Privacy Notice.

P1 ELEVEN LTD is the controller of the personal data covered by this Privacy Notice.

Company number: 17321935

Registered office: 101 International House, King's Cross Road, London, WC1X 9LP, England.

For privacy or data protection enquiries: privacy@p1eleven.com.

For general enquiries: contact@p1eleven.com.

The information we collect depends on how you interact with P1 ELEVEN.

Website and enquiries

We may collect:

• name;
• email address;
• telephone number where provided;
• organisation;
• job title or role;
• information submitted through Request Access forms;
• Advisory or Speaking enquiry information;
• correspondence with P1 ELEVEN;
• technical information associated with use of our website.

P1 ELEVEN Executive

If you use P1 ELEVEN Executive, we may collect information including:

Account and profile information

• name;
• email address;
• account and authentication information;
• role and organisation information where provided;
• working patterns;
• schedule preferences;
• personal priorities and goals;
• preferences about how P1 can support you.

Schedule and contextual information

This may include:

• working hours;
• meetings or important moments;
• travel;
• schedule demand;
• changes to your normal routine;
• information you choose to provide about upcoming commitments.

If you choose to connect an external calendar, P1 may process the calendar information necessary to provide schedule context in accordance with the permissions you grant.

Health and wellbeing information

P1 Executive is designed to provide personalised performance support.

You may therefore choose to provide information relating to areas such as:

• sleep;
• sleep timing and regularity;
• energy;
• alertness;
• tiredness;
• recovery;
• physical activity and exercise;
• nutrition;
• caffeine;
• stress and stress management;
• wellbeing;
• other information you choose to provide about how you are feeling.

If you choose to connect Apple Health, P1 reads the Health data types you permit on your iPhone and imports up to 90 days of derived daily summaries: sleep duration and timing, optional sleep stages, steps, recorded workouts with duration, optional workout average heart rate and effort (including Apple estimated effort, labelled by source when known), resting heart rate and HRV SDNN, with limited source/device information. Exercise Load is calculated from each recorded workout’s duration and available effort; days with missing effort can have only a partial load. P1 refreshes these summaries when you return to the app while connected and consent remains active. Individual HealthKit samples and sample IDs stay on the iPhone and are not stored in P1.

Apple Health is optional. Your own check-in answers remain separate from the measured daily summaries. These imported summaries are not supplied to P1 AI or shown in Admin in this version.

Some of this information may constitute special category personal data relating to health under UK data protection law.

We ask for your explicit consent before processing health and wellbeing information within P1 Executive.

The health and wellbeing information requested by P1 Executive is necessary to provide the personalised performance service.

You can withdraw this consent through the Privacy & Data area of your account.

Because this information is central to personalised P1 Executive support, withdrawing consent may mean that some or all of the core P1 Executive service can no longer be provided.

Apple Health is optional. Disconnecting it stops future imports and background catch-up, while stored P1 summaries remain. Disconnect does not withdraw your broader health and wellbeing consent, remove check-ins or change Apple's iOS permission.

Withdrawing health & wellbeing consent pauses the personalised daily service, stops future Health imports and check-ins, and removes stored Apple Health daily and workout summaries, daily health and wellbeing check-ins, health and wellbeing onboarding answers, and P1 recommendations, plan history and performance insights derived from that information. Independent account information remains. You may explicitly consent again, but erased information is not restored. Deleting your account and data is a separate full-account action in Privacy & Data.

Information you provide in free-text fields

Some parts of P1 Executive allow you to provide additional context in your own words.

Please do not upload or provide full medical records, clinical reports or detailed medical documentation unless P1 specifically asks you to do so for a clearly explained purpose.

P1 Executive is not intended to operate as an electronic medical-record system.

Information created from your use of P1

We may also create or store information derived from your interaction with P1 Executive, including:

• personalised priorities;
• Foundation status and progress;
• behaviour-change progress;
• trends over time;
• changes from your usual patterns;
• contextual interpretations;
• recommendations;
• previous P1 plans and priorities;
• engagement with recommendations;
• information about whether recommendations were followed, ignored or changed;
• administrative records associated with providing your service.

This remains personal data where it relates to you.

We use personal information only where we have an appropriate legal basis.

Providing P1 Executive

We use relevant information to:

• create and maintain your P1 Executive account;
• understand your personal context;
• provide personalised performance support;
• interpret your daily information;
• identify relevant priorities;
• understand changes and trends over time;
• adapt recommendations to your schedule and circumstances;
• maintain your longitudinal P1 performance history;
• respond to requests or support enquiries.

Our principal lawful basis for processing ordinary personal data required to provide the service is that processing is necessary for the performance of our contract with you or to take steps at your request before entering into a contract.

Health and wellbeing information

Where P1 Executive processes special category health or wellbeing information:

• our Article 6 lawful basis is generally that processing is necessary to provide the P1 service you have requested; and
• our additional Article 9 condition is your explicit consent.

The health and wellbeing processing described above is an integral part of the personalised performance support provided by P1 Executive.

We maintain records of:

• when consent was given;
• the consent wording accepted;
• the Privacy Notice and Terms versions associated with that consent;
• whether consent was subsequently withdrawn.

Operating and protecting P1

We may process information where necessary for our legitimate interests in:

• securing P1 systems and accounts;
• preventing misuse or unauthorised access;
• maintaining audit and security records;
• diagnosing technical problems;
• improving the reliability of our service;
• managing our relationship with users;
• defending or establishing legal claims.

Where we rely on legitimate interests, we consider the impact on your rights and interests before doing so.

Legal and regulatory requirements

We may process information where necessary to:

• comply with applicable laws;
• respond to regulators or lawful authorities;
• meet accounting and tax obligations;
• investigate data protection or security incidents;
• establish, exercise or defend legal rights.

P1 Executive may use artificial intelligence and automated processing to help analyse relevant information and support the creation of personalised priorities, patterns or recommendations.

For example, AI may help consider:

• recent daily information;
• personal baselines;
• schedule context;
• existing Foundations;
• changes over time;
• previous priorities and responses.

We aim to minimise the information supplied to AI systems and only use information that is relevant to the task being performed.

P1 uses AI as part of its performance-support process. AI-generated outputs may be used to support draft recommendations, interpretation and prioritisation.

P1 Executive is not designed to make solely automated decisions that have legal or similarly significant effects on you.

P1 does not use Executive information through the app to make decisions about:

• your employment;
• recruitment;
• promotion;
• dismissal;
• insurance;
• credit;
• medical diagnosis;
• medical treatment.

AI outputs should not be treated as medical advice.

P1 Executive is designed as a private individual service.

Your P1 Executive information is not shared with your employer or another external organisation through your account.

We may share information with carefully selected service providers where this is necessary to operate P1.

These may include providers of:

• cloud infrastructure;
• database and authentication services;
• software hosting;
• artificial intelligence services;
• email and communications;
• security;
• technical monitoring and support.

These organisations may only process information for the purposes for which they have been engaged and subject to appropriate contractual and security requirements.

P1 currently uses technology infrastructure including Lovable and Supabase as part of the operation of its digital service.

We may also disclose information where:

• required by law;
• required by a court, regulator or competent authority;
• necessary to protect P1 or another person's legal rights;
• necessary to investigate fraud, misuse or a serious security issue;
• required as part of a legitimate corporate transaction, subject to appropriate safeguards.

We do not sell your personal data.

Some technology providers used by P1 may process or support personal information outside the United Kingdom.

Where personal information is transferred internationally, we take appropriate steps to ensure that the transfer complies with UK data protection law.

Depending on the destination and provider, these safeguards may include:

• UK adequacy regulations;
• recognised data-protection frameworks;
• the UK International Data Transfer Agreement;
• the UK Addendum to approved contractual clauses;
• other legally recognised safeguards.

We review international transfers as part of our supplier and data-protection processes.

We do not retain personal information for longer than reasonably necessary for the purpose for which it was collected.

The period depends on the nature of the information and why we hold it.

Our current approach includes:

P1 Executive account and performance history

Generally retained while your account remains active because longitudinal history forms part of the personalised P1 Executive service.

Account deletion

Privacy & Data offers a self-service control to permanently delete your Executive account and its associated P1 data. Contact us if you need help or have a separate request about information held outside that account.

Information contained in secure system backups may remain temporarily until those backups are overwritten through the normal backup lifecycle.

Security and audit records

Certain security, access and audit records may be retained for a limited period where necessary to protect P1 and its users.

Consent records

Consent history linked to the Executive account is removed when that account is deleted. Any separate retention requirement needs individual review.

Privacy requests and complaints

Account-linked privacy requests and complaints are removed with the Executive account. Contact us about a separate unresolved request or complaint before deletion if you need a copy.

Financial information

Information required for accounting, taxation or other legal purposes is retained for the period required by applicable law.

Website and commercial enquiries

Information provided through Request Access, Advisory, Speaking or other enquiries is retained only for as long as reasonably required to manage the enquiry and our relationship with you.

We periodically review information we hold and delete or anonymise information that is no longer required.

P1 takes appropriate technical and organisational measures to protect personal information.

These measures include controls such as:

• authenticated access;
• database access controls;
• row-level security;
• restricted administrative access;
• role-based permissions where applicable;
• audit logging;
• secure cloud infrastructure;
• access controls designed around least privilege;
• separation of user and administrative functionality;
• controls intended to prevent anonymous access to Executive information.

No internet-based service can guarantee absolute security. We continually review the safeguards appropriate to the nature of the information we process.

Under UK data protection law, you may have rights including the right to:

• be informed about how your personal data is used;
• request access to your personal data;
• request correction of inaccurate information;
• request deletion of your personal data in certain circumstances;
• request restriction of processing in certain circumstances;
• object to certain processing;
• receive certain personal data in a portable format;
• withdraw consent where processing relies on consent;
• raise a concern about how your information has been handled.

Not every right applies in every circumstance.

P1 Executive includes a Privacy & Data area where you can manage certain privacy choices and submit relevant requests.

You can also contact privacy@p1eleven.com.

We may need to verify your identity before responding to certain requests.

We will respond within the time periods required by applicable data protection law.

You may withdraw your explicit consent to the processing of health and wellbeing information through P1 Executive.

If you withdraw consent:

• P1 will record that consent has been withdrawn;
• P1 will stop collecting new health and wellbeing information through the relevant Executive functions;
• certain P1 Executive functionality may become unavailable;
• stored Apple Health summaries, health and wellbeing check-ins and onboarding answers, and derived P1 recommendations, plan history and performance insights are removed; independent account information remains until separately deleted.

You can download your data or delete your account and associated data in Privacy & Data. Apple Health permissions remain controlled by iOS.

Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

If you are concerned about how P1 has handled your personal information, you can raise a data protection complaint through the Privacy & Data section of P1 Executive or by contacting privacy@p1eleven.com.

We will acknowledge receipt of a data protection complaint within the period required by UK law, investigate it appropriately and communicate the outcome to you without unjustifiable or excessive delay.

You also have the right to raise concerns with the Information Commissioner's Office (ICO), the UK's independent data protection regulator.

You can complain to the ICO at any time. You do not need to contact P1 first, although we would welcome the opportunity to resolve your concern directly.

Our website and digital services may use cookies or similar technologies where necessary to:

• operate the website or service;
• maintain authentication and security;
• remember appropriate user preferences;
• understand how our services are used where permitted.

Where consent is legally required for a cookie or similar technology, we will request it before that technology is used.

Further information is provided in our Cookie Notice.

We keep marketing communications separate from the health and wellbeing consent required to provide P1 Executive.

We will not treat agreement to the P1 Executive Terms of Service or health and wellbeing processing as consent to receive optional marketing.

Where required, you can withdraw marketing permission at any time.

P1 Executive is designed for adult users.

It is not intended for children and we do not knowingly offer P1 Executive to children.

We may update this Privacy Notice as P1 ELEVEN develops or where legal or regulatory requirements change.

The current version and last-updated date will be displayed at the top of this Notice.

Where a change materially affects how we process information for which explicit consent is required, we will consider whether renewed consent is necessary before continuing that processing.

For privacy and data protection enquiries: privacy@p1eleven.com.

For general P1 ELEVEN enquiries: contact@p1eleven.com.

P1 ELEVEN LTD, 101 International House, King's Cross Road, London, WC1X 9LP, England.

Company number: 17321935