PRIVACY POLICY — STRUCTIFY FIT

Version 1.0 — Effective from May 7, 2026

Structify Fit values the protection of your personal data. This privacy policy explains how Structify Fit handles your data, what we collect, why we collect it, and what rights you have.

This policy is drafted in accordance with the General Data Protection Regulation (GDPR).

1. Who is responsible?

Data Controller:

Structify Fit (sole proprietorship) Owner: Nick Address: Beukelaar 6, Someren Chamber of Commerce number: 98155563 Email: structifyfit@hotmail.com

For all questions regarding privacy or data processing, please contact us via the email address above.

2. Which personal data is processed?

Structify Fit processes the following categories of personal data:

Basic data:

• First and last name
• Email address
• Phone number
• Home address and country
• Date of birth / age
• Instagram handle

Coaching-related data:

• Height and weight
• Training experience and goals
• Available equipment and training frequency
• Work circumstances (sedentary/standing/physical)
• Nutrition habits
• Progress data (exercise performance, measurements)
• Photos and videos (before/after photos, technique feedback videos)

Special categories of personal data (health):

• Injuries and medical limitations
• Chronic conditions
• Medication use
• Food allergies and intolerances
• Medical clearance to train

Financial data:

• Payment details (processed via Shopify; Structify Fit does not receive full credit card or bank details)
• Invoice information

Technical data:

• IP address
• Browser behavior on the website
• Cookies (see article 9)

3. Why is this data processed?

Structify Fit processes personal data based on the following legal grounds:

Performance of the agreement (Article 6(1)(b) GDPR):

• Creating and adjusting personal training plans
• Weekly check-ins and feedback
• Communication about the coaching program
• Delivery of agreed services

Legal obligation (Article 6(1)(c) GDPR):

• Invoicing and accounting (retention period: 7 years per Dutch Tax Authority)
• Compliance with requirements of the Tax Authority and other regulators

Legitimate interest (Article 6(1)(f) GDPR):

• Customer communication and service
• Improvement of services
• System security and fraud prevention

Consent (Article 6(1)(a) GDPR / Article 9(2)(a) GDPR):

• Processing of health data (explicit consent via registration form and coaching agreement)
• Use of photos, testimonials, or progress data for marketing
• Sending newsletters or promotional messages

Consent can be withdrawn at any time via structifyfit@hotmail.com.

4. With whom is data shared?

Structify Fit shares personal data only with the following parties, and only to the extent necessary for the service provision:

With each party that processes personal data on behalf of Structify Fit, a Data Processing Agreement (DPA) is concluded where applicable, in accordance with GDPR.

Structify Fit does not sell or rent personal data to third parties for commercial purposes.

5. How is data secured?

Structify Fit takes appropriate technical and organizational measures to protect personal data:

• Strong, unique passwords for all systems
• Two-factor authentication (2FA) on all relevant accounts
• Encrypted storage of sensitive data
• Restricted access: only Structify Fit itself has access to client data
• No loose, unsecured storage (such as public cloud folders)
• Regular updates of software and devices

In case of a data breach involving sensitive personal data, this will be reported to the Dutch Data Protection Authority within 72 hours and, where applicable, to the affected clients.

6. How long is data retained?

Structify Fit applies the following retention periods:

After the retention period expires, data is securely and permanently deleted.

7. What rights do you have as a client?

Under the GDPR, you have the following rights:

Right of access — you can request which data Structify Fit processes about you.

Right to rectification — you can have incorrect data corrected.

Right to erasure ("right to be forgotten") — you can request deletion of your data, subject to legal retention obligations.

Right to restriction — you can request that processing be temporarily restricted.

Right to data portability — you can request your data in a common file format to transfer to another party.

Right to object — you can object to processing based on legitimate interest.

Right to withdraw consent — for processing based on consent, such as marketing.

Right to lodge a complaint with the Dutch Data Protection Authority — if you believe Structify Fit is not handling your data correctly. More information: autoriteitpersoonsgegevens.nl.

Requests can be submitted via structifyfit@hotmail.com. Structify Fit will respond within 30 days.

8. Transfer outside the EU

Structify Fit only provides services to clients within the European Union, the United Kingdom, Switzerland, Norway, Iceland, and Liechtenstein.

Some processors (such as Shopify, Meta platforms for Instagram) may process data outside the EU. In those cases, legally permitted safeguards are used, such as the Standard Contractual Clauses of the European Commission.

9. Cookies

The Structify Fit website uses cookies:

Functional cookies — necessary for the website to function (shopping cart, session). No consent required.

Analytical cookies — to measure visitor behavior and improve the website.

Marketing cookies — to display targeted advertisements (for example via Meta Ads).

On your first visit to the website, a cookie banner will appear allowing you to set your preferences. You can adjust your settings at any time.

For more details, see our separate Cookie Policy.

10. Changes

This privacy policy may be amended when legislation, services, or practices give cause for it. The most current version is always available on the Structify Fit website. In case of significant changes, existing clients will be informed via email.

11. Contact

For all questions, requests, or complaints regarding privacy:

Structify Fit Email: structifyfit@hotmail.com KvK: 98155563 VAT: NL005310849B55

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Version 1.0 — May 7, 2026