Master Legal Pack

Effective Date: 13 August 2025
 Company: 101 Life Ltd (Company No. 15015466)
 Trading As: Life 101 / Fasting 101 / Limitless
 Registered Office: 27 Cottages Road, Seaham, County Durham, SR7 7RL, United Kingdom
 Contact Email: [email protected]
 Websites & Subdomains Covered:

Table of Contents

    1. Privacy Policy
    2. Website Terms & Conditions
    3. Service Terms & Conditions (Coaching Agreement)
    4. Health Disclaimer
    5. Coaching Data & AI Consent Agreement
    6. Cookie Policy (GDPR/PECR‑compliant)
    7. Acceptable Use Policy
    8. Accessibility Statement
    9. End User License Agreement (EULA)
    10. Content Release Consent
    11. Annex
      1. Annex A. Sub‑processors & Key Partne
      2. Annex B. Data Retention Schedule
      3. Annex C. Definitions

1) Privacy Policy

1.1 Who we are

“101 Life Ltd”, trading as Life 101, Fasting 101, and Limitless (“we”, “us”, “our”), provides web and mobile software, coaching programs, and related services (together, the “Services”). We are the data controller for personal data processed via our websites, subdomains (including limitless.life101.app), apps, and programs.

1.2 Scope

This Privacy Policy applies to your use of our websites, subdomains, web and mobile apps, coaching programs, messaging groups, email communications, support, and any other touchpoints we operate globally. We respect local privacy rights for users in different countries (e.g., UK/EU, US/California) as outlined below.

1.3 What we collect

  • Personal Identifiers: name, email, phone number, handles/usernames.
  • Account & Technical Data: account credentials, device/browser info, IP address, usage logs, cookie identifiers, crash/error diagnostics.
  • Lifestyle & Health Data (voluntary): weight, height, body composition, fasting and eating windows, training logs, sleep, energy/mood/stress/productivity scores, goals, notes and reflections, AI‑generated reports, photos/videos/audio you upload for progress or form checks.
  • Demographics (optional): age, gender, ethnicity.
  • Payment Data: handled by third‑party processors (e.g., Stripe). We do not store full card details.
  • Communications: messages or voice notes sent via in‑app chat, WhatsApp groups, email, Zoom/Slack or similar platforms used for coaching and support.
  • Public/UGC: testimonials, forum posts, or shared content you choose to make public.

1.4 Sources of data

We collect data directly from you, from your use of our Services (including cookies/SDKs), and—where you authorize—from integrations (e.g., wearables, Apple Health/HealthKit, Google Fit) and community/messaging platforms you join for program participation.

1.5 Special Category Data

Where you choose to submit health‑related information (e.g., weight, body composition, fasting logs), we process it under explicit consent for coaching, analytics, and personalized guidance. You can withdraw consent at any time (see Rights below).

1.6 How we use your data

  • Provide, personalize, and improve our Services and coaching.
  • Generate insights, reports, trends, and progress tracking for you.
  • Operate communities, support, and customer service.
  • Send product updates, educational content, and marketing (opt‑out available).
  • Protect our users and Services (fraud/security/abuse prevention).
  • Comply with legal obligations and enforce our terms.

1.7 Lawful bases

Depending on the context: consent, contract, legitimate interests (e.g., service improvement, security), legal obligation, and—if needed—vital interests. For special‑category data (health), we rely on explicit consent.

1.8 AI and automated analysis

We use AI/ML tools—including integrations with providers such as OpenAI—to analyze check‑ins, identify patterns, and generate personalized insights and reports.
 We anonymize or pseudonymize inputs sent to AI tools and avoid sending direct identifiers (e.g., name, email). Do not input sensitive medical diagnoses, financial data, or passwords into free‑text fields. AI outputs support coaching but do not replace professional medical or mental health advice.

1.9 Marketing & communications

We may contact you about features, content, offers, or programs. You can unsubscribe via email footer links or by contacting us. For SMS/WhatsApp, you can reply STOP or use platform controls.

1.10 Sharing your data

We do not sell your data. We share data with trusted processors who help us run the Services (hosting, analytics, payments, email/messaging). We may disclose data when required by law, to protect users and the platform, or as part of mergers/acquisitions.

1.11 International transfers

Where data is transferred outside the UK/EEA (for example to service providers in the US), we use appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) and/or the UK Addendum to EU Standard Contractual Clauses, plus technical and organizational measures.

1.12 Security

We use encryption in transit and at rest (where supported), secure hosting (e.g., Google Cloud, BigQuery), Wordfence/WAF and SSL for sites, access controls, monitoring, and regular reviews. No system is 100% secure, but we work to protect your information continuously.

1.13 Retention

We keep personal data for as long as needed to provide the Services, meet legal/tax requirements, resolve disputes, and enforce agreements. See Annex B for typical retention periods.

1.14 Your rights

  • UK/EU/EEA (UK GDPR/GDPR): access, rectification, erasure, restriction, portability, objection, and withdraw consent.
  • California (CCPA/CPRA): know/access, delete, correct, opt‑out of sale/sharing (we don’t sell), limit use of sensitive data.
  • Other regions: we honor local rights where applicable.
     Contact: [email protected]. We may need to verify your identity.

1.15 Children’s privacy

The Services are not intended for under‑13s. If you are under 16 in the EEA/UK, you should only use the Services with parental consent. We will delete children’s data if discovered.

1.16 Cookies & tracking

See our Cookie Policy below for categories, purposes, and preference management.

1.17 Third‑party links & platforms

We may link to or integrate with third‑party services (e.g., WhatsApp, Zoom, Instagram). Their privacy practices are governed by their own policies.

1.18 Changes to this policy

We will post updates here and may notify you by email or in‑app notice when changes are material.

1.19 Contact

Data requests and privacy questions: [email protected]
 Postal: 27 Cottages Road, Seaham, County Durham, SR7 7RL, UK

2) Website Terms & Conditions

2.1 Agreement to terms

By accessing or using our websites, subdomains (including limitless.life101.app), or apps, you agree to these Terms. If you do not agree, do not use the Services.

2.2 Accounts

You must provide accurate information, keep credentials secure, and notify us of unauthorized use. We may suspend or terminate accounts that breach these Terms.

2.3 Intellectual property

All content, code, designs, training materials, recipes, data models, and trademarks are owned by or licensed to 101 Life Ltd. You receive a limited, revocable, non‑transferable right to access the Services for personal use. You may not copy, distribute, modify, reverse‑engineer, or create derivative works without our written permission.

2.4 User content

If you upload content, you retain ownership but grant us a worldwide, royalty‑free license to host, store, reproduce, and display it to operate the Services. You warrant you have rights to submit it and that it does not infringe others’ rights.

2.5 Prohibited conduct

You will not:

  • Use the Services unlawfully or for illegal content.
  • Harass, abuse, or harm others; incite violence; post defamatory, obscene, or hateful material.
  • Attempt to access others’ data or bypass security.
  • Interfere with or disrupt the Services or servers.
  • Use bots/scrapers without consent.

2.6 Third‑party links

We are not responsible for external sites or resources.

2.7 Disclaimers

The Services are provided “as is” and “as available.” We do not guarantee specific results, availability, or error‑free operation.

2.8 Limitation of liability

To the maximum extent permitted by law, we are not liable for indirect, incidental, special, punitive, or consequential damages. Our aggregate liability for claims relating to the Services is limited to the amounts you paid to us in the 12 months preceding the claim (or £100 if none).

2.9 Indemnity

You agree to indemnify us against claims arising from your breach of these Terms or misuse of the Services.

2.10 Termination

We may suspend or terminate access for any breach. You may stop using the Services at any time.

2.11 Governing law & jurisdiction

These Terms are governed by the laws of England and Wales. Non‑exclusive jurisdiction applies to the courts of England and Wales. If you reside outside the UK, you retain any non‑waivable consumer rights under your local law.

2.12 Changes to terms

We may update these Terms; material changes will be notified via the site/app.

3) Service Terms & Conditions (Coaching Agreement)

3.1 Services

We provide coaching, courses, analytics, and tools as described at purchase/onboarding. Delivery may include live calls, group messaging, in‑app content, and personalized feedback.

3.2 Health & suitability

Coaching is educational and informational. It is not medical care. You must consult a qualified clinician before making changes to fasting, nutrition, training, or supplementation, particularly if you have existing conditions, are pregnant/breastfeeding, or take medication.

3.3 Client responsibilities

  • Provide accurate information in onboarding/check‑ins.
  • Follow safety instructions and train responsibly.
  • Respect group rules and confidentiality.
  • Use the app/platforms as intended.
  • Do not share your license or materials externally.

3.4 Coaching deliverables

Deliverables vary by program (e.g., number of sessions, response windows, community access). We aim to deliver within published timelines, but timing can vary based on your participation and data completeness.

3.5 Payments, renewals & refunds

Fees are due upfront unless specified. Subscriptions renew automatically until cancelled. Refunds follow the specific offer terms at purchase. Chargebacks for valid services may be disputed; unpaid balances may suspend access.

3.6 Rescheduling & cancellations

Please give reasonable notice to reschedule 1:1s. Missed sessions without notice may be forfeited per program rules.

3.7 Results disclaimer

Results vary by individual (genetics, adherence, context). We do not guarantee specific outcomes.

3.8 IP & license

All program materials, templates, prompts, and software remain our IP. You receive a personal, non‑transferable license for your own use during your program term.

3.9 Confidentiality

We treat non‑public client information as confidential and use it only to deliver Services, except where disclosure is required by law or safety concerns.

3.10 Data & AI

We process your personal data under our Privacy Policy and AI Consent. We may use AI tools to analyze anonymized program inputs and generate insights.

3.11 Term & termination

Your program term starts on purchase/activation. We may end access for breach, safety, or non‑payment. Sections on IP, confidentiality, limitations, and dispute resolution survive termination.

3.12 Consumer rights (UK/EU)

If you are a consumer purchasing online, you may have a 14‑day cooling‑off period unless you ask us to start digital content/services immediately, in which case you acknowledge the cooling‑off right may be lost once full performance begins.

3.13 Limitation of liability

Our aggregate liability under this Coaching Agreement is limited to the fees paid in the 12 months before the claim (or £100 if none), except where not permitted by law (e.g., death/personal injury caused by negligence, fraud).

3.14 Governing law & jurisdiction

England and Wales law; non‑exclusive jurisdiction in England and Wales; non‑waivable local consumer rights preserved.

4) Health Disclaimer

Effective Date: July 11, 2025
 Company: 101 Life Ltd (Company No. 15015466)
 Trading As: Life 101 / Fasting 101
 Registered Office: 27 Cottages Road, Seaham, County Durham, SR7 7RL
 Contact Email: [email protected]

General Disclaimer

The information, coaching, and content provided through Life 101 and Fasting 101—including all programs, applications, websites, emails, messages, calls, and group sessions—is for educational and informational purposes only.
 It is not intended as medical advice, diagnosis, or treatment and must not be interpreted as such.

Not a Medical Provider

Life 101 is not a licensed healthcare provider. Jason Gutsell and affiliated coaches are not acting in the capacity of doctors, registered dietitians, psychologists, or mental health professionals.
 Always consult with your physician or other qualified healthcare provider before making any changes to your diet, fasting routine, exercise habits, supplementation, or overall health practices—especially if you:

  • Are pregnant or breastfeeding
  • Have any medical condition
  • Are taking medication
  • Have a history of eating disorders or mental health concerns

Voluntary Participation and Personal Responsibility

By participating in any Life 101 or Fasting 101 service or program, you do so voluntarily and at your own risk. You accept full responsibility for your decisions, health, and outcomes that result from applying the information or recommendations provided.
 You should never implement any strategy that you feel physically, emotionally, or mentally uncomfortable with.

Results May Vary

Any examples, testimonials, or case studies presented on our platform or marketing materials are illustrative only. Results are not guaranteed and may vary based on:

  • Genetics
  • Lifestyle factors
  • Consistency of application
  • Medical history
  • Individual commitment

Fasting, Training & Nutrition Risk Acknowledgement

Extended fasting, calorie restriction, or intense physical training can carry risks. You should never begin such protocols without first consulting a healthcare professional, particularly if:

  • You have diabetes or blood sugar issues
  • You are underweight or have a history of disordered eating
  • You experience dizziness, fainting, or fatigue
  • You have cardiovascular, endocrine, or gastrointestinal conditions

Use of AI Tools and Generated Reports

Some feedback or reports you receive from our platform may be generated using artificial intelligence and data analytics tools. These tools provide informational insights only and must not replace the advice of a qualified medical or mental health professional.

Emergency Situations

If you experience severe physical or mental health symptoms at any time—including but not limited to disorientation, persistent fatigue, extreme weight loss, or suicidal thoughts—stop all program activity immediately and seek medical attention or contact emergency services.

Acceptance of Disclaimer

By accessing or using any part of the Life 101 or Fasting 101 platform (including downloading the app, joining a program, or completing check-ins), you confirm that:

  • You have read and understood this Health Disclaimer
  • You voluntarily accept the risks involved
  • You agree not to hold Jason Gutsell, 101 Life Ltd, Fasting 101, or any affiliated parties liable for health-related outcomes
     If you do not agree with this disclaimer, you should not use our platform or services.

5) Coaching Data & AI Consent Agreement

Effective Date: July 11, 2025
 Company: 101 Life Ltd (Company No. 15015466)
 Trading As: Life 101 / Fasting 101
 Registered Office: 27 Cottages Road, Seaham, County Durham, SR7 7RL
 Contact Email: [email protected]
 Websites: www.life101.app / www.fasting101.app

This agreement outlines how your data is collected, used, analysed, and stored as part of our coaching programs and digital platforms. It should be read in conjunction with our Privacy Policy and Health Disclaimer.
 By participating in any Life 101 or Fasting 101 program, you agree to the terms set out below.

Types of Data We Collect from You

As part of the coaching process, you may be asked to voluntarily provide personal data, including but not limited to:

  • Health metrics (e.g. weight, height, body fat %, blood pressure)
  • Lifestyle and behaviour data (e.g. fasting windows, nutrition, sleep, movement, energy, stress, mood, and productivity)
  • Check-in responses, reflections, and journal entries
  • Visual media (e.g. progress photos, form checks, video submissions)
  • Voice notes or screen recordings
  • Messages via WhatsApp, email, and app chat
     This data is used exclusively to personalise your experience, track progress, and generate coaching insights.

Use of AI Tools and Data Analytics

Our platform may use third-party artificial intelligence (AI) and machine learning systems (including OpenAI integrations) to:

  • Analyse trends and patterns in your lifestyle data
  • Generate personalised feedback, insights, or reports
  • Support automation of coaching tasks and platform features
  • Improve the overall performance of the coaching system
     Only anonymised data is submitted to AI systems. Personally identifiable information (e.g. your name, email, or contact details) is never shared with AI tools.
     ⚠️ You must not submit sensitive data such as trauma history, bank details, medical diagnoses, or passwords into open check-in fields or voice notes.

Storage and Access

Your data is stored on secure servers (e.g. Google Cloud, BigQuery) with restricted access.
 Only authorised personnel (e.g. your coach or relevant platform developers) will have access to your data.
 Internal reports or insights may be generated using anonymised, aggregated data to improve our systems and user experience.

Media Consent (Photos, Video, Audio)

As part of your program, we may request or collect images, videos, or recordings for the purposes of:

  • Progress tracking
  • Technique analysis
  • Community engagement (e.g. group challenges)
  • Educational material (e.g. anonymised case studies)
  • Testimonials or success stories (with explicit permission only)
     You may withdraw consent for media usage at any time by emailing [email protected].

Group Calls, WhatsApp Groups & Messaging Platforms

By joining our programs, you may be added to group platforms such as WhatsApp, Zoom, or Slack. Participation in group environments implies consent to the following:

  • Group sessions may be recorded for educational or replay purposes
  • Screenshots, photos, or audio snippets may be shared internally
  • You are responsible for protecting your own privacy when speaking or submitting media in a group setting
     We will always use discretion and aim to seek approval before publicly sharing anything identifiable.

Use of Aggregated or Anonymised Data

We may use anonymised and aggregated data from across our client base to create:

  • Internal case studies
  • Platform performance reports
  • Educational content (e.g. habits tracking trends)
  • Statistical summaries for research or development
     Your name and personal identity will never be disclosed without your written permission.

Right to Withdraw & Data Deletion

You may request access to, correction of, or deletion of your personal data at any time. To do so, contact us at [email protected]. Please allow up to 14 working days for your request to be processed.
 Note: Some data may need to be retained to fulfil legal, contractual, or operational obligations.

Acknowledgement and Consent

By using our services and submitting your data through the Life 101 or Fasting 101 platform, you confirm that:

  • You understand how your data will be used
  • You consent to AI-assisted analysis and automated insights
  • You accept the use of anonymised and aggregated data for research and development
  • You acknowledge that media may be used with discretion unless opted out
  • You may withdraw consent or request deletion at any time
     If you have any concerns, please reach out to [email protected].

6.1 What are cookies?

Cookies are small text files stored on your device that help websites and apps function, remember preferences, and understand usage. We also use similar technologies (pixels/SDKs/local storage).

6.2 Categories we use

  • Strictly Necessary: security, session management, load balancing, consent storage.
  • Preferences/Functional: remember settings and choices.
  • Analytics/Performance: understanding usage and improving features (e.g., Google Analytics, error tracking).
  • Marketing/Attribution: measuring campaigns (e.g., Meta/Google Ads pixels), limiting ad frequency.

6.3 Your choices

You can manage consent via our cookie banner and adjust browser settings to block or delete cookies. Blocking some cookies may impair functionality.

6.4 Do Not Track

Because standards vary, our Services may not respond to every DNT signal. You can still manage cookies as above.

6.5 Changes

We may update this Cookie Policy; the latest version will be posted on our sites.

7) Acceptable Use Policy

You agree not to use our Services to:

  • Break the law or infringe IP, privacy, or publicity rights.
  • Harass, bully, threaten, or defame others; post obscene or hateful content.
  • Share illegal, harmful, or exploitative content (including self‑harm encouragement).
  • Upload malware, attempt to bypass security, or disrupt service.
  • Scrape, mine, or harvest data without written permission.
  • Spam or run unauthorized promotions.

Enforcement: We may remove content, suspend, or terminate access for violations. We may report illegal activity to authorities.

8) Accessibility Statement

We aim to provide an accessible experience and strive to conform to WCAG 2.1 AA standards. If you face barriers (e.g., keyboard navigation, screen reader issues, color contrast), contact [email protected]. We can supply information in alternative formats on request.

9) End User License Agreement (EULA)

9.1 License grant

Subject to these terms, we grant you a limited, revocable, non‑exclusive, non‑transferable license to install, access, and use our app/software for personal, non‑commercial use.

9.2 Restrictions

You must not: reverse‑engineer, decompile, disassemble, copy, modify, create derivative works, rent/sell/lease/sublicense, or use the app to build a competing service. Do not remove proprietary notices.

9.3 Updates & availability

We may update, add, or remove features. Availability may vary by device, OS, or region. Some features require internet access.

9.4 Third‑party services & open source

The app may interoperate with third‑party services subject to their terms. Open‑source components are licensed under their licenses.

9.5 Data & privacy

We process data as described in our Privacy Policy and AI Consent. Some features rely on anonymized analytics.

9.6 Termination

We may suspend or terminate the license for breach. You must uninstall upon termination.

9.7 Export controls & sanctions

You agree to comply with applicable export/sanctions laws and not use the app in embargoed or prohibited jurisdictions.

9.8 App stores (if applicable)

If downloaded via Apple/Google stores, you also accept their standard terms and policies, including warranty and support allocations.

9.9 Disclaimers & limitation

The app is provided “as is”. Our total liability for claims related to the app is limited to the amount you paid (if any) in the 12 months prior to the claim (or £100 if none), except where not permitted by law.

10) Content Release Consent

By submitting or approving the use of testimonials, progress photos/videos, audio clips, or written statements (“Content”), you:

  • Grant 101 Life Ltd a worldwide, royalty‑free, perpetual license to use, reproduce, edit, adapt, publish, and display the Content for marketing, education, and portfolio purposes across all media (including social, websites, ads, and printed materials).
  • Confirm you own or control the rights in the Content and it does not infringe others’ rights.
  • Acknowledge that the Content may be combined with other media (e.g., text overlays, music) and used with your first name/initial and general descriptors (e.g., role or region) unless you ask otherwise.
  • Can withdraw consent for future uses by emailing [email protected]. We will stop new uses going forward; prior published materials may continue to exist, and we may retain archival copies for compliance.

If the Content includes third parties or minors, you confirm you have their permission or parental/guardian consent.

11) Annex

Annex A. Sub‑processors & Key Partners (illustrative; keep updated)

  • Infrastructure/Hosting: Google Cloud Platform (e.g., Compute, BigQuery), Cloudflare (security/CDN)
  • AI/ML Processing: OpenAI (pseudonymized inputs), internal analytics tools
  • Payments: Stripe
  • Comms/Support: WhatsApp/Meta, Zoom, email service providers (e.g., transactional mail)
  • Analytics/Diagnostics: Google Analytics, error/crash logging tools

We use contracts and appropriate safeguards (e.g., SCCs/IDTA) for international transfers.

Annex B. Data Retention Schedule (typical)

  • Account data: for the life of the account + up to 6 years (tax/legal).
  • Coaching records/check‑ins: for the program term + up to 24 months (or sooner on deletion request unless legally required).
  • Payment records (from Stripe): up to 7 years (tax/legal).
  • Marketing preferences: until opt‑out + up to 24 months for suppression logs.
  • Support tickets: up to 24 months after closure.

These are typical periods; actual retention may vary based on legal and operational needs.

Annex C. Definitions

  • “Services”: all websites, subdomains (including limitless.life101.app), software/apps, programs, and communications we operate.
  • “Personal Data”: any information relating to an identified or identifiable individual.
  • “Special Category Data”: sensitive data (e.g., health) processed only with explicit consent.
  • “Process/Processing”: any operation on personal data (collection, storage, analysis, etc.).
  • “Controller/Processor”: meanings per UK GDPR/GDPR.
  • “AI Tools”: third‑party or internal models used to analyze inputs and generate outputs.