Privacy Policy
Solum is coaching, and coaching only works if you tell me things about your body and your health. The GDPR treats that kind of information as a special category and protects it more strictly than ordinary personal data. This page says what is collected, why, who sees it, how long it is kept and how you get it back or have it deleted.
Who is responsible
The data controller is WWG - International UAB, company code 183240088, Hipodromo g. 1, LT-20116 Ukmergė, Lithuania, trading as Solum. Tomas Pivoras runs the coaching and is the person who reads what you send.
For anything about your data, hello@solumfitness.com is the address to write to. The company is small enough that it is not required to appoint a data protection officer, so that address reaches the person who can actually act on your request.
What is collected
- Contact details you type into a form: name, email address.
- Body data you volunteer: age, sex, height, weight, activity level, goals.
- Health context you choose to share, including blood work at Level 3.
- Messages you send during coaching, and the notes and plans written for you.
- Body composition readings from the Hume devices at Level 3, where you share them.
- Payment details, which are handled by Stripe and never reach this site. Solum sees your name, email, what you bought and whether the payment succeeded, not your card number.
- Standard server logs held by Cloudflare, our hosting provider.
The calculator on the page works in your browser. The numbers you enter are sent to Solum only when you ask for the ten day plan by email.
Why
- To answer your enquiry and send the free ten day plan: your consent, given when you submit the form.
- To deliver coaching you have bought: the contract between us.
- To use your health information, including body data, blood work and device readings, for building and adjusting your programme: your explicit consent under Article 9(2)(a) of the GDPR, given when you tick the box on the form. You can withdraw it at any time. Coaching that depends on that information stops when you do.
- To take payment, issue invoices and keep accounting records: the contract, and the legal obligations Lithuanian tax and accounting law places on the company.
- To keep the site secure and working: our legitimate interest in running it safely.
- To measure how the page is read: your consent on the cookie bar, and only then.
Your information is never used for automated decisions about you, never sold, and never used for advertising. Plans are written by a person.
Who it is shared with
- Stripe Payments Europe Ltd, Ireland, for taking payment.
- Cloudflare, Inc., for hosting the site and running the forms.
- Loopia AB, Sweden, which hosts the hello@solumfitness.com mailbox your form answers arrive in.
- Licensed medical partners, where blood work is reviewed at Level 3. They see what is needed to read your results and nothing else.
- Hume Health, if you use the Hume Body Pod and Hume Band at Level 3. You set up your own account with them, and their own privacy policy covers what their app collects.
- Google Ireland Ltd, for Google Analytics, only if you accept analytics cookies.
- The company's accountant and the Lithuanian tax authority, for invoices and payment records only, never health information.
Stripe, Cloudflare and Google may process data in the United States. Those transfers rely on the EU-US Data Privacy Framework where the provider is certified, and on the European Commission's standard contractual clauses otherwise. Nobody else receives your information unless the law requires it.
How long it is kept
- Enquiries that do not lead to coaching: 12 months from the last message, then deleted.
- Free ten day plan requests: 12 months, or until you ask for deletion, whichever is sooner.
- Coaching records, including body data and messages: for as long as you are a client and 12 months afterwards, in case you come back, then deleted.
- Blood work and other medical documents: deleted within 30 days of your coaching ending, or sooner if you ask.
- Invoices and payment records: 10 years, as Lithuanian accounting law requires.
- Server logs: held by Cloudflare for up to 30 days.
- Analytics data: 2 months in Google Analytics.
When you stop being a client you can ask for everything except the accounting records to be deleted straight away, and it will be.
Your rights
Access, correction, erasure, restriction, portability, objection, and the right to withdraw consent at any time. Withdrawing consent does not affect what was done before you withdrew it.
To use any of them, email hello@solumfitness.com from the address you signed up with. You will have an answer within 30 days, usually much sooner, and it costs nothing. If the request is complex the law allows a further two months, and you will be told if that applies.
You can also complain to your national data protection authority. In Lithuania that is the State Data Protection Inspectorate, L. Sapiegos g. 17, 10312 Vilnius, vdai.lrv.lt.
Cookies
Solum uses Google Analytics 4 to see which parts of the page are read and where people stop. It is loaded only if you accept it on the cookie bar. Decline and no request is made to Google at all, rather than the cookies being set and your choice recorded afterwards. Your answer is kept for twelve months, after which you are asked again, and you can change it at any time from the Cookie settings link in the footer.
No advertising cookies are set and no data is sold. Google Analytics 4 does not log or store IP addresses. Google Ireland Ltd acts as our processor for this, analytics data is kept for 2 months, and where it reaches Google's servers in the United States the transfer is covered by the EU-US Data Privacy Framework.
Your cookie choice itself is stored in your own browser, not on our side.
Changes to this page
If this policy changes in a way that affects you, clients are told by email before the change takes effect. The date below always shows the current version.
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