GLOBAL PRIVACY POLICY

PRIVACY POLICY

Last updated: 25th July 2025

This Global Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when You use the Service (www.harleyacademy.com,  www.harleytrained.com and learning.harleyacademy.com) from outside of the United Kingdom or Canada, and tells You about your privacy rights and how the law protects You.

We use your personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Definitions

For the purposes of this Privacy Policy:

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party.
• Company (referred to as either "the Company", "We", "Us" or "Our") refers to Harley Academy Limited and Harley Academy Inc.
• Cookies are small files placed on Your device by a website, containing the details of Your browsing history.
• Country refers to any country outside of the UK and Canada.
• Device means any device that can access the Service.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Website/Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company.
• Usage Data refers to data collected automatically by the Service.
• Website refers to Harley Academy's websites.
• You means the individual accessing or using the Service.

Notice to International Users

Harley Academy serves customers globally. If you are accessing our Service from outside the United Kingdom or Canada, your data may be transferred to and processed in the UK, Canada, or other jurisdictions. We ensure appropriate safeguards such as Standard Contractual Clauses are in place.

Legal Basis for Processing (EU/EEA)

We process personal data based on:

• Consent: When you provide explicit permission for data collection and processing.
• Contractual Necessity: When processing is required to fulfill our contractual obligations.
• Legitimate Interests: When necessary for our business operations and not overridden by your rights.
• Compliance with Legal Obligations: When required by applicable laws and regulations.

Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Deletion: Request that we delete your personal data, subject to certain exceptions.
• Right to Correction: Request that we correct any inaccurate or incomplete data.
• Right to Restrict Processing: Request to limit how we use your data.
• Right to Object: Object to the processing of your data for certain purposes.
• Right to Data Portability: Request to receive your data in a commonly used format.
• Right to Withdraw Consent: Withdraw any previously given consent.

To exercise these rights, contact us at privacy@harleyacademy.com.

Data Protection Legislation

We comply with applicable international data protection laws, including the EU GDPR, US state laws (e.g., CCPA), and others as relevant.

What Data Do We Collect From You?

We collect and use data through your use of our services and platform, enquiries You make about our services and your contact with us via the Website/Application, Learning Management system or through other means. In respect of this personal data, we are the Controller.

If You use our services, are enquiring about using our services or if You are a contributor providing information to our platform, it will be necessary for You to provide certain data to us.

If You are passing data to us that belongs to someone else You must ensure You are lawfully permitted to transfer such data to us.

The data You provide or may provide is listed below.

Identity Data 

Identity data includes your name, email address, username, title, date of birth, gender, profession and registration number or similar identifier.

Contact Data

Contact Data includes billing address, email address and telephone numbers.

Financial Data

Financial Data includes bank account and payment card details.

Transaction Data

Transaction Data includes details about payments to and from You and other details of any payments made by You whilst using our services or purchasing services or goods from us.

Profile Data

Profile Data includes your username and password, your user ID, preferences and Feedback.

Usage Data

Usage Data includes information about your visit and use of the platform, including the website that referred You to our Website (if applicable), the path that You take through the Website and platform (including date and time); pages that You viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Marketing and Communications Data

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data

We also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your data but is not considered personal data 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 or we may aggregate your responses to questions on the Website or through our Service and our findings to identify trends. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify You, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Health-related Information (with consent)

We only collect Special Categories of personal data about You (such as information about your health and genetic data) where we have your explicit consent and we ensure our collection and processing of this data is not excessive. Consent is freely given, specific, informed, and unambiguous, and that users have the right to withdraw it at any time. We do not collect any information about criminal convictions and offences.

Personal Data and Information we collect automatically

Information About Your Use of the Service

Our servers automatically record your visits to the Service. Like all other website and mobile app servers, ours compiles a log that records the date, time, browser (i.e., Firefox), device type (i.e., iPhone), operating system (i.e. Android), and originating IP address of each page You visit.

We use cookies to collect information about your visits to our website and Service

Cookies are text files placed on your computer by websites to collect standard log information and visitor behaviour information. Our cookies collect the following information about You: which website or ad You visited right before ours, which pages You visited on our Service, and how much time You spent on each section of our Service. We may also collect other data about your visit, such as search requests and results. We use this information for our legitimate interests to track usage of our Service, to measure the number of unique visitors to the different sections of our Service, to understand how Members find and join our website, and to help us make our Service more valuable to every Host and Member. The use of this information is called “analytics.” Often information used for analytics is aggregated. Our mobile applications on iOS (Apple) and Android (Google) have to interact with our computer servers. We assign your device a token so that You do not have to log in every time You use the Service via our mobile apps.

You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some of our Service features may not work properly without cookies. Most browsers accept cookies automatically but allow You to disable them. For more information about cookies visit https://www.allaboutcookies.org.

Information About Your Location

From your IP address, we can tell generally where You are when You are accessing our Service, such as which city. We start by choosing a location for You based on the IP address of your internet connection. You can update or remove this location at any time by logging in to your account on the Service.

Personal Data and Information Third Parties collect automatically

Third-Party Cookies for Site Use Analysis

We use third parties such as Google to help us analyse how people are using our Service. We also use the Google Analytics service to provide us with demographic data about our Hosts and Members, such as age and gender. Google uses a cookie that can be recognised by Google or its affiliate DoubleClick when You visit other websites. For more information about how Google collects, uses, and shares your information, please visit the Google Privacy Policy-Partners website at https://www.google.com/policies/privacy/partners/.

Third-Party Cookies Used to Target Ads on Other Websites

“Beacons” are transparent pixel images that are used in collecting information about website usage across websites and over time. Our Hosts may use their own or third-party cookies or beacons to target Host ads to You when You visit other websites. Our Hosts may also work with other companies who use their cookies or beacons to target third-party ads to You on other websites based on your prior visits to the Host’s Network on our website Service. This is called online behavioural advertising (“OBA”) because You receive ads based on your prior online behaviour. We do not have access to these cookies; it is third parties who engage in OBA.

How Do We Collect Data?

We use different methods to collect data from You including as follows:

• Enquiring If You contact us to ask about our services or about us generally, either through the Website or otherwise, we will collect and process Identity, Contact and Financial Data
• Signing up If You sign up for our Service, we will collect and process Identity, Contact, Financial, Transaction, Technical, and Profile Data
• Usage When You use our Service or platform, we will collect and process the data You add to our platform
• Correspondence If You correspond with us using our contact form or through our ‘contact us’ or help features, we will collect and process Identity and Contact Data
• Browsing We collect some Technical and Usage Data.

How Do We Use Your Data?

• To deliver services
• To communicate with you
• For marketing (with consent)
• To analyse use of the Service
• To comply with legal obligations

Sharing Your Data

We may share your data with:

• Affiliates
• Service Providers
• Legal or regulatory bodies
• Third-party partners with your consent

We ensure data protection agreements are in place.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of Your data and other personal information.

Cross-Border Data Transfers

Your personal data may be transferred internationally. To ensure compliance with data protection regulations, we use:

Your data may be processed outside your home country. Safeguards include:

• Adequacy decisions
• Standard Contractual Clauses
• Encryption and secure processing

Analytics and Advertising

We use third-party analytics providers such as Google Analytics. Data may be transferred internationally. See: https://support.google.com/analytics/answer/6004245?hl=en

We may engage in online behavioural advertising (OBA) with your consent where required.

Security of Your Data

We implement administrative, technical, and physical safeguards to protect your data. These measures include:

• Encryption: Personal data is encrypted in transit and at rest where appropriate.
• Access Controls: Only authorised personnel have access to your data, based on role-specific permissions.
• Monitoring and Auditing: We regularly monitor systems for vulnerabilities and carry out periodic audits.
• Training: Staff receive regular training on data protection principles and secure handling of personal information.
• Incident Response: We have procedures in place to respond promptly to any suspected data breaches and will notify affected individuals and regulators as required by applicable laws.

Children's Privacy

Our services are not intended for anyone under 18. We do not knowingly collect data from children.

Your Location and Use

We may determine your general location based on your IP address or other technical indicators to personalise your experience, provide appropriate content, comply with legal obligations, and enhance Service performance. This may include:

• Displaying content in your preferred language or regional format
• Complying with regional legal requirements (e.g., cookie consent, data protection rights)
• Directing you to the appropriate privacy policy or support contact

You may manage your location preferences through your browser or device settings, and you can opt out of location-based services where technically feasible. Note that some services may function differently or be limited if location data is restricted.

Contact Us

If you have any questions, please contact:

Harley Academy - Email: privacy@harleyacademy.com

UK: Harley Academy Ltd, 5th Floor Jasper House, 4-6 Copthall Avenue, London, EC2R 7DA

Canada: Harley Academy Canada Ltd, 181 Bay St, Ste 1800, Toronto, Ontario, Canada, M5J 2T9

Changes to This Policy

We may update this Privacy Policy periodically. Please check this page for updates. Your continued use of the Service signifies your agreement to the changes.