{Privacy Policy}

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use our website and services, and tells you about your privacy rights and how the law protects you.

California residents under 18 who are registered users of our Service may request removal of content they have publicly posted by contacting us with the relevant details. Removal is not guaranteed in all circumstances where the law does not require it.

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

Under California Civil Code § 1798.83, California residents with an established business relationship with us may request information about our sharing of personal data with third parties for their direct marketing purposes once per year by contacting us as above.

Interpretation & Definitions

California "Shine the Light" & Minors

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.

We will verify your request and respond within 45 days, as required by law. This may be extended once by a further 45 days where reasonably necessary, with notice to you.

For the purposes of this Privacy Policy:

To exercise these rights, contact us at contact@fitdesignldn.com or via fitdesignldn.com/contact.

• Company (referred to as either "the Company", "We", "Us" or "Our") refers to Solencer Ltd, trading as Fit Design, 71-75 Shelton St, London, WC2H 9JQ, United Kingdom.
• 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.
• Business refers to the Company as described above for the purposes of CCPA/CPRA.
• CCPA/CPRA refers to the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020.
• Consumer means a natural person who is a California resident, as defined under applicable law.
• Cookies are small files placed on your device by a website, containing details of your browsing history among other uses.
• Country refers to the United Kingdom.
• Data Controller refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service, such as a computer, phone, or tablet.
• GDPR refers to the UK GDPR and, where relevant to EU-based visitors, the EU General Data Protection Regulation.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Fit Design website (fitdesignldn.com), including the AI chat assistant embedded on it.
• Service Provider means any natural or legal person who processes data on behalf of the Company. For the purposes of the GDPR, Service Providers are considered Data Processors.
• Usage Data refers to data collected automatically, generated by use of the Service or from the Service infrastructure itself.
• You means the individual accessing or using the Service, or the company or other legal entity on whose behalf such individual is accessing or using the Service.

• Know/Access what personal information we've collected, used, disclosed, or shared about you
• Correct inaccurate personal information
• Delete personal information we hold about you, subject to certain legal exceptions
• Opt out of the sale or sharing of your personal information
• Limit the use of sensitive personal information
• Non-discrimination — we will not deny you goods or services, charge different prices, or provide a different quality of service because you exercised any CCPA/CPRA right

Collecting & Using Your Personal Data

If you are a California resident, you have the right to:

Types of Data Collected

Your Rights Under the CCPA/CPRA

Personal Data

We do not sell or share the personal information of consumers we know to be under 16 years of age without opt-in consent.

While using our Service, we may ask you to provide certain personally identifiable information, including but not limited to:

• Using the Google Analytics opt-out browser add-on
• Adjusting your ad preferences at Google Ads Settings
• Contacting us at contact@fitdesignldn.com to request that we cease sharing your information with these providers

• Email address
• First name and last name
• Phone number
• Business/company name and project details, where voluntarily shared, such as via our website forms or AI chat assistant

You have the right to opt out of this sharing. You can do so by:

Usage Data

However, under the CPRA's broad definition, our use of Google Analytics and Google Ads for remarketing may be considered a "share" of Category A and F information for cross-context behavioural advertising purposes.

Usage Data is collected automatically when using the Service, and may include:

We do not sell personal information for money.

• Your device's IP address
• Browser type and version
• Pages visited
• Time and date of visit
• Time spent on pages
• Unique device identifiers
• Other diagnostic data

Sale or Sharing of Personal Information

Our AI Website Chat Assistant

We disclose Category A, B, F, G, and K information to our Service Providers — Anthropic, Cloudflare, and Google — strictly to enable them to perform services on our behalf, under contracts that require them to keep it confidential and use it only for that purpose.

Our website includes an AI-powered chat assistant that visitors can use to ask about our services, pricing, and process, in place of a traditional contact form.

• Respond to your enquiry
• Operate and improve our Service
• Show relevant advertising via Google Ads, where applicable

What It Collects

We use personal information for the business purposes described earlier in this policy, principally to:

If you chat with the assistant, we collect the content of that conversation, along with any personal details you choose to share within it, such as your name, email address, or project details.

Use and Disclosure of Personal Information

If you don't share any personal details, the conversation is not linked to your identity.

• Directly from you, such as via our website forms or AI chat assistant
• Automatically through cookies and similar technologies as you navigate our Service
• From Service Providers who help us operate the Service, including Anthropic, Cloudflare, and Google

How We Use It

We collect personal information:

Conversations are used to:

Sources of Personal Information

• Respond to your enquiry
• Generate an internal summary and lead classification for our team's follow-up
• Improve the assistant over time

• Category A — Identifiers: name, email address, phone number, IP address, online identifiers. Collected: Yes.
• Category B — California Customer Records: name, address, telephone number, and similar identifiers where voluntarily provided. Collected: Yes.
• Category C — Protected classifications: age, race, religion, etc. Collected: No.
• Category D — Commercial information: records of services considered/purchased. Collected: No.
• Category E — Biometric information: Collected: No.
• Category F — Internet or network activity: interaction with our Service, including our AI chat assistant. Collected: Yes.
• Category G — Geolocation data: approximate, from IP address only. Collected: Yes, approximate only.
• Category H — Sensory data: Collected: No.
• Category I — Professional/employment information: Collected: No.
• Category J — Non-public education information: Collected: No.
• Category K — Inferences: such as our internal lead classification generated from your chat conversation. Collected: Yes.
• Category L — Sensitive personal information: such as account login details or precise geolocation. Collected: No.

We do not use your conversation content to train third-party AI models, and it is not sold or shared for advertising purposes.

In the preceding twelve (12) months, we have collected the following categories of personal information from California residents, as defined under the CCPA/CPRA:

Who Processes It

Categories of Personal Information Collected

• Anthropic — provider of the Claude AI model that powers the assistant. Anthropic processes conversation content in order to generate responses and summaries. Privacy practices are available at anthropic.com/legal/privacy.
• Cloudflare — hosts the chat assistant's backend infrastructure, including temporary storage of conversation transcripts and rate-limiting data. Privacy practices are available at cloudflare.com/privacypolicy.
• Google — Google Sheets, via Google Apps Script, is used to log an AI-generated summary of concluded conversations, including any name, email, or project details you shared, for our internal follow-up. Privacy practices are available at policies.google.com/privacy.

This section supplements the rest of our Privacy Policy and applies solely to visitors, users, and others who reside in the State of California ("Consumers").

Retention

CCPA/CPRA Privacy Notice for California Residents

• Full conversation transcripts are retained for 90 days from the date of the conversation, then permanently deleted.
• Summary records in our internal lead log, including name, email, project type, AI-generated summary, and lead classification, are retained for 24 months from the date of last contact, or until you ask us to delete them, whichever is sooner.

• Email: contact@fitdesignldn.com
• Website: fitdesignldn.com/contact
• Post: Solencer Ltd (trading as Fit Design), 71-75 Shelton St, London, WC2H 9JQ, United Kingdom

Tracking Technologies & Cookies

If you have questions about this Privacy Policy, or wish to exercise any of your rights:

We use Cookies and similar tracking technologies on our Service for the following purposes:

Contact Us

• Necessary/Essential Cookies — required to provide the Service and enable core features.
• Cookie Notice Acceptance Cookies — remember whether you've accepted our use of cookies.
• Functionality Cookies — remember your preferences for a more personalised experience.
• Google Analytics — helps us understand how visitors use our Service. You can opt out using the Google Analytics opt-out browser add-on. More information: policies.google.com/privacy.
• Google Ads (Remarketing) — we use Google Ads to show relevant adverts to visitors who have previously visited our Service. You can manage or opt out of this via Google Ads Settings, and Google recommends the Google Analytics Opt-out Browser Add-on for further control.

Where changes are significant, we will take reasonable steps to make this clear, such as a notice on our website.

We do not currently use any other analytics, behavioural tracking, or remarketing tools beyond those listed above. If that changes, we will update this policy accordingly.

We will post any changes on this page and update the "Last updated" date above.

Use of Your Personal Data

We may update this Privacy Policy from time to time.

The Company may use Personal Data to:

Changes to This Privacy Policy

• Provide and maintain our Service, including responding to enquiries made via our website or AI chat assistant
• Contact you by email, phone, or other electronic means about your enquiry or project
• Send you information about our services where you have enquired about similar services, unless you've opted out
• Show you relevant advertising via Google Ads, where you have previously visited our Service
• Analyse usage trends via Google Analytics and improve our Service, marketing, and your experience
• Comply with our legal obligations

We encourage you to review the privacy policy of every site you visit. We have no control over, and assume no responsibility for, the content or privacy practices of third-party sites.

Sharing Your Personal Data

Our Service may contain links to third-party websites that are not operated by us.

We may share your personal information with:

Links to Other Websites

• Service Providers, to operate, analyse, and improve our Service
• Affiliates, bound by this Privacy Policy
• Parties involved in a business transfer, such as a merger, acquisition, or asset sale
• Other parties with your consent, for any other purpose

If you are a parent or guardian and believe your child has provided us with Personal Data, please contact us and we will take steps to remove it.

Cold Outreach & Direct Marketing

Our Service is not directed at anyone under the age of 16, and we do not knowingly collect Personal Data from anyone under that age.

From time to time, we contact prospective clients by email who have not previously interacted with us, where we believe our services may genuinely be relevant to their business.

Children's Privacy

• We use Instantly as our email sending platform for this outreach.
• Our lawful basis for this contact is legitimate interests, in line with the UK's Privacy and Electronic Communications Regulations (PECR) corporate-subscriber provisions for business-to-business email.
• Every first-contact email includes information on how we obtained your details and a clear, working opt-out.
• You can unsubscribe at any time using the link provided, or by emailing contact@fitdesignldn.com.
• If we contact recipients based outside the UK, we take reasonable steps to meet the applicable standard for that jurisdiction, such as CAN-SPAM in the US or CASL in Canada.

However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

Retention of Your Personal Data

• Restricting access to Service Providers with a legitimate need
• Using reputable, security-conscious infrastructure providers such as Cloudflare, Google, and Anthropic

Beyond the specific periods set out above for chat conversations and lead records, we retain other Personal Data only for as long as necessary for the purposes set out in this Privacy Policy, to:

The security of your Personal Data is important to us. We use commercially reasonable technical and organisational measures to protect it, including:

• Comply with our legal obligations
• Resolve disputes
• Enforce our agreements

Security of Your Personal Data

Usage Data is generally retained for a shorter period unless needed for security or functionality purposes, or where we are legally required to retain it for longer.

We are registered with the UK Information Commissioner's Office (ICO). Our registration reference is ZC205836.

Transfer of Your Personal Data

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO), or with your local data protection authority if you are based in the EU.

Your information may be processed in the United Kingdom and by our Service Providers, which may include locations outside the UK/EEA, including the United States, where Anthropic, Cloudflare, and Google may process data as part of their infrastructure.

We may ask you to verify your identity before responding.

Where we transfer personal data outside the UK/EEA, we rely on appropriate safeguards, such as Standard Contractual Clauses or an equivalent mechanism recognised under UK/EU data protection law, to ensure your data remains protected.

To exercise any of these rights, contact us using the details in Contact Us below.

Your Rights Under the GDPR

• Access the Personal Data we hold about you
• Correct inaccurate or incomplete Personal Data
• Request erasure of your Personal Data where there is no good reason for us to keep processing it
• Restrict our processing of your Personal Data in certain circumstances
• Object to processing based on legitimate interests, including for direct marketing
• Request transfer (portability) of Personal Data you have provided to us, where technically feasible
• Withdraw consent at any time, where processing is based on consent

If you are in the UK or EEA, you have the right to: