Privacy Policy

Last updated: May 6th, 2026

Train Effective Ltd (“Train Effective”, “we”, “us”, “our”) respects your privacy and is committed to protecting personal data. This Privacy Policy explains how we collect, use, store, share, and protect personal data when you enquire about or use our football camps, football-related online programs, website, forms, communications, and related services.

This policy applies to prospective customers, leads, parents or guardians, players, customers, and other individuals who contact us or whose data we receive in connection with our services.

1. Who we are

Train Effective Ltd is a company registered in England and Wales. Our registered address is 4th Floor, Silverstream House, 45 Fitzroy Street, Fitzrovia, London, England, W1T 6EB.

Data controller: Train Effective Ltd

Privacy contact email: team@traineffective.com

2. What personal data we collect

We may collect, use, store, and process the following categories of personal data:

• Full name.
• Email address.
• Phone number.
• WhatsApp number.
• Country and, where provided, country of birth or nationality.
• Whether you have a passport.
• Age or date of birth, where relevant.
• Whether the enquiry is made by a player or by a parent/guardian.
• Parent or guardian contact details where relevant.
• Football-related information, such as whether you play for a club and your reasons for joining a camp or program.
• Enquiry details, message content, communication preferences, and CRM notes.
• Records of marketing preferences, consent choices, and opt-out requests.
• Call recordings, call transcripts, and call notes where calls are recorded or transcribed.
• Technical or website usage information where relevant, such as form submissions and related metadata.

We may ask for additional information later in the customer journey where needed to administer camps or programs. We will only use personal data that is relevant and reasonably necessary for the purposes described in this policy.

3. How we collect personal data

We collect personal data in several ways:

• Directly from you when you fill out a website form, send us a message, email us, call us, message us on WhatsApp, or otherwise contact us.
• From a parent or guardian.
• From a player making an enquiry, including younger users, where our forms allow this.
• From referrals or other third-party sources, where permitted.
• From our communications platforms, CRM systems, telephony systems, and related business tools.

Where we receive personal data from a source other than the individual directly, we will provide privacy information within the time required by law.

4. Children and parent/guardian enquiries

Some of our services are relevant to children and young players. Where an enquiry concerns a player under 17, we may request and use parent or guardian contact details and communicate directly with the parent or guardian instead.

We aim to present privacy information in clear and accessible language where children may interact with our forms or services. Where required by applicable law, additional parental involvement or permission may be required, particularly in relation to younger children and consent-based processing.

5. Why we use personal data

We use personal data to:

• Respond to enquiries and provide information about our camps and online programs.
• Assess suitability, eligibility, logistics, and administration for participation.
• Contact prospective customers and parents/guardians by email, SMS, WhatsApp, and phone.
• Send marketing communications about our football camps and related programs.
• Manage customer relationships and maintain records in our CRM and related systems.
• Record and transcribe calls for training, quality assurance, compliance, dispute handling, sales review, service improvement, and internal monitoring.
• Manage bookings, onboarding, support, complaints, and disputes.
• Maintain records of consent, objections, and opt-out preferences.
• Protect our business, users, systems, and legal rights.
• Comply with legal, regulatory, accounting, and tax obligations.

6. Lawful bases

Under UK GDPR, we rely on one or more of the following lawful bases, depending on the activity:

• Contract: where processing is necessary to take steps at your request before entering into a contract or to perform a contract with you.
• Legitimate interests: where processing is necessary for our legitimate business interests, such as handling enquiries, managing customer relationships, improving services, recording calls for justified business purposes, and maintaining internal records, provided those interests are not overridden by your rights and interests.
• Consent: where consent is required or where we choose to rely on consent, including for certain marketing activities and certain optional data uses.
• Legal obligation: where processing is necessary to comply with a legal or regulatory obligation.

Where we rely on legitimate interests, these interests include promoting and operating our services, responding to enquiries, maintaining service quality, protecting our business, and communicating effectively with prospective and existing customers.

7. Marketing communications

We may send marketing communications about our football camps and related programs by email, SMS, WhatsApp, and phone. We may use your contact details to send updates, promotional offers, follow-up messages, reminders, and other marketing content relevant to our services.

Where required by law, we will ask for your consent before sending electronic marketing. In some situations, we may rely on another permitted basis, such as the soft opt-in, where the legal conditions are satisfied and the communication relates to our own similar services.

You have the right to object to direct marketing at any time, and we will respect your preferences. You can opt out by using the unsubscribe link in emails, replying with a clear opt-out request in SMS or WhatsApp, telling us during a call, or contacting us at team@traineffective.com.

8. Call recordings and transcription

We may record and transcribe inbound and outbound calls. We do this for training, quality assurance, compliance, dispute handling, sales review, service improvement, and related internal business purposes.

Where calls are recorded or transcribed, we will aim to provide appropriate notice at or before the time of the call. We may use third-party tools, including AI-assisted transcription services, to process recordings and transcripts on our behalf.

9. Sources of data and referrals

We may receive personal data directly from the individual, from a parent or guardian, or from a referral or third-party source. Where we obtain personal data indirectly, we will provide privacy information within a reasonable period and at the latest within the period required by applicable law.

10. Who we share personal data with

We may share personal data with trusted service providers and partners where necessary for the purposes described in this policy. These may include:

• CRM and customer-management providers, including Freshsales and Monday.com.
• Email and communications providers, including Beehiiv and Gmail.
• Telephony, SMS, and communications providers, including Telnyx and respond.io.
• WhatsApp service providers and API providers.
• Call recording and transcription providers, including Fathom.
• Professional advisers, such as lawyers, accountants, auditors, and insurers.
• Regulators, law enforcement agencies, courts, and public authorities where required.
• Other suppliers or contractors who process personal data on our behalf under appropriate contractual controls.

Where third parties process personal data on our behalf, we require them to act only on our instructions and to implement appropriate security measures.

11. International transfers

Because we deal with leads and customers around the world and use service providers in different jurisdictions, personal data may be transferred to or accessed from countries outside the UK. This may include the United States and other jurisdictions where our service providers operate.

Where UK GDPR applies and a restricted transfer takes place, we will rely on a lawful transfer mechanism, such as an adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to EU Standard Contractual Clauses, or another permitted safeguard or exception where applicable.

12. Data retention

We retain personal data only for as long as reasonably necessary for the purposes described in this policy, including legal, regulatory, tax, accounting, operational, and dispute-resolution purposes. Retention periods are reviewed periodically.

Our current general retention approach is:

• Non-converted leads and enquiry records: up to 5 years after the last meaningful interaction, unless a longer period is needed for a legal claim, dispute, or compliance reason.
• Customer records: up to 10 years after the relevant service has ended where necessary for legal, accounting, tax, compliance, or dispute-resolution purposes.
• Call recordings and transcripts: generally up to 12 months, unless needed for an ongoing complaint, dispute, investigation, or legal claim.
• Marketing suppression or opt-out records: retained for longer where necessary to ensure we continue to respect your marketing preferences and do not contact you again in breach of those preferences.

13. Your rights

Depending on the circumstances and the law that applies, you may have the right to:

• Request access to your personal data.
• Request correction of inaccurate or incomplete data.
• Request deletion of your data.
• Request restriction of processing.
• Object to processing, including direct marketing.
• Withdraw consent where processing is based on consent.
• Request portability of certain data.
• Lodge a complaint with the UK Information Commissioner’s Office (ICO) or another competent supervisory authority.

If you wish to exercise any of these rights, please contact us at team@traineffective.com. We may need to verify your identity before responding.

14. Complaints

If you are unhappy with how we handle your personal data, we would appreciate the chance to address your concern first. You also have the right to complain to the UK Information Commissioner’s Office. Information about how to do this is available on the ICO website.

15. Security

We use appropriate technical and organisational measures designed to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction, or damage. These measures may include access controls, role-based permissions, secure storage, vendor controls, and process restrictions appropriate to the nature of the data.

16. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version with a revised “Last updated” date.

17. Contact

If you have any questions about this Privacy Policy or our processing of personal data, please contact:

Train Effective Ltd

4th Floor, Silverstream House, 45 Fitzroy Street, Fitzrovia, London, England, W1T 6EB

Email: team@traineffective.com