THEEXERCISEDATABASE

Privacy Policy

The Exercise Database

Last updated: draft, 27 October 2026

1. Who we are

The Exercise Database is run by [company name — to be added] Ltd, a company registered in Scotland, number [company number — to be added], at [registered office address — to be added]. We are registered with the Information Commissioner's Office, number [ico registration number — to be added].

The Exercise Database is a service that physiotherapists, coaches, trainers and other practitioners use to build exercise programmes for the people they work with, record sessions, and give those people a link to their own programme. In this policy we call everyone with an account a clinician, whatever their profession, and the people they work with patients.

Contact us about anything in this policy at [data protection contact email — to be added].

2. Two roles, depending on whose data it is

Whose dataOur roleWhat that means
Clinicians: account holdersControllerWe decide how and why it is used. This policy is our full explanation
Patients: the people clinicians work withProcessorThe clinician decides. We store and process it only on their instructions. Your clinician is responsible for it. See section 3
Website visitorsControllerSection 6

3. If you are a patient

Your clinician holds your record, and we store it for them. Your clinician is the controller of your data, so they are the one to ask about it, and their own privacy notice explains how they use it. You can also see a summary in your portal and in any copy of your data your clinician gives you.

What we do with your record, on your clinician's behalf:

We never use your data for anything else. It is not combined with other clinicians' patients, not used for research or benchmarking, not used to train any automated system, and not sold or shared for marketing.

To see, correct or delete your data, or to complain, contact your clinician. If you contact us instead, we will pass your request to them straight away. We cannot answer it ourselves.

4. If you have an account

What we hold

DataWhere it comes from
Your name, email address and clinic nameYou, when you sign up
Your passwordYou. We never see it: it is stored scrambled (hashed) by our authentication provider
Your account role and status, sign-up date and last sign-inCreated as you use the service
The content you create: exercises, programmes, protocols, KPIs, templatesYou
Messages you send usYou
When you subscribe: billing address, card details, and your subscription and payment historyYou, through our payment provider, Stripe. We never see your full card number: Stripe holds it, and we see only the card type, last four digits and expiry
Short technical logs, including IP addressesYour browser, when you use the service. Kept for security, for at most a few days by our hosting provider

Why we use it, and our lawful basis

PurposeLawful basis
Creating and running your account, signing you in, resetting your passwordContract: we need it to provide the service you signed up for
Emails about the service: password resets, confirmations, important noticesContract
Keeping the service secure, and preventing abuseLegitimate interests: protecting you, your patients and the service
Answering your messagesLegitimate interests, or contract if it is about your account
Taking your subscription paymentsContract
Keeping invoices and payment records for taxLegal obligation: HMRC requires them

We do not send marketing emails. If that changes, we will only do so with your consent.

What you must give us

You need to give us your name, email address and a password to open an account, and your billing details if you subscribe. Without them we cannot provide the service. Everything else is optional.

How long we keep it

DataKept for
Your accountWhile your account is open, then 12 months
Your patients' recordsNot ours to decide. When you leave, you export them, and we delete our copy 30 days later, or sooner on your instruction
Records of emails we sent you30 days, by our email provider
Encrypted backupsUp to six months. A deleted record stays in backups, beyond use, until it ages out
Invoices and payment records6 years after the end of the accounting year they fall in, as HMRC requires, even after your account closes

5. Your rights

You have the right to:

Email [data protection contact email — to be added]. We answer within one month, and it is free. We may ask you to confirm who you are if there is real doubt.

We do not make any decisions about you based solely on automated processing, and we do not profile you.

Patients: these rights apply to your record too, but you exercise them through your clinician. See section 3.

6. If you visit our website

Counting page views. We use Vercel Web Analytics to count which pages are visited. It uses no cookies, does not store your IP address, and does not identify you. It records the page, the country and city the visit came from, your browser, your device type and where you came from. Before anything is sent, we remove anything identifying from the page address, including patient links. Our lawful basis is legitimate interests: understanding what is used so we can improve it. You can object by emailing us.

If you email us, for example to register interest, we keep your email and what you said for as long as we need to reply and follow up, and for no more than 12 months if nothing comes of it. Our email is hosted by Microsoft.

7. Who we share data with

We use a small number of providers to run the service. Each is bound by a contract to use the data only on our instructions and to keep it secure.

ProviderWhat it doesWhereWhat it receives
Supabase (Supabase Pte. Ltd.)Database and sign-inFrankfurt, GermanyEverything stored in the service
Vercel (Vercel Inc.)Runs the website and the serviceFrankfurt, GermanyEverything, while it is being processed
Vercel (Vercel Inc.)Page-view countingUnited StatesNo personal data. See section 6
Resend (Plus Five Five, Inc.)Sends emailsUnited StatesName, email address, and for patients their portal link
Google (Google LLC)Stores our backupsGoogle's data centresEncrypted backups only. Google cannot read them
MicrosoftOur email inboxMicrosoft's data centresEmails you send us
Stripe (Stripe Payments Europe, Limited)Takes subscription paymentsIreland and the United StatesClinicians' billing details only. Never patient data. Stripe also uses them for its own fraud and anti-money-laundering checks, as an independent controller under its own privacy policy

We publish a list of the providers that handle patients' data at /sub-processors, and tell clinicians before it changes.

We never sell personal data, and we never share it with anyone else except where the law requires us to, for example under a court order, or if the business is sold (below).

If the business is sold

If the service, or the company that runs it, is sold or merged with another business, the data we hold would pass to the new owner so the service can carry on. We will tell clinicians by email at least 30 days beforehand. The new owner must keep to this policy, and patients' records stay under their clinician's control.

Data leaving the UK

Germany is covered by UK adequacy regulations, so data held there is protected as it would be in the UK. For Resend in the United States, the transfer is protected by the UK's approved data transfer clauses (the international data transfer addendum to the EU standard contractual clauses), and Resend is also certified under the UK Extension to the EU-US Data Privacy Framework.

For Stripe, which sends billing details to the United States, the transfer is protected by Stripe's certification under the UK Extension to the EU-US Data Privacy Framework, with the UK's approved data transfer clauses as its fallback.

8. How we keep data safe

If something goes wrong, we will tell the clinicians affected without delay, and the ICO and you where the law requires.

9. Children

Accounts are for practitioners, not children. You must be [minimum age — to be confirmed] or over to open one.

Clinicians may work with children as patients. Their records are handled as in section 3, and kept until the child's 25th birthday at least, as the records rules for health care require.

10. Cookies and similar technologies

This section is our cookie notice.

We only use what the service needs to work. No advertising cookies, no tracking across websites, and no cookies from analytics. That is why there is no cookie banner: the law allows strictly necessary storage without asking.

What we store on your device

NameTypeWhat it is forHow long
sb-…-auth-tokenCookieKeeps you signed in. Strictly necessaryUntil you sign out, or up to 400 days
db_sessionBrowser storageHolds the programme you are building, so it is not lost if you refresh the page. Strictly necessaryCleared when you sign out
db_favouritesBrowser storageRemembers the exercises you have starredUntil you clear it
liveServicePatientIdBrowser storageRemembers which patient you last had open in live serviceCleared when you close that patient in live service

Patients using their portal link have no cookies set by us.

Content from YouTube and Google Drive

Exercise videos are hosted on YouTube, and some reference material on Google Drive.

Managing cookies

You can block or delete cookies in your browser's settings. If you block the sign-in cookie, you will not be able to sign in.

11. Complaints

Please tell us first, at [data protection contact email — to be added]. We will acknowledge your complaint within 30 days and aim to resolve it quickly.

If you are not happy with our answer, you can complain to the Information Commissioner's Office: ico.org.uk/make-a-complaint, or 0303 123 1113.

Patients: complain to your clinician first, since they are responsible for your record.

12. Changes to this policy

We will update this page when anything changes, and change the date at the top. If a change matters to you, for example a new provider handling patient data, we will tell clinicians by email at least 30 days before it takes effect.