Privacy Policy

This Privacy Policy describes how Pure Focus FZCO ("Pure Focus," "we," "us," or "our") collects, uses, and protects your personal information when you visit our website at purefocusprogram.com (the "Site") and use our services.

By accessing this Site or submitting any information through it, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

The data controller responsible for your personal data is:

Pure Focus FZCO
Dubai, United Arab Emirates
Email: manou@purefocusprogram.com

We may collect and process the following categories of personal data:

a) Information you provide directly:

• Name, email address, and phone number (when you fill out a form, register for a masterclass, or apply for our program)
• Business information (company name, revenue, role)
• Health and wellness information you voluntarily share during the application or onboarding process (goals, current habits, medical history, dietary preferences)
• Payment and billing information (processed securely by our third-party payment processors)
• Any other information you choose to share with us via forms, emails, or messages

b) Information collected automatically:

• IP address and approximate geographic location
• Browser type, device type, and operating system
• Pages visited, time spent on pages, and referring URLs
• Cookies and similar tracking technologies (see Section 7)

c) Information from third-party sources:

• Social media profile information if you interact with us through platforms such as Instagram, LinkedIn, or YouTube
• Scheduling and call data from booking platforms

If you enroll in our coaching program, we may collect and process health-related data, including but not limited to:

• Body composition measurements (weight, body fat percentage, physique photos)
• Sleep and activity data (e.g., from wearable devices such as Oura Ring)
• Bloodwork and biomarker results
• Gut microbiome test results
• Dietary logs and supplement protocols

This data is classified as special category data under the GDPR. We only process this data with your explicit consent, which you provide during the onboarding process. You may withdraw this consent at any time by contacting us, though this may affect our ability to deliver the coaching services.

We use your personal data for the following purposes:

• Service delivery: To provide, personalize, and improve our coaching programs and related services
• Communication: To respond to your inquiries, send appointment reminders, and provide program-related updates
• Marketing: To send you information about our services, events, and content that may be of interest to you (only with your consent or where we have a legitimate interest; you can opt out at any time)
• Analytics: To analyze website usage, improve our Site, and understand how visitors interact with our content
• Legal compliance: To comply with applicable laws, regulations, and legal obligations
• Fraud prevention: To protect against unauthorized access and ensure the security of our services

If you are located in the European Economic Area (EEA), United Kingdom, or another jurisdiction where GDPR or similar legislation applies, we process your data based on the following legal grounds:

• Consent: Where you have given clear consent for us to process your personal data for a specific purpose (e.g., health data, marketing emails)
• Contract: Where processing is necessary for the performance of a contract with you (e.g., delivering coaching services you have purchased)
• Legitimate interest: Where processing is necessary for our legitimate business interests, provided these are not overridden by your rights (e.g., analytics, fraud prevention)
• Legal obligation: Where processing is necessary to comply with a legal obligation

We do not sell, rent, or trade your personal information. We may share your data with the following categories of third-party service providers who assist us in operating our business:

• CRM and funnel software: GoHighLevel (form submissions, email marketing, scheduling)
• Coaching platform: Trainerize (meal plans, exercise programs, progress tracking)
• Communication tools: WhatsApp, Slack (daily accountability and client support)
• Community platform: Skool (private community access)
• Project management: Notion (client resource dashboards)
• Payment processors: Stripe and/or other payment gateways (payment processing)
• Analytics: Google Analytics or similar tools (website usage data)
• Health testing providers: Inside Tracker, Viome (bloodwork and microbiome analysis, only for enrolled clients who have consented)

Each of these providers has their own privacy policy governing their use of your data. We encourage you to review their policies.

We may also disclose your information if required by law, regulation, legal process, or governmental request.

Our Site uses cookies and similar technologies to enhance your browsing experience. These may include:

• Essential cookies: Required for the Site to function properly (e.g., form submissions, session management)
• Analytics cookies: Used to understand how visitors interact with the Site (e.g., page views, traffic sources)
• Marketing cookies: Used to deliver relevant advertisements and track campaign performance

You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Site.

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:

• Lead/inquiry data: Up to 24 months after your last interaction with us, unless you request earlier deletion
• Client data: For the duration of our coaching relationship and up to 36 months after it ends, to support follow-up services and legal obligations
• Health data: For the duration of our coaching relationship and deleted within 12 months after the relationship ends, unless you request earlier deletion or applicable law requires longer retention
• Financial records: As required by applicable tax and accounting regulations

Your data may be transferred to and processed in countries outside your country of residence, including the United Arab Emirates and the United States (where some of our service providers are based). Where such transfers occur, we take appropriate measures to ensure your data is protected in accordance with applicable data protection laws, including the use of Standard Contractual Clauses (SCCs) where required.

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: The right to request a copy of the personal data we hold about you
• Rectification: The right to request correction of inaccurate or incomplete data
• Erasure: The right to request deletion of your personal data ("right to be forgotten")
• Restriction: The right to request restriction of processing of your data
• Portability: The right to receive your data in a structured, commonly used, machine-readable format
• Objection: The right to object to the processing of your data, including for direct marketing purposes
• Withdraw consent: The right to withdraw consent at any time where processing is based on consent

To exercise any of these rights, please contact us at manou@purefocusprogram.com. We will respond to your request within 30 days.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority in your country of residence.

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit, secure access controls, and regular review of our data processing practices.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security.

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child under 18, we will take steps to delete such information promptly.

Our Site may contain links to third-party websites, platforms, or services. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. Any changes will be posted on this page with an updated "Last updated" date. We encourage you to review this Privacy Policy periodically. Your continued use of the Site after any changes constitutes your acceptance of the updated policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

Pure Focus FZCO
Email: manou@purefocusprogram.com
Website: purefocusprogram.com