Welcome to Harley Therapy Platform Ltd's Privacy Policy. Harley Therapy Platform Ltd (HTP Ltd) respects your privacy, and is committed to maintaining the accuracy, confidentiality and security of your personal information.

This Privacy Policy describes the personal information that HTP Ltd collects from or about you when you visit our website (regardless of where you visit it from) or engage with our services (including via live chat messages or email); how we use and protect your personal information; and outlines your privacy rights and how the law protects you.

Where needed, please also refer to the Glossary included at the end of this privacy policy to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

2. The data we collect about you

3. How your personal data is collected

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Glossary

This privacy notice aims to describe and share information about how Harley Therapy Platform Ltd (HTP Ltd) collects, processes and uses your personal information through your use of this website.

Please note, this website is not intended for children under 16 years of age, and we only collect data relating to children with the guardian’s consent.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

We may revise this policy at any time by amending this page. Please check this page from time to time to take note of any changes made.

This privacy notice is issued on behalf of the Harley Therapy Platform Ltd (HTP Ltd) so when we mention “Harley Therapy”, “Harley Therapy Platform”, "we", "us" or "our" in this privacy notice, we are referring to the relevant brand in the Harley Therapy Group responsible for processing your data.

Harley Therapy Platform Ltd (HTP Ltd) is the controller and is responsible for this website. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details noted below.

We are registered with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), and you are entitled to make a complaint to them at any time. We would, however, appreciate the chance to resolve any concerns before you approach the ICO, so please contact us in the first instance using the details noted above.

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This Privacy Policy was originally created on 24/05/2018 and was last reviewed and updated on 16/04/2025.

Please keep us informed if your personal information changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question, but we will notify you and explain the reasons when needed if this is the case.
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Please be aware, this website may include links to third-party websites, plug-ins and applications. Clicking on these links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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Personal data (or personal information) refers to any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together into the following sub-categories :

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data, but is not considered personal data in law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect any Aggregated Data with your personal data so that it can directly or indirectly identify you, we would treat the combined data as personal data, which would be used in accordance with this privacy policy.

We may collect Special Categories of Personal Data about you (this includes details about your health) as this is necessary for us to provide you with the best match of therapist to you and/or to allow your chosen therapist to confirm they would be able to assist with your presenting issues. We do not collect any other special category data, including information about criminal convictions and offences.

If you do not provide personal data where we need to collect the personal data by law or under the terms of a contract we have with you, and you fail or decline to provide that data when requested, then we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services requested, or to be able to complete a booking with your chosen therapist). In this scenario, we may need to cancel the service you have with us, but we will notify you if this is the case at the time.

We use different methods to collect data from and about you, including through:

Direct interactions: you may provide us with data by filling in forms, or by corresponding with us by post, live chat messages, email or otherwise. This includes any personal data you provide when you:

As a general rule, HTP Ltd collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions). An example of this would be contacting a previous employer to seek an employment reference.

From time to time, we may use the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us. In that case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
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As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Please see our Website Terms & Conditions for more detailed information about the use of cookies on our website.
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We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

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We will only use your personal data when the law explicitly allows us to do so.

Most commonly, we will use your personal data in the following circumstances:

Generally, we do not rely on consent as a legal basis for processing your personal data. We may use your personal information for the purposes described in this Policy, or for any additional purposes that we advise you of, and where your consent is required by law, we have obtained your consent in respect of the use or disclosure of your personal information.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

You have the right to withdraw consent to marketing at any time by contacting us using the details noted under the Contact Details sub-heading in Chapter 1 ("Important information and who we are") of this policy.
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We have set out below, in a table format, a description of all the ways we may use your personal data, and the applicable legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Where more than one ground has been set out in the table below, please contact us if you require further information about the specific legal ground we are relying on to process your personal data.

We may use your Identity, Contact, Technical, Medical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you in our marketing activities.

You will only receive marketing communications from us if you have requested such information from us, or if you have previously purchased services from us and have not opted out of marketing communications (see below).
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You can ask us to stop sending you marketing by following the opt-out links on any marketing message sent to you, or by contacting us at any time using the details noted under the "Contact Details" section of this privacy policy.

If you opt out of receiving marketing messages, please note that this will not apply to personal data provided to us as a result of a product/service purchase, account registration, product/service experience or other transactions, as we may still need to communicate with you about these products or services (for example, if you have booked a session, we will still send information to you about your session to enable that booking to go ahead as requested).
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Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. By continuing to browse the site, you are agreeing to our use of cookies.

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function correctly.

For more information about the cookies we use, please see the "Information about our use of cookies" section included in our Website Terms & Conditions here.
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We will only use your personal data for the purposes for which we originally collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. In this scenario, if you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details noted in the Contact Details section of this privacy policy.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so, however, you would be entitled to object to this new use of your data.

Please be aware that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is legally required or permitted by law.
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Within our communications system, we use email and message tracking features to confirm whether an email has been opened or seen by the recipient.

Given the sensitive nature of mental health services, this feature is used solely to verify the receipt of critical communications, ensuring clients have prompt access to essential information regarding their care.
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Our communication systems rely on tracking pixels to detect when an email is delivered and first seen. For messages and emails sent via Intercom, we do not collect any further details about your device or usage.
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For priority emails (eg. booking confirmation and notification emails; passcodes to login and/or verify account details; cancellation and rearrangement emails; payment failure notifications; and password reset emails), we track more detailed information to ensure receipt by the intended recipient due to the sensitive nature and importance of those communications, and to allow us to identify and resolve any delivery issues. The additional information collected for these types of emails includes: date and time of delivery, the destination server and IP address where opened, browser type and version used, links clicked (including date and time first clicked), delivery failure information (where applicable), and details of any block requests or spam reports submitted.

As a standard function of our communication platforms, email tracking cannot be selectively disabled on a per-user basis.

If any users wish to manage email tracking independently, they may wish to consider:

Please note, where the use of tracking pixels on emails is blocked, we would not have the necessary information available to be able to notify you of issues with email delivery, or to be able to identify or help to resolve any issues with email delivery.

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For visitors to the website who may send us a live chat message or email, but do not create a user account, book a session, or sign up as a therapist, messages are automatically deleted 9 months after their last visit to the website. If a visitor returns after 9 months, they will be treated as a new visitor.

For users who create an account (eg. book a session as a client, or sign up as a therapist), if they request their account be deleted, all emails and live chat messages associated with that user account will be deleted from the system at the same time.

When using our website, you may interact with a chatbot or receive an AI-generated response to a message. These features are GDPR compliant, and any data shared when using these features will not be used for model training or product improvement by any LLM providers, nor will any data be retained by them.

Input (a message sent by a user) is temporarily used to deliver an Output (a response sent to a user) before the Input and Output are both fully deleted from the LLM's systems. The Input may be passed through third-party AI providers’ safety classifiers to ensure no violation of their acceptable usage policies (AUP), however, safety classifiers do not review any personal data.

Please see Chapter 5 ("Disclosures of your personal data") for further information.

We recognise that privacy is of utmost importance, particularly in a mental health context. Email tracking is used strictly under GDPR’s “legitimate interest” provision (Article 6(1)(f)), which allows us to ensure safe and effective communication with our website's users. We do not use this feature to monitor behaviour or collect personal data beyond the stated purpose.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 ("How we use your personal data" ):

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
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Some of our external third parties are based outside the UK or European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the UK or EEA.

Whenever we transfer your personal data outside of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in any unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a specific business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality at all times.

We have put in place procedures to deal with any suspected personal data breach, and in the event of a suspected personal data breach, we would notify you and any applicable regulator of a breach as soon as possible, wherever we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for 7 years after they cease being customers, for tax purposes.

For Communications, please see Chapter 4. ("How we use your personal data", sub-heading "How long are communications retained for?").

You are welcome to request that we delete your data at any time - please Chapter 9. ("Your legal rights") below for further information on your right to request erasure.

Where needed for specific purposes such as legal, accounting or reporting requirements, some information will be anonymised (instead of being fully deleted) so it can no longer be associated with you.

In some circumstances, we may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Data protection legislation also provides you with certain rights. These are not always absolute rights and must be considered within the wider scope of the legislation.

These rights include:

More detailed information on each right is included in Chapter 10. ("Glossary") under the "Your Legal Rights" sub-heading.

If you wish to exercise any of the rights set out above, please contact us at [email protected] or [email protected]

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.
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We endeavor to respond to all legitimate requests within one month.

Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we would notify you and keep you updated.

"Legitimate Interest" means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

"Performance of Contract" means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

"Comply with a legal or regulatory obligation" refers to processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

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