legal
privacy policy.
effective · 1 july 2026 · aligned with india's dpdp act 2023
01who we are
This Privacy Policy applies to vinniesgym.lovable.app, operated by Vincent Davies trading as vinnies gym, Assagao, North Goa, India. We are the data fiduciary in respect of personal data collected through this website and in the course of providing training services.
02what data we collect
Data you provide directly:
- Review submissions: your name and the text of your review, submitted via the reviews page.
- WhatsApp communications: your phone number, name, and message content when you contact us to book a session.
Data collected automatically:
- Technical data: IP address, browser type, device type, pages visited, and timestamps, collected by the Lovable hosting platform.
- Cookie data: see our Cookie Policy for full details.
We do not collect payment card data, operate a mailing list, or use advertising tracking pixels on this website.
03how we collect it
- Directly from you when you submit a review.
- Through WhatsApp when you use the booking link on this website.
- Automatically via the Lovable hosting platform when you browse the site.
04why we use your data
- To manage session bookings via WhatsApp.
- To display your submitted review on the website.
- To operate and improve the website.
- To comply with legal obligations under Indian law.
We do not use your data for automated decision-making, profiling, or advertising.
05legal basis for processing
- Consent: given when you submit a review via the reviews form (via consent checkbox at submission).
- Legitimate use: processing WhatsApp communications to fulfil a booking you have initiated.
- Legal obligation: where retention is required by Indian law (e.g. tax records).
06who we share data with
We do not sell your personal data. Data may be shared only with:
- Lovable (our hosting platform), which processes technical data as part of site delivery.
- Meta (WhatsApp / Instagram), when you use those platforms via our links.
- Authorities, if required by a valid legal order under Indian law.
- A new business owner, in the event of a transfer of the Studio, with notice provided where required.
07data storage & security
Review data is stored on Lovable's platform servers. WhatsApp communications are stored within Meta's infrastructure. We take reasonable steps to handle data securely but cannot guarantee absolute security. If you believe your data has been compromised, contact us immediately.
08how long we keep your data
- Reviews: retained on the website until you request removal.
- WhatsApp communications: retained within WhatsApp per Meta's policies.
- Technical / analytics data: up to 26 months, then aggregated or deleted.
- Financial / booking records: minimum 7 years per Indian tax law requirements.
09your rights
Under the Digital Personal Data Protection Act 2023, you have the right to:
- Access a summary of personal data we hold about you.
- Request correction of inaccurate data.
- Request erasure of your data (subject to legal retention obligations).
- Withdraw consent at any time where processing is consent-based.
- Raise a complaint with us; if unresolved, escalate to the Data Protection Board of India.
To exercise any of these rights, contact us using the details in section 14.
10children's privacy
This website is not directed at children under 18. We do not knowingly collect personal data from minors. Reviews from minors should be submitted by a parent or guardian. If we become aware of data collected from a child, we will delete it promptly.
11cookies & analytics
This website uses cookies. See our Cookie Policy for details on what cookies are used, why, and how to manage your preferences.
12third-party platforms
When you click a WhatsApp or Instagram link, you enter a platform operated by Meta Platforms, Inc., governed by Meta's own Privacy Policy. We are not responsible for the privacy practices of any third-party service linked from this site.
13changes to this policy
We may update this policy from time to time. The effective date above will be updated to reflect changes. We encourage you to review this policy periodically.
14contact & grievance officer
As required under the DPDP Act 2023, the following person is designated to handle data-related complaints:
Grievance Officer: Vincent Davies
vinnies gym, Assagao, North Goa, India
WhatsApp: +91 87998 04013
Instagram: @vinniemdavies
Complaints will be acknowledged within 7 working days and resolved within 30 days where possible.
