Privacy Policy
1. Who we are
This policy explains how Dark Horse S&P ("Dark Horse", "we", "us") collects, uses, and protects personal data about visitors to darkhorsestrength.ie and people who train with us.
We are the data controller for the personal data described in this policy.
- Trading name: Dark Horse S&P (Strength and Performance)
- Address: 17 Main Street (Rear of), Bray, Co. Wicklow, A98 Y5R3, Ireland
- Contact email: info@darkhorsestrength.ie
- Phone: 087 974 8058
If you have any questions about this policy or about how we handle your personal data, please contact us using the details above.
2. What data we collect
2.1 When you book a free trial through this website
When you submit our trial booking form we collect:
- Your name
- Your email address
- Your phone number
- Your preferred training day and time
- Any optional notes you choose to share with us
2.2 When you train with us
If you go on to train at Dark Horse, we collect information needed to coach you safely and write your programme. This may include:
- Date of birth and emergency contact
- Training history, goals, injuries, and any relevant health information you choose to share
- Session attendance, lifts logged, and programme adjustments over time
- Billing and payment records
Programming and session data is stored on our coaching platform, Everfit, once a client begins their paid programme.
2.3 When you visit the website
Like most websites, our hosting infrastructure may log technical information such as your IP address, browser type, device type, referring page, and the pages you visit. We use this to keep the site secure and working. See our Cookie Policy for details on cookies and similar technologies.
3. Why we use your data and our legal basis
Under the GDPR we need a lawful basis for each purpose we process personal data for. The table below sets this out.
| Purpose | Legal basis (GDPR Article 6) |
|---|---|
| Responding to your trial booking enquiry and arranging your free session | Steps taken at your request prior to entering a contract (Art. 6(1)(b)) |
| One brief follow-up if you submit the form and do not show up for your trial | Our legitimate interest in completing the enquiry you started (Art. 6(1)(f)) |
| Delivering coaching, writing your programme, and managing your membership | Performance of a contract with you (Art. 6(1)(b)) |
| Storing health information you share with us so we can coach you safely | Your explicit consent (Art. 9(2)(a)) |
| Sending you marketing emails or newsletters | Your consent, which you can withdraw at any time (Art. 6(1)(a)) |
| Keeping accounting and tax records | Compliance with a legal obligation (Art. 6(1)(c)) |
| Keeping the website secure and protecting against fraud or abuse | Our legitimate interest in operating a secure service (Art. 6(1)(f)) |
We do not send marketing emails to leads collected through this site without a separate, specific opt-in.
4. Who we share your data with
We do not sell your personal data. We share it only with service providers who help us run the business, and only to the extent needed for them to do their job. Our recipients are:
- Everfit (training and programme delivery platform) once you become a client.
- Google Maps (Google Ireland Limited) loads the map embed on our website.
- Google Fonts (Google Ireland Limited) serves the typefaces used on our website.
- Meta (Facebook) Pixel for measuring our advertising. The Pixel only fires after you have given consent through our cookie banner. We also plan to add the Meta Conversions API for the same purpose, which will run on the same consent.
- Our website host and any future form-handling provider chosen by our web developer.
- Our accountant, where required for tax and statutory reporting.
- Law enforcement or regulators where we are required by law to do so.
5. International transfers
Some of the providers above are based outside the European Economic Area, for example Meta Platforms, Inc. (United States). Where personal data is transferred outside the EEA we rely on the European Commission's Standard Contractual Clauses, together with any supplementary measures recommended by the Data Protection Commission and the European Data Protection Board. You can request a copy of the safeguards in place by contacting us.
6. How long we keep your data
- Trial booking enquiries that do not become clients: up to 12 months from the date of your enquiry, then deleted.
- Active client records: for as long as you are a client, plus 6 years after your last session for tax and limitation-period reasons.
- Marketing consent records: for as long as you remain subscribed, plus a short period afterwards to record that you unsubscribed.
- Website server logs: a rolling short window set by our host.
If you would like data deleted sooner, please get in touch (see section 8).
7. How we protect your data
We use appropriate technical and organisational measures to protect personal data, including access controls on our coaching platform, strong passwords, and limiting access to the people who need it. No system is perfectly secure, but we work to keep risk low and review our practices regularly.
8. Your rights
Under the GDPR and the Irish Data Protection Act 2018 you have the following rights in relation to your personal data:
- Access a copy of the personal data we hold about you (Article 15).
- Rectification of inaccurate or incomplete data (Article 16).
- Erasure of your data in certain circumstances (Article 17).
- Restriction of processing in certain circumstances (Article 18).
- Portability of data you have provided to us, in a structured machine-readable format (Article 20).
- Object to processing based on legitimate interest, including direct marketing (Article 21).
- Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects (Article 22). We do not carry out this kind of processing.
- Withdraw consent at any time, where we rely on consent. This does not affect the lawfulness of processing carried out before you withdrew.
To exercise any of these rights, contact us at info@darkhorsestrength.ie. We will respond within one month, as required by law. We may need to verify your identity before acting on your request.
9. Right to complain
If you are not happy with how we have handled your personal data, you have the right to lodge a complaint with the Irish Data Protection Commission. Contact details and an online complaint form are at dataprotection.ie.
10. Children
Dark Horse S&P is a strength and performance facility for adults. We do not knowingly collect personal data about anyone under 16 through this website. If you believe a child has submitted data to us, please contact us and we will delete it.
11. Cookies and tracking
For information about cookies and similar technologies, see our Cookie Policy.
12. Changes to this policy
We may update this policy from time to time. When we do, we will change the "last updated" date at the top of this page. Material changes will be highlighted on the site or notified to current clients by email.