NUTRICOACH PRIVACY POLICY

Effective date: January 2026

This Privacy Policy explains how NUTRICOACH LIMITED, company number 14709771, registered office 79 The Mount, Hale Barns, Cheshire, WA15 8SZ, United Kingdom (“NutriCoach”, “we”, “us” or “our”), collects, uses, stores, shares and otherwise processes your personal data when you use the NutriCoach mobile application, website, content, features and related services (together, the “Platform”).

NutriCoach is a digital, lifestyle-led nutrition and food-planning platform intended for general wellness and lifestyle support. It is not a medical service.

Please read this Privacy Policy carefully. By using NutriCoach, creating an account, starting a trial or purchasing a subscription, you acknowledge that your personal data will be handled as described in this Privacy Policy.

1. Who we are

NutriCoach is the controller of your personal data for the purposes of UK data protection law in relation to the processing described in this Privacy Policy.

Controller: NUTRICOACH LIMITED

Company number: 14709771

Registered office: 79 The Mount, Hale Barns, Cheshire, WA15 8SZ, United Kingdom

Email: hello@nutricoach.co.uk

2. Scope of this Privacy Policy

This Privacy Policy applies to personal data we collect:

• through the NutriCoach app;
• through our website;
• through account creation and onboarding;
• when you subscribe, start a free trial or interact with billing flows;
• when you contact us;
• when you respond to surveys, forms or feedback requests;
• when you use features within the Platform; and
• through certain analytics, cookies and similar technologies on our website and app, where used.

This Policy applies to users globally, although NutriCoach is initially intended primarily for UK users.

3. The personal data we collect

We may collect the following categories of personal data.

3.1 Identity and account data

• name
• email address
• password and login credentials
• account ID
• country or region
• app store account-related subscription identifiers where relevant

3.2 Profile and onboarding data

• age or date of birth
• sex or gender where relevant to app functionality
• height
• weight
• target weight or goals
• activity-related information
• food preferences
• dietary preferences
• allergies or intolerances
• meal structure preferences
• lifestyle and routine information you choose to provide

3.3 Health-related and wellbeing data

Depending on what you provide, this may include:

• weight history
• eating-behaviour information
• information about pregnancy or breastfeeding
• medical-condition information
• medication-related information
• mental health-related information relevant to suitability or safe use
• information about symptoms, restrictions or health circumstances you disclose

Some of this data may be data concerning health and therefore special category data under the UK GDPR.

3.4 Usage and technical data

• device information
• operating system
• app version
• IP address
• browser type
• crash logs
• diagnostic information
• app interaction data
• referral data
• website usage data
• cookie and similar technology data where used

3.5 Subscription and transaction data

• subscription status
• trial status
• billing plan
• renewal dates
• app store transaction identifiers
• limited purchase metadata supplied to us by Apple or Google

NutriCoach does not intend to store your full card details where purchases are made through the Apple App Store or Google Play Store.

3.6 Communications and support data

• emails or messages you send us
• feedback
• survey responses
• customer support history
• complaints or dispute information

3.7 Marketing and preference data

• your communication preferences
• whether you opted into marketing
• engagement with marketing emails where lawful and technically supported

4. How we collect your personal data

We collect personal data:

• directly from you when you sign up, complete onboarding, subscribe, contact us or use the Platform;
• automatically when you use the Platform, including through app and website analytics and similar technologies where applicable;
• from Apple App Store or Google Play Store in connection with subscription status, purchase validation and account administration;
• from service providers who help us run the Platform; and
• in limited cases, from third parties where you ask us to connect or verify information, or where lawful and necessary.

5. How we use your personal data

We use your personal data to:

• create and manage your account;
• provide the Platform and its features to you;
• personalise your in-app experience based on the information you provide;
• generate food planning, meal structure, calorie or nutrition-related outputs within the limits described in our Terms;
• determine whether the Platform may be unsuitable for you based on information you provide;
• manage subscriptions, free trials, renewals and account administration;
• communicate with you about your account, service updates and support issues;
• respond to enquiries, complaints and data rights requests;
• improve, test, troubleshoot and develop the Platform;
• monitor usage, performance and product quality;
• detect misuse, fraud, abuse, bugs or security incidents;
• comply with legal and regulatory obligations;
• establish, exercise or defend legal claims; and
• send you marketing communications where we are allowed to do so.

6. Our lawful bases for processing

Under UK GDPR, organisations must identify a lawful basis for processing personal data.

Depending on the context, we rely on the following lawful bases:

6.1 Contract

We process personal data where necessary to provide the Platform to you, manage your account, administer your subscription, and deliver the services you request.

6.2 Legitimate interests

We process certain personal data where necessary for our legitimate interests, including:

• operating and improving the Platform;
• product analytics and service optimisation;
• preventing fraud and misuse;
• securing our systems;
• handling support and disputes;
• understanding user engagement; and
• developing and improving NutriCoach.

Where we rely on legitimate interests, we consider and balance any potential impact on your rights and freedoms.

6.3 Legal obligation

We may process personal data where necessary to comply with legal obligations, including tax, accounting, consumer law, law enforcement requests, court orders and regulatory obligations.

6.4 Consent

Where required, we rely on your consent, including for certain health-related information, certain optional profile inputs, and certain marketing or cookie-related processing. Where consent is our basis, you can withdraw it at any time, although this will not affect processing already carried out before withdrawal. ICO guidance says privacy notices should explain the right to withdraw consent where consent is used.

7. Special category data and health-related information

Information concerning physical or mental health is special category data under UK GDPR and needs greater protection.

We may process health-related or other special category data you provide during onboarding or while using the Platform, such as:

• weight and body-related information;
• pregnancy or breastfeeding information;
• allergies or intolerances;
• illness or medical-condition information;
• medication-related information;
• mental health-related information relevant to the suitability of the Platform.

Where we process special category data, we intend to rely on:

• your explicit consent, and/or
• another lawful condition available under applicable data protection law where relevant and appropriate.

If you do not provide certain health-related data, some Platform features may not work properly or may be unavailable. In some cases, we may also use health-related inputs to determine that NutriCoach may be unsuitable for you.

8. Important note on health and suitability data

NutriCoach is designed as a general wellness and lifestyle platform. The fact that we collect certain health-related information does not mean NutriCoach provides medical advice, diagnosis, treatment or clinical care.

We collect some health-related information so that:

• we can tailor the user experience to the extent the Platform is designed to do so;
• we can help users determine whether the Platform may be unsuitable for them; and
• we can operate the Platform more responsibly and safely.

Any diet guidance or nutritional framework used within NutriCoach may be overseen internally by a Head of Nutrition Standards and Behaviour qualified in Nutrition and Weight Management through the Royal Society of Public Health. That does not change the non-medical nature of the Platform.

9. Cookies, analytics and similar technologies

If you use our website, we may use cookies and similar technologies to:

• keep the website functioning;
• remember preferences;
• understand website traffic and usage patterns;
• improve performance and user experience; and
• support analytics and marketing, where applicable.

The ICO says privacy notices should explain cookie use and how people can find out more.

Where required by law, we will ask for consent before using non-essential cookies or similar technologies. You can usually control cookies through your browser settings and, where available, our cookie controls.

We may use analytics tools and service providers to understand app and website performance, user behaviour, crashes and engagement.

10. Who we share your personal data with

We may share your personal data with the following categories of recipients where necessary:

• cloud hosting and infrastructure providers;
• app and website development providers;
• analytics and diagnostics providers;
• customer support tools and communication tools;
• email and CRM providers;
• legal, compliance, insurance and professional advisers;
• fraud prevention and security providers;
• Apple App Store and Google Play Store, where relevant to subscriptions and in-app purchases;
• service providers who help us operate, maintain, secure or improve NutriCoach;
• courts, regulators, law enforcement agencies or other authorities where required by law;
• a buyer, investor, successor or transaction counterparty if all or part of our business is sold, merged, reorganised or transferred.

We do not sell your personal data.

We do not share your personal data with third parties for their own independent marketing unless we have clearly told you and have a valid legal basis to do so.

11. International transfers

NutriCoach may use service providers located in, or storing data in, countries outside the UK.

Where we transfer personal data internationally, we will take steps designed to ensure it remains protected in line with applicable data protection law, for example by using approved contractual safeguards or other lawful transfer mechanisms where required.

12. How long we keep your personal data

UK GDPR requires privacy information to explain retention periods, or at least the criteria used to decide them.

We keep personal data only for as long as reasonably necessary for the purposes set out in this Privacy Policy, including to provide the Platform, comply with legal obligations, resolve disputes, enforce agreements and maintain business records.

In practice:

• account and profile data is usually kept while your account is active and for a reasonable period afterwards;
• support communications may be kept for record-keeping and dispute-handling purposes;
• transaction and subscription records may be kept for tax, audit and accounting purposes;
• analytics data may be kept in aggregated or de-identified form for longer where lawful.

If you request deletion, we will assess that request in line with applicable law. We may keep limited data where we are required or entitled to do so, such as for legal, fraud-prevention, accounting or record-keeping purposes.

13. Your rights

Depending on where you are and subject to applicable law, you may have the right to:

• access your personal data;
• request correction of inaccurate personal data;
• request deletion of your personal data;
• request restriction of processing;
• object to certain processing;
• withdraw consent where we rely on consent;
• request transfer of certain data to you or another provider;
• complain to a supervisory authority.

ICO guidance states privacy notices should tell people which rights they have and how to complain.

To exercise your rights, contact us at hello@nutricoach.co.uk. We may need to verify your identity before acting on your request.

If you are in the UK, you also have the right to complain to the Information Commissioner’s Office (ICO).

14. Marketing communications

We may send you service-related communications that are necessary for your account or subscription.

Where permitted by law, we may also send marketing communications about NutriCoach, updates, offers or related content. You can opt out of marketing at any time by using the unsubscribe link or contacting us.

Opting out of marketing does not stop service-related messages, such as subscription, account or security communications.

15. Children

NutriCoach is not intended for anyone under 18. We do not knowingly collect personal data from children under 18 for use of the Platform. If you believe a child has provided us with personal data, please contact us and we will investigate.

16. Security

We use measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

However, no platform, transmission method or storage system is completely secure, and we cannot guarantee absolute security.

If we become aware of a personal data breach, we will respond in accordance with applicable law. UK law requires notification in certain cases.

17. Third-party links and services

The Platform may contain links to third-party websites, services or tools. We are not responsible for the privacy practices of third parties. You should read their privacy notices before submitting personal data to them.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Where changes are material, we will take reasonable steps to notify you, for example by email, in-app notice or website notice. The latest version will always be the version made available through our Platform.

19. Contact us

If you have questions about this Privacy Policy or how we handle your personal data, contact:

NUTRICOACH LIMITED

79 The Mount, Hale Barns, Cheshire, WA15 8SZ, United Kingdom

Email: hello@nutricoach.co.uk

If you are unhappy with our response, you may have the right to complain to the Information Commissioner’s Office.