Privacy Policy
Last updated: 8 August 2026
Data controller: Peter Gawtry, trading as Pete Gawtry Fitness (sole trader)
Address: Suite 1, Arena Business Park, Tarn Lane, Leeds, LS17 9BF
Contact: pete@pg-fitness.co.uk
ICO registration: ZC177088
1. What this policy covers
This policy applies to:
- The website pg-fitness.co.uk and its subdomains (including online.pg-fitness.co.uk and app.pg-fitness.co.uk)
- The Pete Gawtry Fitness App (our own coaching app)
- Any in-person services Pete provides at his studio in Leeds
- Newsletter, social-media interactions, and direct email/messaging
It does not apply to third-party sites we link to.
2. The data we collect
When you browse the site
- We set only strictly-necessary cookies (for security and to make the site work). We use no analytics cookies, no advertising cookies and no tracking pixels.
- Some pages on this site run a cookieless page counter. It records the day, which page was viewed, and one of six coarse arrival buckets — direct, internal, search, social, AI or other — worked out inside your browser, so the referring web address never leaves your device. On the multi-step forms it also counts which step people reach — never what anyone types. No cookie, no stored identifier, nothing added to any URL. Your IP address is used only as an in-memory rate-limit key for 120 seconds; it is never written to disk or to our database.
- Some pages embed a Google map or a YouTube video. When that content loads, your browser contacts Google, which receives your IP address and may set its own cookies. See our Cookie Policy.
- If we add analytics in future, it will run only with your consent, via a cookie banner using Consent Mode v2.
When you use Molly, the live chat on our website
- Whatever you type into the chat box, and the replies Molly gives you. Please don't put medical details, card numbers or anything else sensitive into a chat — if it's about an injury, a medication or a health condition, raise it with Pete at your free consultation instead.
- Which page you were on, a random session id for that conversation, and a one-way hashed version of your IP address used only to stop abuse (we cannot turn it back into your IP address).
- Your first name and a phone number or email only if you choose to give them so Pete can come back to you. When you do, that enquiry is emailed to Pete.
- To produce each reply, the conversation is sent to the Anthropic Claude API — see section 4. Transcripts are stored on our own UK server, outside the public web root, so Pete can follow up your enquiry.
When you sign up for Online PT
- Identity: name, email, phone (optional).
- Service data: goal, training history, equipment access, weigh-in day preference, dietary preferences.
- Special category — health data (Article 9 UK GDPR): height, weight, body measurements; injuries, medical conditions and medications relevant to exercise; progress photos (only if you opt in — separate consent); and your PAR-Q (Physical Activity Readiness Questionnaire) responses.
- Payment data: card details are processed by Stripe and never stored on our servers. We retain only the last 4 digits and the Stripe subscription/customer ID.
- Behavioural data inside the app: workout and nutrition logs, session bookings and session credits, check-in responses, messages to Pete.
- Leaderboard preference (optional): whether you want to appear on the client leaderboard and how your name shows — initials by default, your full name only if you choose it. Leave it off and you stay completely private.
When you subscribe inside the app
The Pete Gawtry Fitness iPhone app sells auto-renewable subscriptions as Apple in-app purchases. Apple takes the payment and is the seller for those purchases, so your card details never reach us. From Apple we receive a transaction identifier, which subscription you bought and its status (active, expired, in billing retry, in grace period, or revoked), and we store those against your account so the app knows what you have access to. You manage or cancel the subscription in your App Store settings — see our Refund Policy.
When you scan a barcode or search for a food in the app
The barcode number, or the words you type into food search, are sent to Open Food Facts — an open, non-profit food database — to look the product up. Nothing that identifies you goes with it: no name, no account id, no login. What you then log lands only in your own food diary on our server. If you add a missing product from its label, that product record is saved to our own food table so other clients can find it; it carries the food, not you.
When you book in-person sessions: studio attendance records and session notes.
When you join the newsletter: email address, name, opt-in status, and basic engagement (opens, clicks).
Connected fitness trackers (optional)
If you choose to connect Fitbit via Google Health, we request read-only access to your daily step count and nothing else. We store one figure per day against your account, plus the secure access token that lets the nightly sync run. This data is used solely to show your activity in your own app and to your coach — it is never sold, never shared with third parties, and never used for advertising or to train any AI model. You can disconnect at any time in the app, which deletes the stored connection and revokes our access at Google. Step figures are covered by the same retention terms as other health data — see section 6. Our use of information received from Google APIs follows the Google API Services User Data Policy, including the Limited Use requirements.
3. Why we collect it (legal basis)
| Data | Legal basis (UK GDPR) |
|---|---|
| Browsing analytics | Consent (you can refuse cookies) — Art. 6(1)(a) |
| Account + service data | Contract — Art. 6(1)(b) |
| Health data | Explicit consent — Art. 9(2)(a) — collected via a separate checkbox at sign-up |
| Progress photos | Explicit consent — Art. 9(2)(a) — separate optional checkbox |
| Payment data | Contract + legal obligation — Art. 6(1)(b) & (c) |
| App subscription records (from Apple) | Contract — Art. 6(1)(b) |
| Live-chat messages (Molly) | Legitimate interest — Art. 6(1)(f) — answering the enquiry you started; consent for any contact details you choose to give |
| Newsletter | Consent — Art. 6(1)(a) — separate opt-in |
| Leaderboard display | Consent — Art. 6(1)(a) — optional checkbox; opt out at any time |
| Anonymised aggregate stats (e.g. corporate HR reports) | Legitimate interest — Art. 6(1)(f) |
You can withdraw any consent at any time by emailing pete@pg-fitness.co.uk. Withdrawing health-data consent means we can't continue providing the online PT service.
4. Who we share it with (processors)
We use the following processors. Where we hold a commercial account, the provider's Data Processing Agreement (DPA) or equivalent data-protection terms apply. Open Food Facts is the exception: it is a free, open public database we query, not a contracted processor, and we send it nothing that identifies you.
| Processor | Purpose | UK/EEA? |
|---|---|---|
| Krystal Hosting Ltd | Website, coaching-app and email hosting (UK data centre — our newsletter, online-PT transactional and nurture emails are all sent from our own UK server, not a third-party email platform) | UK |
| Stripe Payments UK Ltd | Card processing for payments taken through our website — the £80 personalised meal plan and Online PT subscription payment links. Card details never touch our servers. | UK & EEA |
| Apple Distribution International Ltd | App Store distribution of the iPhone app, and billing for the in-app subscriptions sold inside it (Online Coaching £99.99/month; Coaching + Meal Plan £119.99/month). Apple is the seller and takes the payment; we receive a transaction id and your subscription status only. Apple also handles your Apple Account details for that purchase under its own privacy policy. | Ireland (EU), with Apple Inc. in the US |
| Google Ireland Ltd / Google LLC | Three separate things. Google Play distributes our Android app and receives download and crash data under its own terms. The Google map embedded on our website loads from Google, which receives your IP address. And only if you connect it yourself, Fitbit via Google Health returns your daily step count, read-only — see section 2. | Ireland (EU) & US — UK-DPF + SCCs |
| Anthropic PBC | Powers Molly, the live chat on our website. The free text you type and Molly's replies are sent to Anthropic's Claude API to generate each answer. Anthropic acts as our processor and, under its commercial API terms, does not use this content to train its models. Please don't type medical or other sensitive information into the chat. | US — SCCs |
| The Rocket Science Group LLC (Mailchimp) | Our former newsletter platform. Since August 2026 it no longer receives new sign-ups — the newsletter now runs on our own UK server. It still holds historical subscriber records until we close the account, which is why it is still listed here. | US — UK-DPF + SCCs |
| TONVI TECH SL (Upload-Post) | Publishes our social-media posts to Instagram, Facebook and our other channels. It handles the images, video and captions we publish — which include a client's photo, first name or review only where that client has agreed to appear in our marketing. It holds no client account, health or training data. | Spain (EU), hosted in Germany (EU) |
| Open Food Facts (French non-profit association) | Barcode and food-name lookups from the app's food scanner. Receives the barcode number or the search words only — never anything that identifies you. | France (EU) |
That table is the complete list. On 8 August 2026 we re-checked every integration against the live code and removed two social-media tools that earlier versions of this policy had named as processors. Neither was in use and neither had ever held client data.
We don't sell your data. We don't share it with advertisers. We don't share it with insurers. The coaching app is built and run by us, so your app data — profile, session bookings and credits, weigh-ins and measurements, progress photos, workout and nutrition data, messages — stays on our own UK-hosted server and is not shared with any third-party coaching platform. Online PT welcome/nurture emails are sent directly from our own UK-hosted server, so your name and email for that service are not transferred to a third-party email platform.
5. International transfers
Most of our processing stays in the UK or the EU. Data leaves the UK in two places: the Anthropic Claude API that writes Molly's chat replies (US); and Apple and Google for app distribution, in-app purchases and the embedded map (Ireland and the US). Newsletter sign-ups are no longer sent to the US at all — they are handled entirely on our UK server. Historical newsletter records do still sit with our former newsletter platform in the US until we close that account. For each of these we rely on the UK-US Data Privacy Framework where the recipient is certified, or on Standard Contractual Clauses (SCCs), with appropriate technical and organisational measures. A list of transfer mechanisms used per processor is available on request.
6. How long we keep it (retention)
| Data | Retention |
|---|---|
| Browsing analytics | 14 months |
| Account data (after cancellation) | 7 years (tax records, HMRC obligation) |
| PAR-Q answers, injuries & medical conditions (after cancellation) | 7 years — kept as a safety/medical record so we can respond to any later personal-injury claim |
| Other health data — weight, body measurements, training history (after cancellation) | 12 months in active form, then anonymised aggregates only |
| Progress photos (after cancellation) | Deleted within 30 days of cancellation, unless you ask us to keep them |
| Payment records | 7 years (HMRC) |
| Newsletter subscription | Until you unsubscribe + 30 days |
| App subscription records (transaction id, product, status) | 7 years (HMRC), alongside the payment records above |
| Live-chat transcripts (Molly) | Kept on our UK server while we follow up your enquiry, and deleted on request — just email us |
| Corporate aggregated reports | 3 years after the contract ends |
7. Your rights
Under UK GDPR you have the right to: access the data we hold on you; have it corrected; have it erased (where retention obligations allow); restrict processing; receive your data in a portable format; object to direct marketing and legitimate-interest processing; and withdraw consent at any time. All training and meal plans are built by Pete personally — no fully-automated decisions are made about you. Molly, the chat on our website, is an AI assistant: she answers questions and passes enquiries to Pete, and makes no decision about you.
Submit any request to pete@pg-fitness.co.uk. We respond within one month, free of charge for the first request. You can also complain to the ICO at ico.org.uk/make-a-complaint or on 0303 123 1113.
8. Security
- All sites are HTTPS only (TLS 1.3).
- Stripe is PCI-DSS Level 1 — card data never touches our servers.
- The app runs on our own UK server (Krystal, London) — the same encrypted infrastructure as the website; it is not built on any third-party app platform.
- Health data submitted via our online questionnaire is encrypted at rest (AES-256-GCM) on our UK server; database backups are useless without the separate encryption key.
- Server hosting is in the UK (Krystal, London datacentre).
- Access to client data is limited to Pete and any nominated assistants under NDA.
- We log access and will notify you within 72 hours of any breach affecting your data.
9. Children
We do not knowingly collect data from anyone under 18. If a parent or guardian wants to enrol a 16–17-year-old, please contact us directly.
10. Cookies
Categories:
- Strictly necessary (session, security) — always on. These are the only cookies we currently set.
- Analytics (e.g. Google Analytics 4) — not currently used; if added, only with your consent. Our own page counter sets no cookie and stores no identifier (see section 2).
- Marketing (ad pixels) — not currently used; if added, only with your consent.
- Third-party embedded content — the Google map, and the YouTube videos on a few blog pages, are loaded from Google, which may set its own cookies when that content loads.
See our Cookie Policy for full detail. If we introduce non-essential cookies, you'll be able to manage them via a cookie banner.
11. Corporate clients
If you're an employee accessing Pete Gawtry Fitness via your employer's Corporate package:
- Your individual training, check-ins and messages with Pete are never shared with your employer.
- Your employer receives anonymised aggregate stats only (e.g. % participation, average engagement).
- Your employer is the data controller for sharing your name/email with us in the first place; we become the controller for your individual fitness data from the moment you log in.
- A DPA between us and your employer governs this relationship. Your employer can provide a copy.
12. Changes to this policy
We'll update this page when the law or our processing changes. The "Last updated" date at the top tells you when. We'll email registered clients about any material change.
13. Deleting your account and your data
If you use the Pete Gawtry Fitness app, you can delete your account yourself from inside the app: open Account & settings and choose Delete account. That permanently removes your login, training history, workout and food logs, weigh-ins, habit records, session history and progress photos from our systems straight away.
Prefer to ask us instead? Email molly@pg-fitness.co.uk from the email address on your account and we'll delete it for you and confirm once it's done.
14. Questions
Email pete@pg-fitness.co.uk for anything privacy-related.