1. Who We Are
Her Daily Fit is a website operated by Pozitive Ltd, a company registered in England and Wales under company number 10954315. Our registered office address is 85 Great Portland Street, First Floor, London, W1W 7LT.
Pozitive Ltd is registered as a data controller with the Information Commissioner’s Office (ICO). Our registration reference number is [ICO NUMBER – TO BE ADDED ON RECEIPT].
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at: info@herdailyfit.com
2. What This Policy Covers
This Privacy Policy explains how we collect, use, share and protect your personal data when you visit herdailyfit.com (the “Site”), subscribe to our newsletter, use our programme finder quiz, or interact with our content.
We comply with the following laws and regulations:
- UK GDPR and Data Protection Act 2018 – for all users and for all processing carried out by Pozitive Ltd as a UK-established company
- EU General Data Protection Regulation (EU GDPR) – for visitors based in the EU/EEA
- Privacy and Electronic Communications Regulations 2003 (PECR) – governing cookies and electronic marketing
- California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA 2023) – for California residents
3. Personal Data We Collect
Data you provide directly:
- Your name and email address when you subscribe to our newsletter
- Any information you provide when contacting us by email or via a contact form
Data collected automatically when you visit the Site:
- IP address (used to derive approximate location at country/city level – not stored in full)
- Browser type, device type and operating system
- Pages visited, time spent on pages, and the URL that referred you to our Site
- Cookie identifiers and advertising IDs (only with your consent – see Section 6)
Data from third-party partners:
- Advertising performance and audience data from Google Ads and Meta
- Site analytics data from Google Analytics 4
4. A Note on Health-Related and Special Category Data
Our Site covers fitness programmes for women, including topics such as perimenopause, strength training and general wellbeing. We are aware that health information is classified as “special category data” under Article 9 UK GDPR and attracts the highest level of protection.
We collect health data in one specific, limited context – our programme finder quiz (see below). For all other purposes:
- We do not infer or profile users based on health characteristics
- We do not ask for medical history or health conditions
- If you voluntarily share health information when contacting us, we will use it only to respond to your query and will not retain it beyond that purpose
Our programme finder quiz
Most quiz questions ask about your fitness goals, schedule, equipment, and budget. We treat these as general preference data, not health data. Responses are not linked to your identity unless you choose to create an account.
The final quiz question asks about your hormonal health stage (premenopause, perimenopause, or postmenopause). This question involves health data under Article 9 UK GDPR. It is entirely optional – you may skip it without affecting your other results. If you choose to answer, you do so with full knowledge that this constitutes health information, and we rely on your explicit consent under Article 9(2)(a) UK GDPR. Your answer is used solely to personalise your programme recommendations and is not stored beyond your current session.
5. Why We Use Your Data – Legal Bases
We are required by UK GDPR to have a lawful basis for every type of processing we carry out.
| Processing activity | Legal basis |
|---|---|
| Sending our newsletter and email marketing | Consent (Article 6(1)(a)) – you can withdraw at any time via the unsubscribe link |
| Site analytics and performance monitoring | Legitimate interests (Article 6(1)(f)) – we have a genuine interest in understanding how our content performs. We have conducted a Legitimate Interests Assessment and concluded this does not override your rights, given the limited intrusiveness of analytics and your right to opt out |
| Displaying personalised advertising | Consent (Article 6(1)(a)) – advertising cookies are only placed with your prior consent via our cookie banner |
| Affiliate tracking | Legitimate interests (Article 6(1)(f)) – tracking referrals for commission is a minimal, industry-standard practice |
| Responding to enquiries | Legitimate interests / contract performance |
| Fraud prevention and legal compliance | Legal obligation / legitimate interests |
Where we rely on legitimate interests, you have the right to object at any time – see Section 11.
6. Cookies and Tracking Technologies
We use cookies and similar tracking technologies on this Site. Under the Privacy and Electronic Communications Regulations 2003 (PECR), we must obtain your prior informed consent before placing any non-essential cookies on your device.
We use a cookie consent banner to obtain your consent before any non-essential cookies are set. You can change or withdraw your consent at any time using the cookie settings link in the footer of every page.
Strictly necessary cookies – required for the Site to function. No consent required. Examples include session management and security cookies.
Analytics cookies – we use Google Analytics 4 (GA4) to understand how visitors use our Site. GA4 does not log or store full IP addresses by default. Analytics cookies are only placed with your consent.
Advertising and retargeting cookies – we use Google Ads and Meta Pixel for advertising. These cookies are only placed with your consent.
Affiliate tracking cookies – used to attribute referrals and calculate commissions. Placed only with your consent.
A full list of cookies used on this Site is available in our Cookie Policy.
7. Third-Party Partners and Data Processors
Google Analytics 4
We use Google Analytics 4 (GA4) to monitor Site performance. GA4 does not log or store IP addresses by default. Data is processed by Google LLC under Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework (DPF) and the UK Extension to the EU-US DPF (in force October 2023). Privacy Policy: policies.google.com/privacy
Google Ads
We use Google Ads for advertising and remarketing. International transfers are covered by Standard Contractual Clauses and the EU-US DPF. Privacy Policy: policies.google.com/privacy
Meta Pixel (Facebook / Instagram) – Joint Controller Notice
We use Meta Pixel on our Site to measure advertising effectiveness and enable remarketing.
Important: For the processing of data collected via Meta Pixel, Pozitive Ltd and Meta Platforms Ireland Limited are joint controllers under Article 26 UK GDPR and Article 26 EU GDPR. Both parties jointly determine the purposes and means of this processing. The basis for this arrangement is the Facebook Business Tools Terms, available at facebook.com/legal/terms/businesstools. Meta is primarily responsible for enabling you to exercise your data subject rights in respect of the jointly processed data. Meta’s Privacy Policy: facebook.com/privacy/policy
MailPoet (Email Marketing)
We use MailPoet to manage our newsletter subscriptions and send marketing emails. MailPoet is developed by Automattic Inc. (the company behind WordPress.com). Emails are sent via MailPoet’s sending service, which processes subscriber data on servers operated by Automattic. Data may be processed in the United States under Standard Contractual Clauses. We use a double opt-in process – after entering your email address, you will receive a confirmation email and must click the confirmation link before we add you to our list. Privacy Policy: automattic.com/privacy
Hosting Provider
Our Site is hosted by IONOS SE. We have a Data Processing Agreement in place with our hosting provider.
Affiliate Networks
We participate in affiliate programmes. When you click an affiliate link, the affiliate network may set a tracking cookie (with your consent) to attribute any purchase to our referral. Please refer to each network’s privacy policy for details of their data practices.
8. International Data Transfers
Some of our third-party partners are based outside the UK and EEA – in particular, Google LLC and Meta Platforms Inc. are based in the United States. Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including:
- Standard Contractual Clauses (SCCs) approved by the UK ICO (International Data Transfer Agreement / Addendum) or the European Commission
- The EU-US Data Privacy Framework (DPF) and its UK Extension (October 2023), applicable to Google and Meta
- Adequacy decisions made by the UK Secretary of State or European Commission, where applicable
9. How Long We Keep Your Data
| Type of data | Retention period |
|---|---|
| Newsletter subscriber data | Until you unsubscribe, then deleted within 30 days |
| Contact form and email enquiries | 2 years from date of enquiry |
| Analytics data | 14 months (Google Analytics 4 default) |
| Advertising data | As set by Google and Meta in their respective data policies |
| Cookie consent records | 3 years |
10. Automated Processing and Profiling
Programme Finder Quiz: Our programme finder quiz uses your answers to suggest fitness programmes. This constitutes automated processing under Article 22 UK GDPR. No legal or similarly significant decisions are made based on quiz results – the output is a content recommendation only. You have the right to request human review of any automated recommendation by contacting us at info@herdailyfit.com.
Advertising Profiling: Our advertising partners (Google and Meta) may use your data to build advertising profiles and serve personalised ads. You can control this via your cookie preferences on this Site, Google Ad Settings, or Meta Ad Preferences.
11. Your Rights Under UK GDPR (and EU GDPR)
You have the following rights in relation to your personal data:
- Right of access – request a copy of the personal data we hold about you
- Right to rectification – ask us to correct inaccurate or incomplete data
- Right to erasure – ask us to delete your personal data, subject to certain legal exceptions
- Right to restriction – ask us to restrict processing in certain circumstances
- Right to data portability – receive your data in a structured, machine-readable format
- Right to object – object to processing based on legitimate interests, including for direct marketing
- Right to withdraw consent – where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing
- Rights related to automated decisions – request human review of any automated decision that significantly affects you
To exercise any of these rights, contact us at info@herdailyfit.com. We will respond within one calendar month.
12. Data Breach Notification
In the event of a personal data breach, we will:
- Notify the ICO within 72 hours of becoming aware of any breach likely to result in a risk to your rights and freedoms (Article 33 UK GDPR)
- Notify you without undue delay if a breach is likely to result in a high risk to your rights and freedoms (Article 34 UK GDPR), describing the nature of the breach, its likely consequences, and the steps we are taking
We maintain appropriate technical and organisational measures to protect your data against unauthorised access, loss or destruction.
13. Children’s Privacy
This Site is intended for adults aged 18 and over and is not directed at children. We do not knowingly collect personal data from anyone under the age of 18. If you believe we have inadvertently collected data from a child, please contact us at info@herdailyfit.com immediately and we will delete it without delay.
14. Your Rights If You Are Based in California (CCPA / CPRA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA 2023).
Categories of personal information we collect about California residents:
- Identifiers (name, email address, IP address, cookie IDs, advertising IDs)
- Internet or electronic network activity (pages visited, content interactions, browsing history on our Site)
- Geolocation data (approximate location derived from IP address – city/country level only)
- Inferences drawn from the above to create a profile about your content preferences
Do we sell your personal information? We do not sell personal information in exchange for money. However, we “share” certain personal data (cookie identifiers, advertising IDs and browsing data) with Google and Meta for cross-context behavioural advertising. Under the CPRA, this constitutes “sharing” and California residents have the right to opt out.
???? Do Not Sell or Share My Personal Information
To opt out, click the link above or manage your preferences via the cookie settings in our footer. We also honour the Global Privacy Control (GPC) browser signal.
Your CCPA/CPRA rights:
- Right to know what personal information we collect, use, disclose and share
- Right to delete your personal information
- Right to correct inaccurate personal information
- Right to opt out of the sale or sharing of personal information
- Right to limit use and disclosure of sensitive personal information
- Right of no retaliation
To exercise your California rights, contact us at info@herdailyfit.com. We will respond within 45 days (extendable by a further 45 days with notice).
Authorised agent: You may designate an authorised agent to make a request on your behalf. We will require written proof of authorisation.
15. Complaints
UK residents: You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113.
EU/EEA residents: You may lodge a complaint with your local Data Protection Authority. A list of EU supervisory authorities is available at edpb.europa.eu.
We would always appreciate the opportunity to address your concerns before you contact a regulator. Please reach out to us first at info@herdailyfit.com.
16. Changes to This Policy
We may update this Privacy Policy from time to time. For minor changes, we will update the “Last updated” date above. For material changes (new types of data collected, new uses, new third-party partners), we will provide at least 30 days’ prior notice by email to newsletter subscribers and/or a prominent notice on the Site. Continued use of the Site after the end of the notice period constitutes acceptance of the updated Policy.
17. Contact Us
Pozitive Ltd
Email: info@herdailyfit.com
85 Great Portland Street, First Floor, London, W1W 7LT
Company Registration Number: 10954315
ICO Registration Number: [TBC]
Her Daily Fit is a trading name of Pozitive Ltd.
