Privacy Policy

1.About this Privacy Policy

This Privacy Policy explains how Thrive Mobility London collects, uses, stores and protects personal information when people:

● visit this website
● submit an enquiry
● arrange or attend a consultation
● book or receive a service
● complete health screening
● make a payment
● communicate with the business
● submit a complaint or exercise a data protection right

The policy applies to website visitors, prospective clients, current clients and other people who communicate with Thrive Mobility London.

2.Data controller

The person responsible for determining how personal information is used is:
Richard Mark Thompson trading as Thrive Mobility London
Whiston House
Goldsmiths Row
London E2 8SJ
Email: richard@thrivemobilitylondon.co.uk
Telephone: 0791 890 4528
For the purposes of UK data protection law, Richard Mark Thompson is the data controller.

3.Data protection legislation

Personal information is processed in accordance with applicable UK data protection legislation,
including:

● the UK General Data Protection Regulation
● the Data Protection Act 2018
● the Data Use and Access Act 2025
● the Privacy and Electronic Communications Regulations where applicable

Privacy notices must explain matters including the identity of the controller, the purposes of processing, applicable lawful bases, data sharing, retention and individual rights.

4.Personal information collected

Depending on how you interact with the business, Thrive Mobility London may collect:

Contact and identity information
This may include your:
● name
● address
● email address
● telephone number
● preferred method of contact

Enquiry and booking information

This may include:
● services you are interested in
● preferred appointment times
● availability
● appointment history
● consultation notes
● communications concerning bookings or services

Health and screening information

To determine whether exercise can be provided safely, the business may collect:
● health screening responses
● Physical Activity Readiness Questionnaire responses
● medical conditions
● mobility limitations
● injuries
● relevant symptoms
● medication information
● information about advice received from healthcare professionals
● information concerning accessibility or reasonable adjustments

Health information is special category personal data and is subject to additional legal protection. Processing special category data requires both a lawful basis and a separate condition under the UK GDPR.

Emergency contact information

You may be asked to provide:
● the name of an emergency contact
● their relationship to you
● their telephone number
You should make sure that the person knows their information has been provided for emergency purposes.

Payment information

The business may process:
● payment status
● amount paid
● transaction date
● invoice information
● limited payment confirmation information
Card and mobile payments are processed through Square. Thrive Mobility London does not normally receive or store complete payment card details.

Website and technical information

Where enabled, the website may collect:
● IP address
● browser and device information
● pages visited
● time spent on the website
● referral information
● cookie preferences
● analytics information
● technical and security logs

Communications and complaints

Records may be kept of emails, telephone calls, messages, enquiries, feedback, rights requests and complaints

5.How personal information is collected

Personal information may be collected:
● directly from you through forms, email, telephone or in person
● through health screening or consultation documentation
● through a booking system when one is introduced
● through Square when you make a payment
● automatically through cookies and similar technologies
● from someone acting with your authority
● from emergency or safeguarding services where lawful and necessary

6.Why information is used

Personal information may be used to:
● respond to questions and enquiries
● arrange consultations and appointments
● assess whether exercise participation is appropriate
● plan and provide personal training or mobility services
● make appropriate service adjustments
● maintain client and attendance records
● process payments and issue payment confirmations
● communicate changes to appointments or services
● protect clients, the trainer and other people
● manage emergencies, safeguarding concerns or professional boundaries
● respond to complaints and data protection requests
● maintain accounting, tax and insurance records
● establish, exercise or defend legal claims
● protect the website against misuse or security threats
● understand and improve website performance
● comply with legal and regulatory responsibilities

7.Lawful bases

Thrive Mobility London may rely on the following lawful bases:
Contract and steps before entering a contract

Contact, booking, service and payment information may be processed where necessary to respond to your request, arrange a service or perform an agreement with you.
Legal obligation
Information may be processed where necessary to comply with tax, accounting, safeguarding, regulatory or other legal responsibilities.
Legitimate interests
Information may be processed where reasonably necessary to operate and protect the business, communicate with clients, maintain appropriate records, improve services, manage complaints or defend legal claims.
Before relying on legitimate interests, consideration will be given to whether the processing is necessary and whether it could unfairly affect your rights.
Consent
Consent may be used for optional communications, nonessential cookies or other processing where consent is the appropriate legal basis.
You may withdraw consent at any time. Withdrawal does not make earlier processing unlawful.
Vital interests
Information may be used where necessary to protect someone’s life in a genuine emergency, subject to the restrictions that apply to health and other special category data.

8.Health information and explicit consent

Health screening information is used to assess whether participation is appropriate and to adapt exercise safely.
Where health information is processed, Thrive Mobility London will generally rely on your explicit consent as the special category condition.
Explicit consent will be obtained through clear wording in the relevant screening or consent documentation and must be expressly confirmed.
You may withdraw your explicit consent. However, if essential health information can no longer be processed, Thrive Mobility London may be unable to continue providing exercise services safely.
Health information will not be used for unrelated advertising or sold to another organisation.

9.Sharing personal information

Personal information may be shared only where necessary with:
● website hosting and technical service providers
● booking or scheduling providers when introduced
● Square and associated payment service providers
● website analytics and cookie providers
● accountants, insurers, solicitors or other professional advisers
● emergency services or healthcare professionals where legally permitted and necessary to protect life or safety
● safeguarding authorities
● courts, regulators, law enforcement agencies or public authorities where disclosure is legally required
● service providers supporting the handling of enquiries, records or communications
Service providers are expected to use personal information only for the agreed purpose and to protect it appropriately.
personal information is not sold.

10.International data transfers

Some technology, hosting, analytics, booking or payment providers may process information outside the United Kingdom.

Where personal information is transferred internationally, Thrive Mobility London will take reasonable steps to ensure that an appropriate legal transfer mechanism and safeguards are in place.

This may include relying on:

● UK adequacy regulations
● an approved data transfer agreement
● the UK International Data Transfer Addendum
● another legally permitted safeguard

The precise arrangements will depend on the providers used at the relevant time.

11.Data retention

Personal information will not be kept for longer than reasonably necessary.
Retention periods are determined according to:

the reason the information was collected
● the duration of the client relationship
● safety and safeguarding considerations
● insurance and professional requirements
● accounting and tax obligations
● complaint or dispute requirements
● applicable limitation periods
● the need to establish, exercise or defend legal claims

Enquiry records that do not lead to a service will normally be deleted when they are no longer required for follow up, complaint handling or legitimate business administration.
Client, screening and session records may be retained after services end where this is necessary for insurance, professional, safety or legal purposes.
Payment and accounting records will be retained for the period required by tax and financial record keeping laws.
Cookie and analytics retention will depend on the technology used and the preferences selected through the cookie settings.
Information that is no longer required will be securely deleted, destroyed or anonymised.

12.Information security

Reasonable technical and organisational measures are used to protect personal information against:

● unauthorised access
● accidental loss
● misuse
● alteration
● disclosure
● destruction

Access to client and health information is restricted to people who genuinely need it for an authorised purpose.

No internet transmission or electronic storage system can be guaranteed to be completely secure. Any suspected data breach will be investigated and reported where legally required.

13.Confidentiality and safeguarding

Client information will be treated confidentially.
Information may be disclosed without consent where:

● disclosure is required by law
● there is a serious safeguarding concern
● disclosure is necessary to protect life
● a court, regulator or authorised public body lawfully requires it
● disclosure is necessary to establish, exercise or defend a legal claim

Only information that is relevant and necessary will be disclosed.

14.Cookies and website analytics

The website may use:
Essential cookies
These support security, website operation and basic functions. They may be placed where they are strictly necessary to provide the website or a service requested by the visitor.
Analytics cookies
These help explain how visitors use the website and support performance improvements.
Marketing cookies
These may be used to measure advertising or present more relevant promotional content.
A cookie banner should allow visitors to accept, reject or manage nonessential cookie preferences.
Visitors must be given clear information about cookies and, where legally required, must actively provide consent before nonessential technologies are used. Current law also permits limited exemptions for certain low risk uses, but the exact position depends on the technology and purpose.
Further information should be provided in the website’s Cookie Policy or cookie preference centre.

15.Your data protection rights

Depending on the circumstances, you may have the right to:
● be informed about how your information is used
● request access to your personal information
● ask for inaccurate information to be corrected
● ask for information to be erased
● ask for processing to be restricted
● object to certain processing
● receive certain information in a portable format
● withdraw consent
● complain about the handling of your information

Some rights are subject to legal conditions and exemptions.
A request should be sent to:
Email: richard@thrivemobilitylondon.co.uk
Identity verification or additional information may be requested where reasonably necessary.

16.Data protection complaints

You may complain if you believe Thrive Mobility London has not handled your personal information correctly.
Please send the complaint to:
Email: richard@thrivemobilitylondon.co.uk
Include:
● your name and contact details
● an explanation of your concern
● relevant dates or communications
● the outcome you are seeking

Thrive Mobility London will:
● provide a clear way to submit the complaint
● acknowledge receipt within 30 days
● take appropriate steps to investigate
● keep you informed where necessary
● communicate the outcome without unjustifiable or excessive delay

These complaint handling requirements have applied to UK organisations since 19 June 2026.
You also have the right to complain to the Information Commissioner’s Office, the United Kingdom’s data protection regulator.

17.Changes to this Privacy Policy

This policy will be reviewed regularly and may be updated where:
● data protection law changes
● new services are introduced
● a booking system is implemented
● payment or technology providers change
● new cookies or analytics tools are added
● business practices change
The latest version will be published on the website with its effective date

18.Contact

Questions, rights requests and complaints concerning personal information should be sent to:

Richard Mark Thompson
Trading as: Thrive Mobility London
Address: Whiston House, Goldsmiths Row, London E2 8SJ
Email: richard@thrivemobilitylondon.co.uk
Telephone: 0791 890 4528