This agreement is between the coach or business using CutWise Pro ("you", the Controller) and Carbon Software LTD, NI735624 ("CutWise", the Processor).
1. Roles
- What we process for you (we're your processor): the personal data you create or keep on CutWise Pro about your clients and prospective clients: notes, targets you set, programmes and templates assigned to them, meal plans, check-in forms and their answers, intake questionnaires, messages, voice notes and videos in chat, reactions and comments on meals, and your conversations with your assistant (Metis) about them.
- What we don't process for you: each client's own CutWise account and logs. CutWise is the controller of that data. A client shares chosen categories with you on their explicit consent; once shared, you are an independent controller of what you receive.
- Your own account details and billing: CutWise is the controller (see the Privacy Policy).
2. Details of the processing
| Subject matter | Providing CutWise Pro |
|---|---|
| Duration | While your account exists, then deletion under section 9 |
| Nature | Storing, organising, displaying, transmitting, analysing with AI (summaries, drafts, ranking, the assistant), deleting |
| Purpose | Letting you coach your clients |
| Data subjects | Your clients and people you invite |
| Personal data | Names, contact details, messages, notes, check-in answers, programmes and training sessions, targets |
| Special category data | Health data: food and nutrition, weight, body measurements, progress photos, training, how sessions felt, anything clients tell you about health |
3. Our obligations
We will:
- Process this data only on your documented instructions, which are these terms and how you use CutWise Pro, unless the law requires otherwise (and then tell you first, where allowed).
- Make sure everyone who can access it is bound to confidentiality.
- Keep it secure with the measures in Annex 2.
- Only use sub-processors under section 4.
- Help you, as far as we reasonably can, to answer clients' requests to exercise their rights (access, correction, deletion and so on).
- Help you with security, breach notifications, impact assessments and consultations with the ICO, as they relate to our processing.
- Delete or return the data at the end, under section 9.
- Give you the information you reasonably need to show compliance with Article 28, and allow audits under section 8.
- Tell you straight away if we think an instruction breaks data protection law.
4. Sub-processors
You authorise the sub-processors in Annex 1. We'll give you at least 30 days' notice by email of any new one, and you can object on reasonable data protection grounds; if we can't resolve it, you can end your plan and we'll refund any prepaid fees for the unused period. We impose the same data protection obligations on each sub-processor and stay responsible for them.
5. International transfers
Some sub-processors process data outside the UK. We'll only transfer it with an appropriate safeguard: UK adequacy regulations (including the UK Extension to the EU–US Data Privacy Framework where the provider is certified), or the UK International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses.
6. AI providers
AI features send the data needed for each task to Anthropic or OpenAI (Annex 1) through their APIs. Under their API terms, that data isn't used to train their models. We don't use your clients' data to train any model.
7. Personal data breaches
We'll tell you without undue delay, and within 48 hours, after becoming aware of a breach affecting this data, with what we know: what happened, the data and people affected, likely consequences and what we're doing. We'll update you as we learn more.
8. Audits
We'll answer reasonable written questions about our compliance. On-site audits need 30 days' notice, are limited to once a year (unless after a breach or at the ICO's request), are at your cost, and are subject to confidentiality.
9. End of processing
When you delete your CutWise Pro account, we delete the data in section 1.1 from our live systems within 30 days, and it ages out of backups and provider logs within a further 90 days, unless the law requires us to keep it. Export anything you need first. Clients keep their own CutWise data.
10. Liability
Each party's liability under this agreement is subject to the limits in the CutWise Pro terms, except where the law doesn't allow it.
Annex 1: Sub-processors (checked 29 Oct 2026)
| Provider | What for | Where | Safeguard for transfers out of the UK |
|---|---|---|---|
| Convex | Database and backend | EU (Ireland) | Stored in the EU |
| Cloudflare | Hosting the dashboard; storing and delivering exercise videos (R2) | Global network; R2 storage in the EU | UK Extension to the EU–US Data Privacy Framework; Standard Contractual Clauses in its DPA |
| Anthropic | The typed assistant, check-in summaries, draft replies, ranking who needs attention | US | Standard Contractual Clauses with the UK Addendum (its DPA, part of its commercial terms). API data isn't used for training and is deleted within 30 days |
| OpenAI | The voice assistant; speech to text | US | Standard Contractual Clauses with the UK Addendum (its DPA). API data isn't used for training; abuse-monitoring logs are kept up to 30 days |
| Resend | Emails (sign-in, notifications) | US | UK Extension to the EU–US Data Privacy Framework |
| PostHog | Product analytics on the dashboard (text masked, no recordings) | EU | Stored in the EU |
| Sentry | Error reports | EU (Germany) | Stored in the EU |
| Stripe | Coach billing (your data, not clients') | US / Ireland | UK Extension to the EU–US Data Privacy Framework; Standard Contractual Clauses as fallback |
Annex 2: Security measures
- Encryption in transit (TLS) everywhere; providers encrypt data at rest.
- Every coach read of client data checks an active coaching link and the categories the client consented to, on the server; covered by automated tests.
- A client leaving ends access at once; categories can be changed at any time.
- Media files: uploads only with short-lived signed tickets, under each coach's own unguessable paths.
- Rate limits on AI, uploads, messages and sign-in.
- Least-privilege access for CutWise staff; production data isn't read routinely; admin access needs separate credentials.
- Analytics mask on-screen text; no session recordings on the dashboard; error reports exclude IP addresses.
- AI providers used through their APIs, not for training.
- Account deletion removes coaching data (section 9).