PRIVACY POLICY

Last Updated: July 2026

SUMMARY

This privacy policy sets out how we use and protect your personal data. It also gives you information about how we collect and use your personal data through your use of our sites, including any data you may provide when you register as a trainee with us, purchase a Service otherwise interact with us

It is important for you to know that Harley Academy Ltd  is part of a group made up of different legal entities including Harley Academy AI Ltd (“Group”). This Privacy Policy is issued on behalf of the Group so when we mention a company name, "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Harley Academy Ltd is the controller and responsible for this site.

WHAT DATA DO WE COLLECT AND HOW DO WE COLLECT IT

We collect and use personal data through your use of our Services and platform, enquiries you make about our services and your contact with us via the site, platform, our e-learning systems or through other means. 

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 personal data to us.

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

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows (this list is not exhaustive):

• Identity Data includes your name, email address, username, title, date of birth, gender, profession and registration number or similar identifier.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• 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.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this site.
• Profile Data includes your username and password, purchases or learning modules accessed by you, preferences, feedback and survey responses.
• Usage Data includes information about your visit and use of the platform, including the site that referred You to our sites (if applicable), the path that You take through the site 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 includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Health-related Information includes information about your physical or mental health, medical history, allergies, medication, pregnancy or breastfeeding status, previous treatments and procedures, consultation and assessment records, diagnoses, prescriptions, treatment plans, consent forms, adverse reactions, complications, aftercare, referrals and clinical photographs.
• Health and Clinical Data is special category personal data under data protection law. Where we provide healthcare, aesthetic or related clinical services, we process this information only where it is necessary and lawful to do so.
• We do not rely solely on consent to process Health and Clinical Data required to provide safe and appropriate care. Depending on the circumstances, we may process this information because it is necessary:
• to perform a contract with you or take steps at your request before entering into a contract;
• to comply with a legal or regulatory obligation;
• for the provision or management of health care or treatment by, or under the responsibility of, a professional subject to confidentiality obligations;
• to establish, exercise or defend legal claims;
• to protect your vital interests or those of another person where you are unable to give consent; or
• with your explicit consent where consent is the appropriate lawful basis.
• Where we rely on explicit consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing that took place before consent was withdrawn and may not require us to erase information that we must retain for clinical, legal, regulatory, safeguarding or insurance purposes.
• 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 (i) Displaying content in your preferred language or regional format, (ii) Complying with regional legal requirements (e.g., cookie consent, data protection rights), (iii) 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.
• Criminal Convictions and Offences: we do not collect any information about criminal convictions and/or other offences.
• Aggregated and Anonymised 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 personal data but is not considered personal data as it 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 site 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. 
• We may also use aggregated and anonymised data to analyse learning patterns, improve platform functionality, and enhance educational effectiveness. This data does not identify individual users and cannot be used to re-identify individuals.
• Children: Our services are not intended for anyone under 18. We do not knowingly collect personal data from children. Most of our education and aesthetic treatment services are intended for adults. However, we may process information relating to a person under 18 where this is lawful and necessary, for example in connection with an enquiry, safeguarding matter, complaint, emergency, clinical referral or a service that may lawfully be provided to a child.
• Where we process a child’s personal data, we will take account of the child’s age, capacity and best interests and will obtain consent or authority from a parent, guardian or other appropriate person where required by law.
• We do not knowingly use children’s personal data for direct marketing without the appropriate lawful basis and safeguards.

HEALTH INFORMATION AND CLINICAL RECORDS

Companies within the Group may provide healthcare, aesthetic treatment, clinical assessment, prescribing, aftercare, training or related services.

Where you receive a clinical service, we may create and maintain a clinical record containing information such as:

• your medical history and current health;
• allergies, medicines and previous procedures;
• consultation and assessment notes;
• treatment recommendations and treatment provided;
• prescriptions and product information;
• consent forms and communications;
• clinical photographs;
• aftercare and follow-up records;
• adverse reactions and complications;
• referrals and correspondence with other healthcare professionals; and
• complaints, incident records or information required for insurance or legal purposes.

We use this information to assess whether treatment is suitable, provide safe and effective care, maintain continuity of care, respond to complications, meet professional and regulatory requirements and protect patients and others.

Clinical information is accessed only by personnel who require it for their role and is subject to appropriate professional, contractual or legal confidentiality obligations.

CLINICAL AND MARKETING PHOTOGRAPHY

We may take photographs or other images in connection with consultations, assessments, treatments or procedures.

Clinical photography

Clinical photographs may be taken where reasonably necessary to:

• assess your condition or suitability for treatment;
• plan or provide treatment;
• record your condition before, during or after treatment;
• monitor progress or treatment outcomes;
• support continuity of care;
• obtain clinical advice from another authorised professional;
• investigate an adverse event, complaint or claim; or
• comply with clinical, legal, regulatory or insurance requirements.

Clinical photographs form part of your clinical record. They are not dependent on marketing consent and may be retained for the same period as the related clinical record.

We will explain when clinical photographs are required. Where appropriate, you may discuss whether an alternative is available, although declining clinically necessary photography may mean that we cannot safely provide or continue a particular treatment.

Marketing, promotional and educational photography

We will not use identifiable photographs or videos for advertising, social media, websites, promotional campaigns, testimonials, public presentations or similar non-clinical purposes unless we have obtained your separate and explicit consent.

Consent for marketing or promotional photography is voluntary. Refusing consent will not affect the care or service you receive.

You may withdraw your consent for future use at any time by contacting us. Withdrawal will not affect use that took place lawfully before consent was withdrawn. We will take reasonable steps to stop future use under our control, but we may not be able to retrieve material already printed, distributed, lawfully published or shared by third parties.

Where images have been fully anonymised so that you can no longer be identified, they may no longer constitute personal data.

HOW WE COLLECT YOUR PERSONAL DATA 

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

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Enquire about or apply for our products or services;
• create a user account on our site;
• use our Service or platform, we will collect and process the data you add to our platform;
• request marketing to be sent to you;
• give us feedback or contact us;
• make a payment or purchase services from us (including billing and transaction details)
• browse our site.
• Automated technologies or interactions. As you interact with our site, we will 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 sites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.  We use third parties such as Google to help us analyse how people are using our Service. We also use Google Analytics to provide us with demographic data about our customers and prospective customers, such as age and gender. Google uses a cookie that can be recognised by Google or its affiliate DoubleClick when you visit other sites. For more information about how Google collects, uses, and shares your information, please visit the Google Privacy Policy-Partners site at https://www.google.com/policies/privacy/partners/.
• Technical Data is collected from the following parties:
• analytics providers (such as Google based outside the UK);
• advertising networks (such as HubSpot and ScoreApp, based outside the UK); and
• search information providers such as Google, based outside the UK
• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services (such as Stripe and GoCardless, based in the UK; FastSpring, based outside the UK; Premium Credit and Buyline (UK) and Xero, based outside the UK).
• Identity and Contact Data may be collected from publicly available sources such as professional medical registers.

LEGAL BASIS FOR COLLECTING AND USING YOUR DATA

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
• Contractual Necessity: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate Interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure Customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Compliance with Legal Obligations: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

Special Category Personal Data

Where we process Health and Clinical Data or another type of special category personal data, we must also satisfy an additional condition under Article 9 of the UK GDPR.

Depending on the processing activity, we may rely on:

• Article 9(2)(a): your explicit consent;
• Article 9(2)(c): protection of vital interests where you are physically or legally incapable of giving consent;
• Article 9(2)(f): establishment, exercise or defence of legal claims;
• Article 9(2)(g): substantial public interest, where supported by an applicable condition in the Data Protection Act 2018; or
• Article 9(2)(h): provision or management of health care or treatment, where the information is processed by or under the responsibility of a professional subject to confidentiality obligations.

The lawful basis and special category condition used will depend on the particular purpose for which the information is processed.

HOW DO WE USE YOUR PERSONAL DATA

• To deliver our services
• To provide study modules (online or otherwise)
• To manage our operations effectively
• To communicate with you
• For marketing (with consent)
• To analyse use of the Service
• To enable an entity paying for your subscription to access some personal data captured by the AI platform
• To enable an entity paying for your subscription to access some personal data captured by the AI platform
• We do not sell your personal data to any third party
• To assess your suitability for clinical or aesthetic treatment
• To provide consultations, healthcare, treatment, prescribing, aftercare and follow-up
• To create and maintain clinical records
• To take and use clinical photographs for assessment, treatment planning and monitoring
• To manage adverse reactions, complications, incidents and safeguarding concerns
• To make or receive clinical referrals and liaise with other healthcare providers where necessary
• To comply with professional, clinical, regulatory, insurance and legal obligations
• To investigate complaints and establish, exercise or defend legal claims
• To use identifiable photographs or videos for marketing or promotional purposes where we have obtained separate explicit consent.

HOW LONG WE KEEP YOUR DATA FOR

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being consumers for tax purposes.

In some circumstances you can ask us to delete your data: see section YOUR RIGHTS for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research, statistical or educational purposes, as set out in this Privacy Policy.

Clinical records, including consultation notes, consent forms, treatment records, prescriptions, clinical communications and clinical photographs, may need to be retained for longer than ordinary customer information.

We retain clinical records in accordance with applicable legal, regulatory, professional, safeguarding, insurance and limitation requirements and our Data Retention Policy.

The applicable period may vary according to the type of service, the individual’s age, the nature of the treatment, whether a complaint or adverse event has occurred and whether the record may be required in connection with a legal or insurance claim.

Where marketing or promotional photography is based on consent, we will stop using it for new purposes following withdrawal of consent, subject to any continued retention that is necessary to evidence the consent previously given, comply with law or manage legal claims.

WHO WE SHARE YOUR DATA WITH

We may share your data with:

• Members of our Group;
• Service Providers;
• Legal or regulatory bodies; 
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We will only share your personal data with other third-party partners with your consent.

Where necessary in connection with clinical or healthcare services, we may also share relevant personal data with:

• Treating Practitioners and authorised clinical staff;
• pharmacies, prescribers, laboratories and product suppliers;
• other healthcare professionals or organisations involved in your care or referral;
• emergency services or NHS providers where urgent care is required;
• professional regulators, inspection bodies or safeguarding authorities;
• medical defence organisations and professional indemnity insurers;
• legal, compliance and data protection advisers;
• IT, clinical-record, booking, photography-storage and communications providers acting on our instructions; and
• law-enforcement bodies, courts or public authorities where disclosure is required or permitted by law.

We will share only the information reasonably necessary for the relevant purpose.

We may share clinical information without consent where this is necessary and lawful, including for direct care, safeguarding, vital interests, regulatory reporting or legal claims. Where consent is required, we will obtain it before sharing.

We, Harley Academy Limited or Harley Academy Inc. may use your contact details to invite you to access additional educational platforms operated by companies within the Group or third parties. Where this occurs, your email address may be used to enable secure access to the relevant platform and, where applicable, the creation of a basic user profile to provide continuity of service. Each platform operates under its own privacy notice, which will be made available to you when you access that platform.

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.

We use trusted third-party service providers to support our operations, including payment processors (such as Stripe, GoCardless, FastSpring, Premium Credit and Buyline), analytics providers, and technology platforms. These providers act as data processors and are contractually required to process personal data only on our instructions and to implement appropriate security measures.

INTERNATIONAL DATA TRANSFERS

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.

Whenever we transfer your personal data out of the UK or Canada to countries which have laws that do not provide the same level of data protection as UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that safeguards are implemented. 

For transfer of personal data within the Group: We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at privacy@harleyacademy.com

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that safeguards are in place. We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at privacy@harleyacademy.com.

DATA SECURITY

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 law.

YOUR RIGHTS

You may have a number of rights under applicable data privacy legislation including the right to:

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request deletion of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for certain purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. 
• Request restriction of processing of your personal data.

Some rights are not absolute. For example, we may be unable to erase or alter a clinical record where retaining an accurate record is necessary for patient safety, continuity of care, professional accountability, legal compliance, safeguarding, insurance or the establishment, exercise or defence of legal claims.

Where a clinical record contains a factual inaccuracy, we may correct it. Where the issue concerns a clinical opinion or professional judgment, we may retain the original entry and add a supplementary note recording your concern or the updated position rather than deleting the original record.

If you wish to exercise any of the rights set out above, please see the contact us as set out in the CONTACT section below. 

Please note, if you exercise any of your rights, such as right to deletion or withdrawing consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you contact us to exercise your rights. 

AI PLATFORM 

Some Harley Academy platforms use artificial intelligence (AI) to support education, assessment, and professional development. AI-enabled features are designed to enhance learning outcomes and engagement and are not intended to provide medical advice, diagnosis, or treatment.

AI-related processing may involve the use of account and profile information, platform usage and interaction data, and user inputs provided during AI-enabled educational activities.

AI is used in an assistive and educational capacity only. It does not make solely automated decisions that produce legal or similarly significant effects on users. Any AI-generated outputs are intended to support learning and remain subject to human interpretation and professional judgement.

Please see our AI Ethics and Governance Policy for further details regarding how we use personal data in connection with our AI platforms. 

CONTACT

If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact Us in one of the following ways:

Email: privacy@harleyacademy.com

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

CHANGES

We may update this Privacy Policy from time to time. Please check this page for updates. 

COMPLAINTS

You have the right to make a complaint to the data protection regulator in your country. In the UK this is the Information Commissioner’s Office (ICO), (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. 

THIRD PARTY LINKS

This site may include links to third-party sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party sites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy of every site you visit.