Privacy Policy
Clarke Stephen Boulter trading as Clarke Boulter Cycling Coach
Brand: INCREMENTEL
Training Program: INCREMENTEL sistema
This privacy notice tells you what to expect us to do with your personal information when you use our cycling coaching services. This notice applies to all clients globally and complies with UK GDPR, UAE Personal Data Protection Law (PDPL), and other applicable data protection laws worldwide.
Target Demographic: Our services are specifically designed for individuals over 50 years of age participating in high-intensity cycling coaching programs.
Contents
- Contact details
- What information we collect, use, and why
- Lawful bases and data protection rights
- Where we get personal information from
- How long we keep information
- Who we share information with
- International transfers
- How to complain
Contact details
Business Registration: UAE – Sole Professional License
Primary Service Areas: Global English-speaking markets (UK, USA, Europe, UAE, and worldwide)
Telephone: +447962012475
Email: clarke@incrementel.com
For data protection queries specifically, please use the above contact details and mark your communication “Data Protection Query”.
Business Registration:
UAE – Sole Professional License
Primary Service Areas: Global English-speaking markets (UK, USA, Europe, UAE, and worldwide)
Telephone: +447962012475
Email: clarke@incrementel.com
For data protection queries specifically, please use the above contact details and mark your communication “Data Protection Query”.
What information we collect, use, and why
To provide and improve cycling coaching services for clients:
Personal Information:
- Names and contact details
- Addresses and country of residence
- Gender and pronoun preferences
- Occupation
- Date of birth (particularly important for 50+ demographic considerations)
- Payment details (including card or bank information for transfers and direct debits)
- Transaction data (including details about payments to and from you and details of services purchased)
- Usage data (including information about how you interact with our website and services)
- Information relating to compliments or complaints
- Video recordings (training sessions, technique analysis)
- Audio recordings (coaching calls, consultations)
- Records of coaching sessions and progress decisions
- Website user information
- Data from fitness tracking devices, software and websites (Strava, Garmin Connect, etc.)
Health Information (Critical for High-Intensity Training):
- Medical conditions relevant to cycling training, particularly cardiovascular conditions
- Medical clearance documentation for high-intensity exercise participation
- Injury history and physical limitations
- Fitness assessment data and baseline measurements
- Training load and recovery metrics
- Physiological data from fitness tests
- VO2max testing results and cardiovascular response data
- Age-related health considerations and medication information
- Emergency medical contact information
For client account management:
- Names and contact details
- Addresses and jurisdictional information
- Service history and coaching packages purchased
- Account information, including registration details
- Information used for security purposes
- Marketing preferences and communication consent
- Technical data, including browser and operating system information
- Insurance coverage information (where provided)
For information updates and marketing:
- Names and contact details
- Addresses and country-specific considerations
- Profile information and training preferences
- Marketing preferences and consent records
- Service history
- Website user journey information
- IP addresses and geolocation data
- Health information (aggregate fitness trends for service development, anonymised)
For research and service development:
- Names and contact details (anonymised where possible)
- Service history data
- Website usage patterns
- Fitness tracking data (anonymised)
- Training outcome data and performance metrics
- Health information (anonymised for research purposes)
- Age-demographic analysis for service improvement
- VO2max training effectiveness data
For handling queries, complaints or claims:
- Names and contact details
- Addresses and jurisdictional information
- Payment details
- Account information
- Service history
- Call recordings
- Previous correspondence
- Customer accounts and records
- Financial transaction information
- Health and safety information (including incident reports)
- Fitness tracking data relevant to the query
- Health information relevant to complaints or claims
- Insurance claim documentation (where applicable)
Lawful bases and data protection rights
Under UK GDPR, UAE PDPL, and other applicable data protection laws globally, we must have lawful basis for collecting and using your personal information.
Your data protection rights include:
- Right of Access – Request copies of your personal information and details about how we process it
- Right to Rectification – Ask us to correct inaccurate or incomplete information
- Right to Erasure – Request deletion of your personal information (subject to certain exceptions for health and safety records)
- Right to Restriction – Ask us to limit how we use your personal information
- Right to Object – Object to certain types of processing (except essential service delivery)
- Right to Data Portability – Request transfer of your data to another organisation
- Right to Withdraw Consent – Withdraw consent where we rely on it as our lawful basis (particularly important for health data processing)
- Response Time: We will respond to requests within one month (UK GDPR) or as required under applicable local data protection laws.
Our lawful bases:
For providing coaching services:
- Consent – With your explicit permission for health data processing, particularly for high-intensity training programs and VO2max interval training
- Contract – Necessary to fulfil our coaching service agreement
- Legitimate Interests – To provide personalised coaching services, improve training effectiveness, and develop our service offerings
Our legitimate interest: Providing effective, personalised cycling coaching for individuals over 50 requires analysing your fitness data, training history, health information, and age-related considerations to deliver safe and effective high-intensity training programs, including VO2max intervals.
For account management:
- Consent – With your permission for marketing and non-essential communications
- Contract – Necessary for account administration and service delivery
For marketing:
- Consent – With your explicit permission for promotional communications
- Legitimate Interests – To inform existing clients about relevant new services appropriate to their demographic
For research and development:
- Consent – With your permission for health data analysis
- Legitimate Interests – To improve our coaching methods and develop new training approaches specifically for the 50+ demographic (using anonymised data where possible)
For complaints handling:
- Consent – With your permission for investigation
- Legitimate Interests – To resolve issues and improve our services
- Legal Obligation – Where required to investigate safety concerns, particularly for high-intensity training incidents
Where we get personal information from
- Directly from you through forms, consultations, and communications
- From fitness tracking platforms you connect to our services (Strava, Garmin, etc.)
- From your interactions with our website and digital platforms
- From healthcare providers (with your explicit consent) for medical clearance verification
- From insurance providers (where you provide claims information)
How long we keep information
- Active Client Data: Retained for the duration of our coaching relationship plus 3 years to support ongoing training progression and reference
- Health Information: Retained for 7 years after our coaching relationship ends, in line with healthcare record keeping practices and due to the high-intensity nature of our training programs and 50+ client demographic
- VO2max and Cardiovascular Data: Retained for 7 years for safety monitoring and age-related health tracking
- Financial Records: Retained for 7 years for tax and accounting purposes
- Marketing Data: Until you opt out or for 5 years from last interaction
- Website Analytics: Anonymised after 2 years
- Complaints/Claims Data: Retained for 6 years or until resolution plus 2 years, with extended retention for health and safety incidents
- Medical Clearance Documentation: Retained for 7 years for liability and safety purposes
Data will be securely deleted or anonymised when retention periods expire, unless we have legal obligations to retain it longer or safety considerations require extended retention.
Who we share information with
- Service Providers: Payment processors, email marketing platforms, cloud storage providers (all with appropriate data protection agreements and international transfer safeguards)
- Professional Partners: Other sports professionals (physiotherapists, nutritionists, medical professionals) with your explicit consent, particularly important for 50+ demographic health management
- Legal Requirements: Authorities when legally obliged to share information across various jurisdictions
- Emergency Situations: Healthcare providers and emergency services if necessary for your safety during high-intensity training
- Insurance Providers: Where you have made claims related to training activities (with your explicit consent)
We do not sell your personal date to third parties.
International transfers
- Business Location: Our business is registered in the UAE but serves clients globally across multiple jurisdictions including UK, USA, Europe, and other English-speaking markets.
- Data Storage: Your data may be processed and stored across multiple jurisdictions including UAE, UK/EU, and USA through our cloud service providers to ensure optimal service delivery globally.
- Protection Measures: All international transfers are protected by:
- Adequate commercial data protection agreements meeting multiple jurisdictional standards
- Industry-standard encryption and security measures
- Access controls and audit trails
- Regular compliance assessments accross jurisdictions
Security measures
We protect your personal data through:
- Encrypted data transmission and storage with enhanced protection for health data
- Regular security assessments and vulnerability testing
- Multi-factor authentication and access controls
- Staff training on data protection and health data sensitivity
- Incident response procedures with specific protocols for health data breaches
- Enhanced security measures for high-risk demographic data (50+ age group health information)
How to complain
- First Contact: If you have concerns about our use of your personal data, contact us using the details above.
- UK Clients: You can also complain to the Information Commissioner’s Office (ICO):
- Website: https://www.ico.org.uk/make-a-complaint
- Phone: 0303 123 1113
- Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
- UAE Clients: You can contact the UAE data protection authorities through the relevant emirate’s data protection office.
- US Clients: Contact relevant state attorney general offices or federal trade commission as applicable.
- EU Clients: Contact your local data protection authority.
- Other Jurisdictions: Contact relevant local data protection authorities as applicable in your country.
Business Registration:
UAE Sole Professional License: 104763
Dubai, United Arab Emirates
Brand: INCREMENTEL
Training Program: INCREMENTEL sistema
Applicable Laws: UK GDPR, UAE Personal Data Protection Law, and other applicable global data protection laws
Last Updated: 20 February 2026
Version: 2.1
This privacy notice may be updated periodically. We will notify you of significant changes via email or through our website. Changes affecting health data processing will require renewed consent where legally required.
