Privacy Policy

1. Quick summary

We collect the information you give us (account, purchase and payment details, and content you share with us, including information about your health, symptoms, nutrition and exercise where you choose to provide it), information collected automatically (device and usage data, cookies), and information from our service providers.

We use it to provide and improve the Services, take payment, support you, keep our Site secure, comply with law, and - only where permitted - send you marketing and personalise your experience.

We do not sell your personal information for money. Where we use certain advertising and analytics cookies, some laws may treat this as "selling" or "sharing"; you can opt out (see Sections 7 and 11).

We rely on service providers, some of which are outside your country, and we put safeguards in place when we transfer data internationally.

You have rights over your information. How to exercise them, and the supervisory authority you can complain to, depend on where you live - see the country-specific schedules in Sections 10-14.

This summary is for convenience only and does not replace the full Policy.

2. The personal information we collect

We collect the following categories of personal information:

• Identity and account data - name, username, password, and the country/region you are in.
• Contact data - email address, postal address, and telephone number.
• Transaction and payment data - products and programs purchased, order history, and payment-related information. Card details are processed by our payment providers; we do not store full card numbers.
• Health and wellness information you choose to share - for example information about menopause symptoms, nutrition, exercise, goals, measurements or progress that you enter into the Services, share with our team, or post in any community feature. You are not required to provide this information to use core parts of the Services, and you should share it only if you are comfortable doing so. We treat this information as sensitive (see Section 4).
• Communications and support data - the content of messages, enquiries and reviews you send us, and information we need to verify your identity and respond.
• Marketing and engagement data - your preferences, whether you have consented to marketing, and how you engage with our emails (for example whether an email was opened or a link clicked). You can opt out of marketing and email tracking at any time using the "unsubscribe" link in any email.
• Technical and usage data - IP address, device identifiers, cookie and similar identifiers, advertising identifiers, approximate location derived from your IP address, browser type, the pages you view, referral URLs, and analytics about how you use the Site.

If you give us personal information about another person, you confirm you have that person's consent (or are otherwise lawfully permitted) to share it with us for the purposes described here.

3. How we collect your information and why (our legal bases)

We collect information when you visit the Site, register an account, make a purchase, use the Services, contact us, or interact with our emails. We also receive information from service providers who help us run the business - including our hosting and course platform (Kajabi, operated by Kajabi, LLC), payment providers, email and marketing providers, and analytics and advertising providers.

Where data protection law requires a legal basis (such as in the UK, the EU/EEA and, in substance, Quebec and Australia), we rely on the following:

Where we rely on legitimate interests, we have weighed our interests against your rights and will provide further detail on request. Where we rely on consent, you may withdraw it at any time; withdrawal does not affect processing carried out before withdrawal.

4. Health, wellness and other sensitive information

Our Services relate to menopause, nutrition and exercise. If you choose to share information about your symptoms, health, body, nutrition or fitness, that information may reveal information about your health. Many laws give this kind of information special protection - for example it is "special category data" under the UK and EU GDPR, "sensitive data" under several US state laws, and "consumer health data" under certain US state laws (see Section 11).

We will only process this information:

• where you have given us your explicit consent to do so for the specific purpose we have told you about; or
• where another narrow legal ground applies (for example establishing or defending a legal claim, or where you have manifestly made the information public).

We do not use information about your health to make decisions that produce legal or similarly significant effects about you, and we do not sell it. We will not share it with advertising partners for targeted advertising without your separate consent. You can withdraw your consent at any time by contacting us at support@whatthemenopause.com, and you can ask us to delete this information (see your rights in the country-specific schedules).

If you are in the United States, please also read the Consumer Health Data disclosures in Section 11.

5. The Services are for adults

The Services are intended for, and directed to, adults aged 18 and over. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us at support@whatthemenopause.com and we will take appropriate steps to delete it. Additional children's-data disclosures for specific countries appear in the relevant schedules below.

6. Profiling and automated decision-making

We use information about your purchases and how you interact with the Site to personalise your experience, content and marketing. This is a form of profiling. We do not make decisions that have a legal or similarly significant effect on you based solely on automated processing without human involvement. You can object to profiling for marketing purposes at any time (see your rights below).

7. Cookies and similar technologies

We and our service providers use cookies and similar technologies (such as pixels, tags, SDKs and local storage) to operate the Site, remember your preferences, measure and improve performance, and - where permitted - deliver and measure advertising.

Strictly necessary technologies are required to run the Site and your account. Certain low-risk analytics and preference cookies may also operate without consent where local law allows.

Analytics and advertising technologies are used only where we have a lawful basis to do so. In the UK and the EU/EEA we ask for your consent through our cookie banner before setting non-essential cookies, and you can change your choices at any time via the banner or your browser settings.

We honour recognised opt-out preference signals, including the Global Privacy Control (GPC), where applicable law requires us to.

Most browsers let you block or delete cookies through their settings; if you do, some features of the Site may not work properly. Our cookie banner provides more detail about the specific cookies we use and their duration.

8. Marketing and your choices

We send marketing only where we are permitted to. You can opt out at any time by using the "unsubscribe" link in any marketing email or by emailing support@whatthemenopause.com. Even if you opt out of marketing, we will still send you service messages relating to your account, purchases and the Services.

9. Who we share your information with, and international transfers

Who we share with

We share personal information only as needed, with:

• Service providers ("processors") who act on our instructions - including our website and course platform (Kajabi), payment providers, email/marketing and customer-support providers, hosting and security providers, and analytics providers. They may only use your information to provide services to us and must protect it.
• Advertising and analytics partners, where you have consented (or where local law otherwise permits) - see Section 7 and the US disclosures in Section 11.
• [The brand owner / licensor: INSERT FULL LEGAL NAME AND ROLE], with whom we may share limited information to operate and improve the Services. (See note to WTM: this relationship must be characterised correctly - controller, joint controller or processor - and reflected here and in a data-sharing agreement.)
• Professional advisers, insurers, auditors, and potential buyers in connection with a sale, financing or reorganisation of our business.
• Authorities, regulators and law-enforcement where we are legally required to do so, or to establish, exercise or defend legal claims.

We do not sell your personal information for money.

International transfers

We are based in the United Kingdom and some of our service providers are located outside the UK, the EEA, your home country or your home province - including in the United States. When we transfer personal information internationally, we use a lawful transfer mechanism, which may include: an adequacy decision or adequacy regulations; the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses; the EU Standard Contractual Clauses; certification under the EU-US Data Privacy Framework and its UK Extension; or your explicit consent where appropriate. You can ask us for more information about the safeguards we use by emailing support@whatthemenopause.com.

10. How long we keep your information

We keep personal information for as long as we need it for the purposes set out in this Policy. In practice this means:

• account, purchase and content data - for as long as your account is active and for a period afterwards;
• transaction, tax and accounting records - for the period required by law (typically up to [INSERT - e.g. 6-7 years] depending on the country);
• health and wellness information you have shared - until you withdraw consent or ask us to delete it, unless we must retain it to comply with law or defend a claim;
• marketing data - until you opt out, and for a short period afterwards to honour your choice.

When we no longer need information, we delete it or anonymise it. We may keep limited information from closed accounts where the law, a dispute, or our insurance obligations require it.

11. United Kingdom and European Economic Area

If you are in the UK or the EEA, the UK GDPR and Data Protection Act 2018 (as amended by the Data (Use and Access) Act 2025), or the EU GDPR, apply to our processing of your information.

Your rights

You have the right to: be informed about our processing; access your information; have inaccurate information corrected; have your information erased; restrict our processing; object to processing (including profiling for direct marketing); data portability; and withdraw consent where we rely on it. Where we make decisions based solely on automated processing with legal or similarly significant effects, you have rights in relation to that - though, as noted, we do not make such decisions.

How to exercise them

Email support@whatthemenopause.com. We will respond within the time limits set by law. We may need to verify your identity, and in some cases the time limit may pause while we obtain information reasonably needed to deal with your request.

Complaints

If you have a concern, please contact us first so we can try to resolve it - you also have the right to complain directly to us about how we handle your information. You may also complain to the UK Information Commissioner's Office (ICO) at www.ico.org.uk, or to the supervisory authority in your EU/EEA country.

EU representative

(Note to WTM: as a UK controller offering services to people in the EU, you are likely required to appoint an EU representative under Article 27 GDPR. Insert the representative's name and contact details here once appointed.)

12. United States

Depending on where you live and the laws that apply, you may have rights in relation to your personal information. We provide the following disclosures.

State privacy rights

Residents of US states with comprehensive privacy laws (including, among others, California, Virginia, Colorado, Connecticut, Texas, Oregon and others) may have the right to: confirm whether we process your personal information and access it; correct it; delete it; obtain a portable copy; and opt out of (a) "sales" of personal information, (b) "sharing"/processing for targeted (cross-context behavioural) advertising, and (c) certain profiling. You also have the right not to be discriminated against for exercising these rights.

How to exercise them

Email support@whatthemenopause.com. We will verify your request as required by law, and you may use an authorised agent where the law allows. If we decline a request, you may appeal by replying to our response.

We do not sell your personal information for money. Some advertising and analytics cookies may, however, be treated as a "sale" or "share" under certain state laws. You can opt out via our cookie banner and through the Global Privacy Control (GPC) signal.

California - additional disclosures

Categories of personal information. In the past 12 months we have collected the categories described in Section 2 (identifiers; commercial/transaction information; internet and device activity; approximate geolocation; and, where you provide it, information about your health, which is sensitive personal information).

Sources, purposes and disclosures. We collect from the sources, use for the purposes, and disclose to the categories of recipients described in this Policy.

Sensitive personal information. We use sensitive personal information (including any health information you provide) only to provide the Services you request and for other purposes permitted without a right to limit; we do not use it to infer characteristics about you.

Do Not Sell or Share / Limit. Submit a request via our cookie banner or by emailing support@whatthemenopause.com.

Shine the Light. California residents may request information about disclosures to third parties for their direct marketing purposes.

Consumer health data (Washington, Nevada and similar laws)

Some US laws - most notably Washington's My Health My Data Act and Nevada's consumer-health-data law - regulate "consumer health data," which is defined very broadly and can include information about menopause, nutrition, fitness and wellness, including inferences. Where these laws apply:

• We collect consumer health data only as described in this Policy, and use it to provide and improve the Services you request, respond to you, and meet legal obligations.
• We obtain your consent before collecting consumer health data that is not necessary to provide a product or service you have requested, and we obtain your separate authorisation before selling or sharing it (we do not sell it).
• We do not use a geofence around any location to identify or track consumers seeking health services, collect their consumer health data, or send them related advertising.
• You have the right to confirm whether we collect, share or sell your consumer health data; to access it; to obtain a list of the third parties and affiliates with whom we have shared it; to withdraw consent; and to have it deleted. To exercise these rights, email support@whatthemenopause.com.

A standalone Consumer Health Data Privacy Policy is published separately and linked from our homepage, as required by applicable law. [Note to WTM: this separate, separately-linked policy is a specific Washington/Nevada requirement - see my covering note.]

Children

The Services are directed to adults aged 18 and over, and we do not knowingly collect personal information from children under 13 (or under the age set by applicable state law).

13. Australia

If you are in Australia, the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) apply.

What we collect and why is described in Sections 2-6. We collect sensitive information (including health information) only with your consent and where it is reasonably necessary for our functions.

Overseas disclosure

We disclose personal information to service providers located overseas, including in the United Kingdom, the United States and the European Union/European Economic Area (see Section 9).

Access and correction

You may request access to, and correction of, your personal information by emailing support@whatthemenopause.com.

Complaints

Please contact us first. If you are not satisfied, you may complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

14. Canada

If you are in Canada, the federal Personal Information Protection and Electronic Documents Act (PIPEDA) applies, together with provincial laws including Quebec's Law 25 (and the private-sector laws of Alberta and British Columbia) where relevant.

Consent

We collect, use and disclose personal information with your consent (express consent for sensitive information such as health information), or as otherwise permitted by law. You may withdraw consent, subject to legal and contractual limits, by contacting us.

Your rights

You may request access to, and correction of, your personal information, and (in Quebec) data portability and, in certain cases, de-indexing. Email support@whatthemenopause.com.

Cross-border transfers

We use service providers outside Canada, including in the UK, the US and the EU/EEA (see Section 9), and we take reasonable steps to ensure comparable protection.

Complaints

Please contact us first. You may also complain to the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or, for Quebec residents, the Commission d'acces a l'information du Quebec.

15. How we protect your information

We use technical and organisational measures designed to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration of your information, and we require our service providers to do the same. No method of transmission or storage is completely secure, however, and while we work hard to protect your information we cannot guarantee absolute security. If we become aware of a personal data breach affecting you, we will notify you and the relevant authorities where the law requires.

16. Changes to this Policy

We may update this Policy from time to time. The "Last updated" date shows when it last changed. If we make a material change, we will take reasonable steps to bring it to your attention, for example by email or a notice on the Site. Where a change requires your consent, we will ask for it before the change applies to you. Continued use of the Services after a change indicates that you have read the updated Policy.

17. How to contact us

WTM Wellness Ltd. 20 Wenlock Road, London, N1 7GU, United Kingdom Email: support@whatthemenopause.com

For data protection questions, rights requests or complaints, please use the email address above.