Privacy Policy

1. Introduction & Executive Commitment

Portfoliotoptlly Apex Elite Ltd ("Portfoliotoptlly", "We", "Us", or "Our") respects the confidentiality and data integrity of our esteemed clientele. This Privacy Policy governs our data collection, processing, storage, and protection practices across portfoliotoptlly.christmas and all related application interfaces. We operate in full accordance with the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, and international privacy standards.

2. Personal Data We Collect

To provide high-level, bespoke physical coaching, we collect personal and biometric information, including but not limited to:

• Identity & Contact Data: Full legal name, email address, direct telephone number, geographic address.
• Health & Biometric Data: Body composition metrics (body fat %, lean mass), age, height, physiological goals, heart-rate variability (HRV), continuous glucose monitor (CGM) inputs, and food sensitivity records provided directly during intake.
• Technical & Telemetry Data: IP addresses, browser types, session timestamps, and device metrics collected automatically through encrypted cookies.

3. Legal Basis and Purpose for Processing

We process your data exclusively under the following legal frameworks:

1. Performance of Contract: Processing necessary to deliver custom workout architecture, metabolic plans, and direct 1-on-1 coaching oversight.
2. Explicit Consent: Explicit authorization granted when submitting biometric assessment forms or agreeing to telemetry cookies.
3. Legitimate Interests: Enhancing platform security, refining workout algorithms, and preventing fraudulent system access.

4. Data Storage, Security & Encryption

All biometric and client records are encrypted both at rest (AES-256) and in transit (TLS 1.3). We utilize isolated, zero-trust cloud servers located within top-tier data centers in London, United Kingdom. Access to client files is restricted strictly to assigned senior performance coaches.

5. Third-Party Sharing Protocols

Portfoliotoptlly does not sell, trade, rent, or lease your personal or biometric information to third-party brokers or advertisers under any circumstances. Data is shared exclusively with audited service providers essential to service execution (e.g., secure payment gateways, HIPAA/GDPR compliant form servers).

6. Data Retention & Erasure

We retain client records for the duration of your active coaching subscription plus 24 months to maintain long-term metabolic history. Upon contract expiration or formal written request, your data will be permanently wiped via cryptographic shredding protocols.

7. Your Statutory Rights (GDPR / CCPA)

Under global data privacy laws, you possess the following rights:

• Right of Access: Request a full copy of all personal and biometric data held in your profile.
• Right to Rectification: Request correction of inaccurate health or contact information.
• Right to Erasure ("Right to Be Forgotten"): Demand complete deletion of your records.
• Right to Data Portability: Obtain your biometric metrics in a structured JSON or CSV format.

8. Data Protection Officer Contact

To exercise any of your privacy rights or submit inquiries regarding our data handling procedures, please contact our Data Protection Officer at:

Data Protection Officer | Portfoliotoptlly Apex Elite Ltd
74 Mayfair Royal Way, London, W1J 8AJ, United Kingdom
Email: [email protected]