This statement provides information on how GetHarley uses your personal information. It also lets you know your personal information rights. If you want to know more, please contact our privacy team at: firstname.lastname@example.org.
We provide some of your personal information to the clinician who treats you. Please also refer to the privacy statement of your clinician for details of how they use your personal information when treating you.
This is a summary of the personal information we collect and what it is used for. We only use your personal information for these purposes. Further details are provided later.
|How your personal information is used||What personal information we use|
|Creating a GetHarley Account and booking a consultation|
|Creating a GetHarley account profile.||Name, phone number, email address, date of birth, and password.|
|Booking a consultation|
|Matching you with a clinician.||Reasons why you want to have a consultation, clinician preferences, availability times. We also use health-related information: including whether you are on medication, and a photo of your skin.|
|Facilitating an appointment with a clinician. This includes providing your details to the clinician and arranging the consultation.||First name, last name, email address, date of birth, reasons for wishing to consult with the clinician, clinician recommendation preferences, whether you are on medication (and details), other information you have provided, and a photo of your skin.|
|Purchasing products from GetHarley|
|Purchasing products and delivery||The products you have ordered, delivery address, order number, telephone number, email address and limited credit card transaction details (date of transaction and masked credit card details).|
|Managing our services|
|Communicating with you as a client using our services (not direct marketing)||All personal information described above (but not your health information).|
|Dealing with your enquiries|
|Exercising our legal rights and complying with legal obligations|
|Administration, quality, and training|
|System and product development|
|Sending you reminders about our products, including when you run out, provide you with our latest offers and information, and keep you up to date with GetHarley.||Name, email address; WhatsApp profile; telephone number; contact details; interest preferences.|
|Digital marketing programme management||Name; email address; phone number and other personal information described above (but not your health information).|
GetHarley allows you to easily access some of the world’s best skincare clinicians online. Once you have registered with us and booked a consultation, or your clinician enrols you onto GetHarley in-clinic, your clinician will assess your skin and recommend personalised regimens consisting of highly effective, premium pharmaceutical grade products delivered to your door, as well as in-clinic treatments.
When you use GetHarley, we only use your personal information to:
- connect you with a clinician;
- arrange a consultation with that clinician;
- supply you with the products you have ordered; and
- manage the GetHarley business.
Your clinician uses GetHarley to record your recommendations, develop a skin-care plan and send these to you. They also use GetHarley to help provide you further advice and recommendations when you need it. When GetHarley uses your personal information in connection with these activities, this is under the instruction of your clinician who is responsible for your personal information (see “How the clinician uses your personal information” below).
We do not use or share your personal information except as set out in this statement. We never sell your personal information.
Our full details, including how you can contact us, can be found at the end of this statement.
How the clinician uses your personal information
GetHarley does not provide medical services or clinical advice. Only your clinician can do this. Your clinician will collect and use your personal information in connection with your consultation, some of which GetHarley may use on the clinician’s behalf, and under their instruction, as part of GetHarley’s services to the clinician. Ask your clinician for their privacy statement detailing how they use your personal information, which will include information we might provide to them as detailed in this statement.
Where GetHarley gets your personal information
You may have signed up to GetHarley directly, or you may be signed-up in-clinic by your clinician. Where you sign-up directly, your personal information is provided by you using our on-line forms. When you are signed-up by your clinician, they will provide your personal information to GetHarley.
What GetHarley uses your personal information for
Account creation and maintenance
You can create an account with GetHarley directly on GetHarley.com, or your clinician can create it on your behalf during a consultation. The information needed to create an account is your name, phone number, email address, and date of birth. We may also ask you to create a secure password for accessing GetHarley and protecting your account.
Booking a consultation and matching you with a clinician
When you book a consultation with a clinician through GetHarley.com we will ask you for the reasons why you want to have a consultation, clinician preferences, and availability times. Subject to your explicit consent, we also ask for some health-related information, such as whether you are on medication, and for a photo of your skin.
These details are used to allow us to match you with the right clinician (unless you are booking directly with a clinician through their website). They are then provided to the clinician to ensure they have the information they need for the consultation. However, if you do not consent to providing us with this information, we will not be able to provide our services to you because we will not be able to match you with a clinician.
Your clinician will develop a skincare plan for you, which will be provided to you by GetHarley on the clinician’s behalf. This will include the products recommended for you, and personalised instructions on your skincare regimen.
As you clinician is responsible for how we use your personal information on their behalf when sending you the skincare plan, ask for their privacy statement to get further details.
Purchasing products from GetHarley
Once you have completed your consultation, you can buy your skincare products directly from GetHarley. When purchasing our products, we need to use your name, delivery address, telephone number, and email address. We will provide you with an order number, as well as details of the products you have ordered.
We do not collect payment details from you directly as payments are processed using our payment partner Stripe. However, Stripe do provide GetHarley with your unique customer ID, as well as your masked credit card information.
GetHarley Skincare Concierge Service
We know that as you progress through your skincare regimen you will have questions you want ask. We will use your personal information (as described at the beginning of this statement) on behalf of your clinician so they can provide you advice on products, product use and your skincare plan.
As you clinician is responsible for how we use your personal information on their behalf through the skincare concierge service, ask for their privacy statement to get further details.
Other uses of your personal information
Communicating with you as a client using our services (not direct marketing)
We will use your personal information to communicate with you (including by email, ‘phone, text and messaging applications) in connection with the provision of our services to you as a client.
Enquiries and customer care
If you enquire about GetHarley or our services, or contact us in respect of customer care issues (such as undelivered products), we use personal information you provide as part of that enquiry, or in subsequent related communications, only for the purposes of:
- contacting you in connection with our services;
- providing you with information our services; and
- responding to, progressing, and managing your enquiries and requests.
Legal rights and obligations
We will also use your personal information in connection with the exercise of our legal rights. To the extent necessary, we will use and retain your personal information to fulfil our legal obligations.
Administration, quality, and training
To allow us to administer our business (including in accordance with legal or other obligations we must meet), and our relationship with you, we will use your personal information. It will also be used in connection with the maintenance of our quality standards and the provision of internal training.
System and product development
Your personal information is also used in the development and improvement of our systems and products. We will aggregate personal information for this purpose so it can no longer be associated with you. We will also provide your personal information to third parties so they can provide services to us in respect of system and product development or improvement, but they will only be able to use your personal information in accordance with our instructions.
We will use your name, email address and phone number to create digital marketing custom audience profiles. To do this we will provide these details to digital marketing providers, like Google, Bing, Facebook, Pinterest, and RTB House. When creating custom audiences, the providers are obliged to use this information only to provide services to GetHarley, and not for any other purpose.
Where you have asked us to send you product reminders, our latest offers and information, and updates on GetHarley, we will use your name, email address and phone number. We will also use your other personal information (but not health information) to ensure the information we send you is relevant.
Who else gets your personal information?
We provide your personal information to clinicians in the ways described above for the purposes of facilitating consultations and as part of providing you with our Skincare Concierge Service. Ask your clinician for their privacy statement to get details on how they use your personal information.
To help us provide our solutions and services, we share your personal information with third parties who provide services to us, including:
- information technology and information services providers (including WhatsApp, and Calendly);
- other third-party service providers; and
- professional and other third-party advisers.
These third parties can only use the personal information we share to provide their services to us or to support our delivery of our services to you.
Security of personal information and where it is kept
We use strict procedures and security features to ensure the confidentiality and security of your personal information. This includes using third party hosting services that meet the highest international security and resilience standards. Your personal data is generally kept in the United Kingdom or the European Union. Your personal data may be transferred to the United States in connection with our use of WhatsApp and Calendly. If you would like further details on the safeguards we have employed in respect of these transfers, please contact us.
How long we retain your personal information
We only keep your personal information for as long as is necessary for the purposes we collect and use it.
Lawful use of your personal information
We only use your personal information if lawfully we can do so. Your use of GetHarley’s services is subject to our terms and conditions, and we use your personal information to perform our contract with you. The following table details the exceptions to this:
|Use of personal information||Lawful basis for our use of your personal information|
|Using health-related information to match you with a clinician and facilitate the consultation:||Whilst we need to use your health-related information to perform our contract with you, we only use it in this way if you have also provided explicit consent. If you do not provide your explicit consent, we will not be able to provide our services to you. This is because we will not be able to match you with a suitable clinician and the clinician will not be able to prepare for the consultation.|
|Booking a consultation, matching you with a clinician, arranging the appointment with the clinician.||The use of your personal information is necessary for the purposes of performing our contract with you. Where information that is needed to perform our contract with you is not provided, this will mean we will not be able to provide the service to you.|
|Purchasing products from GetHarley||The use of your personal information is necessary for the purposes of performing our contract with you. Where information that is needed to perform our contract with you is not provided, this will mean we will not be able to process your payment, despatch or deliver our product(s) to you.|
Other uses of personal information:
To the extent the use of your personal information is not necessary for the purposes of performing our contract with you, this use of your information is in the legitimate interests of GetHarley to perform the activities described. Where information that is needed to perform our contract with you is not provided, this will mean we will not be able to meet our contractual commitments.
To fulfil our legal obligations and to exercise and defend our legal rights.
|Marketing||Where we use your personal information for digital marketing custom profiles, we do this in GetHarley’s legitimate interest. Where the creation of those profiles requires the setting of cookies and other technologies on your browser, we only do this where we have your consent to do so.
Where you have asked to be sent reminders, receive our latest offers and information and be kept up to date with all the latest at GetHarley, we do this in GetHarley’s legitimate interest, but we rely on your consent to send this information to you electronically.
Use of health-related information
If you want to withdraw consent for the use of your health-related information simply email us (email@example.com). However, this won’t affect our use of the personal information already collected with your consent.
Once you withdraw consent, we will not be able to collect or continue use your health-related information, which may affect the services we provide.
Consent and Legitimate interests
Where you have consented to the use of your personal information, you can withdraw that consent at any time in the ways indicated above. If you withdraw consent this will not affect our prior use of your personal information.
Where the lawful basis for using your personal information is based on legitimate interest, you can object to our use of your personal information in this way at any time. If you want to exercise this right, let us know by sending us a request preferably by email or in writing to the address given below.
Accessing, deleting, rectifying, and moving your personal information
You have the right to:
- access your personal information;
- rectify any incorrect personal information;
- limit how we use your personal information; and/or
- have your personal information transmitted to another data controller.
If you want to exercise these rights, let us know by sending us a request preferably by email or in writing. You may ask you need to provide additional information to verify and complete your request. Where your request is valid, we will complete it within thirty days, subject to any legal or other requirements that requires us not to complete your request, in which case we shall inform you of this where we are permitted to do so
Lodging a complaint
You can complain about our processing of your personal information with the UK’s Information Commissioner’s Office:
How do you contact us?
The data controller is 16HarleyCo Ltd (t/a GetHarley)
You can write to us at: F102 Ambassador Building, Embassy Gardens, London, SW11 7BT, United Kingdom.
If you wish to contact our data protection officer in relation to our use of your personal information, you can do so by emailing: firstname.lastname@example.org
This Statement is effective from 25 July 2022. To see prior privacy statements, email us at the address given above.