PRIVACY POLICY

John Arnett EI

PosturePlan

www.postureplan.com

Updated: 25/05/2026

1. Overview

This Privacy Policy explains how John Arnett EI (“we,” “us,” or “our”) collects, uses, stores, and protects personal data when you use www.postureplan.com and any related pages, courses, videos, articles, downloads, forms, AI-assisted features, emails, and other services, collectively referred to as the “Site” or “Services.”

Users of the Site are referred to as “you” or “your.”

John Arnett EI acts as the data controller for the personal data processed through this Site, as defined under the General Data Protection Regulation (“GDPR”).

By using the Site, you acknowledge that you have read this Privacy Policy. Where we rely on your consent for specific processing, you may withdraw that consent at any time.

2. Personal Data We May Collect

We may collect and process the following categories of personal data.

Information you provide directly

This may include:

  • your name;

  • your email address;

  • messages you send to us;

  • information submitted through contact forms, sign-up forms, questionnaires, quizzes, or similar features;

  • information you provide when subscribing to emails or newsletters;

  • information you provide when using interactive tools, including the AI course navigator;

  • information you provide if you purchase a product or service in the future.

Technical and usage data

When you visit the Site, certain technical information may be collected automatically by the website platform or related service providers. This may include:

  • IP address;

  • browser type and version;

  • device type;

  • operating system;

  • approximate location based on IP address;

  • pages visited;

  • time spent on pages;

  • referring websites;

  • interactions with embedded content, such as YouTube videos;

  • general website navigation and performance information.

Course and interaction data

If the Site includes course access, forms, quizzes, AI tools, or other interactive features, we may process information related to your use of those features, such as:

  • the pages or lessons you access;

  • the information you enter into forms or AI prompts;

  • your stated goals, preferences, or symptoms if you choose to provide them;

  • your communication with us.

3. Health-Related Information

Some features on the Site may invite you to share information about pain, posture, movement, injuries, symptoms, physical limitations, health goals, or similar topics.

Information about your health may be considered special category data under GDPR and receives additional protection. GDPR Article 9 specifically treats data concerning health as a special category of personal data.  

You should avoid sharing unnecessary medical details through the Site. Do not use the Site or AI assistant for urgent or emergency medical situations.

Where required, we rely on your explicit consent to process health-related information that you voluntarily provide. You may withdraw your consent at any time, but this will not affect processing that occurred before withdrawal.

4. AI Course Navigator and Interactive Tools

The Site may include an AI-powered course navigation assistant or similar interactive tool. This tool is intended to help you find relevant educational content on PosturePlan.

If you use the AI assistant, we may process the information you enter into the chat in order to generate a response and suggest relevant courses, lessons, videos, or resources.

At present, the AI assistant is intended to be temporary and session-based. We do not intend to use AI conversations to create user profiles or remember information between sessions. If this changes, we will update this Privacy Policy.

The AI assistant may be provided through a third-party AI service provider. Once selected, this provider should be listed here:

AI provider: [insert provider name once known]

Purpose: to process user prompts and generate responses that help users navigate educational course content.

Data processed: information voluntarily typed by the user into the AI assistant, which may include health-related information if the user chooses to provide it.

Retention: [insert provider retention details once known]

Location of processing: [insert processing location once known]

Please do not enter information that you do not want processed by the AI tool. Do not enter emergency medical information. The AI assistant is not a medical professional, diagnostic tool, or emergency service.

The Belgian Data Protection Authority has highlighted the importance of transparency, accountability, and clear explanations about how AI systems process personal data.  

5. How We Use Your Personal Data

We may use your personal data for the following purposes:

  • to operate and maintain the Site;

  • to provide access to courses, videos, downloads, or other educational content;

  • to respond to your messages or requests;

  • to send you emails, newsletters, or updates if you have subscribed;

  • to help you navigate course content through interactive tools or AI-assisted features;

  • to improve the Site, courses, content, and user experience;

  • to monitor website performance and security;

  • to understand how users interact with the Site;

  • to comply with legal, accounting, or administrative obligations;

  • to protect our legal rights or respond to disputes;

  • to provide products or services you purchase in the future.

6. Legal Bases for Processing

Depending on the context, we may rely on the following legal bases under GDPR:

  • Consent: for example, when you subscribe to a newsletter, submit certain forms, agree to optional cookies, or voluntarily provide health-related information where explicit consent is required.

  • Contract: where processing is necessary to provide a product or service you request or purchase.

  • Legitimate interests: for example, to operate, secure, and improve the Site, respond to messages, prevent misuse, and understand general website performance.

  • Legal obligation: where processing is necessary to comply with applicable laws or regulations.

  • Explicit consent for special category data: where you voluntarily provide health-related information through forms, questionnaires, AI prompts, or similar features and explicit consent is required.

7. Email Marketing

If you subscribe to our email list, newsletter, or free content, we may use your name and email address to send you educational content, updates, and occasional marketing communications.

You can unsubscribe at any time by clicking the unsubscribe link in any marketing email or by contacting us at help@postureplan.com.

We do not want to send you marketing emails without your consent where consent is required by law.

8. Cookies and Similar Technologies

The Site may use cookies or similar technologies. Cookies are small files stored on your device that help websites function, remember preferences, analyze performance, or support embedded content and advertising.

We may use:

  • necessary cookies, which help the Site function properly;

  • analytics cookies, if enabled, to understand how users interact with the Site;

  • marketing cookies or pixels, if enabled, to help measure or deliver advertising;

  • third-party cookies or similar technologies from embedded content such as YouTube videos.

We may use services such as Squarespace, YouTube/Google, Cloudflare, analytics providers, email providers, AI providers, or other tools that may process technical data or set cookies depending on how they are configured.

Where required by law, we will ask for your consent before setting non-essential cookies or similar technologies.

Embedded content, such as YouTube videos, may behave as if you visited the third-party website directly. These third parties may collect data, use cookies, or track your interaction with embedded content according to their own privacy policies.

9. Analytics and Advertising

We may use analytics tools to understand how visitors use the Site and to improve our content and services.

If enabled, analytics tools may collect information such as pages visited, time spent on the Site, device type, browser type, approximate location, and referral source.

We may also use advertising tools, such as social media pixels or ad platforms, if enabled. These tools may help us understand advertising performance or show relevant content to users.

Only include the following tools if actually used:

Analytics provider: [insert provider, e.g. Google Analytics, Squarespace Analytics, etc.]

Advertising provider: [insert provider, e.g. Meta/Facebook Pixel, Google Ads, etc.]

If these tools are not enabled, this section should be simplified accordingly.

10. Payment Data

At present, some content on the Site may be provided free of charge. If we offer paid products or services in the future, payment information may be processed by third-party payment providers.

We do not intend to store full credit card details directly on our own systems. Payment providers process payment information according to their own terms and privacy policies.

Payment provider to be listed if/when used:

Payment provider: [insert provider, e.g. Stripe, PayPal, etc.]

11. Sharing Personal Data With Service Providers

We may share personal data with trusted third-party service providers who help us operate the Site and provide our Services.

These may include:

  • website hosting and website platform providers;

  • email newsletter providers;

  • video hosting platforms;

  • analytics providers;

  • security and performance providers;

  • AI service providers;

  • payment processors, if paid services are offered;

  • legal, accounting, or administrative service providers.

These service providers may process personal data only as necessary to provide their services to us or as otherwise permitted by law.

We do not sell your personal data.

12. International Data Transfers

Some service providers may process personal data outside Belgium or the European Economic Area.

Where personal data is transferred outside the EEA, we aim to use appropriate safeguards where required by law. These may include adequacy decisions, standard contractual clauses, or other approved transfer mechanisms.

The European Commission adopted an adequacy decision for the EU-U.S. Data Privacy Framework in 2023, allowing transfers to participating U.S. companies under that framework.  

If we use a provider outside the EEA, we will seek to rely on an appropriate legal mechanism for that transfer where required.

13. Data Retention

We keep personal data only for as long as necessary for the purposes for which it was collected, including to provide services, respond to requests, maintain records, comply with legal obligations, resolve disputes, and protect our rights.

Examples:

  • email subscription data is kept until you unsubscribe or ask us to delete it, unless we need to retain limited records for legal reasons;

  • contact form messages may be kept for as long as needed to respond and maintain reasonable business records;

  • payment or transaction records, if applicable, may be kept for accounting or tax obligations;

  • AI assistant conversations are intended to be temporary and not used to remember users between sessions, unless this is changed and explained in an updated policy;

  • technical logs may be kept for a limited period for security, troubleshooting, or analytics purposes.

When personal data is no longer needed, we will delete it, anonymize it, or securely retain it only where legally required.

14. Data Security

We take reasonable steps to protect personal data against unauthorized access, loss, misuse, disclosure, alteration, or destruction.

These steps may include using secure platforms, password protection, limited access, and trusted service providers.

However, no website or online service can guarantee complete security. You use the Site with the understanding that transmission of information over the internet always carries some risk.

If we become aware of a personal data breach that requires notification under applicable law, we will take appropriate steps to notify the relevant authority and/or affected individuals where required.

15. Children and Minors

The Site is intended for adults and is not directed at children.

We do not knowingly collect personal data from children. If you are under 16, you should not submit personal data through the Site without the involvement and consent of a parent or guardian.

If we become aware that we have collected personal data from a child without appropriate consent, we will take reasonable steps to delete it.

16. Your Data Protection Rights

Under applicable data protection law, you may have the right to:

  • request access to your personal data;

  • request correction of inaccurate data;

  • request deletion of your personal data;

  • request restriction of processing;

  • object to processing based on legitimate interests;

  • request data portability;

  • withdraw consent where processing is based on consent;

  • lodge a complaint with a supervisory authority.

You can exercise your rights by contacting us at help@postureplan.com.

If you are in Belgium, you may also contact the Belgian Data Protection Authority.

17. Third-Party Links and Embedded Content

The Site may contain links to third-party websites, platforms, or services. It may also include embedded content, such as YouTube videos.

Third-party websites and services are governed by their own privacy policies. We are not responsible for the privacy practices, content, or security of third-party websites or services.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When we make changes, we will update the date at the top of this page. If changes are significant, we may provide a more prominent notice on the Site or by email where appropriate.

Your continued use of the Site after changes are posted means you acknowledge the updated Privacy Policy.

19. Contact Information

This Site is owned and operated by:

John Arnett EI

Website: www.postureplan.com

Email: help@postureplan.com

Address: Chaussée de Wavre 1110, 1160, Bruxelles

If you have questions about this Privacy Policy or how your personal data is handled, contact us at:

help@postureplan.com