Privacy Policy
Last updated: September 2026
1. ABOUT THIS PRIVACY POLICY
NutriManager is committed to protecting your privacy and handling your personal information lawfully, fairly, securely and transparently.
This Privacy Policy explains how NUTRIMANAGER LTD collects, uses, stores, shares and protects your personal information when you:
• visit the NutriManager website;
• submit a coaching application or enquiry;
• book or attend a consultation;
• purchase a coaching programme or other service;
• complete an onboarding assessment or progress check-in;
• participate in nutrition and/or training coaching;
• communicate with NutriManager; or
• otherwise use our services.
It also explains your rights under applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. WHO WE ARE
NutriManager is operated by NUTRIMANAGER LTD, a private limited company registered in England and Wales under company number 16321203.
NUTRIMANAGER LTD provides online nutrition and training coaching services and is the data controller responsible for determining how and why the personal information described in this Privacy Policy is processed.
Registered office:
Apartment 1009 X Q 7 Building
Taylorson Street South
Salford
England
M5 3FY
Email: info@nutrimanager.co.uk
Website: nutrimanager.co.uk
If you have any questions about this Privacy Policy or how we handle your personal information, please contact us using the email address above.
3. PERSONAL INFORMATION WE MAY COLLECT
The information we collect depends on how you interact with NutriManager and the services you use.
3.1 Identity and contact information
We may collect:
• Full name
• Date of birth
• Email address
• Telephone number
• Contact preferences
• Other identifying or contact information you choose to provide
3.2 Coaching application and consultation information
When you apply for coaching or arrange a consultation, we may collect:
• The coaching programme you are interested in
• Your main goals
• What you would like help with
• Information you choose to provide about your current circumstances
• Information you choose to provide in response to the question asking whether there is anything we should be aware of before your consultation
• Information discussed during your consultation
We intentionally limit the information requested during the initial application process. More detailed health, lifestyle and assessment information is requested only when appropriate during onboarding and coaching.
3.3 Health and nutrition information
To provide safe, appropriate and personalised nutrition and dietetic services, we may collect information relating to your health and nutrition, including:
• Relevant medical conditions and medical history
• Medications and supplements
• Allergies and food intolerances
• Dietary requirements
• Relevant symptoms
• Previous or current nutrition-related concerns
• Dietary intake and eating habits
• Food preferences
• Relevant blood test results or other medical information you choose to provide
• Other health information relevant to the services we provide
Information concerning health is special category personal data under UK data protection law and receives additional protection.
3.4 Lifestyle and training information
Depending on the service you receive, we may collect information about:
• Physical activity
• Exercise and training history
• Current training programme
• Training experience
• Available training equipment
• Injuries or physical limitations
• Sleep
• Stress
• Occupation and daily routine
• Lifestyle habits
• Goals relating to fitness, strength, performance or body composition
3.5 Anthropometric and progress information
Where relevant to your programme, we may collect:
• Height
• Weight
• Waist, hip and other body measurements
• Body composition information where available
• Progress measurements
• Nutrition and training records
• Progress check-in information
• Information about adherence, challenges, habits and outcomes
3.6 Photographs
You may have the option to provide photographs for purposes such as progress monitoring or assisting with your coaching.
Providing progress photographs is optional unless we clearly explain otherwise for a particular service.
Photographs supplied privately for coaching or progress-monitoring purposes will not automatically be used for advertising, social media, testimonials, website content or other promotional purposes.
If NutriManager wishes to use identifiable client photographs or other client material for promotional purposes, separate permission will be sought where required.
3.7 Communications
We may retain information contained in communications between you and NutriManager, including:
• Emails
• Messages sent through the coaching platform
• Information submitted through forms
• Consultation and check-in information
• Questions, feedback and other communications relating to your programme
3.8 Payment and transaction information
When you purchase a NutriManager service, we may process information including:
• The service or programme purchased
• Amount paid
• Transaction date
• Payment status
• Instalment status where applicable
• Invoice and billing information
• Refund information where applicable
Payments are processed through Stripe. NutriManager does not need to receive or store your complete payment-card details when those details are processed directly by Stripe.
3.9 Website and technical information
When you use the NutriManager website, Wix and technologies used by the website may collect certain technical information, such as:
• IP address
• Browser type
• Device information
• Website activity and interaction information
• Cookie identifiers and similar technical information
Further information about non-essential cookies and similar technologies will be provided through our website cookie settings or Cookie Policy where applicable.
4. HOW WE COLLECT YOUR INFORMATION
We primarily collect personal information directly from you.
This may occur when you:
• Submit an application or enquiry through our Wix website
• Communicate with us by email
• Book or attend a consultation
• Complete an onboarding assessment through Tally
• Purchase a programme through Stripe
• Create or use your Everfit coaching account
• Complete a progress check-in
• Upload measurements, photographs or other information
• Record nutrition, activity or training information
• Communicate through Everfit or another approved communication method
• Provide information during consultations or progress reviews
In some circumstances, you may choose to provide information originating from another healthcare professional or organisation, such as blood test results, medical correspondence or other health information.
We may also receive limited transaction information from payment providers and technical information from
our website and service providers.
5. HOW WE USE YOUR INFORMATION
We may use personal information where necessary to:
• Receive and review coaching applications and enquiries
• Contact you regarding your application
• Arrange and conduct consultations
• Assess whether a NutriManager service is appropriate for you
• Help determine the most appropriate coaching programme
• Process enrolment and payments
• Conduct nutrition, lifestyle, health and/or training assessments
• Provide personalised nutrition and dietetic services
• Develop personalised nutrition and/or training programmes
• Provide appropriate evidence-based recommendations
• Monitor your progress
• Review measurements and check-ins
• Adjust your programme based on your progress and feedback
• Provide ongoing coaching, accountability and support
• Communicate with you during your programme
• Manage appointments and consultations
• Manage your Everfit coaching account
• Provide educational materials and resources
• Maintain appropriate client and professional records
• Issue or maintain invoices and transaction records
• Respond to questions, complaints or requests
• Protect the security and integrity of our services
• Meet applicable legal, professional, regulatory, accounting and tax requirements
• Establish, exercise or defend legal claims where necessary
We will not use personal information for a materially incompatible purpose without an appropriate lawful basis and, where required, informing you first.
6. OUR LAWFUL BASES FOR PROCESSING
Under the UK GDPR, we must have an appropriate lawful basis for processing personal information.
Depending on the purpose and circumstances, NutriManager may rely on the following bases.
Contract and steps before entering into a contract
We may process personal information where this is necessary to take steps at your request before entering into a contract or to perform our contract with you.
This includes activities such as:
• Reviewing a coaching application
• Arranging an initial suitability consultation
• Administering enrolment
• Providing the coaching programme you have purchased
• Communicating with you about your service
• Managing appointments and programme delivery
Legal obligation
We may process information where necessary to comply with legal requirements applicable to NutriManager, including relevant tax, accounting, regulatory or legal obligations.
Legitimate interests
We may process certain personal information where necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your interests, rights and freedoms.
These legitimate interests may include:
• Operating and administering NutriManager
• Responding to enquiries
• Maintaining appropriate business and client records
• Protecting our systems and services
• Preventing misuse or fraud
• Managing and improving our services
• Establishing, exercising or defending legal rights
Where we rely on legitimate interests, we consider whether the processing is necessary and proportionate and whether your rights and interests override those interests.
Consent
We may rely on your consent for particular activities where consent is the appropriate lawful basis, such as certain marketing communications or specific optional uses of photographs or testimonials.
Where processing relies on consent, you can withdraw that consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.
7. HEALTH AND OTHER SPECIAL CATEGORY PERSONAL DATA
Health information is classified as special category personal data under the UK GDPR and is subject to additional legal protection.
Where NutriManager processes health information for the purpose of providing appropriate nutrition, dietetic or related health services, we may rely on Article 9(2)(h) of the UK GDPR and the relevant provisions of the Data Protection Act 2018 where the requirements of that condition are met.
This condition permits necessary processing for purposes including the provision of health care or treatment where the applicable legal safeguards are satisfied.
Dietetic services are provided by an HCPC Registered Dietitian who is subject to professional standards and obligations relating to confidentiality.
We will only process health information where it is relevant and necessary for the services being provided.
For processing that falls outside the health-care condition, another appropriate Article 9 condition will be identified where required. For example, we may seek explicit consent for a particular optional use of special category information where explicit consent is the appropriate condition.
Providing information that is necessary for us to safely and appropriately deliver a requested coaching or dietetic service may be necessary for us to provide that service. If relevant information is not provided, we may be unable to provide some or all of the requested service safely or appropriately.
8. THE SERVICES AND PLATFORMS WE USE
NutriManager uses third-party technology providers to operate our website, communicate with clients, process payments and deliver coaching.
These currently include, or are intended to include:
Wix
The NutriManager website is hosted and operated using Wix. Information submitted through website forms, including initial coaching applications, may be processed through Wix.
Stripe
Stripe is used to process payments and may also be used to provide payment confirmations, receipts or invoices.
Stripe processes payment information in accordance with its own privacy and security arrangements.
Tally
Tally is used for onboarding assessments and may also be used for questionnaires, progress check-ins and other forms.
Because our onboarding assessment is personalised, information submitted through Tally may include health information, lifestyle information, nutrition information, anthropometric measurements and other information necessary to provide the service.
Everfit
Everfit is used as NutriManager's coaching and client-management platform.
Depending on your programme and how you use the platform, Everfit may process information including:
• Name and contact information
• Date of birth
• Nutrition information
• Training information
• Measurements and progress information
• Photographs you choose to upload
• Messages and communications
• Coaching programme information
• Other information you choose to record or share through the platform
Namecheap Private Email
NutriManager uses Namecheap Private Email for business email communications.
Information contained in emails sent to or from NutriManager may therefore be processed through the email service.
Booking and video consultation providers
NutriManager intends to use an online scheduling service and a secure video-conferencing service for arranging and conducting consultations.
At present, Calendly and Google Meet are the intended services. This Privacy Policy will be updated if necessary once the final booking and video consultation systems are implemented.
These third-party providers have their own privacy practices and may act as processors on our behalf or, for certain activities, as independent data controllers.
9. WHO WE SHARE PERSONAL INFORMATION WITH
NutriManager does not sell your personal information.
Where necessary to operate our business or provide your services, information may be processed or shared with appropriate service providers, including:
• Website and form providers
• Coaching and client-management platforms
• Payment processors
• Email providers
• Booking and scheduling providers
• Video-conferencing providers
• Cloud and data-storage providers where used
• IT and security providers where required
• Accountants, legal advisers, insurers or other professional advisers where necessary
We may also disclose information where:
• We are legally required to do so
• It is necessary to protect someone's vital interests in an appropriate situation
• It is necessary for the establishment, exercise or defence of legal claims
• Another lawful basis permits or requires disclosure
We will not routinely disclose your health information to family members, employers or other third parties without an appropriate legal basis or your authorisation.
10. INTERNATIONAL DATA TRANSFERS
Some of the technology providers used by NutriManager operate internationally or use infrastructure located outside the United Kingdom.
As a result, personal information may in some circumstances be processed outside the UK.
Where UK data protection law requires safeguards for an international transfer, NutriManager will take reasonable steps to ensure that an appropriate transfer mechanism is in place. Depending on the circumstances, this may include UK adequacy regulations or appropriate contractual safeguards recognised under UK data protection law.
You may contact us at info@nutrimanager.co.uk if you would like further information about applicable safeguards relating to your personal information.
11. HOW WE PROTECT YOUR INFORMATION
NutriManager takes appropriate technical and organisational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access or misuse.
Measures may include, where appropriate:
• Password-protected accounts and devices
• Appropriate account access controls
• Secure third-party platforms
• Multi-factor authentication where available and appropriate
• Limiting access to information to those who require it
• Appropriate handling of client information
• Secure storage and transmission practices
• Maintaining confidentiality of health and coaching information
While no online or electronic system can guarantee absolute security, we take reasonable measures proportionate to the nature and sensitivity of the information we process.
12. HOW LONG WE KEEP PERSONAL INFORMATION
We do not keep personal information for longer than is necessary for the purposes for which it was collected, subject to applicable professional, legal, regulatory, insurance, accounting and record-keeping requirements.
Different types of information may therefore be retained for different periods.
Client coaching and health records
NutriManager will normally retain relevant adult client coaching and health records for 8 years following the end of the client's coaching relationship with NutriManager, unless there is a professional, legal, regulatory, insurance or other legitimate reason requiring a different retention period.
Records retained as part of the client record may include, where relevant:
• Onboarding assessments and health information
• Nutrition, lifestyle and training assessments
• Anthropometric measurements and progress records
• Progress check-ins
• Nutrition and/or training programmes provided
• Relevant consultation and coaching notes
• Relevant client communications
• Relevant information recorded through Everfit
• Information necessary to understand recommendations, programme changes and professional decisions made during the client's coaching
Retaining an appropriate client record helps NutriManager meet professional record-keeping obligations, respond appropriately to any subsequent questions or concerns and, where appropriate, provide continuity if a former client returns for further services.
Everfit and other coaching platforms
When a coaching programme ends, the client's active Everfit coaching account may be archived rather than immediately deleted.
Archiving allows relevant historical coaching information to remain available during the applicable retention period and may support continuity of service if the client returns to NutriManager in the future.
Where appropriate, an archived client may subsequently be reactivated if they purchase or begin a new NutriManager service.
Information held through Tally, Everfit or other systems used by NutriManager will be retained only where it remains necessary as part of the client record or for another legitimate professional, legal or business purpose.
Enquiries and unsuccessful applications
Information relating to enquiries and prospective clients who do not proceed with a NutriManager service will be retained only for an appropriate period where necessary to manage the enquiry, respond to subsequent questions, establish or defend legal claims or meet another legitimate business or legal requirement.
Information that is no longer required for these purposes will be securely deleted or otherwise appropriately disposed of.
Payment and accounting records
Payment, invoice, transaction and accounting information will be retained for the period required by applicable tax and accounting legislation.
NutriManager will normally retain relevant company tax and accounting records for at least 6 years from the end of the relevant accounting period, or longer where required by law or HM Revenue & Customs.
Marketing information
Personal information processed for marketing purposes on the basis of consent will be retained until consent is withdrawn or the information is no longer required.
Limited information may be retained where necessary to record and respect a person's request not to receive future marketing communications.
Review and secure disposal
Retention applies regardless of where relevant records are held, including appropriate records held through NutriManager's approved digital systems and service providers.
At the end of the applicable retention period, NutriManager will review whether there is a continuing professional, legal, regulatory, insurance or other legitimate reason to retain the information.
Where there is no continuing reason for retention, the information will be securely deleted, anonymised or otherwise appropriately disposed of.
13. MARKETING COMMUNICATIONS
Submitting a coaching application, booking a consultation or purchasing a NutriManager programme does not automatically mean that you have agreed to receive unrelated promotional marketing.
Where consent is required for electronic marketing, we will request it separately.
If you choose to receive marketing communications, you can unsubscribe at any time by using an unsubscribe facility provided in the communication or by contacting:
Administrative and service communications relating to your application, consultation, payment, onboarding or active coaching programme are not the same as promotional marketing and may still be sent where necessary to administer or provide your service.
14. PHOTOGRAPHS, TESTIMONIALS AND MARKETING MATERIAL
Photographs, messages, measurements, testimonials or other information supplied as part of private coaching will not automatically be treated as permission for NutriManager to publish them.
Where we wish to use identifiable client material for advertising, testimonials, social media, website content or other promotional purposes, we will seek appropriate separate permission where required.
Declining permission for promotional use will not affect your ability to receive NutriManager coaching services.
Where promotional use is based on consent, you may withdraw that consent for future use by contacting us, subject to any limitations relating to material that has already been lawfully published or distributed.
15. YOUR DATA PROTECTION RIGHTS
Depending on the circumstances and the lawful basis used for processing, UK data protection law may give you rights including:
• The right to be informed about how your information is used
• The right to request access to your personal information
• The right to request correction of inaccurate or incomplete information
• The right to request erasure of personal information in certain circumstances
• The right to request restriction of processing in certain circumstances
• The right to object to certain processing
• The right to data portability in certain circumstances
• Rights relating to certain automated decision-making
• The right to withdraw consent where processing is based on consent
These rights are not absolute and may not apply in every situation.
For example, we may need to retain certain information despite an erasure request where we have a legal or professional reason to retain it or where another applicable exemption or lawful basis permits retention.
To exercise a data protection right, contact:
We may need to verify your identity before responding to a request.
16. YOUR RIGHT TO OBJECT
Where we process personal information on the basis of legitimate interests, you have the right to object to that processing in certain circumstances.
You also have the right to object to the use of your personal information for direct marketing.
To exercise your right to object, contact:
17. AUTOMATED DECISION-MAKING
NutriManager does not use solely automated decision-making to determine whether you are suitable for coaching or to make decisions about your personalised nutrition or training programme that produce legal or similarly significant effects.
Applications, assessments and coaching decisions involve human and, where appropriate, professional review.
Technology may be used to assist with administration, tracking and delivery, but personalised coaching decisions are not intended to be made solely by automated systems.
18. CHILDREN AND YOUNG PEOPLE
NutriManager's standard online coaching services are intended for adults aged 18 and over unless we specifically agree to provide an appropriate service to a person under 18.
Where services are provided to a child or young person, appropriate arrangements concerning parental responsibility, consent, confidentiality, safeguarding and data protection will be considered before the service begins.
We do not knowingly seek to collect children's personal information through our standard website coaching application where the service is not intended for them.
19. COOKIES AND WEBSITE TECHNOLOGIES
The NutriManager website may use cookies and similar technologies.
Some cookies may be necessary for the website to operate correctly. Other cookies, such as analytics or marketing cookies, may require an appropriate choice or consent before they are used.
Where required, users will be provided with appropriate cookie controls.
More detailed information may be provided in a separate Cookie Policy or through the website's cookie-management system.
20. THIRD-PARTY WEBSITES AND SERVICES
Our website or communications may contain links to third-party websites or services.
Third-party organisations may process personal information under their own privacy policies where they act as independent controllers.
NutriManager is not responsible for the privacy practices of independent third-party organisations. We encourage you to review the relevant privacy information when using external services.
21. DATA BREACHES
NutriManager maintains procedures for responding to suspected personal data breaches.
Where a breach creates a legal requirement to notify the Information Commissioner's Office or affected individuals, we will take the appropriate steps in accordance with applicable data protection law.
22. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes to:
• NutriManager services
• Technology and service providers
• Our data-processing practices
• Legal or regulatory requirements
The latest version will be made available through the NutriManager website and the “Last updated” date will be amended accordingly.
Where a change materially affects how we use existing personal information, we will take appropriate steps to bring that change to the attention of affected individuals where required.
23. QUESTIONS, REQUESTS AND COMPLAINTS
If you have questions about this Privacy Policy, wish to exercise your data protection rights or have concerns about how NutriManager handles your personal information, please contact:
NUTRIMANAGER LTD
Email: info@nutrimanager.co.uk
Registered office:
Apartment 1009 X Q 7 Building
Taylorson Street South
Salford
England
M5 3FY
We encourage you to contact us first so that we have an opportunity to address your concern.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data protection regulator.