Privacy Policy

1 · Introduction
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.thehumanpremium.co.uk. By providing us with your data, you warrant to us that you are over 18 years of age. Adam Clarke is the data controller and we are responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice).

Our details
· Data controller: Adam Clarke, trading as The Human Premium, a sole trader established in England
· Address for service of documents: 3 Oriel Road, Street, Somerset, BA16 0JL
· Email: [email protected]
· Information Commissioner's Office registration number: [INSERT ICO NUMBER]

There is no separate data protection officer. Adam Clarke handles all data protection matters personally, and any question about this notice should be sent to the email address above.

2 · What data do we collect about you, for what purpose and on what ground we process it
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you:

2.1 Communication Data
This includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

2.2 Customer Data
This includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

2.3 User Data
This includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

2.4 Technical Data
This includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

2.5 Marketing Data
This includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is either consent, contract or our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy. We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business or for direct marketing). We may also use Communications Data, Customer Data, User Data, Technical Data and Marketing Data for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to establish, pursue or defend legal claims.

2.6 Resource Data
This includes data about your request for a free resource made available for download from our website — your name, your email address, the resource requested, the date of the request, and any further detail you choose to give us, such as your organisation or your role. We process this data to send you the resource you have asked for, to keep a record of that request, and to contact you no more than twice afterwards where you have agreed to that, as described at 2.11. Our lawful ground of processing is your consent, and our legitimate interests which in this case are to keep an accurate record of the material we have sent and to whom, and to grow our practice.

2.7 Required Processing
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don't provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time. We may process your personal data without your knowledge or consent where this is required or permitted by law.

2.8 Purposes of Processing
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at [email protected]. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

2.9 Sensitive Data, Criminal Conviction Data and Automated Processing
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences. We do not carry out automated decision making or any type of automated profiling.

2.10 The form on our website
There is one form on this website, and it is the only part of the site that collects anything you type. It asks for your name and your email address, and it is used both to request a free resource and to send us a direct enquiry. Submissions are delivered to our own email account and are read by Adam Clarke alone. Where you have sent us an enquiry, we use what you send us to answer you, and to take any steps you have asked us to take towards working together. Our lawful ground is our legitimate interests in responding to enquiries, and, where the enquiry concerns a possible engagement, taking steps at your request to enter into a contract. Where you have requested a free resource, section 2.11 explains what happens next. Please do not send confidential or sensitive information through the form. If a matter needs that kind of care, say so briefly and we will agree a secure route.

2.11 The free resource, and what happens to your email address
Our website carries one form. Where you use it to request a free resource, you give us your name and your email address. The form sends those details to our own email account. Our website host also keeps a copy of the submission for 30 days as a backup, after which it is deleted from their systems. We use your email address for two things, and nothing else:

· To send you the resource you asked for.
· To contact you no more than twice afterwards, to explore whether we might work together.

That is the whole of it. There is no mailing list, no newsletter sequence, and no third-party marketing platform. Our lawful ground is your consent, given when you complete the form, and our legitimate interests in following up an expression of interest in our work. After the second contact, or sooner if you ask, your email address is archived and then deleted within 90 days. If you tell us at any point that you would rather not hear from us again, we stop immediately. In that case we keep a minimal record of your email address indefinitely, and nothing else, for the sole purpose of making sure we do not contact you again by mistake. If you go on to become a client, your details move into our client records and are kept as described at section 8.

2.12 Booking a discovery call
Our website links out to Calendly, a separate scheduling service, where you can book a 30-minute discovery call. Following that link takes you off our website. Calendly collects your name, your email address, your time zone, and anything you enter when booking, and holds it in the United States. We use it to hold the appointment and to prepare for it. A booking also creates an entry in our own calendar and an email in our own inbox, each containing the details you gave. If you ask us to delete your booking data, we remove it from all three.

2.13 Health information, where you take part in breathing training
Where you take part in Oxygen Advantage functional breathing training with us — whether as a standalone programme, within The AI-Era Leadership Mentoring, or in a corporate setting — we ask you to complete a health declaration and the Oxygen Advantage client intake form before you begin. It asks about conditions that make breath-hold and reduced-breathing exercises unsuitable, or that require clearance from your doctor first — for example pregnancy, epilepsy, cardiovascular conditions, uncontrolled blood pressure, severe asthma, type 1 diabetes, sickle cell disease or trait, kidney conditions, panic or anxiety disorders, and recent surgery or injury. We also ask you to tell us if your health changes during the training. This is health information, and health information is special category data under Article 9 of the UK GDPR. We handle it accordingly:

· We collect it for one purpose only: to decide whether it is safe for you to take part, and to keep you safe while you do.
· Our lawful ground is your explicit consent, given separately from these terms and from anything else. You may withdraw it at any time, although we will not be able to continue the training if you do.
· You send it to us by email, and we then hold it in a restricted folder within our own Google Drive account, separate from all our other records. Only Adam Clarke has access to it.
· Where your employer or another organisation has commissioned the training, we collect your declaration from you directly and we do not disclose it, or anything in it, to them. What they receive is confirmation that you are cleared to take part, and nothing more.
· We keep it for six years after the training concludes, and then delete it. We hold it for that period because it is the period during which a claim arising from the training could be brought, and because it is the record of the screening we carried out. This training is for adults. We do not deliver it, or any other service, to any person under the age of 18. If you are in any doubt about whether the training is suitable for you, speak to your doctor. We are not clinicians and the declaration is not a medical assessment.

2.14 What we do not do
For the avoidance of doubt, and although the categories above are drawn widely:

· We do not sell, rent, or trade your personal data, and we never will.
· We do not run advertising, and we do not use your data to serve advertisements to you on this or any other platform.
· We do not build profiles about you as an individual, and we make no decisions about you by automated means.
· We do not buy contact lists, and we do not obtain your details from data brokers.
· We use analytics cookies to count visits and understand which writing is read, and only where you have agreed to them. We have switched off the advertising and cross-device features our analytics provider offers, and we do not share the data with advertising networks.
· Apart from the health declaration described at 2.13, we collect no special category data, and we collect no information about criminal convictions or offences. If any of this changes, we will amend this notice and say so plainly.

3 · How we collect your personal data
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this. We may receive data from third parties such as analytics providers such as Google based outside the UK and/or the EU, advertising networks such as Facebook based outside the UK and/or the EU, search information providers such as Google based outside the UK and/or the EU, providers of technical, payment and delivery services, such as data brokers or aggregators. We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside or outside the UK and/or the EU.

3.1 How this works in practice
In practice, we collect personal data in four ways only:

· When you complete the form on our website to request a free resource.
· When you book a conversation with us through our scheduling provider.
· When you complete a health declaration before taking part in breathing training.
· When you write to us directly by email, or through a professional network such as LinkedIn.

Alongside this, our website uses Google Analytics, but only where you have agreed to it through the cookie banner. It reports figures such as how many people visited a page, roughly where in the world they were, and which site or search they arrived from. We have switched off the advertising and cross-device features it offers, we do not use it to identify you, and we do not combine it with anything else we hold about you. If you decline analytics cookies, your visit is simply not counted. We also use search console data provided by search engines, which is aggregated and sets no cookies on this website.

4 · Marketing communications
Our lawful ground of processing your personal data to send you marketing communications is either your consent, our legitimate interests (namely to grow our business). Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time. We will never share your personal details with any third party for their own marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you. If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

4.1 How to opt out
Our website has no member area or login, and we send no bulk marketing. To stop hearing from us, reply to any message we send you, or write to [email protected]. Either route is acted on straight away, and no reason is needed.

5 · Disclosures of your personal data
We may have to share your personal data with the parties set out below: Calendly and Showit. We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

5.1 The providers we rely on
In full, the service providers who may process personal data on our behalf are:

· Calendly: appointment scheduling for discovery calls. Calendly holds the name, email address, and time zone you give when booking, in data centres in the United States.
· Google Workspace, including Google Drive: email, file storage, our private record of enquiries and contacts, and the restricted location in which health declarations are held.
· Showit: the platform on which this website is built and hosted, and which handles submissions from our website form and holds a copy of each for 30 days.
· Google Analytics: website analytics, used only where you have consented to analytics cookies.

We may also disclose personal data to our accountant, our insurers, or our professional advisers where it is necessary to do so, and to a regulator, court, or public authority where we are required to by law.

6 · International transfers
We are subject to the provisions of the UK General Data Protection Regulations (UK GDPR) that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such: We may transfer your personal data to countries that the United Kingdom regulatory authorities have approved as providing an adequate level of protection for personal data; or If we use US-based providers that are part of the UK-US Data Bridge (the UK Extension to the EU-US Data Privacy Framework), we may transfer data to them, as they have equivalent safeguards in place; or Where we use certain service providers who are established outside of the UK, we may use specific contracts approved by the ICO (the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses), or codes of conduct or certification mechanisms approved by the UK government, which give personal data the same protection it has in the UK. If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. We are subject to the provisions of the EU General Data Protection Regulation (EU GDPR) that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such: We may transfer your personal data to countries that the European Commission has approved as providing an adequate level of protection for personal data; or
If we use US-based providers that are part of the EU-US Data Privacy Framework, we may transfer data to them, as they have equivalent safeguards in place; or where we use certain service providers who are established outside of the EEA, we may use specific contracts (the EU Standard Contractual Clauses adopted by the European Commission in June 2021), or codes of conduct or certification mechanisms approved by the European Commission, which give personal data the same protection it has in the EEA. If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

6.1 Which of our providers are outside the UK
Calendly, Google (including Google Workspace and Google Analytics), and Showit, are established in the United States and personal data held by them may be processed there. Transfers to these providers are made under the safeguards described above.

7 · Data security
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

7.1 What this means for a practice of one
The Human Premium is a sole trader with no employees. Adam Clarke is the only person with access to your personal data, other than the service providers named in section 5, who act on our instructions. Accounts are protected by two-factor authentication, devices are encrypted and password-protected, and access to our records is reviewed periodically. Health declarations are held separately from all other records, in a restricted folder within our own Google Drive account, accessible only to Adam Clarke. They are not shared with any other service provider, with any commissioning organisation, or with anyone else.

8 · Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements. For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers. In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8.1 Our retention periods
· Website form submissions held by our host: 30 days, after which they are deleted by the host.
· Email addresses given in exchange for a free resource: 90 days from our final contact with you, after which they are deleted. Where you have asked not to be contacted again, we keep a minimal suppression record indefinitely, as described at 2.11.
· General enquiries and correspondence by email: 24 months from our last exchange.
· Discovery call bookings held by our scheduling provider: 12 months from the date of the appointment.
· Health declarations for breathing training: six years from the conclusion of the training, after which they are deleted.
· Client records, contracts, Scopes of Work, and financial records: six years from the end of the engagement, in line with the period during which a claim may be brought and as required for tax purposes.
· Complaint records: six years from the conclusion of the complaint.
· Website analytics data: 14 months, after which it is deleted by our analytics provider. The cookies themselves expire after 12 months.

9 · Your legal rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. If you are within the UK, you can see more about these rights at: https://ico.org.uk/for-organisations/uk- gdpr-guidance-and-resources/individual-rights/. If you wish to exercise any of the rights set out above, please email us at [email protected]. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. When responding to a request to access your personal data, we are only required to carry out searches that are reasonable and proportionate in the circumstances (as now expressly recognised in the Data (Use and Access) Act 2025). This means we will take into account factors such as the nature of the information sought, the context in which it is held, any difficulty involved in locating it and the potential benefit to you of receiving it. We try to respond to all legitimate requests within one month of receiving the request (or, where applicable, of receiving the identity verification information or clarification we have asked for — the response period is paused, or "stopped", while we wait for that information, in line with the Data (Use and Access) Act 2025). Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests, in which case we may extend the response period by up to a further two months. We will notify you within one month of receiving your request if an extension is needed and explain why.

10 · How to complain
If you have a complaint about how we handle your personal data, we ask that you contact us first so that we can try to resolve it for you. You can submit a data protection complaint to us by emailing us at [email protected]. We will acknowledge your complaint within 30 days of receiving it. We will investigate your complaint without undue delay, keep you informed of our progress, and communicate the outcome to you clearly with sufficient detail for you to understand how we reached our conclusion. If you are within the UK and are not satisfied with our response, you have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you are within the EU and are not satisfied with our response, you have the right to complain to the data protection authority of the country in which you are based.

11 · Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

12 · Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

12.1 The cookies this website sets
This website sets no advertising or cross-site tracking cookies. A small number of strictly necessary cookies are set by our hosting platform to keep the site working and secure, along with one cookie that records your own cookie preferences. Analytics cookies are set only where you have agreed to them. When you first arrive, a banner asks how you would like cookies to be handled. No non-essential cookie is set until you have answered it, and you may change your answer at any time. We embed nothing from a third party. Booking a discovery call is done by following a link to Calendly, a separate service, so no third-party cookie is placed on this website at all. Where you follow that link you leave our website, and any cookie set there belongs to Calendly and is governed by its own policy. Our cookie policy sets this out in full.

13 · Age
Our services are intended for adults, and by providing us with your data you confirm that you are over 18 years of age. We do not work with any person under the age of 18, in any context, under any of our services, and we do not knowingly collect personal data relating to children. If you believe that a child has given us their personal data, write to [email protected] and we will delete it.

14 · Our use of artificial intelligence
We advise organisations on the governance of artificial intelligence, and we hold ourselves to the standard we ask of them. We use AI tools in the preparation of our own written and visual material. We do not enter your personal data, your correspondence, or confidential client material into any general-purpose AI tool. We do not use your personal data to train any AI model, and we do not permit our providers to use it for that purpose. No decision affecting you is made by automated means; judgement remains ours, and accountability with it.

15 · Changes to this privacy notice
We keep this notice under review and may amend it from time to time by updating this page. Where a change is material, we will say so. The version in force is the one published here. Please check this page periodically.

16 · How to contact us
Questions about this notice, or about how we handle your personal data, should be sent to:
· Email: [email protected]
· Post: Adam Clarke, trading as The Human Premium, 3 Oriel Road, Street, Somerset, BA16 0JL

Version 1.0 · Last updated 11th August 2026

© 2026 Adam Clarke trading as The Human Premium. All rights reserved.