This Privacy Policy applies between you, the User of the Website and App, and True Health Limited, the owner and provider of the Loaded website and mobile application. True Health Limited takes the privacy of your information very seriously. This Privacy Policy applies to our use of any and all Personal Data collected by us or provided by you in relation to your use of the Website, the App and the Services.

This Privacy Policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: https://www.loadedapp.co.uk/legal/privacy-policy.

Please read this Privacy Policy carefully.

Definitions and Interpretation

1.  In this Privacy Policy, the following definitions are used:

2.  In this Privacy Policy, unless the context requires a different interpretation:

a.  the singular includes the plural and vice versa;

b.  references to clauses and sub-clauses are to clauses and sub-clauses of this Privacy Policy;

c.  a reference to a person includes firms, companies, government entities, trusts, partnerships and other legal entities;

d.  "including" is understood to mean "including without limitation";

e.  reference to any statutory provision includes any modification, amendment, replacement or re-enactment of it; and

f.  the headings and sub-headings do not form part of this Privacy Policy.

Scope of this Privacy Policy

3.  This Privacy Policy applies to the collection and use of Personal Data by True Health Limited in connection with the Website, App and Services. It does not apply to any websites, platforms, app stores or third-party services that may be accessed from the Website or App, including the Apple App Store, Google Play, social media websites and any third-party websites that we may link to.

4.  For the purposes of the applicable Data Protection Laws, True Health Limited is the “data controller”. This means that True Health Limited determines the purposes for which, and the manner in which, your Personal Data is processed.

5.  Loaded is currently intended for users in the United Kingdom only and is not marketed or intended for use by individuals located outside the United Kingdom.

6.  You must not use Loaded if you are under 18. We do not knowingly collect Personal Data from anyone under 18. If we become aware that we have collected Personal Data from a person under 18, we will take reasonable steps to close the account and delete the relevant Personal Data, unless we are required to keep it for legal reasons.

7.  Loaded does not sell physical products, provide one-to-one coaching or live consultations, operate coach messaging or chat functionality, or provide wearable devices or hardware products.

Personal Data Collected

8.     We may collect the following Personal Data from or about you:

a. account and sign-in information, including your name, email address, username, password credentials stored in protected or hashed form, account identifiers and sign-in/session information;

b. Apple ID or Google account information if you choose Sign in with Apple or Sign in with Google, such as the identifier and email address made available by the relevant provider;

c. account role information, including whether you are a Standard User or a Loaded Coach;

d. onboarding and profile information, including date of birth or age, gender if collected, training experience level, goals, preferred session duration, training frequency, home gym, equipment selection and equipment exclusions;

e. fitness programme information, including generated programmes, programme names, workouts, exercises, training systems, assigned sets, rep ranges, rest periods, exercise video references, active programme status and programme history;

f. progress information, including per-set weights used, reps achieved, RPE or difficulty feedback, completed exercises, skipped exercises, replacement exercises, workout completion history and progression suggestions;

g. information you choose to provide about injuries, health conditions, physical limitations or other relevant circumstances when using onboarding, skip, replacement or personalisation features. This may include health information and, where applicable, will be treated as Special Category Data in accordance with the Data Protection Laws;

h. Loaded Coach and sharing information, including programmes created, edited and shared, role status, subscription tier, username-based sharing actions, username connections, shared records, programme ownership or attribution and changes made to shared programmes;

i. subscription and purchase information, including subscription plan, billing tier, subscription status, trial status where applicable, renewal, cancellation, expiry, entitlement information, store transaction identifiers, receipt information and subscription lifecycle information received from Apple, Google and RevenueCat;

j. device, technical and usage information, including IP address, device type and model, operating system, app version, language, time zone, crash or diagnostic data, security logs, token/session data, screens viewed, feature use, programme generation, programme sharing, workout starts and completions, subscription gate events and app errors;

k. push notification tokens for Apple Push Notification service and Firebase Cloud Messaging, where push notifications are enabled;

l. location and gym search information, including gym name, location query, selected gym, map pin or similar information where you use a gym search or selection feature. If the App requests device location permission in the future, we will only use precise location where you allow it through your device settings and where it is needed for the relevant feature;

m. communications information, including the content of your message, contact details, support history and any attachments or information you choose to provide if you contact us; and

n. cookie, SDK and similar technology information used for security, login, subscription access, analytics, performance and crash/error reporting.

in each case, in accordance with this Privacy Policy.

How We Collect Personal Data

9.  We collect Personal Data in the following ways:

a.  you give it to us;

b.  we receive it from other sources; and

c.  we collect it automatically.

Personal Data That is Given to Us by You

10.  True Health Limited will collect your Personal Data in a number of ways, for example:

a.  when you contact us through the Website, App, by e-mail or through any other support or feedback channel;

b.  when you register with us and set up an account to receive the Services;

c.  when you complete onboarding questions or update your profile, goals, experience level, training frequency, session duration, home gym or equipment selection;

d.  when you generate, save, regenerate, use, edit or receive fitness or mobility programmes;

e.  when you log workout progress, weights, repetitions, perceived effort, skipped exercises, replacement exercises or completion history;

f.  when you voluntarily provide your username to a Loaded Coach and choose to connect with that Loaded Coach;

g.  when you purchase, cancel, renew or otherwise manage a subscription through the Apple App Store or Google Play;

h.  when you elect to receive marketing communications from us; and

i.  when you otherwise use the Website, App or Services.

in each case, in accordance with this Privacy Policy.

Personal Data That is Received From Third Parties

11.  True Health Limited will receive Personal Data about you from the following third parties:

a.  Apple and Google, where you use Apple ID, Sign in with Apple, Sign in with Google or similar platform authentication services;

b.  the Apple App Store and Google Play, including confirmation of your purchase, subscription status, trial status where applicable, renewal, cancellation, expiry and related transaction identifiers;

c.  RevenueCat, which supports subscription entitlement management, receipt validation and subscription lifecycle events;

d.  Google Maps SDK or similar map/location providers, where you use home gym search, map or location query functionality;

e.  Firebase Cloud Messaging and Apple Push Notification service, where push notifications are enabled; and

f.  technical service providers that support hosting, backend functionality, monitoring, analytics, security, support and e-mail services.

12.  We do not receive your full payment card details. Payments are processed by the Apple App Store or Google Play and not directly by Loaded through the Website or App.

Personal Data That is Received From Publicly Available Third Party Sources

13.  We do not routinely collect Personal Data from publicly available third-party sources. If you interact with our social media profiles or public pages, we may receive information that you choose to make available through the relevant platform, subject to that platform’s terms and your privacy settings.

Personal Data That is Collected Automatically

14.  To the extent that you access the Website, App or Services, we will collect certain Personal Data automatically, for example:

a.  we automatically collect some information about your visit to the Website, including your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content;

b.  we automatically collect some App usage and technical information, including device type and model, operating system, app version, language, time zone, crash or diagnostic information, security logs, token/session information and similar technical information;

c.  we may collect usage events, such as screens viewed, feature use, programme generation, programme sharing, workout starts and completions, subscription gate events and app errors;

d.  we may collect push notification tokens where you enable push notifications; and

e.  we will collect information automatically via cookies, SDKs and similar technologies, in line with your cookie settings, device settings and applicable law. For more information about cookies and similar technologies, see the section below headed “Cookies”.

Special Category Personal Data

15.  Some fitness, mobility, injury and limitation information may reveal information about your health. Where this information relates to your health, it may be treated as Special Category Data under the Data Protection Laws.

16.  Where we process Special Category Data to provide optional personalisation, safety-related or programme-related features, we will rely on your explicit consent unless another condition under the Data Protection Laws applies.

17.  Where we rely on your consent to process Special Category Data, you can withdraw that consent by contacting us or by using in-app controls where available. Withdrawing consent may affect features that depend on that information, but it will not affect processing already carried out lawfully before withdrawal.

Our Use of Personal Data

18.  We may use the Personal Data described above where necessary to provide, operate and improve the Website, App and Services. Specifically, we may use your Personal Data for the following reasons:

a.  to create and maintain your account, authenticate you, keep you logged in, route you through logged-in, logged-out and subscription states and operate the programme library and App features;

b.  to generate, save, regenerate, display and update fitness and mobility programmes using onboarding information, goals, experience, equipment and training frequency;

c.  to track workout progress and progression, including storing weights, repetitions, RPE, exercise history, skipped exercises, replacements and progression suggestions;

d.  to operate Loaded Coach features, including enabling Loaded Coaches to create and share programmes by username, enforcing role-based permissions and applying programme ownership rules;

e.  to manage subscriptions, check subscription entitlements, process Apple and Google subscription events through RevenueCat, manage Standard User and Loaded Coach billing tiers and restrict paid features to active subscribers;

f.  to respond to support requests and send account, security, password reset, subscription and service notices;

g.  to send push notifications about shared programmes or App features where enabled;

h.  to fix bugs, analyse usage, measure feature performance, maintain security, prevent fraud, protect against misuse and improve user experience;

i.  to send optional marketing e-mails or App messages about Loaded where permitted and in accordance with your preferences;

j.  to keep records, respond to legal requests, enforce our terms, defend claims and comply with legal obligations.

in each case, in accordance with this Privacy Policy.

19.  We may use your Personal Data for the purposes set out above where it is necessary for the performance of a contract between you and us, where we need to comply with a legal obligation, where you have given consent, or where it is necessary for our legitimate interests and your interests, rights and freedoms do not override those interests.

20.  Where we rely on legitimate interests, those interests may include operating and improving Loaded, maintaining security, preventing fraud, enforcing our terms, understanding the use of the Services and communicating with you about service-related matters.

21.  For the delivery of direct marketing to you via e-mail, we will rely on your consent or the soft opt-in where applicable. You have the right to withdraw consent or opt out of marketing at any time.

22.  We do not use Special Category Data for marketing unless permitted by law and with appropriate consent.

23.  We may use cookies, SDKs and similar technologies to show you True Health Limited adverts and other content on other websites only where permitted by your cookie choices and applicable law. If you do not want us to use your Personal Data in this way, please turn off the relevant cookies or adjust your device settings.

Automated Decisions and Personalisation

24.  Loaded may use rules, algorithms or automated logic to generate or adjust programmes, suggest progression, replace exercises, preserve old programmes after profile changes and display plain-language training suggestions.

25.  These features are intended to support your use of the App and do not replace professional medical, physiotherapy, nutritional or personal training advice.

26.  We do not currently use automated decision-making that produces legal or similarly significant effects about you.

Who We Share Personal Data With

27.  We may share your Personal Data with the following groups of people for the following reasons:

a.  our employees, agents and/or professional advisers, to manage the Services, user profiles, support requests, legal compliance and business administration;

b.  third-party service providers who provide services to us which require the processing of Personal Data, including hosting, backend, e-mail, monitoring, analytics, crash/error reporting, security and support providers, to help ensure the Website, App and Services operate securely and effectively;

c.  Apple and Google, for app distribution, social sign-in where selected, in-app purchase processing, subscription management and platform services;

d.  RevenueCat, for subscription entitlement management, receipt validation and subscription lifecycle events;

e.  Supabase, for real-time programme sync and related backend functionality, where used;

f.  Firebase Cloud Messaging and Apple Push Notification service, for delivery of App push notifications and device token handling;

g.  Google Maps SDK, for home gym search, map and location query functionality, where used;

h.  Loaded Coaches, where you voluntarily provide your username to a Loaded Coach and choose to connect with that Loaded Coach. Relevant programme-related information may be made available to that Loaded Coach within the App, such as your username, shared programme details, programme attribution, changes to the programme, workout completion information, progress information and RPE or difficulty feedback. Loaded does not share your email address, payment details or direct contact details with Loaded Coaches through the App;

i.  Funxtion, from whom Loaded licenses exercise content. Loaded does not provide Funxtion with user Personal Data for the routine operation of the App;

j.  relevant authorities, regulators, law enforcement agencies, courts, professional advisers and insurers, where needed for legal, regulatory, accounting, insurance, dispute or security reasons; and

k.  a buyer, investor or successor if we sell, transfer or reorganise all or part of our business, subject to appropriate safeguards.

in each case, in accordance with this Privacy Policy.

28.  We will update this Privacy Policy where necessary to reflect the third-party service providers used in connection with the Website, App and Services.

29.  Where you choose to connect with a Loaded Coach, that Loaded Coach may be able to view relevant programme-related information made available through the App, including shared programme details, workout completion information, progress information and RPE or difficulty feedback, where this functionality is enabled.

Keeping Personal Data Secure

30.  We will use technical and organisational measures to safeguard your Personal Data, for example:

a.  access to your account is controlled by a password and a username that is unique to you;

b.  password credentials are stored in protected or hashed form;

c.  we use measures designed to protect Personal Data, including secure authentication, HTTPS, rate limiting, access controls, secure API tokens, administrative access controls and monitoring; and

d.  we store your Personal Data on secure servers and restrict access to those who need it for legitimate business purposes.

31.  Technical and organisational measures include measures to deal with any suspected Personal Data breach. If you suspect any misuse or loss of, or unauthorised access to, your Personal Data, please let us know immediately by contacting us via this email address: hq@loadedapp.co.uk.

32.  No system is completely secure, so you should keep your login details confidential and tell us if you believe your account has been compromised.

Personal Data Retention

33.  Unless a longer retention period is required or permitted by law, we will only hold your Personal Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Personal Data be deleted.

34.  Our current retention approach is as follows:

a.  account, profile and programme Personal Data: for the life of the account, then deleted or anonymised within a reasonable period after account deletion unless a legal reason requires retention;

b.  subscription and transaction records: normally up to 6 years after the relevant transaction or account closure for tax, accounting and legal reasons;

c.  support communications: normally up to 6 years from the last interaction, unless a shorter or longer period is appropriate for the issue;

d.  analytics and diagnostic information: retained in identifiable form only as long as necessary for analytics, security and debugging, then deleted or aggregated;

e.  push notification tokens: until logout, uninstall, token expiry, account deletion or when no longer needed; and

f.  backups: deleted Personal Data may persist on backup or archival media for a limited period until backups rotate, subject to access restrictions.

35.  Even if we delete your Personal Data, it may persist on backup or archival media for legal, tax, regulatory or technical reasons for a limited period.

Your Rights

36.  You have the following rights in relation to your Personal Data:

a.  Right to access - the right to request copies of the information we hold about you at any time;

b.  Right to correct - the right to have your Personal Data rectified if it is inaccurate or incomplete;

c.  Right to erase - the right to request that we delete or remove your Personal Data from our systems;

d.  Right to restrict our use of your Personal Data - the right to block us from using your Personal Data or limit the way in which we can use it;

e.  Right to data portability - the right to request that we move, copy or transfer your Personal Data;

f.  Right to object - the right to object to our use of your Personal Data, including where we use it for our legitimate interests or direct marketing;

g.  Right to withdraw consent - the right to withdraw consent where consent is our legal basis for processing your Personal Data; and

h.  Right to complain - the right to raise a complaint with us directly about how we handle your Personal Data and to complain to the Information Commissioner's Office.

37.  Your rights are not absolute and may depend on the lawful basis and circumstances. If we provide you with access to the Personal Data we hold about you, we will not charge you for this unless your request is manifestly unfounded or excessive. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

38.  To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Personal Data where consent is our legal basis for processing your Personal Data, please contact us via this email address: hq@loadedapp.co.uk.

39.  If you have a complaint about how we handle your Personal Data, please contact us in the first instance via this email address: hq@loadedapp.co.uk. We will investigate and respond without undue delay and inform you of the outcome.

40.  If you are not satisfied with the way your complaint is handled by us, you may refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office. The ICO's contact details can be found on their website at https://ico.org.uk/.

41.  It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during the period for which we hold it.

Transfers Outside the United Kingdom

42.  Loaded is intended for UK users, but some service providers may process Personal Data outside the United Kingdom.

43.  Where we transfer Personal Data outside the United Kingdom, we will only do so where it is compliant with Data Protection Laws and the means of transfer provides adequate safeguards in relation to your Personal Data, for example by way of UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or another lawful transfer mechanism.

44.  To ensure that your Personal Data receives an adequate level of protection, we will put in place appropriate safeguards and procedures with the third parties we share your Personal Data with. This helps ensure your Personal Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Links to Other Websites

45.  The Website or App may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of Business Ownership and Control

46.  True Health Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of True Health Limited. Personal Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Personal Data for the purposes for which it was originally supplied to us.

47.  We may also disclose Personal Data to a prospective purchaser, investor or successor of our business or any part of it.

48.  In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

49.  The Website and App may place and access certain Cookies, SDKs and similar technologies on your computer or device. True Health Limited uses Cookies and similar technologies to improve your experience of using the Website, App and Services and to support security, login, subscription management, analytics, performance and crash/error reporting.

50.  All Cookies and similar technologies used by the Website and App are used in accordance with applicable UK cookie and privacy laws.

51.  Strictly necessary technologies are used to provide the Services. Non-essential cookies or similar technologies, including analytics or marketing technologies, will be used only where enabled and where appropriate consent or other lawful basis has been obtained.

52.  Before the Website or App uses non-essential Cookies or similar technologies, you should be presented with a message bar, consent tool or equivalent consent mechanism requesting your consent where required by applicable law. You may deny consent to the use of non-essential Cookies or similar technologies; however, certain features of the Website or App may not function fully or as intended.

53.  The Website and App may use the following Cookies or similar technologies:

54.  The table above sets out the main categories of Cookies and similar technologies that we may use.

55.  You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies, but this can be changed. For further details, please see the help menu in your internet browser. You can also manage certain App permissions and settings through your device settings. You can switch off Cookies or adjust relevant App permissions at any time; however, certain features of the Website or App may not function fully or as intended.

56.  You can choose to delete Cookies at any time or adjust relevant App permissions and settings through your device settings; however, certain features of the Website or App may not function fully or as intended, including personalisation settings.

57.  It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

58.  For more information generally on Cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete Cookies from your computer.

59.  Where required, further details about the actual Cookies and similar technologies used by Loaded, including relevant providers, purposes and retention periods, will be made available through our cookie notice, consent tool or App settings.

General

60.  You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected.

61.  If any court or competent authority finds that any provision of this Privacy Policy, or part of any provision, is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.

62.  Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

63.  This Privacy Policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under this Privacy Policy will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to This Privacy Policy

64.  True Health Limited reserves the right to change this Privacy Policy from time to time or as may be required by law. Any changes will be posted on the Website or made available through the App. The updated Privacy Policy will apply from the next time you use the Website, App or Services following the changes.

65.  If a change materially affects your rights or how we use Personal Data, we will take reasonable steps to notify you, such as by email, in-app notice or other prominent notice.

66.  This Privacy Policy was last updated on 29 June 2026. You may contact True Health Limited by email at hq@loadedapp.co.uk.