Privacy Policy
Last updated: November 1, 2026
PRIVACY POLICY
Version 1.0 | Effective date: 01/11/2026 | Last updated 01/11/2026
1 INTRODUCTION
This Privacy Policy is provided by Gymlium Limited, a company registered in England and Wales under company number 17337013 with registered office at Wiston House, 1 Wiston Avenue, Worthing, West Sussex, BN14 7QL, England ('we', 'our' or 'us') for use of our products and services including our Gymlium is a software platform that enables personal trainers and fitness businesses to launch, operate and grow their own branded fitness businesses. The Services may include a branded website, branded client application, client management, booking, workout and nutrition functionality, communications, AI-assisted tools and other business management functionality. The Services are used both by personal trainers and fitness businesses ("Trainers") and by their clients ("Clients").
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
Data protection responsibilities vary depending on how the Services are used.
Where a Trainer uses the Services to collect, manage and process information relating to their Clients, the Trainer will generally act as the data controller and Gymlium will act as a data processor on the Trainer's behalf.
Gymlium acts as a controller in relation to personal data processed for its own purposes, including:
· creating and managing Trainer accounts;
· platform administration and security;
· technical support;
· product development and analytics; and
· compliance with legal and regulatory obligations.
Where we act as a processor, we process personal data in accordance with the instructions of the relevant Trainer and our contractual obligations.
2 WHAT THIS POLICY APPLIES TO
This privacy policy relates to your use of the Services only.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
3 PERSONAL DATA WE COLLECT ABOUT YOU
The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:
Category of data | In more detail |
Identity and account data you input into the Services (Registration is mandatory in order to use the Services) | Where applicable: · Personal identification and contact data, including name, email address, telephone number, date of birth/age, gender (where provided), address and profile information. · Fitness, health and wellbeing data, including height, weight, body measurements, fitness goals, activity and exercise information, workout history, progress information, injuries, physical limitations, health conditions, dietary requirements, nutrition information, progress photographs and other health or fitness information entered by the Personal Trainer or their client. · Client management and service data, including appointments, bookings, check-ins, notes, communications/messages, programme information, workout plans, nutrition plans, goals, progress records and client/trainer interactions. · Account and technical data, including account identifiers, login/account information, device information, IP addresses, usage information and other technical information generated through use of the Platform. · Transaction and payment-related data, where applicable, including transaction records, payment status and subscription/purchase information. Payment card details may be processed directly by third-party payment providers such as Stripe rather than stored by Gymlium. · User-generated content, including photographs, videos, documents, files and other information uploaded to or created within the Platform. · Content and Media, Website content, branding, logos, photographs, progress photographs, videos, documents, files and other content uploaded to or created through the Services. |
Data collected when you use specific functions in the Services | Information generated through your use of specific Gymlium functionality, including website content and settings, branding and preferences, workout and nutrition plans, bookings and appointments, communications, AI-generated or AI-assisted content, website configuration and theme selections, and Platform activity and preferences. |
Data collected when you permit the collection of location data | Details of your general location, see the section 'Location services/data' below. Data concerning location is collected when using the maps function of the Services. |
Other data the Services collects automatically when you use it | Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use. |
Data collected when you make an enquiry with us | Enquiry Data: Your name, email address, telephone number (where provided), the contents of your enquiry and any other information you voluntarily provide when contacting us. Log Data: Internet Protocol (IP) address, system and approximate geographic location. Device Characteristics: Browser type (e.g., Chrome, Safari), operating system (e.g., Windows, iOS), device type (e.g., mobile, desktop), and screen resolution. Usage & Marketing Data · Referral Source: We track the referrer URL (the website or search engine you visited before ours) and any UTM marketing parameters associated with the link you clicked. · Browsing Behaviour: We record your landing page, active session identifiers, and the specific pages you viewed on our site prior to submitting the form. |
If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services and/or the Services to you.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
4 SENSITIVE DATA
Due to the nature of the Services, we may process sensitive data category personal data relating to health, fitness and wellbeing. Depending on how the Services are used, this may include:
· height and weight;
· body measurements;
· fitness goals;
· workout and activity information;
· progress records;
· injuries and physical limitations;
· health conditions disclosed by users;
· dietary requirements;
· nutrition information; and
· progress photographs.
Where Trainers collect and input this information about their Clients through the Services, the Trainer is generally the controller of that information and is responsible for identifying an appropriate lawful basis and, where required, an Article 9 UK GDPR condition for processing such special category personal data.
Gymlium processes such information on behalf of the Trainer in accordance with the Services agreement and applicable data protection legislation.
Where Gymlium processes special category data as a controller for its own purposes, we will do so only where an appropriate lawful basis and Article 9 condition under UK GDPR applies.
5 LOCATION SERVICES/DATA
The Services may request your consent to use location services to generally identify your location each session. We may require access to that data in order to Establish the location where your services are performed.
If you do not provide your consent, you may use the Services but that will mean the “maps” feature on the Services will not be available. To withdraw your consent at any time you can turn off the localisation permissions for our app on your device.
The location services in the Services will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by turning your device’s location on “off” using the device’s settings app. When you allow your device to use location services/data, data will also be collected by Google in accordance with their Privacy Policy, as this is the map service we integrate to our app.
We exert no control over Google’s Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data please visit their site - https://policies.google.com/privacy?hl=en-US. For more information see the section ‘Who we share your personal data with’ below.
6 HOW YOUR PERSONAL DATA IS COLLECTED
We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.
We may also receive personal data about Clients from their Trainer. For example, a Trainer may create or manage a Client account, upload information about a Client, record fitness or health information, create workout or nutrition plans, maintain progress records or otherwise enter information about a Client into the Services.
In such circumstances, the Trainer is generally responsible for the information they collect and provide to the Services and acts as the controller of that personal data.
We may also collect location data where you enable location services.
We may also collect personal information about you using cookies or similar technologies. Please refer to our Cookies Policy for details about the cookies and similar technologies we use and how you can control them.
7 HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
(i) where you have given consent
(ii) to comply with our legal and regulatory obligations
(iii) for the performance of a contract with you or to take steps at your request before entering into a contract, or
(iv) for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
What we use your personal data for | Our reasons |
Create and manage your account with us | To perform our contract with you or to take steps at your request before entering into a contract |
Providing services and/or the functionalities of the Services to you | Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions which apply to the Services) the maps function will use data relating to your location only based on your consent as described in 'Location services/data' (above) |
To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others |
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices | Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you |
Protect the security of systems and data | To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you |
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app |
Updating and enhancing user records | Depending on the circumstances: · to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) · to comply with our legal and regulatory obligations · where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services |
To comply with our legal and regulatory obligations | Depending on the circumstances: · to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) · to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services |
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets |
Enabling Trainers to provide fitness, coaching and related services to their Clients through the Platform, including creating and managing workouts, programmes, nutrition information, goals and progress. | Depending on the circumstances: · to provide and operate the Platform and Services. · to enable Trainers and their Clients to use the Platform's features and manage fitness and coaching services efficiently. · where health-related information is processed, processing is carried out in accordance with an applicable Article 9 UK GDPR condition, such as the individual's explicit consent or another condition identified by the Trainer. |
Providing AI-assisted functionality, including generating or assisting with website content, workouts, nutrition-related content and other functionality available through the Services. | · to provide and improve AI-assisted features requested by Trainers and their Clients, enhance the functionality of the Services, and assist with the creation of personalised fitness and nutrition content. · where the AI functionality forms part of the Services we have agreed to provide. · Where information relating to health, fitness, body measurements, dietary preferences, injuries, activity levels or similar information is processed by AI tools, such information may constitute special category personal data under UK GDPR. Such processing is carried out only where necessary to provide the requested functionality and in accordance with an applicable lawful basis and Article 9 condition under UK GDPR. |
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
8 MARKETING
The Services may enable Trainers to send marketing and promotional communications to their Clients, including information about services, programmes, offers, events and related fitness or coaching activities.
Where a Trainer uses the Services for marketing purposes, the Trainer is responsible for ensuring that such communications comply with applicable data protection and electronic marketing laws, including obtaining any required consents and providing any required opt-out mechanisms.
Gymlium provides the technology used to facilitate such communications but does not determine the content of a Trainer's marketing communications or the lawful basis on which they are sent.
We will always treat personal data with care and will not sell your personal data to third parties for their own marketing purposes.
For more information about your right to object to the use of your personal data for marketing purposes, please see "Your Rights" below.
9 WHO WE SHARE YOUR PERSONAL DATA WITH
We may share personal data with trusted third-party service providers who help us operate, maintain and improve the Services.
Depending on the functionality used, these providers may include:
§ cloud hosting and infrastructure providers;
§ content delivery and security providers;
§ payment processors;
§ transactional email and messaging providers;
§ customer support systems;
§ analytics providers;
§ AI service providers;
§ mapping and location service providers;
§ authentication and social login providers; and
§ communications and notification providers.
Examples may include providers such as DigitalOcean, Vercel, Cloudflare, Stripe, Google, Resend and similar technology providers used to deliver the Services from time to time.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
§ external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
§ professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
§ law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
§ other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
10 HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and in accordance with applicable legal obligations.
Retention periods may vary depending on the nature of the information.
Typically:
§ financial, accounting and tax records may be retained for up to six years after the end of the relevant relationship or longer where required by law;
§ account, platform and client-content data will generally be retained in accordance with the applicable account retention settings and contractual arrangements;
§ following termination of a subscription, content and personal data may be retained for a limited period to facilitate retrieval before deletion;
§ backup copies will be retained in accordance with our backup retention schedules and then securely overwritten or deleted.
Where a valid request for erasure is received, we will delete personal data unless we are legally entitled or required to retain it.
Following the expiry of applicable retention periods, personal data will be securely deleted or anonymised.
11 DE-IDENTIFIED INFORMATION
The personal data we collect may have analytical, educational, or commercial value to us. Where we have de-identified the information we have collected, we reserve the right to process and distribute such information.
12 TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK
As part of providing the Services, we may share your personal data with third parties based outside of the UK.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:
§ The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
§ Any country located outside the UK/EEA: we would rely on appropriate safeguards under the UK GDPR, such as by relying on an Adequacy Decision being in place for that country, or entering into an International Data Transfer Agreement.
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
13 YOUR RIGHTS
You generally have the following rights, which you can usually exercise free of charge.
For more information regarding these rights, please visit the ICO website here.
Access to a copy of your personal data | The right to be provided with a copy of your personal data. |
Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data. |
Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations. |
Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data. |
Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations. |
To object to use | The right to object: · at any time to your personal data being used for direct marketing (including profiling) · in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests. |
Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by the Services. |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please complete a request form available on our website www.gymlium.com/en/contact. When contacting us please:
§ provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
§ let us know which right(s) you want to exercise and the information to which your request relates
Please note that where your personal data is processed by a Trainer through the Services, the Trainer may be the data controller responsible for determining how and why that personal data is processed. In those circumstances, requests relating to your personal data may need to be directed to the relevant Trainer in the first instance.
14 KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
15 HOW TO COMPLAIN
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
16 CHANGES TO THIS PRIVACY POLICY
We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.
17 PREVAILING LANGUAGE
This policy, the services and any material provided by us may be translated into one or more languages for convenience. In the event of any conflict, inconsistency, ambiguity, or discrepancy between the English version and any translated version, the English version shall prevail and be controlling for all purposes.
18 HOW TO CONTACT US
For further information about our privacy policy or practices, or to access or correct your personal data, or make a complaint, please contact us using our contact form: www.gymlium.com/en/contact