Privacy Notice

Climbing Performance Lab Ltd · Version 1.2 · 30 August 2026

1. Who we are

Climbing Performance Lab Ltd (company number 14516692), registered at Flat 24 Drapers Court, 59 Lurline Gardens, London, SW11 4DF. Coaching is delivered by our director, James Goodey. We are registered with the Information Commissioner's Office (ICO), registration number ZC140686.

For anything about your data, contact: climbingperformancelab@gmail.com.

2. What this notice covers

This notice explains how we collect, use, and protect personal data when delivering climbing performance coaching and our coaching app. It has three labelled sections. Please read the one that applies to you:

• Section 3a: adult clients (18+)
• Section 3b: junior athletes (16 to 17)
• Section 3c: parents and guardians of junior athletes

Sections 4–11 apply to everyone.

3a. For adult clients

We collect the data listed in section 4 to deliver your coaching.

Performance data (climb logs, workouts, test results) is recorded as part of providing the coaching you have signed up for, under your coaching agreement.

Wellbeing monitoring (sleep, soreness, stress and mood, energy and recovery, injury tracking) is entirely optional and separate. It is health data, so we treat it carefully. You are never required to fill in the daily check-in, you can leave any part of it blank, and your coaching is exactly the same whether you take part or not. None of it is recorded unless you enter it.

The switches, and what they do for an adult account today. The app has a Privacy and consent page with a switch for each of these categories, and you can see it and use it. We would rather be straight with you about what those switches currently do:

• Bodyweight: this switch works. It is off unless you turn it on, and while it is off the app will not record a bodyweight you enter.
• Everything else: the switch records your preference, but it does not yet stop us collecting that category. For adults, that data is collected under your coaching agreement rather than under a separate consent for each category.

We plan to make all of the adult switches work the way the bodyweight one does. Until they do, the way to stop us recording something is to tell your coach or email us, and we will stop it. There is no penalty and no effect on your coaching. So if you want a category stopped now, please ask us rather than relying on the switch.

For athletes under 18 this works differently, and the switches are real: the app itself refuses to record a switched-off category, and nobody can enter it for them, including their coach. Section 3b sets that out.

What your coach records. Alongside what you enter, your coach keeps their own coaching records about you: session notes, observations, your programme and goals, and body measurements used to interpret test results. These are part of delivering and evidencing the coaching, not something you switch on and off. They are covered by this notice and by your rights in section 8.

Your rights are in section 8.

3b. For junior athletes (16 to 17)

This section is written for you, not your parents.

What you control. The app has thirteen switches, covering things like climb logs, workouts, sleep, soreness, stress and mood, energy and recovery, injuries, test results, photos you add, and written notes and reflections. Every switch starts OFF. If a switch is off, you cannot enter that information and nobody can enter it for you, including your coach.

Who decides. You do. The law lets you make your own decisions about your data at your age. Your parent signs a separate agreement about coaching and safety, but they cannot switch your switches on. Only you can, on your own device. Before any of this, both your parent's agreement and your own agreement to use the app are needed.

Changing your mind. Turn any switch off whenever you like. New recording stops straight away. What was already recorded stays until it reaches the end of the periods in section 5, or you can ask us to delete it sooner.

What your coach writes. Your switches control what goes into your training record, and that includes testing: your coach cannot record a test result for you unless the switch for that kind of test (flexibility, strength and power, or jump testing) is on.

Separately, your coach keeps their own coaching notes about your sessions, and your programme and goals. Those are part of coaching you rather than something you switch on, and your coach will tell you what they are recording if you ask. Measurements like your height and weight belong with those coaching notes: your coach takes them at a testing session so your results make sense, so they are not switched. We never ask anyone under 18 to record their own weight in the app. Everything in section 8 applies to all of it, so you can ask to see it.

If something worries your coach. If your coach ever becomes concerned about your safety or wellbeing, they will write that down and act on it, whatever your switches say. That is a safeguarding duty and it exists to protect you.

Who can see it. One person: your coach. Nobody else at Climbing Performance Lab can see your data. It is stored by Oracle, a database company we pay, under a contract that only lets them hold it for us and not use it for anything of their own. Section 6 has the full list of who is involved. Your data is never sold, shared with advertisers, or posted anywhere.

Worried about anything? Reply to your coach in the app, on any message they have left you, or email climbingperformancelab@gmail.com. You can also complain to the ICO (section 11). That is your right, and it is free.

3c. For parents and guardians

We hold your child's data as described in this notice, and your own contact details for the safeguarding & services agreement, emergency contact, and being cc'd on any email to your child. Because a 16–17-year-old gives their own data consent in law, the data itself belongs to their relationship with us: your child exercises the rights in section 8 themselves, and we would normally need their agreement before discussing the content of their data with you. Safeguarding matters are different. Those we raise with you directly under the safeguarding & services agreement. To raise any concern: climbingperformancelab@gmail.com.

4. Data we collect

For junior athletes, the app records a switched category only where that switch is on. Every switch starts OFF. For adult clients, only the bodyweight switch works that way today; section 3a explains the rest, and how to stop us recording a category in the meantime.

What you record

About row 14. Bodyweight is for adults only, and it is optional. Rows 1 to 13 are the thirteen switches a junior athlete has; bodyweight is not one of them, because we never ask an athlete under 18 to record their own weight. The bodyweight switch works the same way for adults as every switch does for juniors: it starts off, and while it is off the app will not record a bodyweight you enter. Where weight matters for a junior's test results, their coach measures it at a testing session and it is held with the coaching records below.

About the "lawful basis" column. Where it says consent for a wellbeing category, that is exactly what it means for athletes under 18: the switch is the consent, and without it the app will not record the category at all. The same is true of bodyweight for adults. For the other wellbeing rows an adult's position today is different, and section 3a sets it out.

Junior athletes also give their own agreement to use the app before any of the above, which is recorded alongside their parent's agreement.

What your coach records

Your coach keeps coaching records about you which are not switch controlled, because they are part of delivering and evidencing your coaching rather than something you enter yourself:

Other records

Account details and date of birth (to run your account and apply under-18 protections), kept while your account exists, and then with the records above. Consent and agreement records, kept 6 years after you leave. For juniors, a parent's name and contact details. Emergency contact and medical declaration from your registration form, kept 6 years after the coaching relationship ends. Payment and invoicing records, which we hold outside the app, kept 6 years as required by tax law.

Withdrawing consent stops new recording but does not delete what was already recorded. That stays until the periods below, unless you ask us to erase it (section 8). For an under-18 it stops the moment the switch goes off; for an adult, see section 3a.

5. How long we keep your data

Performance and coaching records, including climb logs, workouts, test results, photos, written notes, injury records, and your coach's own notes and plans, are kept while you are training with us, so your progress can be tracked over the long term, and for 6 years after the coaching relationship ends. We keep them for that period so we can answer questions about the training we prescribed. For anyone who was under 18 while training with us, that 6 years runs from their 18th birthday or from the end of the relationship, whichever is later. After that we either delete the records or strip out anything identifying you and keep only anonymous group statistics.

Wellbeing observations, meaning sleep, soreness, stress and mood, energy and recovery scores, and bodyweight you log yourself, are kept on a rolling 12 month basis and deleted 12 months after the coaching relationship ends. If you would rather keep your wellbeing history, so you can look back at long-term trends, you can choose to keep it: it is then kept while you are training with us and deleted 12 months after you leave, or 12 months after you turn that choice off. We may keep anonymous group statistics, for example average results across all climbers, which cannot be traced back to any individual. Injury records are the exception and are kept with the performance records above, with access restricted, because they are the records most likely to matter if a question is raised about your training.

We have not started removing anything yet. Before rolling deletion begins for you, we will put a notice about it in the app, and at least 90 days will pass between you being offered that notice and anything of yours being removed. Once it is running, rolling deletion runs monthly rather than on the exact day a record expires, so a record may persist for up to one month past its date.

Backups and deletion

Your data is held in a managed Oracle Cloud database in the UK. When you ask us to delete your data, we remove it from the live database as soon as we can, and within one month, and it is fully gone within 60 days once encrypted backup copies have cycled out. Backups are encrypted, cannot be accessed or restored selectively, and are only used in the event of a full database recovery.

One limitation worth knowing: if you have viewed your own photos in the app, copies may remain in your own device's browser cache for up to a year afterwards. That copy is private to your device and we cannot reach it to delete it. Clearing your browser cache removes it.

6. Who has access to your data

• Director (named coach): full access. He is the only person with access to the database, and he carries out all maintenance and deployments himself
• Oracle (as data processor): under DPA (081425), UK South region, no international transfers
• Squarespace (as data processor): hosts our website and handles enquiries sent through the contact form. No coaching or health data is held there

No data is sold, shared with advertisers, or used for marketing.

7. Where your data is stored

Your coaching data, meaning everything listed in section 4, is held in a managed Oracle Cloud database in the UK South region and is not transferred outside the UK. It is encrypted at rest (Transparent Data Encryption, Oracle-managed key) and in transit (TLS).

Two things are not in that database. Payment and invoicing records are held outside the app, as section 4 says. And the forms you fill in on paper stay on paper: your registration form, the emergency contact and medical declaration on it, and a parent's signed agreement. We do not type those into the database, so they are held as paper records and kept for the periods in section 5. For a parent's agreement, the app records their name, that the agreement was given and when; the signed form itself, and their contact details, stay on paper or in our email.

If you contact us through our website, that enquiry is handled by our website provider, Squarespace, which is based in the United States and processes it under its own data protection terms. This applies only to website enquiries. No coaching, performance, or health data is held on the website.

8. Your rights

You can, at any time and for free:

• Access: get a copy of everything we hold about you
• Correction: have anything wrong fixed
• Erasure: ask us to delete your data. Some records are kept for the periods in section 5 where we need them to answer a possible claim, and we will tell you if that applies
• Portability: receive your data in a usable format
• Objection: object to a specific use
• Withdraw consent, with no penalty either way. If you are under 18: flip any switch off in the app and it takes effect straight away. If you are an adult: the bodyweight switch in the app works the same way, and for anything else tell your coach or email us, and we will stop it
• Complain to the ICO: see section 11

To use any of these: email climbingperformancelab@gmail.com. We respond within one month. Junior athletes exercise these rights themselves.

9. Cookies & tracking

The app uses only the essential cookies/session storage needed to keep you logged in. No advertising, analytics, or tracking cookies.

10. Changes to this notice

We may update this notice. Material changes will be notified by email and in-app before they take effect, with the version and date at the top updated.

11. Contact & complaints

Data questions and requests: climbingperformancelab@gmail.com · Climbing Performance Lab Ltd, Flat 24 Drapers Court, 59 Lurline Gardens, London, SW11 4DF.

You have the right to complain to the Information Commissioner's Office: ico.org.uk/make-a-complaint · 0303 123 1113 · ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.