Under revision as of Friday 9 October 2026. We are rewriting this policy in full. This interim version describes how we handle your information today.

Who we are

Rethink Drink Ltd ("Rethink Drink", "we", "us") runs rethinkdrink.ie. We are a coaching company built around The Sinclair Method. We are registered in England and Wales, company number 14619896, at Unit 11a Bow Court, Fletchworth Gate, Coventry CV5 6SP, United Kingdom.

We are registered with the UK Information Commissioner's Office (ICO), registration number ZB760472.

We are the controller of the personal information described in this policy. For anything about your data, email [email protected] and put "Privacy" in the subject line.

Because we offer our services to people in Ireland, the EU General Data Protection Regulation (GDPR) applies to the information we hold about you. We are appointing a representative in the EU under Article 27 GDPR, and we will add their details here once that appointment is in place.

What we collect

• Contact details: your name, email address and phone number, when you send an enquiry, book a call or sign up.
• What you tell us about your drinking and your health: in forms, on calls and in messages, including the medical questionnaire you complete before a doctor's consultation.
• Booking and programme details: the calls you book, the programme you join and your progress through it.
• Payment information: handled securely by our payment provider. We never see or store your full card number.
• Calls and messages: phone calls with us may be recorded, and you are told at the start of the call. Coaching calls are recorded and transcribed so you and your coach can refer back to them; tell your coach if you would rather a call was not recorded. We also keep the emails and messages you send us.
• Website information: if you agree to cookies, information about how you use this site.

Why we use it, and our legal basis

• To answer your enquiries and arrange calls: because you have asked us to (steps before a contract, and our legitimate interest in replying to you).
• To provide your programme and take payment: to perform our contract with you.
• Health information: information about your drinking and health is special category data. We only use it with your explicit consent (Article 9(2)(a) GDPR), and only to coach you and, where you choose the medication route, to let a doctor decide whether it is right for you. You can withdraw that consent at any time; we will then stop using the information, although we may not be able to continue coaching you.
• Marketing emails: only if you have agreed to receive them. Every email has an unsubscribe link.
• Keeping records the law requires, such as accounting records: to meet our legal obligations.

We do not make decisions about you by automated means alone.

Who we share it with

The doctor. If you choose the medication route, your medical questionnaire and booking details go to our clinical lead based in Ireland, an independent GP and addiction medicine specialist who decides whether to prescribe. The doctor keeps their own clinical record under their own professional and legal duties.

Your pharmacy. If a prescription is issued, it is sent to the pharmacy you choose. The pharmacy handles it under its own duties. You pay the pharmacy directly for any medication.

Selected partners who help us run our service. We use carefully chosen providers for:

• client management, bookings and our members' area;
• communication tools, including email, phone, messaging and video calls, and call recording;
• secure payments;
• secure storage of our records;
• AI tools that help our team with admin;
• website hosting, technical support and, with your consent, website analytics.

They can only use your information to provide their service to us, under written agreements that require them to keep it secure and confidential.

We do not sell your information, and we do not use what you tell us about your health to target advertising at you.

We may share information if the law requires it, or where there is a genuine risk to someone's life.

Where your information is held

We are based in the United Kingdom. The European Commission has decided that the UK protects personal data to an adequate standard, so information can pass between Ireland and the UK without extra safeguards. Some of our partners store information outside the UK and the EU. Where they do, it is protected by the safeguards EU law requires, such as the European Commission's standard contractual clauses.

How long we keep it

We are finalising our retention schedule as part of this revision. These are the periods we are putting in place:

• Enquiries that do not lead to a programme: 12 months.
• Your client and coaching record: while you are a client, then 6 years.
• Call recordings: 12 months from the call.
• Payment and accounting records: 6 years.
• Marketing permissions: until you unsubscribe.

Cookies

We use a small number of cookies.

• Essential cookies make the site work, for example forms, bookings and payments. They are always on.
• Analytics cookies help us understand how the site is used so we can improve it. They only run if you choose Accept.

Your choice is remembered so we do not ask on every page, and you can change it at any time with the small cookie button at the bottom left of every page.

Your rights

You have the right to ask for a copy of the information we hold about you, to have it corrected, to have it deleted, to restrict or object to how we use it, to take it with you in a usable format, and to withdraw any consent you have given. Email [email protected]. We will reply within one month.

If you are unhappy with how we have handled your information, please tell us first so we can put it right. You can also complain to the Data Protection Commission in Ireland (dataprotection.ie), or to the UK Information Commissioner's Office (ico.org.uk).

Age

Our services are for adults aged 18 and over.

Changes to this policy

This policy is being revised. When the full version is published, we will update this page and the date at the top.