PUBLISHED CUSTOMER ISSUE — EFFECTIVE 27 AUGUST 2026

Document code: COM-PRIV-001

Version: 1.0 — Founding Edition

Status: Published customer issue

Document owner: Founder and Director

Applies to: Prospective purchasers, purchasers, named Authorised Users, customer-support contacts and complainants

Effective date: 27 August 2026

Vital Adaptation Ltd



Customer and Purchaser Privacy Notice

Initial UK digital-product sales under an Individual Licence

1. Who we are

Vital Adaptation Ltd is responsible for deciding how and why personal information is used in connection with its digital-product sales, licences, customer support and related commercial administration.

Company: Vital Adaptation Ltd

Company number: 15693670

Registered office or approved public correspondence address: 65 Crouch Avenue, Hullbridge, Hockley, England, SS5 6BS

Privacy email: vitaladaptation@gmail.com

Customer support email: vitaladaptation@gmail.com

Complaints email: vitaladaptation@gmail.com

Website: https://www.vitaladaptation.com/

In this Notice, “Vital Adaptation”, “we”, “us” and “our” mean Vital Adaptation Ltd.

2. Who this Notice covers

This Notice applies to people whose personal information is used in connection with the purchase, supply or administration of a Vital Adaptation digital product. This includes:

people considering a purchase;

purchasers and named Authorised Users;

people purchasing on behalf of a named individual;

people contacting us about a product, licence or order;

people requesting technical or accessibility support;

people raising a cancellation, refund, complaint or privacy concern;

people providing feedback, survey responses or testimonials.

Separate privacy information may apply to clinical or consultancy clients, event participants, course delegates, employees, associates, contractors, research participants, mailing-list subscribers, or other activities not covered by this Notice.

3. The information we may collect

3.1 Identity and contact information

name;

email address;

postal or billing address;

telephone number where supplied;

country or location;

company, employer, profession or role where supplied.

3.2 Purchase, contract and licence information

product and edition purchased;

licence type and named Authorised User;

purchase date and order reference;

amount paid and tax information shown on the transaction;

discount, complimentary-copy or pricing-exception record;

delivery and fulfilment status;

download or access information;

the versions of the Terms, Licence and Product Schedule applying to the sale;

checkout acknowledgements, including immediate-digital-supply consent.

3.3 Payment information

We may receive payment status, payment-method type, transaction identifiers, refund or chargeback information and limited billing information from the payment or sales platform. Vital Adaptation does not normally receive or retain complete payment-card details.

3.4 Customer-service and complaint information

support requests and correspondence;

technical-access information, filenames, error messages or screenshots;

cancellation, refund or duplicate-purchase requests;

complaints, investigation records and outcomes;

accessibility or communication requirements;

remedies, replacements or exceptional permissions provided.

3.5 Licence and intellectual-property information

approved licence variations or permissions;

reports or evidence of suspected unauthorised sharing, redistribution or misuse;

steps taken to investigate or resolve a licence concern;

records reasonably required to protect Vital Adaptation’s intellectual property and contractual rights.

3.6 Technical information

Depending on the website, sales platform and delivery system, technical information may include IP address, browser, device, account activity, access time, download history, cookie information, and fraud or security indicators.

3.7 Feedback and communications information

product feedback and survey responses;

testimonials and permissions;

communication preferences;

marketing consent or opt-out records.

4. Information we ask you not to provide

Please do not send personal information that is not reasonably necessary for your purchase, support request or complaint. In particular, please avoid sending:

identifiable patient, client or service-user information;

clinical records or safeguarding records;

confidential employer or organisational documents;

completed Toolkit records containing third-party information;

special-category information that is not needed to resolve the matter.

Where unnecessary sensitive or third-party information is received, we may delete, redact or restrict it where appropriate.

5. How we obtain information

directly from you;

from a person purchasing on your behalf;

through the website, sales platform, payment provider or delivery system;

through email, forms, customer accounts or support communications;

from an authorised representative;

from a payment provider, card issuer or platform in connection with a transaction dispute;

from public, professional, legal, regulatory or insurance sources where reasonably necessary to investigate fraud, infringement or misuse.

6. Why we use personal information

respond to product enquiries and provide pre-contract information;

process orders, payments, refunds and chargebacks;

form and administer the contract and Individual Licence;

identify the purchaser and named Authorised User;

supply digital content and provide order or licence evidence;

maintain product-version, checkout and fulfilment records;

provide technical, accessibility and customer support;

investigate complaints, errors, fraud, misuse or licence breaches;

protect Vital Adaptation’s intellectual property and business interests;

comply with consumer, accounting, tax, company, data-protection and other legal obligations;

obtain professional, legal, insurance or technical advice;

establish, exercise or defend legal claims;

maintain security, business continuity and governance records;

issue material corrections, replacement files or contractual communications;

evaluate and improve products, support processes and pricing;

send optional marketing where lawful.

7. Our lawful bases

7.1 Contract

We may use personal information where necessary to take steps at your request before purchase, process and fulfil an order, administer the licence, provide contractual support, or manage a contractual refund or remedy.

7.2 Legal obligation

We may use personal information where necessary to comply with accounting, tax, company, consumer, data-protection, court, regulatory or other legal requirements.

7.3 Legitimate interests

We may use personal information where reasonably necessary for legitimate interests such as maintaining accurate sales and licence records, protecting intellectual property, preventing fraud, improving products, managing security, handling complaints, obtaining advice, and managing legal claims. We will consider whether those interests are overridden by your rights and interests.

7.4 Consent

We may rely on consent for optional marketing, publication of an identifiable testimonial, or another purpose where consent is the appropriate lawful basis. Consent may be withdrawn for future use, although withdrawal does not affect processing already carried out lawfully.

7.5 Contract acceptance is not blanket privacy consent

Acceptance of the Terms of Sale and Individual Licence does not mean that all personal-information processing is based on consent. Much of the information is used because it is necessary for the contract, legal compliance or legitimate business interests. This Notice explains that processing; it does not expand the product licence.

8. Special-category and sensitive information

We do not ordinarily need health, disability or other special-category information to sell a digital product. You may choose to tell us about an accessibility need, communication requirement or sensitive circumstance relevant to a support, complaint or discretionary request.

Where such information is processed, we will limit it to what is necessary, identify an appropriate lawful basis and additional condition, restrict access, and avoid recording unnecessary detail. You do not need to disclose a diagnosis to request a reasonable adjustment unless that information is genuinely necessary.

9. Who we may share information with

Where necessary, lawful and proportionate, information may be shared with:

website, hosting, cloud-storage and document-management providers;

sales, checkout and digital-delivery platforms;

payment providers, banks and card issuers;

email and communication providers;

accounting, bookkeeping and tax advisers;

legal advisers, insurers and professional advisers;

information-technology and cybersecurity support;

regulators, courts, law-enforcement bodies and public authorities;

another party involved in a legitimate business sale, restructuring, merger or succession arrangement, subject to appropriate safeguards.

We do not sell personal information to advertisers.

We will not normally disclose purchaser information to an employer, colleague or organisation merely because it paid for the product, unless this is necessary to administer the payment, the purchaser has authorised the disclosure, the information is already held by that payer, or disclosure is otherwise required or permitted by law.

10. Sales, payment and delivery platforms

An approved sales, payment or delivery platform may process information independently or on our behalf. The platform may collect identity, billing, payment, tax, technical, fraud-prevention, checkout and download information. Its own privacy notice and terms may also apply.

Vital Adaptation currently uses Payhip for its storefront, checkout, digital delivery and order administration, and Stripe for card-payment processing. Payhip states that payment is handled separately through the selected payment processor and that Payhip does not collect payment-card details. Payhip and Stripe may process information for their own stated purposes as well as when providing services to Vital Adaptation. Their privacy information is available at https://payhip.com/privacy and https://stripe.com/gb/privacy.

11. International transfers

Some service providers may process or store personal information outside the United Kingdom. Where a restricted international transfer occurs, we will use an appropriate lawful transfer mechanism and proportionate safeguards where required, such as UK adequacy regulations, approved contractual clauses, the UK International Data Transfer Agreement, the UK Addendum, or another lawful mechanism.

12. Security

We use proportionate technical and organisational measures intended to protect personal information. These may include controlled account access, strong passwords, multi-factor authentication where available, secure business systems, restricted folders, device security, backups, supplier due diligence, confidentiality controls and incident-response procedures.

No system can be guaranteed to be completely secure. Please contact us promptly if you believe purchaser, licence or account information has been compromised.

13. Retention

We retain information only for as long as reasonably necessary for the relevant purpose. Retention periods may reflect contractual administration, licence evidence, accounting and tax duties, consumer-law requirements, intellectual-property protection, insurance, complaints, fraud prevention and legal claims.

13.1 Order and accounting records

Normally retained for the period required by applicable accounting and tax law.

13.2 Contract, licence and fulfilment records

May be retained for the duration of the licence and for a reasonable period afterwards to establish what rights were granted, which edition was supplied, and what contractual terms applied.

13.3 Complaints, refunds and support records

Retained for the period reasonably required to resolve the issue, demonstrate accountability and manage possible legal, insurance or governance matters.

13.4 Marketing preferences

Retained while marketing is active and afterwards where necessary to maintain an opt-out or suppression record.

14. Your information rights

Depending on the circumstances, you may have the right to:

be informed about how your information is used;

request access to your personal information;

ask for inaccurate or incomplete information to be corrected;

ask for erasure where the right applies;

ask for processing to be restricted where the right applies;

object to processing based on legitimate interests;

object to direct marketing;

request data portability where the legal conditions apply;

withdraw consent where processing relies on consent;

raise concerns about solely automated decision-making where relevant.

These rights are not absolute and legal exemptions may apply.

15. How to exercise your rights

Contact: vitaladaptation@gmail.com or write to 65 Crouch Avenue, Hullbridge, Hockley, England, SS5 6BS.

Please state your name, the email address used for the purchase, your order reference where relevant, the right you wish to exercise, and the information or processing concerned. We may need to verify your identity. Requests are normally free of charge, although the law permits a reasonable fee or refusal in limited circumstances.

16. Marketing and product communications

Purchasing a product does not automatically require you to receive optional marketing. Marketing will be sent only where lawful, and you may opt out at any time.

Opting out of marketing does not prevent us from sending communications reasonably necessary to fulfil the contract, provide support, administer the licence, issue a material correction or security notice, or comply with law. Promotional content will not be disguised as a necessary service message.

17. Feedback and testimonials

We may use non-identifiable feedback to improve products, evaluate usefulness, review pricing, plan future resources and identify common support needs.

We will not publish your name, job title, employer, photograph, identifiable quotation or case example without an appropriate lawful basis and permission where required. You are not required to provide a testimonial, and refusal or withdrawal of promotional permission will not affect your purchase.

18. Cookies and website information

The Vital Adaptation website and Payhip store may use cookies and similar technologies for essential operation, checkout, login, fraud prevention, preferences, analytics and marketing where consent is required. The applicable website or platform cookie information explains the cookies used and the choices available.

19. Automated fraud and security checks

Payment and sales platforms may use automated tools to identify suspected fraud, unusual transactions, payment risk, account misuse or security concerns. This may result in a payment being declined, an order being held, additional verification, or temporary access restriction. Where relevant legal rights apply, you may request further information or human review through the appropriate provider or Vital Adaptation.

20. Children

The initial professional digital products are intended for adult purchasers. We do not knowingly market them directly to children. A purchaser must be at least 18 years old and legally capable of entering into a contract.

21. Complaints about personal information

Please contact vitaladaptation@gmail.com or write to 65 Crouch Avenue, Hullbridge, Hockley, England, SS5 6BS if you are concerned about how your personal information has been handled.

You also have the right to complain to the Information Commissioner’s Office. Current contact routes are available from the ICO. The ICO’s postal address is Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

22. Personal-data breaches

Actual or suspected personal-data breaches will be handled under Vital Adaptation’s Personal Data Breach Procedure. Depending on the circumstances, we may contain and assess the incident, preserve evidence, record it, notify providers, notify the ICO where required, inform affected individuals where legally required, and take corrective action.

Please contact us promptly if you receive another purchaser’s information, receive an incorrect Order Confirmation or licence record, believe your order details have been disclosed, suspect unauthorised account access, or identify another privacy or security concern.

23. Changes to this Notice

We may update this Notice where products, providers, contact details, legal requirements or governance arrangements change. The current public version will show its version number and effective date. Where a material change affects existing purchasers, we may provide appropriate notice.

A new Privacy Notice does not retrospectively alter the product, price, licence rights or contractual terms applying to a completed purchase.

24. Relationship with other documents

This Notice should be read alongside the Master Terms of Sale, applicable Individual Licence, Product Schedule, Purchases, Refunds and Complaints Information, and relevant website or cookie information.

This Notice explains personal-information processing. It does not grant product-use rights, create a duty of care to a purchaser’s clients or other third parties, or replace the contractual documents.