Privacy Policy
Last updated: 8 September 2026
This website, djordjecoaching.com, is operated by Đorđe Đorđević, a part-time self-employed fitness and nutrition coach based in Malta ("I", "me"). I am the data controller for the personal data described below. This page explains what personal data is collected when you use this site, why, how long it is kept, and what your rights are under the EU General Data Protection Regulation (GDPR).
You can reach me about anything on this page at djordje@djordjecoaching.com.
No cookies, no tracking
This site sets no cookies. There is no Google Analytics, no advertising pixel, no social media tracker, and nothing is stored in your browser's local storage. That is why you are not seeing a cookie banner. There is nothing to consent to. I do not profile visitors, and I never sell or share data for advertising.
What data I collect, and why
- Your email address, only if you choose to give it, to receive the free recipe pack, join a waitlist, or apply for coaching. Legal basis: your consent. You confirm your subscription by clicking a link in a confirmation email, and you can withdraw consent at any time via the unsubscribe link in any email.
- Macro calculator inputs (sex, age, height, weight, activity level). I treat these as health-related data, which the GDPR protects as a special category. They are therefore only processed after you give explicit consent by ticking the box on the calculator. Legal basis: explicit consent, Article 9(2)(a) GDPR. See the dedicated section below for exactly what happens to them.
- Application and waitlist answers: if you apply for coaching or join a waitlist, the information you submit in that form. Legal basis: steps taken at your request before entering into a contract.
- Testimonial material (a quote, a photograph, your name or initials, your numbers), only if you are a client and you say yes when I ask, after your programme has finished. I treat before-and-after photographs and body measurements as health-related data. Legal basis: your explicit consent, Article 9(2)(a) GDPR. See "Publishing your results" below.
- Technical data: when you visit any website, the hosting provider automatically processes your IP address, browser type and the time of the request, in server logs. This is needed to deliver the site and protect it from abuse. Legal basis: my legitimate interest in operating a secure, working website.
The macro calculator: exactly what happens
Body measurements can say something about a person's health, so I treat them as special category (health) data and ask for your explicit consent before anything is processed. Nothing is sent until you tick the consent box.
When you submit the calculator, the values you entered (sex, age, height, weight, activity level) are sent to my server so the calculation can run there. This is deliberate: the calculation method is my own work and is not exposed in the browser.
On the server, those values are used to compute your result and are then discarded immediately. They are not saved to any database, not written to any log, and not linked to your name or email address, even if you later enter your email on the results screen. I keep no record of anyone's body measurements.
The calculator gives you a general starting estimate. It is not medical advice and is not a decision that produces any legal or similarly significant effect for you.
Publishing your results
If you finish a programme with me, I may ask whether I can show your result, on this site or on social media. That question is separate from the coaching and comes after it. It is never a condition of a place, a price or a free place, and saying no changes nothing about what you received. I do not ask twice.
The consent is granular: you answer for each part on its own: your photograph, your name (initials instead, if you prefer), your numbers, and the wording of your quote. A yes to one is not a yes to the others, and I publish only the parts you said yes to.
You can withdraw it at any time, by email, without giving a reason. I take the material off this site and off my own social media accounts without undue delay. What other people have already saved, screenshotted or reshared is outside my reach, and I will tell you that plainly rather than promise otherwise. Withdrawing does not make the earlier publication unlawful, and it never affects your coaching.
How long this one is kept. Your permission, the message where you said yes and to which parts, is kept for as long as the consent stands, that is, until you withdraw it. It does not expire with the retention periods listed below and it is not deleted on the same schedule as your check-in material: if it were, I would have nothing left to show that you ever agreed. After you withdraw it, I keep only the short record that you withdrew and that I acted on it, and delete the rest.
Who else processes the data
I use the following service providers, who process data on my behalf under data processing agreements:
- Kit (kit.com, United States): email list management and sending emails.
- Vercel (vercel.com, United States): website hosting and the calculator function; processes server logs including IP addresses.
- Tally (tally.so, Belgium, EU): application and waitlist forms.
- ImprovMX (improvmx.com, France, EU): forwarding email sent to my contact address.
- WhatsApp (Meta, United States): only if you are an Elite 1:1 client and choose to message me there. Messages are end-to-end encrypted, but Meta still processes your phone number and metadata. If you would rather not use it, tell me and we will use email or the platform instead. I keep detailed health information out of WhatsApp.
Transfers outside the EU
Kit, Vercel and WhatsApp (Meta) are based in the United States, so some data is transferred outside the European Economic Area. These transfers are covered by the safeguards required under Chapter V of the GDPR: the EU–US Data Privacy Framework and/or the European Commission's Standard Contractual Clauses, as set out in each provider's data processing terms. Tally and ImprovMX are based in the EU.
How long I keep it
- Email address: until you unsubscribe or ask me to delete it, and then removed without undue delay.
- Application and waitlist answers: up to 24 months after our last contact if we do not work together, so I can follow up if you asked me to; if we do work together, for the duration of our coaching plus any period required by law (for example tax records).
- Macro calculator inputs: not retained at all, discarded as soon as the result is calculated.
- Testimonial material and the consent behind it: kept for as long as the consent stands, until you withdraw it. This one does not run on the same clock as anything else on this list; see "Publishing your results" above.
- Server logs: kept short-term by the hosting provider for security and diagnostics, per their retention policy.
Your rights
Under the GDPR you have the right to:
- Access the personal data I hold about you, and get a copy of it.
- Correct data that is wrong or incomplete.
- Erase your data ("right to be forgotten").
- Restrict or object to processing, including direct marketing.
- Portability: receive your data in a structured, commonly used format.
- Withdraw consent at any time, without affecting processing that already happened.
To use any of these rights, email me at djordje@djordjecoaching.com. I will respond within one month. There is no charge, and you do not need to give a reason.
Automated decision-making
I do not carry out automated decision-making or profiling that produces legal effects or similarly significantly affects you. The macro calculator performs an automated calculation, but its output is only an informational estimate for you.
Age
This site, the calculator and my coaching services are intended for people aged 16 and over. I do not knowingly collect personal data from anyone under 16, and I do not take on coaching clients under 16. If you believe someone under 16 has submitted data to me, email me and I will delete it.
Complaints
If you are not satisfied with how I handle your data, please contact me first. I would rather fix it directly. You also have the right to lodge a complaint with a supervisory authority. In Malta this is the Office of the Information and Data Protection Commissioner (IDPC), idpc.org.mt. You may also complain to the authority in your own EU country of residence.
Changes to this policy
If I change how data is handled, I will update this page and the "last updated" date above.
Contact
Đorđe Đorđević · part-time self-employed coach, Malta · djordje@djordjecoaching.com