Google does not give us access to your calendar or any other Google data; that is a separate, optional connection (see 3.11). 3.2 Billing data (coaches): payment card details are collected and stored by Stripe, not us; we hold billing history, plan, currency and country, and tax status. Where clients pay their coach through Coachflow, those payments are also processed by Stripe, and we never see or store full card numbers. 3.3 Content and usage data: content you create and store on the platform, messages sent through it, features used, actions taken, and technical logs (IP address, device and browser type, timestamps, error reports). We also record how long the app takes to load for you (with your app version, time zone and the screen you opened) so we can keep it fast wherever you are; we delete these measurements after 90 days. 3.4 AI interaction data: prompts, inputs and outputs when you use AI features (see Section 5). 3.5 Support and communications: emails, chat messages and call notes with our team. Sales and demo calls with us may be recorded - we tell you at the time - and used for follow-up, training and improving how we sell and support. 3.6 Marketing data: email engagement (opens/clicks), preferences, and where you came from (referral source, campaign tags). 3.7 Website visitor data: anything you submit through our forms, and the technical data our hosting provider logs to deliver and protect the site (IP address, browser, pages requested). We do not currently use analytics or advertising cookies; see Section 14 and our Cookie Policy. 3.8 Client and lead data processed for coaches: held for your coach as described in Section 2, including names, contact details, date of birth, sex, height, health and fitness information (for example weight and body measurements), progress photos and videos, check-ins, bookings, messages and posts in your coach's community spaces. Listed here for transparency; your coach's notice governs it. 3.9 Coach community content: posts, comments and participation activity (for example points and leaderboard standing) in the Coachflow coach community, which we host and control in our own right. 3.10 Calendar and integration data: where you connect a calendar or another service to Coachflow, we collect the data that service provides, and what's collected is shown when you connect it. Today the only such connection is Google Calendar, described in full in 3.11. 3.11 Google Calendar. If you connect a Google account to Coachflow's calendar features, this is exactly what we access through Google's APIs and what we do with it. (a) What we access. Your Google account's email address and account ID, so you can see which account is connected; the list of calendars in that account, which we read only to find your primary calendar (we keep its name, colour, time zone and your access level, and nothing about your other calendars); and the events on that primary calendar. From those events we store the title, the start and end time, whether the event shows you as busy, its status, and Google's identifiers and link for it. Titles are there so you can see your own events in Coachflow: only you see them unless you choose to share them, and they show as "Busy" while privacy mode is on. We do not store event descriptions, locations, attendees or attachments. (b) What we change. When a client books, reschedules or cancels a session with you, we add, move or remove the matching event on that calendar if you have turned on adding bookings to it, including a Google Meet link if you turned automatic Meet links on. We never change or delete events that Coachflow did not create. If you move or delete one of these booking events in Google yourself, we flag the booking so you can reschedule or cancel it in Coachflow (which tells your client); we never change the booking on our own. (c) How we use it. Only to show your busy times inside Coachflow, to stop clients booking times when you are busy (if you turn that on), and to keep your Coachflow bookings in your Google Calendar. A connected calendar is visible only to you by default. If you choose to share it with your workspace's team, teammates see that time as "Busy", plus event titles only if you also turn that on. If you choose to share it with your clients, each client sees "Coach busy" at those times on their own calendar, never what the events are. You can separately choose what the community calendar shows: nothing (the default), "Busy", or also the names of events you mark Public in Google. An event you mark Private in Google never shows its name to anyone but you. Otherwise clients never see your events: when blocking is on, busy times are simply not offered for booking. (d) What we never do. We do not sell Google user data, use it for advertising, or transfer it to anyone except as needed to provide these features (Supabase stores it for us), to comply with the law, or as part of a sale or restructuring of the business under Section 7.5. We do not send it to our AI providers, and we do not use it to develop, improve or train AI or machine learning models. Our staff do not read it unless you ask us to (for example, for support), it is needed for security, or the law requires it. (e) Storage and deletion. Google data, and the access tokens Google gives us, are stored with Supabase in the UK and encrypted in transit and at rest. When you disconnect a Google account in Account Settings, we delete its tokens, its calendar list and every event time and title we stored for it. Events Coachflow already added to your Google Calendar stay there until you remove them. You can also remove Coachflow's access at any time at myaccount.google.com/permissions. (f) Coachflow's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. 3.12 Your own calendar entries (clients). If you add your own events to your Coachflow calendar, for example an appointment or a birthday, they are yours. For each one you choose what your coach sees: nothing (the default, only you can see it), that you are busy at that time, or the event's name and time. Notes you add are only ever visible to you. Other clients never see your entries, and they never stop anyone booking. They are deleted if you delete them, and with your account.

4 Why we use your data and our legal grounds

We rely on the following lawful bases under UK GDPR Article 6 (and EU GDPR where it applies). For each purpose, the data used and the legal basis: (a) Providing the platform, your account and support. Data: account, content, usage, support. Legal basis: contract (Art 6(1)(b)). (b) Billing and collecting Fees. Data: billing. Legal basis: contract. (c) Tax, accounting and legal records. Data: billing, account. Legal basis: legal obligation (Art 6(1)(c)). (d) Confirming users are 18 or over. Data: date of birth. Legal basis: legitimate interests (keeping a platform built for adults free of children's data). (e) Securing the platform, preventing fraud and abuse. Data: usage, technical logs, security events. Legal basis: legitimate interests (Art 6(1)(f)) and, where applicable, recognised legitimate interests for crime prevention under the Data (Use and Access) Act 2025. (f) Keeping the app fast and reliable, improving the product, and publishing aggregate, de-identified statistics. Data: usage and app performance measurements (aggregated or pseudonymised where possible). Legal basis: legitimate interests. (g) Running AI features you invoke. Data: AI interaction data. Legal basis: contract. (h) Connecting your Google Calendar or another integration you choose. Data: the integration data described in 3.10 and 3.11. Legal basis: contract (you ask us to connect it, and you can disconnect it at any time). (i) Hosting and moderating the coach community, including participation features and leaderboards. Data: community content, account data. Legal basis: contract and legitimate interests. (j) Showcasing coach success stories in our marketing (anonymised, or identifying the coach's business with opt-out). Data: Coach Content, business name and branding, business results as percentages. Legal basis: legitimate interests, with opt-out (Terms, Section 10.11). (k) Sharing client transformations (before/after photos, testimonials) in marketing. Data: client personal data, only where consented. Legal basis: consent of the client, captured and evidenced via the coach (Terms, Section 10.11(c)); withdrawable at any time. (l) Developing and improving AI features, including training. Data: coach content and de-identified or aggregated data only; identifiable client data never without the client's own consent. Legal basis: legitimate interests / contract (Terms, Section 10.3). (m) Sending you marketing (coaches and prospects). Data: marketing data. Legal basis: consent, or legitimate interests and the soft opt-in for existing customers (see Section 6). (n) Responding to legal requests and enforcing our terms. Data: as needed. Legal basis: legal obligation / legitimate interests. 4.1 Where we rely on legitimate interests, we have weighed our interests against your rights, and you can object (Section 11). Details of any balancing assessment are available on request. 4.2 We do not make decisions with legal or similarly significant effects on you based solely on automated processing. 4.3 Health information about clients (for example height, weight, measurements, progress photos and check-in answers) is special category data. We process it only as your coach's processor, and your coach is responsible for having a lawful basis and an Article 9 condition for it, usually your explicit consent.

5 AI features and your data

5.1 When you use AI features, your inputs and the generated outputs are processed by our AI subprocessors, under API contracts restricting their use of it. Features that work with identifiable information, such as check-in suggestions and spotting clients who may need attention (which can include Coach Content and client check-in information such as notes and photos), use Anthropic. Our meal plan features use Google's Gemini models, reached through Lovable's AI gateway; for these we send only what the plan needs, such as daily calorie and protein targets, a list of recipes and ingredients to avoid, and never names or anything else that identifies a person. Providers may retain inputs briefly (typically up to around 30 days) to detect abuse, then delete them. 5.2 Improving our AI. We use coaches' own content, and data that has been de-identified or aggregated so that it identifies nobody, to develop, test and improve our AI features and internal AI processes - including building or improving internal models from de-identified data. Identifiable client and lead personal data is used to provide AI features and for internal quality checks, not to build or train AI models - we would only ever do that with the affected individual's own recorded consent, captured through the platform (Terms, Section 10.3). Anthropic does not train its models on data sent through its commercial API, which is how we use it. 5.3 We retain AI interaction data as part of your content and logs (Section 9) so you can revisit outputs and so we can investigate abuse and errors. 5.4 AI outputs are generated content and can be inaccurate. Coaches are responsible for reviewing outputs before using them (see Terms, Section 13). 5.5 Data from a connected Google Calendar is never sent to AI providers (see 3.11).

6 Marketing

6.1 We send marketing emails about Coachflow to: (a) people who opt in; and (b) existing customers about similar products and services under the "soft opt-in" rules, in each case with an unsubscribe link in every message. 6.2 We do not sell your personal data, and we do not share it with third parties for their own independent marketing. 6.3 Our advertising. We do not currently use advertising cookies or pixels on our website or platform, or share your details with advertising platforms. If we start, we will update this policy and our Cookie Policy first, use cookies and pixels only with your consent, and share at most limited, hashed identifiers with platforms such as Meta or Google, acting on our instructions to measure and target our ads, not for their own marketing to you. You will be able to opt out via the cookie settings or by emailing admin@coachflow.io. 6.4 Unsubscribing from marketing does not stop service emails (billing, security, legal notices) - we have to send those.

7 Who we share data with

7.1 Subprocessors and service providers acting on our instructions: (a) Supabase: database, sign-in, file storage and backend functions. All platform data is stored here, in London, UK. (b) Lovable: hosts and serves our website and web app (through Cloudflare's network), and provides the AI gateway our meal plan features use to reach Google's Gemini models (see 5.1). (c) Stripe: payments, both coaches' subscriptions and payments clients make to coaches. (d) Resend: sending our emails, both service and notification emails (invites, reminders, confirmations) and our marketing emails, delivered through Amazon Web Services in Ireland. (e) Anthropic and Google: AI features, as described in Section 5. (f) Google Workspace: our own email, so messages you send to our team are held there. We will update this list when it changes. 7.2 Your coach or your clients, where the platform's purpose is to share it (messages, check-ins, community posts go to the people they're addressed to). 7.3 Professional advisers (lawyers, accountants, insurers) under confidentiality. 7.4 Authorities, where required by law or to protect people from serious harm. 7.5 A buyer or successor, if we sell or restructure the business - your data remains protected by this policy or one materially like it, and we will notify you of any change of controller. 7.6 Services your browser contacts directly. Some features load content straight from another provider, which then receives your IP address and what you ask it for, under its own privacy policy: Giphy when you search for a GIF; OpenStreetMap and OpenFreeMap when you search for an address or view a map; Google Fonts for some typefaces; and video or form providers (such as YouTube, Vimeo, Loom, Wistia, Typeform, Jotform, Fillout or Paperform) when a coach embeds their content and you open it.

8 International transfers

8.1 We are a UK company and store platform data with Supabase in London, UK. Some subprocessors process data in other countries, including the United States, mainly for AI features, email delivery, payments and website delivery. 8.2 Where personal data leaves the UK (or the EEA, for data subject to EU GDPR), we protect it using: (a) the UK-US Data Bridge, for US providers certified under it; (b) the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses; or (c) EU Standard Contractual Clauses where EU GDPR applies - plus transfer risk assessments where required. 8.3 To find out which safeguard applies to a particular provider, email admin@coachflow.io.

9 How long we keep data

(a) Coach account and content: life of the account + 30-day export window + deletion from live systems within 30 days (Terms, Section 17); shared recipes retained under the Terms, Section 10.10; business contact details move to marketing data (below) after closure. (a2) Files in inactive free accounts: files uploaded to a free Starter account (such as photos, videos and attachments) are removed after 12 months of inactivity, with emailed warnings first (Terms, Section 16.6). (b) Client and lead data we process for coaches: per your coach's instructions; deleted on the same cycle when the coach's account closes. (c) Check-in videos: deleted automatically 180 days after the check-in is submitted. (d) Google Calendar data: until you disconnect the Google account, or your account closes (see 3.11). (e) Billing and tax records: 6 years (legal requirement). (f) Security and technical logs: 12 months. (g) App performance measurements: 90 days. (h) AI interaction data: as coach content, above. (i) Support conversations: 24 months after closure. (j) Marketing data: until you unsubscribe or 24 months of inactivity. (k) Backups: Supabase rolling backup cycle; deleted data expires with the cycle as per Supabase's terms.

10 Security

10.1 We protect personal data with technical and organisational measures including: encryption in transit (TLS) and at rest, database access rules that limit every user to their own workspace's data, least-privilege access for our team, logging and monitoring, and regular backups. 10.2 No system is perfectly secure. If a breach affects your data, we will notify you and the ICO where required by law, without undue delay.

11 Your rights

11.1 You have the right to: access your data; correct it; delete it; restrict or object to processing (including any processing based on legitimate interests, and always for direct marketing); data portability; and to withdraw consent at any time where processing is based on consent. 11.2 To exercise a right, email admin@coachflow.io. We may need to verify your identity. We respond within one month (extendable by two months for complex requests, and we'll tell you if so). 11.3 If your request concerns coaching data controlled by your coach, Section 2 applies - we'll route it to your coach and assist them. 11.4 These rights are not absolute; where an exemption applies (for example legal privilege or others' privacy), we will explain.

12 Complaints

12.1 If you're unhappy with how we've handled your data, complain to us first at admin@coachflow.io. We acknowledge complaints within 30 days and aim to resolve them promptly. (This is also your statutory right under the Data (Use and Access) Act 2025.) 12.2 You can also complain to the ICO (ico.org.uk) or, if you are in the EU, to your local supervisory authority. We'd appreciate the chance to fix it first.

13 Children

13.1 Coachflow is for adults. Coaches must be 18 or over (Terms, Section 3.1), and coaches may not give platform access to, or collect data about, anyone under 18 (Terms, Sections 12.6 and 13.4). We do not knowingly process children's data. 13.2 To check this, we ask everyone who uses the platform for their date of birth. If the date given shows someone is under 18, we do not add it to their profile; we keep a record of the answer and flag the account for review. 13.3 If we learn that data of a person under 18 is on the platform, we will work with the relevant coach to remove it, or remove it ourselves. 13.4 If you believe a child's data is on Coachflow, tell us at admin@coachflow.io.

14 Cookies

14.1 We use cookies and similar technologies such as your browser's local storage. Today we use only what is strictly necessary: keeping you signed in and remembering choices you make, such as dismissing a notice. We do not use analytics or advertising cookies. If we ever add optional ones, we will only use them with your consent via our cookie banner, except where law permits limited low-risk analytics without consent. 14.2 Full details are in our Cookie Policy.

15 Changes to this policy

15.1 We may update this policy. Material changes: at least 30 days' notice by email or in-app before they take effect. Minor changes take effect on posting, with the "last updated" date changed. 15.2 Dated previous versions are available on request.

16 Contact

Coachflow Ltd, 66 Paul Street, London, England, EC2A 4NA Privacy: admin@coachflow.io General: support@coachflow.io

Coachflow LTD · Company no. 17111426

66 Paul Street, London, England, EC2A 4NA

Coachflow® is a registered UK trade mark of Coachflow LTD, and coachflow.io is its only official website.

support@coachflow.io

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