Last updated: 3/14/2025

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use SCULPT and tells you about your privacy rights under UK data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

We use your personal data to provide and improve SCULPT. By using SCULPT, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation

The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

Account means a unique account created for you to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Company (referred to as either "the Company", "we", "us" or "our") refers to Daniel Graham Consultancy Limited, registered in the United Kingdom.
Cookies are small files placed on your computer, mobile device or any other device by a website, containing details of your browsing history on that website among its many uses.
Country refers to: United Kingdom
Device means any device that can access the Service such as a computer, a mobile phone or a digital tablet.
Personal Data means any information relating to an identified or identifiable individual.
Service refers to SCULPT.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service or assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Legal Basis for Processing Personal Data

Under UK data protection law, we must have a valid legal basis for processing your personal data. The legal bases we rely on are:

Contract performance: Processing necessary for the performance of a contract with you
Legitimate interests: Processing necessary for our legitimate interests, provided your rights don't override these interests
Legal obligation: Processing necessary to comply with our legal obligations
Consent: Processing based on your consent

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. This may include, but is not limited to:

Email address
First and last name
Phone number
Body composition data
Training and workout data
Health and fitness metrics
Device information

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track activity on our Service and store certain information. These technologies include:

Cookies or Browser Cookies: A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service.
Web Beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons that permit the Company to count users who have visited those pages or opened an email and for other related website statistics.

We use both Session and Persistent Cookies:

Necessary / Essential Cookies: Type: Session Cookies. Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features.
Cookies Policy / Notice Acceptance Cookies: Type: Persistent Cookies. Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies: Type: Persistent Cookies. Purpose: These Cookies allow us to remember choices you make when you use the Website.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service
To manage your Account
For the performance of a contract
To contact you regarding updates or informative communications
To provide you with news and special offers
To manage your requests
For business transfers
For other purposes such as data analysis and service improvement

Sharing of Your Personal Data

We may share your personal information in the following situations:

With Service Providers
For business transfers
With Affiliates
With business partners
With other users (when you share information publicly)
With your consent

Your Rights Under UK Data Protection Law

Under UK data protection law, you have the following rights:

The right to be informed about our collection and use of your personal data
The right to access your personal data
The right to have inaccurate personal data rectified
The right to be forgotten (deletion or removal of personal data)
The right to restrict processing of your personal data
The right to data portability (obtaining a copy of your data to reuse)
The right to object to our use of your personal data
Rights relating to automated decision-making and profiling

To exercise any of these rights, please contact us using the details in the Contact section. We will respond to all legitimate requests within one month.

International Transfers

Your information may be transferred to and processed in countries outside the UK. When we do so, we ensure appropriate safeguards are in place in compliance with UK data protection law. These safeguards include using standard contractual clauses approved by the UK government or other appropriate safeguards under the UK GDPR.

Data Retention

We retain your personal data only for as long as necessary for the purposes set out in this Privacy Policy or to comply with legal obligations. Usage Data is generally retained for a shorter period unless used for security or functionality improvements, or we are legally obligated to retain it longer.

Security of Your Personal Data

While we implement commercially acceptable means to protect your Personal Data, no method of transmission over the Internet or electronic storage is 100% secure. We strive to use commercially acceptable means to protect your Personal Data, but cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

Links to Other Websites

Our Service may contain links to other websites not operated by us. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Subscriptions

SCULPT offers auto-renewing subscriptions. Payment will be charged to your Apple ID account at the confirmation of purchase. Subscription automatically renews unless it is canceled at least 24 hours before the end of the current period. Your account will be charged for renewal within 24 hours prior to the end of the current period. You can manage and cancel your subscriptions by going to your account settings on the App Store after purchase.

Prices are in US Dollars (USD). Pricing in other countries may vary and actual charges may be converted to your local currency depending on your country of residence.

Third-Party Services

We use RevenueCat as our subscription management service provider. RevenueCat collects and processes data on our behalf to facilitate subscription management, including purchase validation, renewal, and receipt validation. For information about how RevenueCat processes your data, please refer to RevenueCat's Privacy Policy at https://www.revenuecat.com/privacy.

The following data may be collected by our third-party service providers:

Purchase history
Device identifiers
App usage data
Diagnostic information
Subscription status

This data is collected for the purposes of providing and improving our services, processing transactions, subscription management, and complying with app store policies.

App Tracking Transparency

We may request your permission to track your activity across third-party apps and websites to deliver personalized advertising to you. You can change your tracking preferences at any time through your device settings. If you choose to limit tracking, we will still collect and use your app information for analytics, improvements to our service, and to measure the effectiveness of our own ads.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. You are advised to review this Privacy Policy periodically for any changes.

Complaints

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details below. You also have the right to complain to the Information Commissioner's Office (ICO) if you are unhappy with how we have used your data. The ICO's contact details are:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

Contact Us

If you have questions about this Privacy Policy or wish to exercise any of your rights, please contact us at: me@danielsamgraham.com

Daniel Graham Consultancy Limited