1. WHO WE ARE

ZTraining is operated by Francesco Zen, trading as Zen Vitality Partners FZ-LLC, registered in Ras Al Khaimah, UAE. Contact: Francesco@ztraining.co.uk

This policy explains how we collect, use, and protect your personal data when you purchase or enquire about the 24-Week Recomposition System.

2. WHAT DATA WE COLLECT

We collect data you provide directly: your name, email address, age range, occupation, fitness goals, and health-related information submitted through our onboarding assessment. Payment data is processed by Digistore24 — ZTraining does not store card or payment details directly. We collect email engagement data (open rates, click rates) through our email platform for communication optimisation.

3. WHY WE COLLECT IT

Your data is collected and used solely to: deliver your personalised coaching programme, communicate with you about your programme progress, process your payment via Digistore24, and improve our services. We do not use your data for any other purpose without your explicit consent.

4. LEGAL BASIS FOR PROCESSING

We process your data under the UK GDPR and UAE Federal Data Protection Law (Federal Decree-Law No. 45 of 2021) on the basis of: contractual necessity (to deliver the service you purchased), legitimate interest (to send relevant follow-up communications to prospective clients), and consent (where you have opted in through our assessment or enquiry form).

5. THIRD-PARTY SERVICES

We use the following third-party services to operate our business:

— Digistore24 (payment processing and affiliate management — digistore24.com/privacy) — Tally (assessment forms — tally.so/privacy) — Squarespace (website hosting — squarespace.com/privacy)

We do not sell, rent, or share your personal data with any other third party. Where Digistore24 processes affiliate-referred purchases, affiliate tracking is handled solely by Digistore24 under their own data policy.

6. COLD EMAIL COMMUNICATION

If you received an email from ZTraining, your contact details were sourced from a professionally verified B2B data provider. You were contacted because your professional profile indicated potential relevance to our services. You have the right to opt out at any time by replying with "remove" or by emailing Francesco@ztraining.co.uk.

7. CALIFORNIA RESIDENTS (CCPA)

If you are a California resident, you have the right to: know what personal data we hold about you, request deletion of your data, opt out of any data sale (we do not sell data), and non-discrimination for exercising these rights. To exercise any right, email Francesco@ztraining.co.uk.

8. DATA RETENTION

We retain your data for the duration of your coaching programme and for up to 2 years afterwards for legitimate business record purposes. If you request deletion, we will remove your data within 30 days, except where retention is required by applicable law.

9. DATA SECURITY

We take reasonable technical and organisational measures to protect your personal data. All payment processing is handled by Digistore24, which maintains PCI-DSS compliance. Our website is hosted on Squarespace using SSL encryption.

10. YOUR RIGHTS

Under UK GDPR and UAE data protection law, you have the right to access, correct, delete, restrict processing of, and port your personal data. You also have the right to lodge a complaint with the UK Information Commissioner's Office (ico.org.uk) if you believe your data has been handled unlawfully. To exercise any right, contact: Francesco@ztraining.co.uk

11. INTELLECTUAL PROPERTY

All programme materials, frameworks, protocols, and written content provided by ZTraining are the intellectual property of Francesco Zen and ZLIFE. They may not be reproduced, shared, resold, or distributed without written permission.

12. COOKIES

Our website uses minimal cookies through Squarespace for basic functionality and analytics. Digistore24 uses tracking cookies for affiliate commission attribution. No advertising or behavioural tracking cookies are used by ZTraining directly.

13. CONTACT

Francesco@ztraining.co.uk ZTraining | Zen Vitality Partners FZ-LLC | Ras Al Khaimah, UAE