Legal · Draft

Privacy notice.

How NGU by Denisa handles your personal information. This is a draft and will be finalised before launch.

DRAFT - pending confirmation. This document is not yet in force and has not been legally reviewed.

Last updated: [to be confirmed]

1. Who we are

The controller of your personal data is Denisa Avramescu, trading as NGU ("NGU", "I", "me").

[Address and contact email to be confirmed]

2. Data we collect

Application data: name, age, email, phone (optional), country, Instagram handle (optional), goals, training background, lifestyle and preferences.
Health information you choose to share, such as injuries, physical limitations, allergies and dietary requirements.
In the client app: progress photos, measurements, workout, food and habit logs, and check-in answers.
Messages you send to me and coaching replies.
Payment status (for example paid, failed, refunded). Card details are handled by the payment provider and are never stored by NGU.

3. Why we use it

To assess your application and recommend a suitable offer.
To create, deliver and adjust your personalised plan and coaching.
To manage your membership and billing status.
To contact you about your application or membership.
To send occasional news and offers, only if you opt in.

4. Lawful bases

Contract — to provide the coaching services you sign up for.
Explicit consent — for health information you share (special category data). You can withdraw it at any time.
Legitimate interests — to run and protect the service.
Consent — for marketing messages.
Legal obligation — for records we must keep by law.

5. Who we share it with

[to be confirmed - planned: hosting/database provider, payment provider, email provider, AI drafting assistance provider]

6. Use of AI

[AI-use disclosure wording pending Denisa's approval - any AI-assisted drafts are reviewed and approved by Denisa before you receive them]

7. How long we keep it

Retention: [to be confirmed]

8. Your rights

Under UK GDPR and EU GDPR you have the right to access, rectify and erase your data, to object to or restrict certain processing, to data portability, and to withdraw consent at any time.

You also have the right to complain to the UK Information Commissioner's Office (ICO) or your local data protection authority.