Our Privacy Policy

Last updated: 27 August 2026

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our website and services, including when you contact us, request information or resources, or purchase our services.

By providing us with your data, you warrant to us that you are over 13 years of age.

The Thrive Programme is the data controller and is responsible for your personal data. References to "we", "us" or "our" in this privacy notice refer to The Thrive Programme.

Contact details

Our full details are:

Full name of legal entity: The Thrive Programme

Email address: ca**@**********co.uk

It is important that the information we hold about you is accurate and up to date. Please let us know if your personal information changes by emailing us at ca**@**********co.uk.

2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUNDS DO WE PROCESS IT?

Personal data means any information that can identify an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

Communication Data

Communication Data includes any communication that you send to us, whether through a contact form on our website, email, text, social media messaging, social media posting or any other form of communication.

We process this data for purposes including:

• communicating with you;
• responding to enquiries;
• sending free reports or other resources you have requested;
• delivering an eletter or other communication you have requested;
• keeping appropriate records; and
• establishing, pursuing or defending legal claims.

Our lawful basis for this processing is our legitimate interests in responding to communications, providing appropriate customer support, keeping records and establishing, pursuing or defending legal claims.

Where communication is necessary to provide a service you have purchased or requested, we may also process it on the basis that it is necessary for the performance of our contract with you or to take steps at your request before entering into a contract.

Customer Data

Customer Data includes data relating to purchases of our products or services, such as your name, title, billing address, email address, telephone number, contact details and details of your purchases and payments.

Payment card information may be processed by our payment service providers. We do not use your payment information for purposes other than facilitating and recording transactions.

We process Customer Data to supply the products and services you have purchased and to keep appropriate records of those transactions.

Our lawful basis for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. We may also be required to retain certain transaction information to comply with our legal obligations.

User Data

User Data includes information about how you use our website, emails and online services, together with any data that you post for publication on our website or through other online services.

We process this data to operate our website and online services, ensure that relevant content is provided to you, maintain the security of our website, maintain backups of our website and databases, and administer our website and business.

Our lawful basis for this processing is our legitimate interests in properly administering and operating our website, services and business.

Technical Data

Technical Data includes information about your use of our website and online services, such as your IP address, login data where applicable, browser information, time spent on pages, page views, navigation paths, frequency of visits, time-zone settings and information about the devices and technology you use to access our website.

This data may be collected through analytics tools, cookies and similar technologies.

We process Technical Data to analyse the use of our website and online services, administer and protect our business and website, understand how our website is being used, deliver relevant website content and advertising where appropriate, and measure the effectiveness of our advertising.

Depending on the technology involved, our lawful basis for processing may be our legitimate interests in administering and developing our website and business, or your consent where consent is required for cookies or similar technologies.

Please see our Cookie Policy for further information.

Marketing Data

Marketing Data includes information about your preferences in receiving marketing communications from us and your communication preferences.

We process this data to send relevant communications, offers and information about our products and services and to understand the effectiveness of our marketing.

Our lawful basis for processing Marketing Data is either your consent or, where permitted by law, our legitimate interests in developing and growing our business.

Where consent is required for a particular form of electronic marketing, we will obtain that consent before sending it.

Special Category Data

Because our services relate to vaginismus, information you choose to provide through enquiry forms, consultation forms or other communications may include special category personal data. In particular, this may include information concerning your physical or mental health or sex life.

We use this information only where it is relevant to responding to your enquiry, providing a consultation or providing a service you have requested.

For the purposes of Article 6 of the UK GDPR, our lawful basis will normally be taking steps at your request before entering into a contract or performing our contract with you.

Where we process special category personal data, we also need an additional condition under Article 9 of the UK GDPR. Where appropriate, we rely on your explicit consent under Article 9(2)(a).

Where we rely on explicit consent, you may withdraw that consent at any time by emailing ca**@**********co.uk. Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn. However, because information about your symptoms and experiences may be necessary for us to respond appropriately to your enquiry or provide a personalised service, withdrawing consent may limit our ability to provide some services.

We do not ask you to provide more sensitive information than is reasonably necessary for the service or information you have requested.

We do not knowingly collect information about criminal convictions or offences.

If you do not provide personal data

Where we are required to collect personal data by law, or under the terms of a contract between you and us, and you do not provide that data when requested, we may not be able to perform the contract or provide the relevant product or service.

If this happens, we will notify you.

We will only use your personal data for the purpose for which it was collected or for a reasonably compatible purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision-making that produces legal or similarly significant effects about you.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect personal data directly from you when you:

• complete a form on our website;
• contact us by email or another method;
• book a consultation;
• purchase one of our products or services;
• request a free resource or report;
• subscribe to our emails or eletters; or
• otherwise communicate with us.

We may also automatically collect certain Technical Data when you use our website through cookies, analytics and similar technologies. Please see our Cookie Policy for further information.

We may receive personal data from third parties where appropriate, including:

• analytics providers;
• advertising networks and platforms;
• search information providers;
• payment providers;
• website, email and other technical service providers; and
• other service providers that assist us in operating our business.

Some of these providers may be based outside the UK. Where this results in an international transfer of personal data, we take appropriate steps as described in section 6 below.

4. MARKETING COMMUNICATIONS

We may process your personal data to send you marketing communications where we have an appropriate lawful basis to do so.

Depending on the circumstances, this may be your consent or our legitimate interests in promoting and developing our products and services.

We comply with applicable electronic marketing and data protection laws when sending marketing communications.

You can ask us to stop sending you marketing messages at any time by:

• following the unsubscribe or opt-out link contained in a marketing email; or
• emailing us at ca**@**********co.uk.

If you opt out of receiving marketing communications, this does not prevent us from processing personal data provided to us as a result of another transaction or relationship with you, such as a purchase or consultation.

We may still send you service-related communications that are necessary for the administration or delivery of a product or service you have purchased.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with trusted third parties where this is necessary for the operation of our business or provision of our services.

These may include:

• service providers who provide website hosting, IT, email, payment processing, analytics, administration or other technical services;
• professional advisers, including lawyers, accountants, auditors, bankers and insurers;
• government bodies, regulators or other authorities where we are legally required to provide information;
• third parties involved in products or services provided in partnership with The Thrive Programme; and
• third parties to whom we may sell, transfer or merge parts of our business or assets.

We require third parties who process personal data on our behalf to respect the security and confidentiality of your personal data and to process it only for specified purposes and in accordance with applicable data protection law.

6. INTERNATIONAL TRANSFERS

Some of the external service providers we use may process or store personal data outside the United Kingdom.

Where our use of a provider involves a restricted transfer of personal data outside the UK, we take steps to ensure that the transfer complies with UK data protection law and that appropriate protection is in place.

Depending on the circumstances, this may include:

• transferring personal data to a country or organisation covered by UK adequacy regulations;
• using an appropriate safeguard recognised under UK data protection law, such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to approved standard contractual clauses;
• transferring data to an organisation participating in an applicable UK-approved data transfer framework, where the requirements of that framework are met; or
• relying on another lawful exception or mechanism permitted under UK data protection law where appropriate.

Where an appropriate safeguard is used, we take reasonable steps to ensure that the transferred personal data receives a level of protection consistent with UK data protection requirements.

You can contact us at ca**@**********co.uk if you would like further information about the safeguards used for international transfers relevant to your personal data.

7. DATA SECURITY

We have put appropriate security measures in place to help prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without authorisation.

We limit access to personal data to people and service providers who have a genuine business need to access it. Anyone processing personal data on our behalf is required to do so in accordance with our instructions and to keep it appropriately confidential and secure.

We have procedures in place to deal with suspected personal data breaches and will notify affected individuals and the Information Commissioner's Office or another applicable regulator where we are legally required to do so.

8. DATA RETENTION

We retain personal data only for as long as reasonably necessary to fulfil the purposes for which we collected it, including satisfying legal, regulatory, tax, accounting or reporting requirements.

When determining an appropriate retention period, we consider factors including:

• the amount, nature and sensitivity of the personal data;
• the potential risk of harm from unauthorised use or disclosure;
• the purposes for which we process the data;
• whether those purposes can be achieved by other means; and
• applicable legal requirements.

For tax and accounting purposes, we may be required to retain basic information about our customers and transactions for six years after the relevant accounting period or business relationship.

In some circumstances, we may anonymise personal data so that it can no longer be associated with an identifiable individual. We may use anonymised information for research, statistical or business purposes without further notice to you.

9. YOUR LEGAL RIGHTS

Under UK data protection laws, you may have rights in relation to your personal data. Depending on the circumstances, these can include the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request erasure of your personal data;
• request restriction of the processing of your personal data;
• object to certain processing of your personal data;
• request transfer of your personal data to you or a third party where applicable; and
• withdraw consent at any time where we rely on consent to process your personal data.

If you wish to exercise any of these rights, please email us at ca**@**********co.uk.

You will not normally have to pay a fee to exercise your rights. However, where permitted by law, we may charge a reasonable fee or refuse to comply with a request if it is manifestly unfounded or excessive.

We may need to request specific information from you to confirm your identity before responding to a request. This is a security measure intended to ensure that personal data is not disclosed to someone who is not entitled to receive it.

We may also contact you for further information where necessary to help us respond to your request.

We aim to respond to legitimate requests within one month. In some circumstances, such as where a request is particularly complex or you have made several requests, we may be permitted to take longer. If this applies, we will let you know.

If you are unhappy with how we collect or use your personal data, you have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection.

We would appreciate the opportunity to address your concerns first, so please contact us at ca**@**********co.uk if you have a complaint about our use of your personal data.

10. THIRD-PARTY LINKS

Our website may contain links to third-party websites, plug-ins or applications.

Clicking on those links or enabling those connections may allow third parties to collect or share information about you.

We do not control third-party websites and are not responsible for their privacy notices or data-protection practices. When you leave our website, we encourage you to read the privacy notice of any website you visit.

11. COOKIES

Our website uses cookies and similar technologies.

Some cookies may be necessary for the website to function properly. Other cookies, including certain analytics or advertising cookies, may require your consent before they are placed on your device.

You can control cookies through the cookie settings provided on our website and through your browser settings.

If you disable or refuse certain cookies, some parts of the website may not function properly.

Please see our Cookie Policy for further information about the cookies we use and the choices available to you.