PRIVACY
NOTICE.

WHO I AM

I am Ruud Chircop, trading as Chircop Coaching, a personal trainer based in Malta. I am the data controller for the personal data described in this notice. You can contact me at info.chircopcoaching@gmail.com. If you have a question about anything on this page, email me and I will answer it.

WHAT I COLLECT

If you join the email list

• Your email address
• The date and time you gave your consent

If you send a consultation enquiry

• Your name
• Your email address
• Your WhatsApp number
• Your main goal
• Your training preference (online, in person, or either)
• Anything you choose to write in the optional “a bit about you” box
• How you heard about me, if you tell me
• Whether you confirmed you are 18 or over
• The date and time you gave your consent

Please do not include medical details in the enquiry form. I do not ask for injuries, health conditions, measurements, photographs, your age or your training history at this stage, and the form is not set up to handle that kind of information. If we go on to work together, I will collect what I need properly, separately, and with your explicit consent.

WHY I USE IT, AND MY LEGAL BASIS

In both cases my legal basis is your consent (Article 6(1)(a) of the GDPR). You tick the box yourself; the boxes are never pre-ticked.

• Email list: to send you tips, workouts and recipes by email.
• Consultation enquiry: to reply to you and to talk about whether coaching is a good fit.

Sending an enquiry does not put you on the email list. The two are separate, they have separate consent, and enquiry details are not used for marketing. If you want the emails as well, you sign up for them separately.

WHO SEES IT

Only me, plus the services I use to run the website and send email:

• [EMAIL PROVIDER NAME] — stores the email list and sends the emails
• [FORM SERVICE NAME] — receives the signup and enquiry forms
• WhatsApp (Meta) — if you message me there, or if I reply to you there, WhatsApp processes that conversation under its own terms

I do not sell your data and I do not share it so that anyone else can market to you.

[TRANSFERS OUTSIDE THE EU/EEA: confirm whether any of the providers above store or process data outside the EU/EEA, and if so name the safeguard relied on — for example the European Commission's Standard Contractual Clauses or an adequacy decision.]

HOW LONG I KEEP IT

• Email list: until you unsubscribe or ask me to delete you, and then I remove your address.
• Consultation enquiries: [RETENTION PERIOD] if we do not end up working together, after which I delete them. If we do work together, your details move over to your client records and are kept under the terms you agree at that point.

YOUR RIGHTS

Under the GDPR you have the right to:

• ask for a copy of the personal data I hold about you (access)
• have it corrected if it is wrong (rectification)
• have it deleted (erasure)
• ask me to restrict how I use it (restriction)
• object to how I use it (objection)
• receive it in a portable format, or have it sent to someone else (portability)
• withdraw your consent at any time — use the unsubscribe link in any email, or email me. Withdrawing consent does not affect anything I did before you withdrew it.

To use any of these, email info.chircopcoaching@gmail.com. It costs nothing and I will respond within one month.

If you are not happy with how I have handled your data, you can complain to Malta's supervisory authority, the Information and Data Protection Commissioner (IDPC) — [IDPC CONTACT DETAILS / WEBSITE].

DO YOU HAVE TO GIVE IT TO ME?

No. Everything on this site is optional and there is no obligation to give me anything.

• Without your email address I cannot add you to the list or send you the tips, workouts and recipes.
• Without your name and a way to contact you I cannot reply to your enquiry or arrange a consultation.
• The “a bit about you” box and “how did you hear about me” are optional. Leaving them blank changes nothing about my reply.

You can always just message me on WhatsApp instead of using a form.

UNDER-18s

[DRAFT — for lawyer review.]

If you are under 18, you must not send a consultation enquiry or sign up to the email list yourself. A parent or legal guardian has to do it for you — completing the form in your name and giving the consent themselves.

The enquiry form asks whether you are 18 or over. If the answer is no, the consent you are agreeing to is the guardian's consent, and I record that it was given on that basis.

If I find out that information about someone under 18 has been given to me without a parent or legal guardian's consent, I will delete it. If you are a parent or guardian and you think this has happened, email me and I will remove it.

AUTOMATED DECISIONS

None. I do not use automated decision-making or profiling. Every reply, every plan and every decision about working together is made by me, personally.

COOKIES AND THIRD PARTIES

[CONFIRM BEFORE LAUNCH: no tracking or advertising cookies; fonts self-hosted.]

As this notice is written, the site sets no cookies of its own, uses no analytics and no advertising pixels, and stores nothing in your browser. The fonts are served from this website rather than from Google, so loading a page does not send your IP address to a font provider.

COACHING CLIENTS

If we go on to work together, I need a good deal more than the website collects — including health information such as injuries, medical conditions, measurements and progress photographs. That is a special category of data under the GDPR and it is handled separately: I ask for your separate, explicit consent at intake, and I explain there exactly what I collect, why, and how long I keep it.

None of that applies to simply browsing this site, joining the email list, or sending an enquiry.

[LINK TO INTAKE PRIVACY WORDING]

CHANGES TO THIS NOTICE

If I change how I handle personal data, I will update this page and change the “last updated” date at the top. If the change is a significant one and I hold your email address, I will tell you by email.