Please read them carefully before using Our Service.

The data controller for the personal data we collect is:

Niamh Brangwyn Address: 56 Brunswick Road, BN3 1DH Email: hello@niamhbrangwyn.com

If you have any questions about this policy or your data, please contact us at the email above.

We may collect the following categories of personal data:

When you visit our website:

• IP address

• Browser type and version

• Device information

• Pages visited and time spent on the site

• Referring website

When you sign up for our newsletter or download a free resource:

• Name

• Email address

• Any information you provide voluntarily

When you purchase the Back Freedom Program:

• Full name

• Email address

• Billing address

• Payment information (processed by our payment provider — we do not store full card details)

• Information you share through coaching calls, programme communications, intake forms, and community spaces (which may include health-related information you choose to share)

When you contact us:

• Name

• Email address

• Any information you provide in your message

We collect data:

• Directly from you (e.g., when you fill in a form, purchase a programme, or email us)

• Automatically (e.g., through cookies and website analytics)

• From third parties (e.g., payment processors, where you authorise the sharing)

We process your personal data for the following purposes, under the following legal bases (UK GDPR Article 6):

• To deliver the Back Freedom Program after you purchase — Contract (necessary to fulfil our agreement with you)

• To process payments — Contract

• To send you marketing emails and newsletters — Consent (you can withdraw at any time)

• To respond to your enquiries — Legitimate interests / pre-contract steps

• To improve our website and services through analytics — Legitimate interests

• To keep financial and business records — Legal obligation (UK tax and accounting law)

• To protect our legal rights — Legitimate interests

You have the right to withdraw consent at any time where consent is the legal basis. Withdrawing consent will not affect the lawfulness of processing carried out before withdrawal.

We do not sell your personal data to third parties. We may share your data with the following types of trusted service providers, all of whom are required to protect your data and process it only on our instructions:

• Payment processors (e.g., Stripe, PayPal) — to process your purchase

• Email marketing platform (e.g., Systems.oi Mailchimp) — to send newsletters and Programme communications

• Website hosting and platform providers (e.g., Systems.oi, Squarespace, Showit, Kajabi) — to operate our website and deliver the Programme

• Analytics providers (e.g., Google Analytics) — to understand how our site is used

• Booking and scheduling tools (e.g., Acuity, Calendly) — where applicable

• Accountants and professional advisers — where required for legal or financial purposes

We may also disclose your data where required by law (e.g., to respond to a court order or regulatory request).

Some of our service providers (e.g., Stripe, Google) may be based outside the UK. Where personal data is transferred outside the UK, we take steps to ensure appropriate safeguards are in place, including standard contractual clauses approved by the UK Information Commissioner's Office (ICO).

We keep personal data only as long as necessary for the purposes for which it was collected, including:

• Customer purchase records: 7 years (UK tax and accounting requirement)

• Marketing email subscribers: until you unsubscribe, plus a short period to confirm removal

• Website analytics: in accordance with the analytics provider's retention settings (typically 14–26 months)

• General enquiries: up to 2 years from last contact, unless we are continuing to correspond with you

Under UK GDPR, you have the following rights:

• Right of access — request a copy of the personal data we hold about you

• Right to rectification — ask us to correct inaccurate or incomplete data

• Right to erasure — ask us to delete your data ("right to be forgotten")

• Right to restrict processing — ask us to limit how we use your data

• Right to data portability — receive your data in a portable format

• Right to object — object to certain types of processing (including direct marketing)

• Right to withdraw consent — where we rely on consent

• Right to lodge a complaint with the Information Commissioner's Office (ICO)

To exercise any of these rights, please email hello@niamhbrangwyn.com.

We will respond to all legitimate requests within one month. Occasionally it may take longer if your request is particularly complex or you have made several requests — we will let you know if this is the case.

Our website uses cookies and similar technologies to function correctly, improve your experience, and understand how the site is used.

We use the following types of cookies:

• Strictly necessary cookies — required for the website to function (cannot be disabled)

• Analytics cookies — help us understand how visitors use the site (e.g., Google Analytics)

• Functionality cookies — remember your preferences

• Marketing cookies — track activity for marketing purposes (only used with your consent)

You can manage your cookie preferences via our cookie banner when you first visit the site, or by adjusting your browser settings. Disabling certain cookies may affect site functionality.

Our website and services are not directed at anyone under the age of 18. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us and we will delete it.

We take appropriate technical and organisational measures to protect your personal data against accidental loss, unauthorised access, alteration, or disclosure. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page will reflect any changes. We encourage you to review this policy periodically.

If you have any questions about this Privacy Policy or how we handle your data, please contact us:

Email: hello@niamhbrangwyn.com

If you are not satisfied with how we have handled your data, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):

• Website: ico.org.uk

• Phone: 0303 123 1113