PRIVACY AND COOKIES POLICY

This is the Privacy & Cookies Policy (the “Policy”) of Chloe Bowler (a sole trader who trades under the name ‘CHLOËBOWLER’) (hereafter “CHLOËBOWLER”, “we” or “us”). This Policy describes the ways in which we collect and use information about you when you choose to become a member of the website at www.chloebowler.com (the “Website”).

We may change this Policy at any time and whilst we will tell you about what we feel are key changes to the Policy via the email address that you use when applying for a membership, please check it regularly to keep up-to-date. If you do not wish to accept the new Policy you should stop being a member of the Website. If you continue to be a member of the Website after the changes, your continued membership shows us your agreement to be bound by the new Policy.

This Policy was last changed in January 2025.

1. ICO registration and EU Representative: For the purposes of data protection legislation, we have registered with the Information Commissioner’s Office (“ICO”). Our registration number is ZB832363.
2. Information we use about you: We collect and process the following information from you via the Website:

What information do we collect?	When do we collect this?	How do we use this information?	Our reasons
●      First name ●      Last name ●      Telephone number ●      Email address ●      Address ●      Any other information submitted when raising a query	If you choose to submit an enquiry or query via the Website	To answer your enquiry/query	Consent	You choose whether or not to raise an enquiry or query with us and what information to provide to us in doing so.
●      First name ●      Last name ●      Email address	If you choose to subscribe to marketing emails from CHLOËBOWLER by choosing to subscribe to the newsletter on the Website.	To send you emails about our upcoming activities as well as other news and features relating to CHLOËBOWLER.	Consent.	We only send you marketing emails where you have consented to receive them, or if we are otherwise permitted to send them to you by law (e.g., by  virtue of the soft opt-in), and you can unsubscribe at any time by clicking the unsubscribe button in any marketing message sent to you.
●      The information collected via those cookies/technologies which are not necessary cookies, as set out in our Cookie Notice (see here).	If you choose to allow these cookies (other than necessary cookies) to be placed then we will place those cookies and therefore collect the information provided via them accordingly.	To assess visitor numbers to our Website and how users interact with our Website, as well as for other maintenance and support purposes.	Consent.	We only place non-necessary cookies if you consent to these when first visiting our Website.

If you then choose to become a member of the Website we collect and process the following information:

What information do we collect?	When do we collect this?	How do we use this information?	Our reasons
●      Title ●      First name ●      Last name ●      Gender ●      Date of birth ●      Email address ●      Address ●      Telephone number ●      Financial data such as payment and card details and bank account information together with transactional data relating to any payments made by you	If you choose to sign up and become a member of the Website.	To create your member account and allow you to access videos, meal plans and other membership perks.	Contractual necessity or, in certain cases consent.	We require certain details to create and administer the account in question, e.g., your name in order to send personalised system notifications and for account administration purposes and your email address, address and, where applicable, billing information to verify your identity as a unique account identifier and charge you for being a member of the Website, together with other account administration activities. Other information will be collected on a consent only basis i.e., it is optional for you as to whether to provide that information or not and, if provided, is used by us to provide a more personalised service to you as a member of the Website.   We may arrange that card or payment data you submit when applying for a membership is stored for the purpose of processing your application, initiating your membership, and collecting subscription fees.   We may also store and use card or payment information for the purpose of processing any future payments that you make as a member or customer for other goods and services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted.

3. Sharing your information with third parties: Some of the information we collect from you is passed to third parties. These third parties are:

• • our payment provider services such as PayPal;
  • our website hosting provider, The Refinery;
  • our marketing automation providers, currently Mailchimp;
  • certain third party analytics and cookies providers as described further in paragraph 7 below;
  • in the future, any group companies of ours;
  • our regulator (the ICO);
  • in anonymised form, we may share the information with:
    1. any third party, in relation to the sale of some or all of our business, or its assets, or as part of any business restructuring or reorganisation. We will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred under these circumstances;
    2. data aggregators and platform providers as part of an analysis of user metrics or sales performance; or
  • law enforcement agencies in compliance with law enforcement.

4. Links to third party websites: We are not responsible for the privacy policies and practices of other sites even if you access them via the Website. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
5. Security: We have implemented technology and policies to safeguard your privacy from unauthorised access and improper use.
6. Storage and Data Retention: We store your personal data in the UK. Where we permit any third party to transfer personal data outside the UK and/or EEA we ensure that we have an appropriate adequacy ground to do so e.g., SCCs. We retain your data for no longer than is reasonable in line with the purposes for which it was originally collected, although please note that we shall be entitled to anonymise any information collected hereunder and retain such anonymised data indefinitely in order to refine and improve our membership service.
7. Cookies/ other similar technologies:

• • What are Cookies? Cookies are small text files that are placed on your device when you use the App. Our use of cookies is detailed below. Session cookies enable you to move from page to page within the Website and/or and any information you enter will be remembered but is deleted when you close the page on the Website or after a short time. Persistent cookies allow us to remember your preferences and settings when you use the Website in the future.
  • Disabling Cookies: The use of the cookies described above improves the functionality of the Website and your experience of using the Website. If you do not want these cookies to be served on your device, you are able to disable them by changing the settings on your device. Please note that if you do decide to disable any necessary cookies you may not be able to access the Website, and some of the features of the Website may not function properly.
  • Third Party Cookies: Third Party advertisers may place or read cookies on your device when you use the Website. This Policy is applicable only to the use of cookies by us and does not cover the use of cookies by any third parties.
  • More information: To find out more about how cookies work, how to manage and delete them and to see which ones have been set please visit aboutcookies.org or www.allaboutcookies.org.
  • What Cookies do we use? We use cookies and similar technologies when you use the Website, as detailed to you when you first visit the Website. At the time of making your first visit, you will be able to, using technology provided by our third party provider Cookiebot^TM , choose which cookies you wish to permit to be placed and which you do not. If you wish to change your settings at any time in the future, then you can click on the applicable button to change your settings accordingly. Please see our Cookie Notice here for further details.

8. Exercising your rights: You can contact us using the details set out in paragraph 9 below if you wish to: (i) access a copy of the personal data that we hold about you; (ii) correct any items of personal data that we hold about you; and/or (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data. Please note that these rights only relate to your personal data and, as noted above, we shall be entitled to anonymise any information collected hereunder and retain such anonymised data indefinitely in order to refine and improve the Service to which these rights do not apply.
9. Our Details: If at any time you would like to contact us about your views on this Policy or any enquiry relating to your personal information, you can do so by sending an e-mail to us at [email protected]. You also have the right to make a complaint to the ICO by contacting them at any time.