Privacy Policy

Last updated: 21 September 2026

At SHARD, privacy is an essential part of the relationship we build with our clients.

This Privacy Policy explains how WELLBEING COACH LTD (“SHARD”, “we”, “us” or “our”) collects, uses, stores and protects personal data when you visit our website, contact us or use our health, wellbeing and retreat services.

We process personal data in accordance with applicable data-protection legislation, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) where applicable to individuals in the European Union.

1. Who We Are

The SHARD website and services are operated by:

WELLBEING COACH LTD
Company Number: 13838702
Registered Office: 67, Meridian Centre, Havant PO9 1UN, United Kingdom
Email: healthwithnicoleta@gmail.com
Telephone: +44 7767 305616

WELLBEING COACH LTD is a private limited company incorporated in England and Wales.

For the purposes of applicable data-protection legislation, WELLBEING COACH LTD acts as the data controller for personal information for which it determines the purposes and means of processing.

Certain medical providers, laboratories and specialist professionals involved in your health journey may process your personal data as separate controllers or under other legally appropriate arrangements.

2. The Personal Data We Collect

The information we collect depends on how you interact with SHARD and which services you choose.

Contact and enquiry information

When you contact us or submit an enquiry through the website, we may collect:

• your name;
• email address;
• telephone number;
• country or location;
• details about the service or retreat you are interested in;
• preferred dates;
• information contained in your message; and
• any other information you voluntarily provide.

We ask that you do not send detailed medical records or sensitive health information through a general website contact form unless specifically requested through an appropriate secure process.

3. Health and Lifestyle Information

If you choose to proceed with a SHARD health journey, additional information may be required in order to personalise your experience.

Depending on the programme, this may include:

• health and medical history;
• existing medical information or results;
• lifestyle information;
• wellbeing priorities;
• personal objectives;
• movement and fitness information;
• nutrition-related information;
• sleep and recovery information;
• health assessment information;
• coaching information;
• personalised testing results;
• genetic or functional testing information, where applicable;
• medical consultation or assessment information;
• information relating to your Personal Health Strategy or Personal Health Blueprint; and
• information relating to your participation in the SHARD programme and continuing support.

The client programme documentation specifically provides for health and medical history review, personalised health assessment, Nordic Laboratories testing and medical consultations through Privatklinik Döbling / Mavie Med in Vienna.

More comprehensive programmes may also involve medical check-ups, health reports, personalised health strategies, dedicated coaching and continuing support after SHARD.

4. Special Category Data

Information concerning your health and genetic information can constitute special categories of personal data under the GDPR and receives additional legal protection.

Where we process health, genetic or other special-category information, we will do so only where an appropriate legal basis and additional condition under applicable data-protection law exists.

Depending on the circumstances, this may include:

• your explicit consent;
• processing necessary for the provision or management of health-related services by or under the responsibility of professionals subject to appropriate confidentiality obligations; or
• another applicable basis permitted by law.

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

Because some health information may be necessary to personalise or safely provide certain services, withdrawing consent or choosing not to provide particular information may mean that we cannot provide some or all elements of a programme.

5. How We Use Your Personal Data

We may process your personal information for the following purposes.

Responding to enquiries

To:

• respond to questions;
• contact you about SHARD;
• discuss available retreats and services;
• arrange an initial conversation; and
• recommend an appropriate next step.

Providing SHARD services

To:

• manage your booking or programme;
• understand your priorities and objectives;
• personalise your SHARD experience;
• coordinate coaching and wellbeing services;
• provide continuing support;
• maintain records relating to your programme; and
• communicate with you before, during and after your stay.

Health assessment and personalised guidance

Where appropriate, information may be used to:

• understand your health in context;
• coordinate health assessments;
• interpret relevant health information;
• arrange personalised testing;
• coordinate specialist consultations;
• develop a personalised health strategy;
• develop your Personal Health Blueprint;
• support lifestyle implementation; and
• review, refine and adapt your programme over time.

SHARD’s programme model explicitly connects health information, assessment and personal context with personalised direction and real-life practice.

Website administration and security

We may process technical information to:

• operate the website;
• keep the website secure;
• prevent fraud or misuse;
• diagnose technical problems; and
• improve website performance.

Legal and regulatory requirements

We may process or retain information where necessary to:

• comply with legal obligations;
• respond to lawful requests from authorities;
• establish or defend legal claims;
• maintain appropriate business records; or
• comply with professional, insurance or regulatory requirements.

6. Our Legal Bases for Processing

Depending on the purpose, we may rely on one or more of the following legal bases under the GDPR:

Contract

Processing may be necessary to:

• take steps at your request before entering into a contract; or
• perform services that you have requested.

Consent

We may rely on your consent for certain activities, including where required for:

• particular health-related processing;
• genetic or other personalised testing;
• optional cookies;
• certain marketing communications.

Legitimate Interests

We may process information where necessary for legitimate business purposes, provided those interests do not override your rights and freedoms.

These may include:

• responding to enquiries;
• administering our services;
• improving our website;
• protecting our business and systems; and
• maintaining appropriate client relationships.

Legal Obligation

We may process information where required to comply with applicable legal obligations.

GDPR requires organisations collecting personal information to explain the purposes and legal basis of processing to individuals.

7. Where We Obtain Your Information

We may obtain personal information:

Directly from you

For example when you:

• contact us;
• complete a form;
• book a consultation;
• participate in an assessment;
• communicate with a coach;
• participate in a SHARD programme; or
• provide information during ongoing support.

From healthcare or specialist providers

With an appropriate lawful basis, information may be received from or shared with relevant medical professionals, laboratories or specialists participating in your health journey.

Automatically through the website

Certain technical information may be collected when you use our website, including:

• IP address;
• browser information;
• device information;
• website interaction information; and
• cookies or similar technologies.

Please see our Cookie Policy for more information.

8. Who We May Share Your Information With

We only share personal data where this is necessary, appropriate and legally permitted.

Depending on your selected programme, recipients may include:

Medical providers

Where appropriate, this may include medical professionals and healthcare providers involved in your assessment or consultation, including Privatklinik Döbling / Mavie Med in Vienna.

The client’s service documentation provides for medical consultations in Vienna or remotely and allows medical assessment to be coordinated with appropriate providers.

Laboratories and testing providers

Where personalised testing is part of your programme, relevant information may be processed by authorised testing providers, including Nordic Laboratories, where applicable.

Health and performance specialists

Where relevant to your individual programme, SHARD may coordinate with selected specialists in areas such as:

• preventive medicine;
• specialist medicine;
• nutrition;
• sleep;
• psychology or mental performance;
• movement;
• sport and performance;
• recovery; and
• longevity and healthspan.

The client documentation describes the development of an international network of physicians, clinics, laboratories, health specialists and performance experts.

Service providers

We may also use trusted providers for functions such as:

• website hosting;
• email;
• IT infrastructure;
• website security;
• client administration;
• cloud storage;
• professional consultancy;
• accounting;
• legal services.

Where such organisations act as processors on our behalf, we require appropriate data-protection arrangements.

We do not sell your personal information.

9. Medical Professionals and Independent Controllers

Some healthcare professionals, clinics, laboratories and specialist organisations may determine independently how they process personal information for their professional services.

In such circumstances, they may act as independent data controllers and their own privacy policies may apply.

Where appropriate, you will receive additional information about how a particular provider processes your data before information is transferred or a service is provided.

10. International Transfers

SHARD operates internationally and some personal information may therefore be processed outside Romania or elsewhere outside the European Economic Area.

WELLBEING COACH LTD is registered in the United Kingdom.

The European Commission currently recognises the United Kingdom as providing an adequate level of protection for personal data under the GDPR, following renewal of the UK adequacy decision in December 2025. This allows GDPR-covered personal data to flow from the EU/EEA to the UK without additional transfer safeguards being required solely because of the transfer.

Where information is transferred to another country that is not covered by an adequacy decision, we will use appropriate safeguards where required, which may include:

• European Commission Standard Contractual Clauses;
• contractual and organisational safeguards; or
• another lawful transfer mechanism recognised by the GDPR.

11. How Long We Keep Your Personal Data

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to comply with applicable legal, contractual, professional or regulatory requirements.

Retention periods may vary depending on the type of information.

For example, different periods may apply to:

• general enquiries;
• contractual records;
• coaching records;
• medical or health information;
• testing information;
• invoices and accounting records;
• consent records; and
• website technical data.

When information is no longer required, it will be securely deleted, anonymised or otherwise handled in accordance with applicable law.

12. How We Protect Your Information

SHARD is designed around privacy and confidentiality.

We use appropriate technical and organisational measures intended to protect personal information against:

• unauthorised access;
• accidental loss;
• alteration;
• disclosure;
• destruction; and
• misuse.

Measures may include, where appropriate:

• restricted access;
• secure systems;
• authentication controls;
• confidentiality obligations;
• encrypted communications or storage;
• appropriate contractual safeguards;
• staff and professional confidentiality requirements; and
• secure information-handling procedures.

The SHARD documentation expressly describes the service as “Private by Design”, with confidentiality, professional ethics and data protection forming part of the client relationship.

13. Your Data Protection Rights

Subject to applicable law and any relevant exceptions, you may have the right to:

Access your personal data

You may request confirmation that we process your personal information and obtain a copy of that information.

Correct your personal data

You may ask us to correct information that is inaccurate or incomplete.

Request deletion

You may ask us to delete your personal data in circumstances where the law gives you that right.

Restrict processing

You may ask us to restrict the use of your information in certain circumstances.

Data portability

Where applicable, you may ask to receive information you provided in a structured, commonly used and machine-readable format or ask for it to be transferred to another provider.

Object to processing

Where processing is based on legitimate interests, you may have the right to object.

Withdraw consent

Where processing is based on your consent, you may withdraw that consent at any time.

Lodge a complaint

You have the right to lodge a complaint with a competent data-protection supervisory authority.

These rights are established by the GDPR, including the rights of access, rectification, erasure and other forms of control over personal data.

14. Exercising Your Rights

To exercise a privacy right or ask a question about your personal information, contact:

WELLBEING COACH LTD

Email: healthwithnicoleta@gmail.com

Telephone: +44 7767 305616

We may need to verify your identity before fulfilling a request in order to protect your personal information.

We will respond within the period required by applicable data-protection legislation.

15. Complaints

If you are concerned about how we process your personal data, please contact us first so that we can try to resolve the matter.

If you are located in Romania, you may also have the right to submit a complaint to:

Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal — ANSPDCP

B-dul General Gheorghe Magheru 28–30
Sector 1
Bucharest 010336
Romania

The Romanian supervisory authority provides a GDPR complaint procedure for data subjects.

You may also contact another competent supervisory authority where applicable.

16. Cookies

Our website uses cookies and similar technologies.

Some cookies are necessary for the website to operate, while optional technologies such as analytics or marketing cookies will only be used where an appropriate lawful basis exists.

For more information, please see our Cookie Policy.

17. Marketing Communications

Where you have requested information from us or consented to receive communications, we may contact you with relevant information about SHARD and its services.

Where consent is required, you may withdraw it at any time.

You can also ask us to stop sending marketing communications by contacting:

healthwithnicoleta@gmail.com

Service-related messages concerning an existing enquiry, booking or programme are not necessarily marketing communications and may still be sent where required to provide the service.

18. Automated Decision-Making

We do not intend to make decisions that have legal or similarly significant effects on you solely through automated processing.

Health and programme decisions are intended to involve appropriate human and professional judgement.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes to our services;
• changes to our processing activities;
• new healthcare or specialist partners;
• new technology;
• legal or regulatory changes; or
• changes to how the website operates.

The latest version will always be published on this page with the date of the most recent revision.

20. Contact Us

If you have questions about this Privacy Policy, the way we process your information or your privacy rights, please contact:

WELLBEING COACH LTD

Email: healthwithnicoleta@gmail.com
Telephone: +44 7767 305616

Registered Office:

67, Meridian Centre, Havant PO9 1UN, United Kingdom

Company Number: 13838702