01 / who controls your information
Jesse Keating trading as FRAME by Jesse is the controller of personal information used to operate the coaching business, based in Kildare, Ireland.
privacy questions, rights requests and complaints can be sent to hello@framebyjesse.com.
02 / information collected
FRAME may collect only the information relevant to an enquiry, application, purchase or coaching relationship.
identity and contact details
application answers and coaching goals
billing status and transaction records
training history, programme activity and exercise records
communications, check ins and coach feedback
optional measurements, weight records and progress photographs
optional nutrition records and food journal entries
optional exercise videos, injury information and other health information
technical information needed for site security, consent records and service delivery
03 / coaching data and Everfit
Everfit provides the client and coach software used for parts of online coaching. FRAME determines why client coaching information is used and is generally the controller for that activity. Everfit generally acts as a processor when it handles information on FRAME instructions, while Everfit may be an independent controller for some account or service activity described in its own privacy information.
the app is not monitored continuously. feedback, review frequency and response expectations depend on the coaching experience selected.
measurements, photographs, nutrition records and exercise videos are optional unless a specific item is clearly identified as necessary for safe delivery of the service.
04 / purposes and legal bases
FRAME uses contact, application and service information to take steps you request before a contract and to perform a coaching contract.
payment, tax and accounting records are used to meet legal obligations.
service security, administration, record keeping and the improvement of business operations may rely on legitimate interests where those interests do not override your rights.
optional marketing relies on consent or another basis permitted by law. you can opt out at any time.
health information and other special category data is processed only with explicit consent or another valid condition under data protection law.
05 / choices and health data
required and optional information should be identified when it is requested. you may decline optional measurements, progress photographs, nutrition records or videos without consenting to unrelated use.
health data consent is separate from marketing consent. you may withdraw consent by contacting FRAME or using the available platform control. withdrawal does not affect processing that was lawful before it was withdrawn.
where a piece of information is necessary to deliver coaching safely, FRAME will explain the consequence of not providing it.
06 / sharing and processors
information is shared only where necessary with service providers that support coaching, payment, forms, website delivery, email, storage, security and professional administration.
current categories may include Everfit for coaching delivery, Framer for the website, Tally for forms, Google for consented website analytics, payment providers used at checkout, and email or cloud service providers used for communication and records.
providers receive only the information needed for their role and are subject to appropriate contractual and security requirements. FRAME does not sell personal information.
07 / international transfers
some providers may process information outside Ireland or the European Economic Area.
where a transfer requires protection, FRAME relies on an adequacy decision, approved standard contractual clauses or another lawful safeguard. you may request information about the safeguard used for a relevant transfer.
08 / retention
information is kept only for as long as needed for the purpose collected, legal obligations and the fair handling of disputes.
applications that do not progress are normally removed within twelve months
coaching records and optional health information are normally retained during the relationship and for up to twenty four months after it ends, unless earlier deletion is appropriate or law requires longer
financial and contractual records may be retained for six years or another period required by Irish law
marketing records are kept until consent is withdrawn or the record is no longer needed
the local consent preference for Google Analytics expires after one hundred and eighty days
Google Analytics event information is kept according to the shortest practical property setting and reviewed against the need for continued site analysis
09 / security
FRAME uses proportionate access controls, account protection, provider safeguards and retention limits. no internet service can promise absolute security.
you should use a strong unique password for any client platform and report suspected unauthorised access promptly.
11 / automated decisions
FRAME does not make decisions based solely on automated processing that produce legal or similarly significant effects for clients.
coaching decisions are reviewed by a person. identifiable client information will not be placed into an artificial intelligence service for a new purpose without an appropriate basis, notice and safeguard.
12 / your rights
subject to the conditions in data protection law, you may request access, correction, deletion, restriction, portability or objection. you may withdraw consent at any time and may object to direct marketing without giving a reason.
FRAME may need to verify your identity before completing a request and will normally respond within one month.
13 / complaints
please contact FRAME first if you believe information has been handled incorrectly so the concern can be investigated.
you also have the right to complain to the Irish Data Protection Commission or the supervisory authority where you live or work.
14 / policy changes
this notice may be updated when services, providers or legal duties change. a material change will be explained clearly and, where required, brought to your attention before the new use begins.
15 / contact
Jesse Keating trading as FRAME by Jesse
Kildare, Ireland
hello@framebyjesse.com