Privacy Policy

Last updated: 10/10/26

The Coaching Core ("we", "us", or "our") respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, and protect your information when you visit our website, contact us, or use our services.

The Coaching Core is a trading name of Sam Clarke, an independent sole trader operating in the United Kingdom.

1. Who we are

The Coaching Core provides done-for-you CRM and business systems for fitness coaches and personal trainers, along with an education membership and courses.

We operate as a sole-trader business under UK law and process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR). For the purpose of the UK GDPR, the data controller is Sam Clarke trading as The Coaching Core.

We are registered with the Information Commissioner's Office (ICO) under registration number ZC092406.

If you have any questions or requests regarding this policy or your data, please contact us at: [email protected].

Our address is: The Coaching Core, 66 Paul Street, London, EC2A 4NA.

This policy applies to The Coaching Core only.

2. What information we collect

We may collect and process the following categories of personal information:

a. Information You Provide

  • Name, contact details (email, phone number, social media handles), and communication preferences.

  • Business details, such as your business name, website, services, and goals.

  • Answers you give in enquiry forms, onboarding questionnaires, surveys, and feedback forms.

  • Payment and billing details (processed securely via Stripe).

  • For affiliates: bank details used to pay commission and referral records.

  • Emails, WhatsApp messages, and support requests sent to us.

  • Testimonials, photos, videos, or results you agree to share with us.

b. Information Collected During Calls

  • Consultations and check-in calls take place on Google Meet.

  • Google Meet may use Gemini to generate notes of consultations and check-in calls. We use these notes to maintain an accurate record of advice, actions and agreed next steps, and make them available in your Notion client dashboard.

c. Information Collected Automatically

  • Technical information such as IP address, browser type, device, operating system, and pages visited.

  • Cookies and similar technologies that help operate the website and, with your consent, measure how the website is used (Google Analytics) and how our advertising performs (Meta Pixel and Conversions API) (see Section 12 and our Cookie Policy).

  • Information about how you use The Coaching Core system, membership, or courses (for functionality, support, and improvement).

d. Advertising and Analytics Platforms

  • If you consent to advertising cookies, the Meta Pixel may send Meta information about your visit to our website and actions you take, such as submitting an enquiry or booking a consultation. This can include your IP address, browser details and, if you enter them in a form, details such as your email address or name, which are hashed (scrambled) before they are sent.

  • If you consent, we may also send Meta a record of these actions directly from our systems using Meta's Conversions API. This can include the type of action, its value, an ad click identifier if you arrived from a Meta ad, and details that help Meta match the action to your account, which may include a hashed email address or phone number.

  • We may receive information from Meta about whether you arrived from one of our ads.

  • If you consent to analytics cookies, Google Analytics collects information about how you use our website, such as the pages you view and how you found us.

e. Health Information

  • We do not intend to collect health information about you. Where information you voluntarily provide constitutes special-category personal data, we will only process it where an appropriate Article 9 condition applies, such as your explicit consent where appropriate, or where processing is necessary for the establishment, exercise or defence of legal claims.

3. How we use your information

We use your data to:

  • Respond to enquiries and run consultations.

  • Provide, set up, operate, and support your system, membership, or courses, including onboarding and check-in calls.

  • Manage billing, payments, and account access.

  • Run our affiliate programme, including tracking referrals and paying commission.

  • Communicate with you, including customer support and service updates.

  • Send marketing emails (only with consent).

  • Measure and improve our website, advertising, and services.

  • Publish testimonials (only with your specific consent).

  • Keep our systems and your data secure.

  • Comply with legal obligations and establish, exercise, or defend legal claims.

4. Legal basis for processing

We process your data under the following lawful bases:

  • Performance of a contract - to deliver services you have purchased or signed up for, run the affiliate programme, and take steps you request before entering a contract (such as a consultation).

  • Legitimate interests - to respond to enquiries, keep accurate call notes, improve our services, prevent fraud, keep our systems secure, and defend legal claims.

  • Consent - for marketing emails, testimonials, and non-essential cookies and similar technologies, including Google Analytics and Meta advertising (the Meta Pixel and Conversions API).

  • Legal obligations - where processing is required by law, such as keeping financial records for HMRC.

Where we rely on legitimate interests, we have balanced our interests against your rights, and you can object at any time. Where we rely on consent, you can withdraw it at any time.

We do not make decisions about you based solely on automated processing.

5. Marketing and testimonials

a. Marketing Emails

We only send marketing emails if you have opted in. On our forms, the marketing consent box is unticked by default and optional, so you can still enquire or sign up without joining our email list.

Every marketing email includes an unsubscribe link, or you can email us to opt out. We will keep a record of your opt-out so we do not contact you again. We will still send service-related messages about your account, payments, or services.

b. Testimonials

We only publish your feedback, results, name, photo, or video with your specific consent, which we request in advance and with a clear explanation that it will be shared publicly.

You can withdraw consent at any time. We will stop using it in new content and remove it from channels we control within 30 days. We cannot recall content already shared or reposted by others.

6. Payment information

All payments are securely processed via Stripe through the HighLevel platform.

The Coaching Core does not store or directly access your full payment card details.

Stripe's privacy policy is available at: https://stripe.com/privacy

Affiliate commission is paid by bank transfer. We store the bank details you provide for this purpose only.

7. Data sharing and third parties

We share your data with the following providers and organisations:

  • HighLevel - for website hosting, CRM, forms, booking calendars, email marketing, automation, client systems, and the membership platform.

  • Stripe - for payment processing and subscriptions.

  • Google (Workspace, Gmail, Meet, and Gemini) - for business email, video calls, and call notes.

  • Google Analytics - for measuring how visitors use our website, only where you have consented to analytics cookies.

  • Notion - for shared client dashboards and project records.

  • WhatsApp (Meta) - for 1-1 messaging with clients.

  • Meta (Facebook and Instagram) - for advertising and measuring ad performance through Meta Pixel and Conversions API, only where you have consented to advertising cookies. Meta also uses this data for its own purposes; see https://www.facebook.com/privacy/policy/

  • Professional advisers - such as accountants, lawyers, and insurers, where necessary.

  • Legal or regulatory authorities - such as HMRC, courts, or law enforcement, if required by law.

Where a provider acts as our data processor, it processes personal data on our instructions and is contractually required to protect that information. Some providers may also act as independent controllers for certain processing, in which case their own privacy notices explain how they use personal data. We assess the providers we use and take reasonable steps to ensure appropriate data-protection arrangements are in place.

We do not sell or rent your personal information to any third party.

8. Coaches' client data

If you are a coach using a system we build or support, the data you hold about your own clients in your HighLevel sub-account (including forms, questionnaires, and check-ins) belongs to you.

For that data, you are the data controller. You are responsible for informing your clients how their data is used and for identifying an appropriate lawful basis under Article 6 UK GDPR and, where you process special-category data such as health information, an appropriate condition under Article 9 UK GDPR.

We act as your data processor. We only access that data to build, maintain, and support your system, on your instructions and under our Data Processing Agreement - [link]. We do not use your client's data for our own purposes or marketing.

If you are a client of one of our coaches and want to exercise your data rights, please contact your coach directly. If you contact us, we will pass your request on to them.

9. International Transfers

Some of our service providers (including HighLevel, Google, Stripe, Notion, and Meta) may store or process data outside the UK, mainly in the United States. Where this involves a restricted transfer occurs, we use an appropriate transfer mechanism where required by UK data protection law. Depending on the recipient and destination, this may include UK adequacy regulations, the UK extension to the EU-US Data Privacy Framework for eligible certified US organisations, the International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses.

10. Data retention

We keep your personal data only for as long as necessary to fulfil the purposes outlined in this policy, comply with legal obligations, and resolve disputes. Specifically:

  • Enquiries and leads who do not become clients - 2 years from last contact.

  • Marketing list - until you unsubscribe. We keep a minimal opt-out record so we do not contact you again.

  • Client contracts, billing, and financial records, and bank details - 6 years from the end of your contract.

  • Affiliate agreements, commission records, and bank details - 6 years from the last commission payment.

  • Call notes and Notion client dashboards - 6 months after you stop being a client.

  • Other client records (such as form responses and support messages) - 2 years after you stop being a client.

  • Coach sub-account data - at the end of the subscription, the coach may request the return, export or deletion of personal data processed on their behalf. Where no instruction is provided, the sub-account may remain securely deactivated for up to 12 months solely to allow recovery, transfer or reactivation, after which it will be deleted. Data retained in this state will not be actively processed except where required for security, recovery, legal compliance or on the coach's documented instructions.

  • Testimonials - while in use, or until you withdraw consent.

  • Cookie and tracking data - as set out in our Cookie Policy.

We may keep data for longer where required by law or for an actual or potential legal claim. When your data is no longer required, it will be securely deleted or anonymised.

11. Your rights

Under the UK GDPR, you have the right to:

  • Access a copy of your data.

  • Correct or update inaccurate information.

  • Request deletion of your data ("right to be forgotten").

  • Restrict or object to processing, including objecting to direct marketing at any time.

  • Withdraw consent (where applicable).

  • Request data portability.

To exercise any of these rights, email us at [email protected]. We may need to confirm your identity. We will respond within one month, which may be extended by up to two further months for complex requests. There is usually no fee.

Some rights have exceptions. For example, we must keep financial records for tax purposes. We will explain if an exception applies.

If you are unhappy with how we have handled your personal data, please contact us and we will investigate your concerns and respond as soon as reasonably practicable. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection issues (www.ico.org.uk, 0303 123 1113). We would, however, appreciate the chance to deal with your concerns first.

12. Cookies

Our website uses cookies. Cookies are small text files placed on your device.

Essential Cookies:

We use essential cookies that are necessary for the website, forms, booking calendars and checkout to function and remember cookie choices. These do not require your consent.

Analytics cookies:

We use Google Analytics to understand how visitors use our website, such as which pages are viewed and how people find us. These cookies are only set if you consent.

Advertising cookies and technologies:

We use the Meta Pixel and Meta's Conversion API to measure how our ads perform and show them to relevant people. The Pixel tells Meta when someone who saw or clicked our ads visits our website or takes an action, such as submitting an enquiry or booking a consultation. The Conversion API sends similar event information directly from our systems to Meta. These technologies will only be used if you actively consent.

You can manage your cookie preferences at any time via the cookie consent tool on our website. You can also manage or disable cookies through your browser settings, though this may affect the functionality of our services. Full details are in our [Cookie Policy].

13. Data security

We use appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse, including access controls and two-factor authentication on our business accounts. While we take all reasonable steps to secure your data, no system is entirely foolproof. If a data breach is likely to put your rights at risk, we will notify you and the ICO where required by law.

14. Children

Our website and services are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe we have, please contact us and we will delete it.

15. Links to other websites

Our website may include links to third-party websites (e.g. social media, partner coaches, or resources we recommend).

We are not responsible for the content or privacy practices of these external sites and encourage you to review their privacy policies.

16. Changes to this policy

We may update this Privacy Policy from time to time to reflect operational, legal, or regulatory changes.

The most recent version will always be available at https://thecoachingcore.com/privacy-policy with the latest update shown above. If we make significant changes, we will let clients, members, and affiliates know by email.

17. Contact us

If you have questions, concerns, or wish to exercise your data rights, please contact:

Email: [email protected]
Address: The Coaching Core, 66 Paul Street, London, EC2A 4NA