Head Active
Privacy Policy
Last updated: 7 September 2026
Head Active ("we", "us") is the data controller for the personal data processed in the Head Active members app. This policy explains what we collect, why, how long we keep it and the rights you have under the UK GDPR and EU GDPR. Contact: hello@headactiveonline.com.
1. Who we are
Head Active Ltd (company number 17442457), 39 Kingston Close, Shoreham-By-Sea, BN43 6LP, United Kingdom.
Data protection contact: Jordan Head, hello@headactiveonline.com.
2. What we collect
Account data: name, email address, password (stored hashed by our authentication provider), profile photo if you add one.
Onboarding data: gender, age, height, weight, activity level, goals, preferences, exercise availability and any notes you provide.
Health and wellbeing data (special category data): weight and body measurements, nutrition and hydration logs, habit logs, sleep and recovery answers, training and movement logs, check-ins and progress photos.
Coaching interaction data: messages with your coach (including photos you send), check-ins, progress reviews, community posts, comments and reactions.
Technical data: device and browser type, and error logs needed to keep the app working securely.
3. Why we use it and our lawful basis
Contract: to give you access to the members app, your personalised protocol, tracking and reviews.
Explicit consent (Article 9(2)(a)): to process your health-related data and your progress photos, which are part of the coaching programme. You can withdraw consent at any time, though we can no longer coach you through the app if you do.
Legitimate interests: to keep the app secure, prevent misuse, and improve the service.
Contract and legitimate interests: to send essential coaching and service notifications about your Game Plan, check-ins, appointments and member sessions included in your programme.
Consent: to send separate promotional emails about new programmes and offers where you have opted in.
Legal obligation: to keep records required for tax and accounting where a payment relationship exists.
4. Automated tools and AI features
The app includes an AI workout generator. When you use it, the workout request you make — such as the type of session, time available and equipment — is sent to an AI provider so it can return a suggested workout.
Only the content needed for that feature is sent. It is not used to train third-party models where the provider offers that setting.
AI suggestions are approximations and are not medical or dietary advice. You can always edit or delete the result.
5a. Connected health and wearable services
Connecting a supported health or wearable service (for example an Apple Health shortcut, or a wearable account where supported) is optional. You can use Head Active without connecting one.
We only access data from a connected service after you authorise the connection. We request only the data needed for the relevant Head Active features, such as steps, sleep, resting heart rate, heart rate variability and recovery or readiness information.
Connected data is stored with the rest of your coaching data, is visible only to you and your coach, and is used to personalise and review your coaching. It is never sold or used for advertising.
Connection credentials are stored securely on our servers and are never shown in the app.
You can disconnect a connected service at any time in the app, by revoking access in the provider's own settings, or by emailing hello@headactiveonline.com. Data already received is kept and deleted in line with section 7, or sooner on request.
Connected data is handled in accordance with this Privacy Policy and the applicable requirements of the connected provider.
6. International transfers
Some processors may store or process data outside the UK/EEA. Where they do, transfers are covered by UK International Data Transfer Agreements, the EU Standard Contractual Clauses, or an adequacy decision.
7. How long we keep it
Account and coaching data: for as long as you are a member, and for 12 months after your last activity so you can return without losing your history.
Progress photos: until you delete them, or 12 months after your membership ends.
Messages: for the duration of your membership plus 12 months.
Financial records: 6 years, where legally required.
You can ask us to delete everything sooner — see your rights below.
8. Your rights
You have the right to access your data, correct it, delete it, restrict or object to processing, withdraw consent, and receive a portable copy.
In the app: Profile → Settings → Privacy & data lets you download a machine-readable copy of your data, manage your consents, and request deletion of your account and data.
You can also email hello@headactiveonline.com. We respond within one month.
If you are unhappy with how we handle your data you can complain to the Information Commissioner's Office (ico.org.uk) or your local supervisory authority.
9. Security
Data is encrypted in transit and at rest. Access is protected by row-level security so members can only reach their own records, and progress photos are stored in a private bucket accessible only to you and your coach.
We will notify you and the relevant regulator without undue delay if a breach is likely to affect your rights.
9a. Progress photos
Progress photos are a required part of the Head Active coaching programme and are used for your progress reviews.
They are stored privately and are visible only to you and your coach. They are never shown to community members and are never used for marketing, testimonials, social media or before/after promotion unless you give separate, specific written permission first.
Agreeing to programme progress photos does not create any marketing or testimonial permission.
Free 14-Day Challenge: promotional permission is requested separately through an unticked checkbox at registration and confirmed during onboarding. The dated permission and its wording are recorded with your challenge profile. Uploaded originals remain securely stored; permitted promotional copies may be shared publicly.
I explicitly give Head Active permission to share my challenge progress photos, before-and-after images and results for promotion on its website, social media and promotional materials. I understand that the £200 winner must agree to their before-and-after photos and results being shared to receive the prize.
You keep ownership of your photos. You can withdraw promotional permission by contacting hello@headactiveonline.com; this stops future use but cannot recall material already distributed or shared by others. Withdrawing permission means you cannot receive the £200 prize.
10. Children
The app is not intended for anyone under 18. We do not knowingly collect data from children.
11. Changes
This policy was last updated on 2026-09-07. If we make material changes we will ask you to review and re-accept them in the app.
