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Privacy Policy

The Recovery Signal  ·  6 Fern Road, Dublin Sandyford, D18 FP98, Ireland  ·  info@crt-trainer.ie
Effective: 1 January 2026  ·  Last updated: July 2026

1. Who We Are

The Recovery Signal is owned and operated by Sarah Frosting ("we", "our", "us"). Our registered business address is 6 Fern Road, Dublin Sandyford, D18 FP98, Ireland. Sessions are delivered at your preferred location within Ireland — I am based in Shannon, County Clare and offer a mobile service — or remotely via video call, as agreed. We are a data controller of your personal data as defined under the General Data Protection Regulation (GDPR) (EU) 2016/679 and the Data Protection Acts 1988–2018 (Ireland).

This Privacy Policy explains how we collect, use, protect and share your personal information when you visit our website, contact us, book a Clarity Call, or engage in our Recovery Signal Programme.

By using our website or engaging our services, you acknowledge that you have read and understood this policy.

2. Information We Collect

2.1 Personal Information

  • Full name, email address and phone number
  • County or country of residence
  • Professional background or role, where relevant to your enquiry
  • Communication records, emails, WhatsApp messages and notes from calls

2.2 Health and Wellbeing Information

When you book a Clarity Call, complete an intake form, or engage in our programme, you may share information about:

  • Pain levels, fatigue, sleep quality, energy and recovery history
  • Previous treatments, therapies or diagnoses you choose to disclose
  • Your personal goals and areas of concern

You provide this information voluntarily. We use it solely to deliver your programme and support your progress. It is held in strict professional confidence.

Because this is health-related information, we rely on your explicit, separate consent to process it, in addition to the legal bases described in Section 3. You can withdraw this consent at any time by contacting us, though this may affect our ability to continue delivering your programme.

2.3 Website and Technical Information

  • IP address, browser type and device information
  • Pages visited, time spent on site and referral source
  • Booking data collected via Calendly (name, email, intake responses)

2.4 Analytics Information

Where Google Analytics 4 is used and you have accepted analytics cookies, we collect anonymised data about website usage, pages viewed, approximate location and referral source. We do not send your name, email address, health information or session content to any analytics tool.

2.5 Payment Information

Payment details are processed by our payment provider. We do not store your card details or bank information on our own systems.

3. Why We Use Your Information

  • To respond to your enquiry and schedule your Clarity Call
  • To deliver and manage your personalised Recovery Signal Programme
  • To send programme communications and session reminders
  • To maintain records that support your progress throughout the programme
  • To improve our website and services
  • To comply with our legal obligations under GDPR and Irish law

Our legal bases for processing your personal data are your consent (for marketing communications and for health-related data specifically), the performance of a contract (for your programme), and our legitimate interests (for improving our services and maintaining appropriate records).

4. Who We Share Your Information With

We never sell, rent or share your personal data for commercial purposes.

4.1 Service Providers

We share limited information only with the following trusted third parties:

  • Calendly, booking and scheduling management (hosted in the United States; see Section 8)
  • Email service provider, for programme and administrative communications
  • Payment processor, for handling programme fees securely
  • Google Analytics, anonymised website usage data only, where analytics cookies are accepted
  • Notion and Google Drive/Workspace, used to securely store client records and session notes, including health-related information disclosed during your programme

4.2 Legal Requirements

We may disclose your information if required by law, court order, or where necessary to protect the safety of any person.

4.3 Business Transfers

In the event of a change in business ownership, your data would continue to be protected under terms no less protective than this policy.

5. Data Security

We take appropriate technical and organisational measures to protect your personal information from unauthorised access, disclosure or loss. Health and wellbeing information shared during sessions is held in strict professional confidence and is not disclosed to any third party without your explicit written consent.

All website communication is encrypted via HTTPS. While we take every reasonable precaution, no internet transmission can be guaranteed as completely secure. Please contact us immediately at info@crt-trainer.ie if you believe your information may have been compromised.

6. Your Rights Under GDPR

If you are based in Ireland or the European Economic Area, you have the following rights:

  • Right to be informed, to know how your data is used (this policy fulfils that obligation)
  • Right of access, to request a copy of the personal data we hold about you
  • Right to rectification, to correct inaccurate or incomplete information
  • Right to erasure, to request deletion of your data ("right to be forgotten")
  • Right to restrict processing, to limit how we use your data in certain circumstances
  • Right to data portability, to receive your data in a commonly used, machine-readable format
  • Right to object, to object to processing based on our legitimate interests
  • Right to withdraw consent, specifically for health-related data, at any time — contact us at info@crt-trainer.ie to do so

To exercise any of these rights, contact us at info@crt-trainer.ie. We will respond within 30 days.

You also have the right to lodge a complaint with the Data Protection Commission Ireland:

  • Website: www.dataprotection.ie
  • Lo-Call: 1800 437 737
  • Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28

7. Data Retention

  • Enquiry and contact records: 2 years from last contact, unless you become a client
  • Client programme records, including health-related session notes: retained for 6 years following the end of your programme
  • General financial and administrative client records: 6 years following the end of your programme, in line with standard Irish business record retention requirements
  • Website analytics: as per Google Analytics defaults (typically 26 months)
  • Legal and financial records: 7 years as required under Irish revenue law

When data is no longer required, it is securely deleted or irreversibly anonymised.

8. International Data Transfers

Calendly, our booking platform, is headquartered in the United States. When you book a call, your name and email are transferred to Calendly's servers. Calendly operates under the EU–US Data Privacy Framework and Standard Contractual Clauses, which provide appropriate safeguards for your data.

9. Cookies

Our website uses essential cookies required for the site to function. Where you consent, we also use Google Analytics 4 cookies to collect anonymised usage data. You can manage your cookie preferences through the cookie consent banner on our website at any time.

10. Children's Privacy

Our services are designed for adults aged 18 and over. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with personal data, please contact us at info@crt-trainer.ie and we will delete it without delay.

11. Links to Other Websites

Our website may contain links to third-party websites including Calendly and social media platforms. We are not responsible for their privacy practices and encourage you to review their policies before providing personal information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify you by email and by updating the effective date above. Continued engagement with our services after changes take effect constitutes acceptance of the updated policy.

13. Contact Us

For any questions about this Privacy Policy, or to exercise your rights:

  • Email: info@crt-trainer.ie
  • Website: www.crt-trainer.com

Registered address:
The Recovery Signal
6 Fern Road, Dublin Sandyford, D18 FP98, Ireland

  • Based in Shannon, County Clare, Ireland · Mobile service · Sessions at your preferred location by arrangement
  • Response time: within 30 days

© 2026 The Recovery Signal  ·  Sarah Frosting  ·  6 Fern Road, Dublin Sandyford, D18 FP98, Ireland  ·  Based in Shannon, County Clare  ·  www.crt-trainer.com