As part of the service, ZISHI Elite processes health related data provided by you.

This includes psychological data such as mood and anxiety collected when you complete the twice daily questionnaire.

If we have supplied you with a HRV Monitor (Polar H10, CorSense, or similar device) we will process physiological data such as heart rate variability (HRV) collected when you use the Monitor.


ZISHI Elite are the Data Controller in respect of your Personal Health Related Data.

We can be contacted at:

Imperial House,
21-25 North Street,

We have appointed a data protection officer (DPO) to oversee compliance of data protection laws. Our DPO can be contacted at

Why We Collect Your Personal Health Data

a)     Purposes

We collect your personal health related data in order to provide the ZISHI Elite service, understand how your wellbeing affects your performance and offer recommendations as to how you can achieve peak performance.

b)     Lawful Basis

We will only process your personal health data where you have given explicit consent.

With Whom We Share Your Personal Health Data

Your information may be shared internally for administration purposes. This includes members of the ZISHI Elite team, IT staff if access to the data is necessary for the performance of their roles.

Your information will also be shared with third parties like Bangor University Professors to conduct analysis to determine correlation between variables and Trader’s performance.

Under no circumstance will your data be sold or shared with any parties who are external to the company or project other than those listed above.

We may also disclose your personal information to comply with any applicable law, regulation or government request or to protect our rights or the rights of our customers, users, partners, or others.

In the event that we sell all, or substantially all, of our assets to a third party, your personal data held by us will be transferred as part of the sale and we will endeavour to provide you with notice of such event.


We partner with Bangor University to conduct analysis to determine correlation between variables and Trader’s performance. We have a data sharing agreement in place to ensure that your data is protected to the same standard as our internal policies and controls to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by employees in the proper performance of their duties.

How Long We Store Your Personal Health Data

We will only retain personal health data for as long as necessary to fulfil the purposes that we collected it for, including for the purposes of satisfying any contract, legal, accounting, reporting requirements, or to comply with internal policy requirements.

If You Don’t Provide Us Your Personal Health Data

If you do not consent to ZISHI Elite processing your Personal Health Data we will not be able to provide you with the full functionality of the service.

Your Rights

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.
  • Withdraw consent at any time by emailing

If you want to review, verify, correct, request erasure of your personal information; request that we transfer a copy of your personal information to another party; withdraw consent, or if you have any general queries about how we handle your personal data, please email:

Withdrawal of Consent

You have the right to withdraw consent at any time by emailing

International Transfer of Personal Data

Given the international dimension of ZISHI Elite, and in order to optimize the quality of our services, the communication of information mentioned above may involve the transfer of personal data outside the UK and/or EEA, whose legislation on the protection of personal data is different from that of the UK and/or European Union.

Where we transfer personal data outside the UK and/or EEA (except where the concerned country has been officially recognized by the European Commission as ensuring that personal data has an adequate level of protection equivalent to the European standard), we will ensure that the transferred data is protected by suitable Standard Contractual Clauses or other appropriate safeguards referred to in the DPA2018 and GDPR.

How to Complain

If you are unhappy with any aspect of how we process your personal data please contact us at

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at the following address:

Information Commissioner’s Office
Wycliffe House
Water Lane