Privacy policy.

Last updated: [30/04/2026]

Prime Human Performance is operated by PrimeMD Lda (“we,” “us,” “our”).

We are committed to protecting your privacy and handling your personal data responsibly. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and your rights under applicable data protection laws, including the General Data Protection Regulation.

This Privacy Policy applies to the website primehumanperformance.com, including application forms, contact forms, and related communications.

1. Who is responsible for your data

The data controller is:

PrimeMD Lda
Operating as Prime Human Performance
Portugal
Email: md@primehumanperformance.com

For any privacy-related questions or requests, contact us at:

md@primehumanperformance.com

2. Personal data we collect

We may collect personal data that you voluntarily provide or authorize us to access, including:

  • Name

  • Email address

  • Phone number or WhatsApp contact

  • Location

  • Professional role

  • Company or organization

  • Information submitted through application, contact, registration, or appointment forms

  • Messages or communications you send to us

  • Marketing preferences, including newsletter sign-up status

  • Payment-related data where payments are processed online

  • Health, lifestyle, performance, sleep, recovery, stress, training, and goal-related information you choose to share

  • Wearable or connected-device data where you explicitly authorize an integration

Where available and authorized by you, wearable data may include information such as heart rate, heart rate variability, sleep, activity, workout history, steps, recovery metrics, or similar health and performance data.

We may also collect basic technical information when you use the website, such as device type, browser type, pages visited, and general usage data, depending on the website tools and analytics services enabled.

3. How we collect personal data

We may collect personal data when you:

  • Submit an application form

  • Contact us by email or through the website

  • Register for an account, if account functionality is available

  • Book an appointment or consultation

  • Make a payment, where payment functionality is enabled

  • Subscribe to updates or newsletters

  • Authorize a wearable or third-party data integration

  • Interact with the website or any client dashboard, where available

4. Why we use your personal data

We use your personal data to:

  • Review applications for the Prime Founder Program or other Prime services

  • Understand whether a program may be appropriate for your situation

  • Contact you about your application or enquiry

  • Schedule private consultations or appointments

  • Manage user accounts or client dashboards, where available

  • Process payments and send confirmations, receipts, or reminders

  • Provide health, performance, and medical support where a formal service relationship exists

  • Review authorized wearable or health-performance data where relevant to your program

  • Send newsletters or marketing communications where you have opted in

  • Respond to your messages or requests

  • Improve the website, application process, client experience, and services

  • Comply with legal, regulatory, administrative, or professional obligations

We do not sell or rent your personal data.

5. Legal basis for processing

Depending on the context, we may process your personal data based on:

  • Your consent, when you submit information through a form, authorize an integration, or subscribe to communications

  • Steps taken at your request before entering into a potential service relationship

  • The performance of a contract, where you become a client or patient

  • Our legitimate interests, such as reviewing applications, responding to enquiries, managing communications, and improving our services

  • Legal, regulatory, administrative, or professional obligations where applicable

  • Healthcare or medical-related obligations where a formal clinical relationship exists

6. Health-related information

Some information submitted through the website, application forms, consultations, wearable integrations, or client dashboards may relate to health, lifestyle, symptoms, sleep, recovery, stress, performance, training, or medical history.

Please only share information that you are comfortable submitting through the relevant form or platform.

Submitting an application does not create a doctor-patient relationship. A clinical relationship, if appropriate, only begins after formal acceptance, consultation, consent, and agreement to the relevant terms.

7. Wearable and connected-device data

Where wearable integrations are available, we only access connected-device data after you explicitly authorize the connection.

This may include data from services such as Garmin Connect or other wearable platforms, depending on the integrations available.

Such data may include metrics such as heart rate, heart rate variability, sleep, steps, activity, workouts, or other health and performance indicators.

You may revoke access through the relevant wearable platform settings or through our systems where such functionality is available.

Wearable data is used to support health and performance evaluation, monitoring, and personalization where relevant. It is not used as a standalone diagnostic tool.

8. Payment data

Where online payments are enabled, payment information may be processed by a third-party payment provider such as Stripe.

Prime Human Performance does not store full payment card details on its own systems.

Payment data may be used to process transactions, issue receipts, manage subscriptions or payment plans where applicable, and comply with accounting, tax, and legal obligations.

9. Third-party services and processors

We may use trusted third-party service providers to operate the website, manage applications, schedule consultations, process payments, communicate with you, store information, or provide connected services.

These may include, where applicable:

  • Squarespace, for website hosting

  • Typeform, for application or intake forms

  • Google Workspace, for email, document management, and administration

  • Calendly, for scheduling consultations

  • Stripe, for payment processing

  • Wearable platforms such as Garmin Connect, where integrations are authorized

  • Other software providers used to operate Prime Human Performance services

These providers may process personal data on our behalf according to their own terms, privacy policies, and applicable data protection obligations.

Where required, we use appropriate contractual and organizational safeguards with service providers.

10. Sharing and disclosure

We do not sell or rent your personal data.

We may share personal data only where necessary to:

  • Operate the website and related services

  • Review applications and communicate with applicants

  • Schedule appointments or consultations

  • Process payments

  • Provide services to clients or patients

  • Store and manage records securely

  • Comply with legal, regulatory, administrative, accounting, tax, or professional obligations

  • Protect our rights, users, clients, patients, or systems

Access to personal data is limited to those who need it for legitimate operational, clinical, administrative, or legal purposes.

11. International transfers

Some third-party service providers may process or store data outside Portugal or the European Economic Area.

Where this happens, we rely on appropriate safeguards where required by applicable data protection law, such as adequacy decisions, Standard Contractual Clauses, or other GDPR-approved mechanisms.

12. Data retention

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy, including reviewing applications, communicating with you, providing services, managing records, and complying with legal, regulatory, administrative, tax, accounting, or professional obligations.

If your application does not proceed, we may retain the information for a reasonable period unless you request deletion, subject to legal or legitimate record-keeping needs.

If you become a client or patient, different retention periods may apply to clinical, administrative, payment, or legal records. Clinical and healthcare-related records may need to be retained for longer periods in accordance with applicable Portuguese healthcare, professional, legal, or regulatory requirements.

13. Security measures

We implement reasonable technical and organizational measures to protect personal data against unauthorized access, misuse, loss, alteration, or disclosure.

These measures may include access controls, secure storage, limited access permissions, use of trusted service providers, and internal procedures designed to protect personal data.

However, no online system can be guaranteed to be completely secure.

14. Your rights

Depending on the circumstances and applicable law, 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

  • Request data portability

  • Withdraw consent where processing is based on consent

  • Lodge a complaint with a supervisory authority

To exercise your rights, contact:

md@primehumanperformance.com

In Portugal, the relevant supervisory authority is the Comissão Nacional de Proteção de Dados — CNPD.

15. Marketing communications

If you subscribe to newsletters, updates, or other marketing communications, we may use your contact details to send you relevant information about Prime Human Performance, programs, articles, events, or services.

You can unsubscribe or opt out at any time using the unsubscribe link in the communication or by contacting us at:

md@primehumanperformance.com

16. Cookies and analytics

This website may use cookies or similar technologies to support website functionality, improve user experience, understand website usage, and support analytics or marketing where enabled.

Where required, you may be asked to accept or manage cookies through the website’s cookie settings.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised “Last updated” date.

18. Contact

For privacy questions or requests, contact:

md@primehumanperformance.com