Privacy Policy — SteelRep

Introduction

This website (“ironwolfpack.com”) is operated by ThoughtGears Ltd, a company registered in England and Wales. This Privacy Policy explains how we collect, use, and protect your personal data when you purchase digital products through our site.

We are committed to handling your data in an open and transparent manner. This policy complies with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and the California Consumer Privacy Act (CCPA).

Data Controller

ThoughtGears Ltd is the data controller for your personal data.

Contact: [email protected]

Data We Collect

Purchase Data (via Stripe)

When you purchase the SteelRep Protocol Founder Bundle, your payment is processed by Stripe. Stripe collects your email address and payment details (card number, billing address) directly. We receive only your email address and purchase confirmation from Stripe. We do not store or have access to your full payment card details.

Website Analytics

We use two analytics services:

Cloudflare Web Analytics: A privacy-preserving analytics service that does not use cookies, does not track individual visitors, and collects only aggregated data (page views, referrers, device types). No personally identifiable information is collected through Cloudflare Analytics.
Google Analytics 4 (GA4): We use GA4 to understand how visitors interact with our site (pages visited, time on site, traffic sources). GA4 sets cookies on your device and may collect your IP address, which Google anonymises. GA4 data is used solely to improve our website and content. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on. See Google’s privacy policy.

What We Do Not Collect

We do not collect workout data, health data, or any data beyond what is necessary to fulfil your order. We do not require you to create an account.

How We Use Your Data

We use your email address to:

Deliver the training programs you purchased
Send your SteelRep app early access invite when the program begins
Respond to support requests related to your purchase
Retain records for tax and legal compliance

Legal Basis for Processing

Under UK and EU GDPR, we process your data based on:

Contract performance: To fulfil the order you placed (deliver your programs by email)
Legal obligation: To maintain purchase records for tax and accounting purposes
Legitimate interests: To operate and improve our website (aggregated analytics)

Data Retention

Email and purchase records: Retained for 7 years to comply with UK tax and accounting obligations, then deleted
Cloudflare analytics data: Aggregated and not personally identifiable; retained by Cloudflare per their data retention policy
Google Analytics data: Retained for 14 months (GA4 default), then automatically deleted

We share your data only with:

Stripe: Payment processing. Stripe acts as an independent data controller for payment data. See Stripe’s privacy policy
Cloudflare: Website hosting and analytics. See Cloudflare’s privacy policy
Google: Website analytics (GA4). Google acts as a data processor for analytics data. See Google’s privacy policy

We do not sell, rent, or trade your personal data.

Your Rights

Under UK GDPR, EU GDPR, and CCPA, you have the right to:

Access: Request a copy of the data we hold about you
Rectification: Correct inaccurate data
Erasure: Request deletion of your data (subject to legal retention obligations)
Portability: Receive your data in a machine-readable format
Restriction: Limit how we process your data
Objection: Object to certain processing activities

To exercise these rights, contact [email protected].

Children’s Privacy

Our products are not intended for users under 16 years of age. We do not knowingly collect data from children under 16.

Changes to This Policy

We may update this policy from time to time. Material changes will be posted on this page with an updated “Last updated” date.

Contact Us

For privacy-related questions or to exercise your rights:

Email: [email protected]

Data Protection: ThoughtGears Ltd, United Kingdom

Complaints

If you are not satisfied with our response, you can lodge a complaint with:

UK: Information Commissioner’s Office (ICO) — ico.org.uk

EU: Your local data protection authority