Privacy Policy
This Privacy Policy explains how New Terrain Health ("the Coach", "we", "us") collects, uses and protects personal data belonging to website visitors, prospective clients and coaching clients, in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who We Are
The Coach is the Data Controller for the personal data described in this Policy.
Name: Amar Kapila
Trading name: New Terrain Health
Contact email: amar@newterrainhealth.com
2. What Data We Collect
We collect different categories of personal data depending on how you interact with us.
Website visitors
Technical data, such as IP address, browser type and device information, collected automatically through cookies and analytics, where applicable. Please see our Cookie Policy for details.
Information you submit through contact or enquiry forms, such as your name, email address and message.
Newsletter sign-up details, such as your name and email address, where you choose to opt in.
Prospective and current coaching clients
Contact details, such as name, address, email address and telephone number.
Health and lifestyle information you provide through the Health & Lifestyle Questionnaire or voluntarily disclose during coaching sessions, where relevant to your coaching.
Emergency contact details and, where relevant and necessary, healthcare professional contact details.
Payment information processed through our third-party payment provider. We do not store card details ourselves.
Session notes and other records relating to your coaching programme.
We aim to collect only personal information that is adequate, relevant and necessary for the purposes described in this Policy.
AI-Assisted Transcription and Note-Taking
Where AI-assisted transcription and note-taking are used, Google Meet and Gemini within Google Workspace, and Read AI, may process the text and other content of a coaching conversation to generate transcripts, notes, summaries and action points.
The Coach reviews generated information for accuracy and uses only information that is relevant and necessary for the coaching record.
Google Workspace-generated material is processed through the Coach's Google Workspace account and stored in the Coach's Google Drive. Read AI may separately process and store meeting data, including transcripts and recordings, within the Coach's Read AI account in accordance with Read AI's privacy and security policies. Read AI reports are kept private by the Coach and are deleted when no longer required, subject to any applicable retention requirements.
These materials are used for the Coach's working purposes and are not ordinarily shared with the Client or other third parties, except as described in this Privacy Policy or where required by law.
AI-generated working material and transcripts are retained only for as long as necessary to review and incorporate relevant information into the coaching record, after which they are securely deleted in accordance with the Coach's data retention and deletion procedures. They are not ordinarily retained for the full retention period applicable to the coaching record.
Google states that Workspace customer data used with its generative AI services is not used to train or fine-tune Google's generative AI models without the customer's prior permission or instruction. Read AI states that meeting data is not used to train its AI models without explicit opt-in.
Health information is special category data under the UK GDPR and is treated with additional care, as set out in Section 4 below.
3. How We Use Your Data
We use personal data for the following purposes:
To respond to enquiries and provide information about our services.
To assess suitability for coaching and deliver the coaching programme safely, including managing any medical or emergency considerations.
To manage bookings, scheduling and payments.
To maintain professional records in line with our professional, insurance and other applicable obligations.
To send newsletters or marketing communications where you have opted in. You may unsubscribe at any time.
To improve our website, using aggregated and anonymised analytics data where possible.
To comply with legal and regulatory obligations.
4. Our Legal Basis for Processing
We rely on different lawful bases depending on the purpose for which personal data is processed.
1. General contact and enquiry data: processed on the basis of our legitimate interests in responding to enquiries and administering our business, or with your consent where appropriate.
2. Coaching client contact and booking data: processed where necessary to perform our contract with you under the Coaching Agreement.
3. Health and lifestyle information: Where health information constitutes special category personal data, we process it where necessary to provide and safely deliver the health coaching services you have requested, relying on Article 6(1)(b) of the UK GDPR (processing necessary for the performance of a contract) together with Article 9(2)(a) (explicit consent). Relevant health information may be provided through the Health & Lifestyle Questionnaire or voluntarily disclosed during coaching sessions and recorded in relevant session notes. You may withdraw your explicit consent at any time, although this may affect our ability to continue providing coaching where such information is necessary for safe and appropriate delivery of the service.
4. Marketing communications: processed on the basis of your consent, given when you opt in. You can withdraw consent at any time.
5. Legal and regulatory record-keeping: processed where necessary to comply with legal obligations and, where applicable, on the basis of our legitimate interests in maintaining appropriate professional and business records.
5. Who We Share Data With
We do not sell personal data. We may share personal data with:
Third-party payment processors, such as Stripe, to process payments securely. We do not store card details ourselves.
Email or newsletter platforms, where you have opted in to marketing communications.
Website hosting and analytics providers, who process technical data on our behalf.
Your GP or another healthcare professional, where you have given specific consent or where disclosure is necessary in an emergency or otherwise permitted or required by law.
Relevant professional bodies, such as UKIHCA, our insurer, or legal or law-enforcement authorities, where required or permitted by law.
Where a third-party processor is based outside the UK, we take reasonable steps to ensure that your personal data is protected to a standard consistent with UK data-protection law, including where appropriate through adequacy regulations or appropriate safeguards such as the UK International Data Transfer Agreement or UK Addendum to EU Standard Contractual Clauses.
Professional supervision
I may discuss our coaching work with a professional supervisor to reflect on my practice, maintain professional standards and keep clients safe. Cases are discussed anonymously. I do not share your name, contact details or other information that would identify you, and we leave out details that could identify you indirectly. Supervisors are bound by confidentiality. Any notes I keep from supervision are anonymised and do not identify you.
6. How Long We Keep Data
1. Coaching client records: Coaching records, including relevant health information, are retained for up to 7 years for professional-record purposes and then securely deleted, in line with our Coaching Agreement and applicable professional and insurance requirements.
2. AI-generated transcripts and working notes: These are retained only for the period necessary to review and incorporate relevant information into the coaching record and are then securely deleted, as described in Section 2. They are not ordinarily retained for the full retention period applicable to the coaching record.
3. General enquiry data: Retained only for as long as needed to respond to your enquiry, unless you become a client or opt in to further contact.
4. Newsletter and marketing data: Retained until you unsubscribe or withdraw your consent, subject to any information we need to retain to record your previous consent or preference.
7. Your Rights
Under the UK GDPR, you have rights in relation to your personal data, including, where applicable, the right to:
Access the personal data we hold about you.
Request correction of inaccurate or incomplete data.
Request deletion of your data, where applicable.
Request restriction of processing in certain circumstances.
Object to certain processing.
Request a copy of your data in a portable format, where applicable.
Withdraw consent at any time where processing is based on consent.
These rights are subject to certain legal conditions and exemptions.
To exercise any of these rights, please contact us using the details in Section 1.
We will normally respond to a valid request within one month. In certain circumstances, we may extend this period by up to a further two months, as permitted by data-protection law.
If you are unhappy with how we have handled your personal data, you have the right to complain to the Information Commissioner's Office (ICO).
8. Automated Decision-Making
We do not use your personal data to make solely automated decisions that produce legal or similarly significant effects on you.
AI-assisted tools may be used to help generate transcripts, notes, summaries or action points, as described in Section 2. These outputs are reviewed by the Coach and are not used to make solely automated decisions about you.
9. Keeping Your Data Secure
We take reasonable technical and organisational measures to protect personal data against unauthorised access, loss or misuse, including secure storage of client records and restricted access to sensitive health information.
However, no online transmission or storage system can be guaranteed to be completely secure.
10. Cookies
Our website uses cookies and similar technologies. Full details of the cookies we use and how to manage them are set out in our separate Cookie Policy.
11. Changes to This Policy
We may update this Privacy Policy from time to time, for example to reflect changes in the law or how we handle personal data.
Any changes will be posted on this page with an updated effective date.
Last updated: September 2026
12. Contact Us
Questions about this Privacy Policy, or requests relating to your personal data, can be sent to:
Email: amar@newterrainhealth.com