Privacy Policy
David Fleming / AMN Calibrate Ltd
Last updated: 13 July 2026
1. Who we are
This website and the services offered through it are operated by: AMN Calibrate Ltd, trading as David Fleming / TheDavidFleming.com
Company number: 15494246
Registered address: 1 Magpie Farm, Ashford Kent, England TN26 2BF, UK
Email: [email protected]
For the purposes of UK data protection law, AMN Calibrate Ltd is the data controller unless otherwise stated.
2. Scope of this policy
This Privacy Policy explains how we collect, use, share and protect personal data when you interact with:
- TheDavidFleming.com;
- RHM training programmes and live courses;
- The Frontier;
- Clarity Map;
- Clarity Snapshot;
- consultations, webinars and events;
- forms, email communications and payment pages;
- related websites, subdomains and online tools.
3. Personal data we may collect
We may collect:
- your name, email address, telephone number and contact details;
- information submitted through forms, applications and waitlists;
- information you provide during training, consultations or AI-based interactions;
- booking, order, payment and transaction information;
- communications between you and us;
- marketing preferences and consent records;
- technical information such as IP address, browser type, device information, referring URL and page activity;
- advertising identifiers, including Meta click and browser identifiers;
- information about registrations, checkout activity and purchases.
We do not intentionally collect special category data unless it is necessary for a clearly stated purpose and an appropriate lawful basis applies.
4. How we use personal data
We may use personal data to:
- provide training, products, consultations and AI-based tools;
- process bookings, applications, registrations and payments;
- administer RHM courses and related practitioner services;
- provide customer support;
- communicate service-related information;
- send marketing communications where permitted;
- improve our website, products, educational content and systems;
- measure website and campaign performance;
- create advertising and remarketing audiences;
- prevent fraud and protect the security of our services;
- comply with legal, accounting and regulatory obligations.
5. Lawful bases
Depending on the circumstances, we process personal data on the basis of:
- contract, where processing is necessary to provide a service or fulfil a purchase;
- consent, including for non-essential cookies, advertising technologies and certain marketing communications;
- legitimate interests, including operating, improving and protecting our services, where those interests are not overridden by your rights;
- legal obligation, where we must retain or disclose information to comply with applicable law.
Where consent is the lawful basis, you may withdraw it at any time.
6. Cookies and similar technologies
We use cookies and similar technologies to operate the website, remember preferences, analyse usage and, where you consent, measure advertising performance.
Non-essential advertising technologies are not activated until you provide consent through our cookie banner. You may reject non-essential cookies or change your preferences using the cookie settings available on the website.
Our cookie tools may record your consent decision, consent ID, date, time and selected cookie categories.
Tracking pixels, tags and scripts may be subject to the Privacy and Electronic Communications Regulations and UK GDPR requirements.
7. Meta Pixel and advertising measurement
With your consent, we use the Meta Pixel and related advertising services provided by:
Meta Platforms Ireland Limited
Merrion Road
Dublin 4
D04 X2K5
Ireland
The Meta Pixel helps us:
- understand how visitors interact with our websites;
- measure advertising performance;
- record events such as page visits, form submissions, registrations, checkout activity and purchases;
- create Custom Audiences for remarketing;
- create similar or Lookalike Audiences;
- avoid showing certain advertisements to people who have already registered or purchased.
Depending on your interaction with our services, information sent to Meta may include:
- pages viewed;
- form submissions and registrations;
- checkout and purchase events;
- transaction value and currency;
- product or service identifiers;
- IP address, browser and device information;
- Meta browser or click identifiers;
- hashed contact information where server-side conversion tracking is used.
We use one Meta Pixel across our services, with product-specific event information for The Frontier, RHM live training, Clarity Map and Clarity Snapshot.
Meta may process this information under its own privacy terms and may act as an independent controller for certain processing activities.
You may withdraw or change your advertising consent at any time through the cookie settings on our website.
8. AI-based tools
Our AI-based tools may process information you enter in order to generate a response, report, analysis or other output.
Depending on the tool, data may be processed by third-party AI and hosting providers acting on our behalf. We will provide additional product-specific information where the operation of a particular AI tool differs from this policy.
You should not submit confidential medical information, sensitive personal data or information about another person unless specifically requested and legally appropriate.
AI-generated outputs may be inaccurate and should not be treated as medical, psychological, legal or financial advice.
The current statement that AI data is “not stored or reused beyond system improvement” should be removed unless Dave and Awais can verify that this is technically true for every AI provider, database, log and product.
9. Payments and Merchant of Record services
Payments may be processed by Stripe or another payment or Merchant of Record provider.
These providers may process:
- billing details;
- transaction information;
- payment method information;
- fraud-prevention data;
- tax and invoicing information.
Where a Merchant of Record is used, that provider may act as an independent controller for parts of the payment, tax, fraud and compliance process. Stripe explains that a Merchant of Record may handle transaction data, personal information and purchase histories.
We do not normally receive or store full payment card details.
10. Service providers and data recipients
We may share personal data with trusted providers where necessary, including:
- Meta Platforms Ireland Limited — advertising measurement, conversion tracking, remarketing, Custom Audiences and Lookalike Audiences;
- GoHighLevel / LeadConnector — CRM, forms, websites, workflows and communications;
- CookieYes — cookie consent management and consent records;
- Stripe and relevant Merchant of Record providers — payment, fraud, tax and transaction processing;
- email and communications providers;
- website hosting, cloud infrastructure and security providers;
- AI technology providers used to operate Clarity Map, Clarity Snapshot or related tools;
- professional advisers, accountants and legal advisers;
- regulators, courts or public authorities where legally required.
We do not sell personal data.
11. International data transfers
Some service providers may process personal data outside the United Kingdom or European Economic Area.
Where required, we use appropriate safeguards, such as adequacy regulations, recognised data transfer frameworks or approved contractual clauses.
12. Data retention
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, tax, dispute-resolution and security requirements.
Retention periods may vary depending on the data, for example:
- enquiry and waitlist data: [insert period, e.g. 24 months];
- customer and transaction records: [insert period, commonly six years where required for accounting/tax];
- marketing records: until consent is withdrawn or the data is no longer required;
- consent records: for as long as reasonably necessary to demonstrate compliance;
- AI interaction data: according to the retention settings and operational requirements of the relevant product.
13. Marketing communications
We may send marketing communications where you have consented or where another lawful route applies.
You may unsubscribe at any time by using the unsubscribe link in an email or contacting us at:
[email protected]
Withdrawing marketing consent does not affect service-related communications that are necessary to fulfil a booking or contract.
14. Your rights
Depending on applicable law, you may have the right to:
- request access to your personal data;
- request correction of inaccurate data;
- request deletion of your data;
- request restriction of processing;
- object to certain processing;
- request data portability;
- withdraw consent;
- object to direct marketing;
- complain to a supervisory authority.
To exercise your rights, contact:
[email protected]
You also have the right to complain to the UK Information Commissioner’s Office.
15. Security
We use reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.
No internet-based service is completely secure, and we cannot guarantee absolute security.
16. Changes to this policy
We may update this Privacy Policy when our services, providers or legal obligations change.
The latest version will be published on this page with an updated revision date.
17. Contact
For privacy-related questions or requests:
Email: [email protected]
Controller: AMN Calibrate Ltd
Registered address: 1 Magpie Farm, Ashford Kent, England TN26 2BF, UK
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