1. Who we are
Gym Primer is a coaching software product operated by Trueblood Labs LTD for personal trainers and their clients. This Privacy Policy explains how we collect, use, store, share, and protect personal data when you use our website, dashboards, mobile-friendly app surfaces, billing features, and support channels.
Throughout this policy, 'Gym Primer', 'we', 'our', and 'us' refer to Trueblood Labs LTD as the operator of Gym Primer. 'Coach' refers to the trainer or fitness business using Gym Primer to manage clients. 'Client' refers to a person invited into a coach's workspace.
2. When Gym Primer is a controller and when we act for a coach
For account creation, platform administration, authentication, security, support, website analytics, and Gym Primer billing, we generally act as the controller of the personal data we process.
For coaching records that a coach creates or manages inside Gym Primer, such as workout programs, training logs, habits, nutrition targets, intake forms, check-ins, notes, and client progress history, Gym Primer generally acts as a processor or service provider on the coach's behalf. In those situations, the coach remains responsible for deciding why the data is collected, what is entered into the platform, and what lawful basis or consent is relied on for that coaching relationship.
3. The data we collect
The information we collect depends on how you use Gym Primer and whether you use the platform as a coach, client, admin, or website visitor.
4. Health-related and special category data
Some information used in a coaching product can reveal details about health, injury status, physical condition, wellbeing, nutrition, or similar matters. In UK data protection law, some of that information may be special category data.
Where coaches collect or upload this type of information, they are responsible for ensuring they have an appropriate lawful basis and any additional condition required for handling special category data. Gym Primer provides the software infrastructure, but coaches are responsible for deciding what information they collect from clients and whether explicit consent or another valid condition is required.
5. How we use personal data
6. Lawful bases
Depending on the context, we rely on one or more lawful bases such as performance of a contract, legitimate interests, legal obligation, and consent where appropriate.
If special category data is involved, an Article 6 lawful basis on its own is not enough. An additional condition is also required for that category of data.
7. Who we share data with
8. International transfers
Some of our service providers may process data outside the UK. Where that happens, we aim to use appropriate safeguards, such as adequacy regulations, contractual protections, or equivalent transfer mechanisms supported by the provider.
9. How long we keep data
We keep personal data for as long as needed to operate accounts, provide the service, maintain security, comply with legal or tax obligations, resolve disputes, and enforce agreements.
If an account is deleted or a coach removes a client, some information may remain in backups, audit trails, or accounting records for a reasonable period where required for security, billing, or legal compliance.
10. Your rights
Depending on your location and the context of the processing, you may have rights to access your data, correct inaccurate information, request deletion, restrict or object to certain processing, request portability, or complain to a supervisory authority.
If you are in the UK, you can also complain to the Information Commissioner's Office (ICO). We would appreciate the chance to address concerns first.
11. Security
We use reasonable technical and organisational measures designed to protect personal data against unauthorised access, disclosure, misuse, loss, or destruction. These measures include access controls, authentication safeguards, and the use of third-party infrastructure providers for core platform services.
Even so, no system is perfectly secure, and you should keep your login details confidential and notify us promptly if you believe your account has been compromised.
12. Children
Gym Primer is not directed to children under 16 and is intended for coaches, adult clients, and authorised business users. If a coach uses Gym Primer in a setting involving younger clients, that coach is responsible for ensuring they have the authority and safeguards required to do so lawfully.
13. Changes to this policy
We may update this Privacy Policy from time to time to reflect product changes, legal requirements, or operational improvements. When we make material updates, we will post the updated version on this page and change the 'Last updated' date.
14. Contact us
For privacy questions, rights requests, or data protection concerns about Gym Primer, contact support@gymprimer.co.uk.
