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Privacy Policy

Last updated: 7 August 2026  ·  Data fiduciary: Dion Samuel Coaching System, India

Coaching means you tell us things about your body, your health and your life. This page explains exactly what we collect, why, who sees it, how long we keep it, and how you can get it deleted. Short version: we collect only what coaching needs, we never sell it, and you can have it erased whenever you want.

1. Who is responsible for your data

Dion Samuel, trading as Dion Samuel Coaching System (Team DSF), based in India, is the data fiduciary / controller for the personal data described here. Our official contact channel is direct message to @dionsamuel_ on Instagram.

2. What we collect

When you just browse this website

Nothing that identifies you by name. Google Analytics 4 records anonymous usage measurement — pages viewed, time on page, approximate location at city level, device and browser type, and the site or search that referred you — tied to a randomly generated visitor ID stored in a cookie on your device, not to your identity. Details, including how to opt out, are in section 3 and the Cookie Policy. Separately, our hosting provider and Google Fonts may process your IP address and browser user-agent in ordinary server logs to deliver the page and defend against abuse; we don't have access to those logs as an identifiable record of you.

When you enquire

• Your Instagram or WhatsApp handle and display name
• Whatever you choose to tell us in your message — typically your goal, your situation and your rough starting point

When you become a coaching client

• Identity and contact: name, age, phone number or messaging handle, city, and email if you give one
• Health and fitness information: height, weight, body measurements, body-fat estimates, training history, current lifts, injuries, medical conditions, medication, allergies, sleep, stress, digestion, menstrual-cycle information where you choose to share it
• Nutrition information: food preferences and restrictions, typical intake, food logs
• Progress data: weekly check-in responses, progress photos, weight and measurement history
• Payment information: transaction records and confirmations. Payments are processed by third-party gateways — we never see or store your full card, UPI or bank credentials
• Correspondence: your messages with Dion

3. Analytics on this website

We use Google Analytics 4 (measurement ID G-144KJ00BF6) to understand how the site is used — which articles are worth writing more of, which pages people leave immediately, and whether anyone finds us from search at all. It is the only third-party script on the site that stores anything on your device.

What it collects

• Pages viewed, order of pages, time on page and scroll depth
• Clicks on our "Enquire" / "Message Dion" buttons and Instagram links — we record which button on which page was clicked, so we know which pages actually help people decide. We record the click, not who you are, and nothing you write in the message that follows
• Referrer — the search engine, social post or link that brought you here
• Device type, screen size, browser, operating system and language
• Approximate location derived from your IP address, at city level at most
• A random visitor and session ID, stored in first-party _ga cookies for up to two years, so a returning visitor isn't counted twice

What it does not collect

Your name, email, phone number or any coaching data. We never send personal identifiers to Google, and analytics data is never linked to your client record.

How we've configured it

• IP anonymisation is on — Google truncates your IP address and we never see the full one.
• Google Signals is off — your visit is not joined to your Google account or cross-device history.
• Ad personalisation is off — this data is not used to build advertising audiences, and we run no remarketing.
• Analytics data is retained by Google for 14 months and then deleted automatically.

Your legal basis and how to opt out

We rely on our legitimate interest in measuring and improving a site we publish, kept narrow by the settings above. If you'd rather not be counted, any of these works and none of them affects the site: install Google's official opt-out browser add-on, turn on your browser's tracking protection or "Do Not Track", block cookies for this site, or use a content blocker. You can also delete the _ga cookies at any time from your browser settings.

Google acts as our data processor for analytics and processes this data on servers outside India — see section 12. Their handling is governed by the Google Privacy Policy.

4. Why we collect it and our legal basis

We do not use your data for advertising, we do not profile you for marketing, and we never sell your personal data to anyone.

5. Health data and your consent

Health information is sensitive, and we treat it that way. We collect it only because it is necessary to coach you safely, only with your explicit consent, and only to the extent it's relevant to your programme. You can decline to share any particular item — though some omissions may mean we can't safely coach you.

You can withdraw your consent at any time by messaging us. Withdrawing consent stops any further processing, and generally means coaching has to end, but it doesn't affect processing that already lawfully happened before you withdrew.

6. Who we share it with

Your coaching data is seen by Dion Samuel. Beyond that, it is disclosed only to:

• Messaging platforms (Meta — Instagram and WhatsApp) that carry our conversations, under their own privacy policies
• Payment gateways that process your transaction
• Software we use to run the service, such as cloud storage, spreadsheets and check-in tools, acting on our instructions as data processors
• Google Analytics, which receives website usage data only — never your name, contact details or coaching data (see section 3)
• Professional advisers or authorities, where we are legally required to disclose

We do not share your health data with advertisers, data brokers, insurers or employers. Ever.

7. Photos, testimonials and social media

Your progress photos are used to assess your progress. That's it — unless you separately and explicitly agree that we may publish them.

• We ask for permission before posting any photo, result or testimonial publicly.
• You can ask us to anonymise (crop the face) or to skip publication entirely, with no effect on your coaching.
• You can withdraw permission later. We'll remove the content from our website and our own social posts as soon as reasonably possible — although we can't force reposts by third parties to disappear.

8. How long we keep it

• Enquiries that don't become coaching: deleted or left to lapse in the messaging platform within about 12 months.
• Active client records: for the duration of coaching, so we can see your history and trends.
• Former client records: up to 24 months after coaching ends, so that returning clients keep their history — then deleted on request or as part of periodic clean-up.
• Payment and tax records: as long as Indian tax and accounting law requires (currently up to 8 years).
• Progress photos: deleted on request at any time, and otherwise not retained beyond the periods above.

9. How we protect it

We keep client data on password-protected, access-controlled devices and accounts with two-factor authentication enabled where the platform supports it. Access is limited to Dion. We keep only what we need, and we delete what we no longer need.

No system is perfectly secure, and messages travel through third-party platforms whose security we don't control. If a breach occurs that is likely to affect you, we will notify you and the relevant authority as required by law.

10. Your rights

Whatever your location, we will honour the following for anyone we hold data about:

• Access — ask for a copy of what we hold about you
• Correction — have inaccurate or incomplete information fixed
• Erasure — have your data deleted, subject to records we must keep by law
• Withdraw consent — at any time, for health data, photos or messaging
• Portability — receive your programme history and data in a usable format
• Object or restrict — object to a particular use, or ask us to pause processing while a dispute is resolved
• Nominate — nominate someone to exercise these rights on your behalf in the event of death or incapacity
• Complain — to us first, and then to the relevant data protection authority (in India, the Data Protection Board)

Message us to exercise any of these. We respond within 30 days and don't charge for it.

11. Children

We do not knowingly collect personal data from anyone under 13. Clients aged 13–18 are coached only with verifiable parental or guardian consent, and we do not use minors' data for tracking or advertising of any kind. If you believe a child's data has reached us without proper consent, message us and we'll delete it.

12. International transfers

Our analytics, messaging, storage and payment providers may process data on servers outside India — Google Analytics data in particular is processed on Google infrastructure in the United States and elsewhere. Where that happens we rely on those providers' contractual safeguards and their own compliance frameworks. If you'd rather your data stayed within a specific region, tell us — we may not be able to accommodate it, but we'll be straight with you about it.

13. Changes to this policy

We'll update this page when our practices or the law change, and the "last updated" date will always tell you which version you're reading. If a change materially affects how we handle your health data, we'll tell active clients directly.

14. Grievance officer and contact

In line with Indian data protection requirements, the grievance officer for Dion Samuel Coaching System is: