Comeback HQ — Privacy Notice

Comeback HQ respects your privacy and is committed to protecting your personal information.

This Privacy Notice explains how we collect, use, store and protect personal data when you visit our website, join our communities, complete an assessment, participate in a challenge, purchase a programme or contact us.

Comeback HQ is operated by [insert legal business or proprietor name], based in Jersey, Channel Islands.

For the purposes of applicable data protection law, the business is the data controller for the personal information described in this notice.

Depending on how you interact with Comeback HQ, we may collect:

• Your name, email address and contact details.
• Information submitted through website forms and enquiries.
• Answers and results from the Edge Score assessment.
• Information about your goals, habits and personal development interests.
• Information voluntarily shared during coaching or community participation.
• Purchase, transaction and booking information.
• Communications and feedback.
• Technical information, such as device type, browser information and website usage data.

We do not intentionally collect more personal information than is reasonably necessary for the relevant purpose.

Some information you voluntarily provide may relate to your physical or mental health. We will only process special-category personal data where a valid legal basis and an additional lawful condition apply, such as explicit consent where appropriate.

We may use personal information to:

• Respond to enquiries.
• Provide coaching, programmes and challenges.
• Administer membership of the Comeback Circle and other communities.
• Deliver assessment results and requested resources.
• Process payments and bookings.
• Communicate important service information.
• Improve our website, services and participant experience.
• Send newsletters and marketing communications where permitted.
• Meet legal, regulatory and accounting obligations.
• Protect the security and integrity of our services.

We do not sell your personal information to advertisers or data brokers.

Depending on the circumstances, we may process personal data because:

Contract: Processing is necessary to provide a service you have purchased or requested.

Legitimate interests: Processing is reasonably necessary to operate and improve our business, respond to enquiries, maintain security or manage customer relationships, provided those interests do not override your rights.

Consent: You have given consent for specific processing, such as certain marketing communications or the processing of sensitive information where explicit consent is appropriate.

Legal obligation: Processing is necessary to comply with applicable legal or regulatory requirements.

Where we rely on consent, you may withdraw it at any time. Withdrawal will not affect processing that was lawful before consent was withdrawn.

When you complete the Comeback HQ Edge Score or another assessment, we may collect your responses, calculated score and contact details.

We use this information to provide assessment results, help you understand relevant personal development themes and, where appropriate, respond to requests for further support.

We will not use assessment responses to make decisions that produce legal or similarly significant effects about you solely through automated processing.

Assessment results are not medical diagnoses or clinical evaluations.

We will not use assessment information for unrelated marketing without an appropriate legal basis.

We may send service-related emails necessary to provide programmes or respond to enquiries.

We may also send newsletters, updates and promotional communications where we have an appropriate legal basis and comply with applicable electronic marketing rules.

You can opt out of marketing emails at any time by using the unsubscribe facility or contacting us.

Opting out of marketing does not prevent us from sending necessary service communications.

Comeback HQ may operate WhatsApp groups and other online communities.

When joining a WhatsApp group, your phone number, profile information and messages may be visible to other group members, depending on the platform's settings.

Members should be mindful of the information they choose to share.

We cannot guarantee that other members will maintain the confidentiality of information voluntarily posted in a group.

WhatsApp and other third-party platforms process information in accordance with their own privacy policies.

We may use third-party providers to deliver services, process payments, host our website, manage email communications and support online bookings.

These providers may process personal information on our behalf or independently, depending on their role.

We only share information reasonably necessary for the relevant purpose and seek appropriate contractual and security safeguards where required.

Payment card information is generally processed by the relevant payment provider rather than stored directly by Comeback HQ.

Our website may use cookies or similar technologies necessary for website functionality, security, analytics or user preferences.

Where required by applicable law, we will request consent before using non-essential cookies or tracking technologies.

You can manage cookies through your browser settings and any cookie preference controls provided on our website.

[Before publication: confirm the actual cookies, analytics services and consent controls used by the website.]

Some service providers may process personal data outside Jersey, the United Kingdom or the European Economic Area.

Where international transfers occur, we will use appropriate legal safeguards as required by applicable data protection law.

These may include recognised adequacy arrangements or appropriate contractual protections.

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including legal, accounting, contractual and dispute-resolution requirements.

Retention periods depend on the type of information and the relevant purpose.

For example:

• Enquiry information is retained only while reasonably necessary to respond and manage follow-up.
• Customer and transaction records may be retained for applicable accounting and legal obligations.
• Marketing information is retained until consent is withdrawn or another applicable retention limit is reached.
• Assessment and coaching information is periodically reviewed and deleted or anonymised when no longer required.

We aim to securely delete or anonymise personal information when it is no longer needed.

We take reasonable technical and organisational measures to protect personal information from unauthorised access, misuse, loss, alteration or disclosure.

However, no online system can guarantee absolute security.

If a personal data breach occurs, we will assess and report it where required by applicable law.

Depending on the applicable law and circumstances, you may have rights to:

• Access personal information held about you.
• Request correction of inaccurate information.
• Request deletion of personal information.
• Restrict or object to certain processing.
• Request transfer of certain information.
• Withdraw consent where processing relies on consent.
• Raise concerns about the way your information is handled.

These rights are subject to applicable legal conditions and exceptions.

To exercise your rights, please contact us using the details below.

If you have concerns about how we handle personal information, please contact us first so that we can investigate.

You may also complain to the relevant data protection authority.

For Jersey, this is the Jersey Office of the Information Commissioner.

Website: https://www.jerseyoic.org/

Where UK data protection law applies, you may also have the right to complain to the UK Information Commissioner's Office.

Website: https://ico.org.uk/

Comeback HQ's coaching programmes, assessments and communities are intended for adults aged 18 and over.

We do not knowingly collect personal information directly from children through these services.

If we become aware that personal information has been collected from a child inappropriately, we will take appropriate steps to address the situation.

We may update this Privacy Notice to reflect changes in our services, data processing practices or legal requirements.

The latest version will be published on our website with an updated revision date.

Where material changes require additional notice or consent, we will take appropriate steps.

For questions, privacy requests or concerns, please contact:

Comeback HQ

Website: www.comebackhq.co.uk

Email: tim.guest2@icloud.com

Legal business name: Comeback HQ / Tim Guest

Business address: Rue de Haut, St Lawrence, Jersey, JE3 1JZ