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Privacy

Privacy Policy

How I collect, use and protect personal information, whether you are visiting this site, on my newsletter, working with me, or you have received an email from me at work. It is written to be read, not to bury you.

Last updated: 15 August 2026

On this page

  1. Who I am
  2. Visiting this website
  3. Enquiries and bookings
  4. The newsletter and the free guide
  5. Clients and programme participants
  6. Business outreach emails
  7. Who else processes your information
  8. How long I keep information
  9. Your rights
  10. Changes to this policy

1. Who I am

The data controller is Primordial Health Ltd (company number 13645120), a company registered in England and Wales, trading as Primordial Sleep Lab. I am Carolina Ramuski, its founder, a sleep and circadian consultant working with business owners, executives and senior professionals on sleep, energy and recovery.

Email: carolina@primordialhealth.co.uk

Postal address: Primordial Health Ltd, 3 Yeovil House, Andover Road, London, N7 7HN, United Kingdom

This policy covers everything I do with personal information: this website, enquiries and bookings, the newsletter and free guide, client work, and business outreach emails. If you received an email from me at your work address and want the part that applies to you, go straight to business outreach emails.

2. Visiting this website

This site is deliberately simple. It does not run advertising trackers, and it does not set cookies of its own.

  • Hosting. The site is hosted by Netlify, which records standard server information such as your IP address and browser type in order to serve the pages and keep the service secure.
  • Fonts. The site loads typefaces from Google Fonts, which means your browser contacts Google's servers and Google receives your IP address as part of that request.
  • Links out. Buttons that take you to Calendly, Kit, Skool, Hotmart or Stripe hand you over to those companies, and their own privacy policies apply once you are there.

My lawful basis for this limited processing is legitimate interests, specifically running a working, secure website.

3. Enquiries and bookings

If you email me, book a call through Calendly, or enquire about a workshop, I hold what you send me: your name, your email address, anything you choose to tell me about your situation, and the details of the booking.

I use this to reply to you, hold the conversation, and arrange the call. My lawful basis is legitimate interests in responding to someone who has contacted me, and where you are moving towards working with me, steps taken at your request before entering a contract.

Please do not send detailed medical information in an initial enquiry. If it is relevant, we will collect it properly once you are a client.

4. The newsletter and the free guide

If you request the free guide or subscribe to my newsletter, I hold your name and email address and a record of what you have opened or clicked. This runs on Kit.

My lawful basis is consent. You gave it by signing up, and you can withdraw it at any time using the unsubscribe link at the bottom of every email, or by emailing me. Withdrawing consent does not affect anything sent before you withdrew it.

I do not sell your details, and I do not share them for anyone else's marketing.

5. Clients and programme participants

If you work with me in 1:1 consulting, the course, a cohort or a corporate workshop, I hold considerably more, because the work requires it.

What I hold

  • Your contact and billing details, and your payment record through Stripe or Hotmart
  • Intake forms, questionnaires and assessments
  • Sleep and lifestyle information, including sleep diaries, wearable and app data you choose to share, and any night video observations you record and send me
  • Health information you tell me, which can include medical history, diagnoses, medication, and symptoms
  • Session notes, and recordings or transcripts of calls where these are made

Health information, and why it is treated differently

Health information is special category data under UK data protection law and carries extra protection. I process it on the basis of your explicit consent, which I ask for at the start of our work and which you can withdraw at any time. My lawful basis for the rest is performance of our contract.

You are never obliged to tell me something. Withholding relevant health information may limit what I can safely help with, and I will say so if that happens.

Call recordings

I use Fathom to record and transcribe calls so that I can be present in the conversation rather than writing throughout it. You will be told when a call is being recorded and you can ask me not to record, or to delete a recording, at any time.

Testimonials and case studies

I only use your words, image or results publicly if you have specifically agreed to it. That is a separate decision from the work itself, it is always asked for after the fact, and saying no changes nothing about the service you receive. You can withdraw permission later and I will remove the material from anything I control.

I am a sleep and circadian consultant and naturopathic nutritionist, not a doctor. I do not diagnose or treat medical conditions, and where something needs medical assessment I will tell you and point you to appropriate care rather than work around it.

If you received an email from me at work

6. Business outreach emails

This section explains what I hold about you, where it came from, why I contacted you, and how to make it stop.

What I hold, and where it came from

If I have contacted you, I hold some or all of the following: your name, your job title, your employer's name and approximate size, your business email address, your country or city, and a link to your public LinkedIn profile.

Your professional details came from publicly available professional sources, including your public LinkedIn profile and your company's website. I gathered these using Apify, a data collection platform.

Your business email address was usually not taken from a public listing. It was derived from your name and your employer's email domain, then checked for validity using Saleshandy's email verification service. That means the address I used may never have appeared publicly anywhere, and you are entitled to know that.

I hold no health information about you and no special category data. Nothing in my emails should be read as a claim that I know anything about your health or how you sleep.

Why I contacted you, and my lawful basis

I contact selected business owners and senior decision-makers whose roles suggest my work may be genuinely relevant to them.

My lawful basis is legitimate interests. I have a legitimate interest in telling relevant businesses about my services, I use only professional information relating to your working role, and I balance that against your interests by keeping contact minimal, making it effortless to opt out, and honouring every objection permanently. I have carried out and recorded a legitimate interests assessment for this activity, and you can ask me for a summary of it.

Cold email is directed only at corporate subscribers, meaning limited companies, LLPs and other bodies with separate legal personality. I do not send cold marketing email to sole traders or ordinary partnerships.

What I do with it

  • Send you up to four emails introducing my work, after which I stop contacting you
  • Keep a record of who I have contacted, so I do not approach you again by mistake in a later campaign
  • If you ask me not to contact you, keep your details on a suppression list, which is the minimum record needed to guarantee I never email you again

I do not sell your information, share it for anyone else's marketing, or add you to my newsletter without your explicit consent.

How to make it stop

Reply "no thanks" to any email, or write to carolina@primordialhealth.co.uk. I honour objections immediately and permanently, and you do not have to give a reason.

7. Who else processes your information

I use a small number of service providers to run my business, each acting under contract as a data processor:

  • Netlify, website hosting
  • Google Workspace, email and business documents
  • Kit, newsletter and the free guide
  • Calendly, scheduling calls
  • Stripe and Hotmart, payments and course purchases
  • Skool, the course and community platform
  • Fathom, call recording and transcription
  • Apify, gathering professional profile information from publicly available sources for business outreach
  • Saleshandy, email verification, sending and reply management for business outreach

Information leaving the United Kingdom

Several of these providers are based outside the United Kingdom, or process data outside it. Where that happens I rely on the safeguards recognised under UK data protection law, which are the UK Extension to the EU-US Data Privacy Framework where the provider is certified under it, and Standard Contractual Clauses with the UK Addendum or an International Data Transfer Agreement where it is not.

For the providers involved in business outreach and in this website, the position at the time of writing is:

Apify Technologies s.r.o.
Established in the Czech Republic. Where it transfers data onward, its data processing addendum applies the EU Standard Contractual Clauses together with the UK Addendum.
Saleshandy (Ikigai Infotech LLP)
Based in India, with the service hosted in the United States. It states that transfers outside the UK and EEA are protected by Standard Contractual Clauses and by adequacy decisions where available.
Google LLC
Processes data in the United States. It relies on the EU-US Data Privacy Framework including its UK Extension, and on Standard Contractual Clauses where required.
Netlify, Inc.
Based in the United States. It is certified under the EU-US Data Privacy Framework and its UK Extension, and uses Standard Contractual Clauses where required.
Kit, Inc.
Based in the United States. It is certified under the EU-US Data Privacy Framework and its UK Extension.
Calendly, Stripe, Hotmart, Skool and Fathom
Based outside the United Kingdom and engaged under their standard data processing terms, which include the transfer safeguards described above.

If you want the current detail for any specific provider, ask me and I will tell you.

8. How long I keep information

  • Business outreach, no reply: deleted from active outreach records no later than 12 months after the campaign ends
  • Anyone who objects or opts out: name and email address kept on the suppression list indefinitely, because that is what guarantees the objection is honoured
  • Newsletter subscribers: kept until you unsubscribe, and removed from active mailing shortly afterwards
  • Enquiries that go nowhere: kept for up to 12 months, then deleted
  • Clients: kept for the duration of the work and then for as long as I need it for professional and legal reasons, including the six years of financial records that UK tax rules require

9. Your rights

You have the right to:

  • Object to direct marketing at any time, which I always honour, immediately and permanently
  • Ask what I hold about you, which is a subject access request
  • Ask me to correct anything that is wrong
  • Ask me to erase your information where the law applies. If you object to direct marketing, I will retain only the minimum suppression record needed to ensure that I do not contact you again.
  • Ask me to restrict how I use it, or to provide it in a portable form
  • Withdraw consent at any time where I relied on consent, including for health information and the newsletter

To use any of these, email carolina@primordialhealth.co.uk. None of these rights costs anything, none of them requires a form, and I will respond within one month.

If you think I have handled your information improperly, please tell me first so I can put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.

10. Changes to this policy

If I change how I handle personal information, I will update this page and change the date at the top. If the change is significant and affects people already on my list, I will tell them directly rather than relying on them noticing.

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