Privacy and cookies
What we collect, why we collect it and what you can ask us to do about it. Written to be read, not to be survived.
Last updated 5 September 2026
Who you are dealing with
This website belongs to The Fray, the personal training practice of Claudio Fray in Amsterdam. When this policy says we or I, that is who it means. We decide why and how your personal data is used, which under the GDPR makes us the controller.
- The Fray, trading as Claudio Fray
- Elizabeth Cady Stantonplein 547, 1102 BL Amsterdam, Netherlands
- Chamber of Commerce 62734636
- VAT NL002481815B25
- mail@claudiofray.com
If anything here is unclear, or you want something done with your data, write to that address and Claudio will answer personally.
What we collect
We try to ask for as little as possible, and only for things we genuinely need.
- When you apply for personal training: your name, email, phone number, what you do for work, how you prefer to be contacted, your goals, your training experience, how comfortable you feel in a gym, what tends to get in your way, anything you tell us about injuries, and your general availability.
- When you ask for the free guide: your first name and your email address.
- When you become a client: the health and training information needed to coach you safely, such as injuries, pain, relevant medical conditions, medication where it matters, body composition readings, measurements and progress notes. This is sensitive data and we treat it that way.
- When you buy a programme: the order details. Payment card details go straight to our payment provider and never reach us.
- When you visit the site: technical and usage information such as your approximate location, device, browser, pages viewed and how you arrived. This only happens for analytics and marketing if you agree to it.
Why we use it, and the legal basis
Under the GDPR we need a lawful basis for everything we do with your data. Here is ours, in plain terms.
| What we do | Why | Legal basis |
|---|---|---|
| Read and answer your application | To judge whether coaching is a good fit and to arrange a conversation | Steps taken at your request before a contract |
| Send you the free guide and occasional emails about training | Because you asked for it | Your consent, which you can withdraw at any time |
| Coach you and keep your training records | To deliver the coaching you signed up for | Performance of our contract |
| Record health information about you as a client | So we can train you safely | Your explicit consent |
| Handle purchases, invoices and bookkeeping | To sell programmes and meet tax rules | Contract and legal obligation |
| Measure how the website is used | To understand what works and improve the site | Your consent through the cookie banner |
| Show and measure adverts | To reach people who might want coaching | Your consent through the cookie banner |
| Keep the site secure and working | To prevent abuse and fix faults | Our legitimate interest |
We do not sell your data, and we do not make automated decisions about you that have a legal or similarly significant effect.
Cookies and similar technology
Cookies are small files stored by your browser. Some are needed for the site to function. The rest only load if you accept them in the cookie banner, and nothing in the analytics or marketing categories runs before you do.
- Necessary: required for the site to load, to remember your cookie choice and to protect forms from abuse. These cannot be switched off.
- Analytics: helps us see which pages people read and where they lose interest, so we can make the site better.
- Marketing: lets us measure adverts and show them to people with similar interests.
You can change your mind whenever you like using the cookie settings link at the bottom of any page, and you can clear or block cookies in your browser settings at any time.
The tools we use
These are the outside services that process data for us. Each one only receives what it needs.
| Tool | What it does | Category |
|---|---|---|
| Resend | Sends the emails triggered by our forms, such as your application confirmation and the free guide, and holds the mailing list | Necessary |
| Vercel | Hosts the website and keeps it online and secure | Necessary |
| Google Analytics 4 | Counts visits and shows which pages are read, using aggregated reports | Analytics |
| Microsoft Clarity | Shows anonymised usage patterns such as scrolling and clicks, so we can spot what confuses people | Analytics |
| Meta Pixel | Measures whether adverts on Facebook and Instagram lead to applications, and builds audiences | Marketing |
| Stripe | Takes payment for programmes. Stripe receives your payment details directly and we never see your card number | Necessary for purchases |
| Skool | Delivers the online programmes you buy and holds your programme account | Necessary for purchases |
Who else sees your data
Your data is not sold, rented or traded. It is shared only with the providers listed above, who act on our instructions under a data processing agreement, and with our accountant or advisers where the law requires it.
Some of these companies are based in the United States. Where data leaves the European Economic Area we rely on the safeguards the GDPR allows, such as the EU US Data Privacy Framework or the European Commission's standard contractual clauses. Our email sending runs in the European Union.
How long we keep it
- Applications that do not lead to coaching: up to one year, in case you come back to us.
- Client records, including training and health notes: five years after our work together ends.
- Invoices and payment records: seven years, because Dutch tax law requires it.
- Mailing list: until you unsubscribe, which you can do from any email we send.
- Analytics and advertising data: according to each provider's own retention window, which is typically between two and twenty six months.
When a period ends we delete the data or make it anonymous so it can no longer be traced back to you.
Your rights
The GDPR gives you real control over your data. You can ask us to do any of the following, free of charge.
- See a copy of the data we hold about you.
- Correct anything that is wrong or incomplete.
- Delete your data, where we have no obligation to keep it.
- Limit what we do with it while a question is being sorted out.
- Receive your data in a portable format, or have it sent to someone else.
- Object to us using it, including for direct marketing.
- Withdraw consent at any time, which does not affect anything done before you withdrew it.
Write to mail@claudiofray.com and we will answer within one month. We may ask you to confirm who you are first, so that nobody else can request your data. If you are not happy with how we handle it, you can complain to the Dutch data protection authority, the Autoriteit Persoonsgegevens, at autoriteitpersoonsgegevens.nl.
How we protect it
The site runs over an encrypted connection, access to client records is limited to Claudio, and the providers we use are chosen partly for their security record. Health information is kept separate from marketing data and is never used to target advertising.
No system is perfect. If a breach ever affects your data and creates a real risk to you, we will tell you and the regulator as the law requires.
Changes to this policy
When the way we work changes, this page changes with it. The date at the top always tells you which version you are reading. If a change materially affects you, we will say so clearly rather than quietly editing the page.
Contact
Questions about your data, or about anything on this page, go straight to Claudio at mail@claudiofray.com. You are also welcome to ask before you apply, if you would rather know first.