1. Introduction

Harley Institute of Aesthetics ("Harley Institute", "we", "us" or "our") is committed to protecting and respecting your privacy and personal data.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you:

• Visit our website

• Enquire about our courses, programmes or services

• Apply for or enrol on a programme

• Attend our training, clinical practice or fellowship programmes

• Become a patient or model in connection with practical training

• Contact our academic, admissions or support teams

• Subscribe to our communications

• Participate in events, consultations, assessments or research activities

• Otherwise interact with Harley Institute of Aesthetics

Harley Institute of Aesthetics is a trading division of the European School of Applied Sciences, dedicated to providing specialised professional education and training.

We take appropriate steps to ensure that personal data is handled lawfully, fairly, transparently and securely.

2. Who We Are
For the purposes of applicable data protection legislation, the organisation responsible for processing your personal data will depend on the nature of your relationship and interaction with us.

Harley Institute of Aesthetics operates as a trading division of the European School of Applied Sciences.

Our contact details are:

Harley Institute of Aesthetics
Hamilton House
4 Mabledon Place
4th Floor, Bloomsbury
London WC1H 9BB
United Kingdom

Email: [email protected]
Telephone: 020 3475 3758

If you have any questions about this Privacy Policy or how we process your personal data, please contact us using the details above.

3. Personal Data We May Collect
The personal information we collect depends on how you interact with us.

3.1 Information You Provide Directly
We may collect:

• Full name

• Date of birth

• Email address

• Telephone number

• Postal address

• Nationality and country of residence

• Professional occupation

• Educational background

• Professional registration details, where relevant

• Employment information

• Qualifications and training history

• Curriculum vitae or supporting documentation

• Application and enrolment information

• Payment and transaction information

• Course attendance information

• Assessment and examination records

• Academic progress and achievement information

• Communications and correspondence with us

• Feedback, surveys and reviews

• Any other information you voluntarily provide

3.2 Special Category Personal Data
Depending on the programme, service or activity involved, we may need to process additional categories of information. This may include information relating to:

• Health

• Medical history

• Allergies

• Disabilities or accessibility requirements

• Clinical suitability

• Professional fitness or regulatory requirements

• Other information necessary to protect your health, safety or wellbeing

We will only process special category personal data where there is an appropriate legal basis and, where required, an additional condition for processing under applicable data protection law.

4. Information Collected Through Our Website
When you visit our website, we may automatically collect certain technical and usage information. This may include:

• Internet Protocol (IP) address

• Browser type and version

• Device information

• Operating system

• Approximate location

• Pages visited

• Date and time of visits

• Referring website or source

• Website interactions

• Cookie information

• Other technical information relating to your use of our website

This information may be collected through cookies, analytics technologies and similar tools.

5. How We Use Your Personal Data
We may use your personal data for the following purposes.

5.1 Course Enquiries and Admissions
We may use your information to:

• Respond to your enquiry

• Provide information about relevant programmes

• Arrange consultations

• Process applications

• Assess eligibility and entry requirements

• Verify qualifications or professional information where appropriate

• Communicate admissions decisions

• Complete enrolment procedures

• Provide student support

5.2 Delivery of Education and Training
We may process your personal information to:

• Deliver courses and programmes

• Provide access to online learning platforms

• Maintain academic records

• Record attendance

• Organise practical training

• Assess academic and practical performance

• Issue certificates or other records of achievement

• Provide academic support

• Monitor progression

• Maintain quality assurance standards

5.3 Clinical Training and Practical Activities
Where you participate in practical, clinical or fellowship-based education, we may process relevant information to:

• Assess suitability for participation

• Plan and deliver supervised training

• Maintain safety and clinical records where applicable

• Manage attendance and competency assessments

• Document practical experience

• Support clinical governance

• Manage incidents or concerns

• Protect the health and safety of participants, staff, patients and models

5.4 Models and Clinical Participants
If you apply to become a model or participate in a clinical training activity, we may collect and process information necessary to:

• Assess your suitability

• Understand relevant medical information

• Arrange appointments

• Provide treatment or services where applicable

• Maintain appropriate records

• Communicate before and after appointments

• Support safety and clinical governance

• Manage follow-up where appropriate

We may request explicit consent where this is required for particular activities, including the use of photographs or clinical images.

6. Our Legal Bases for Processing
We process personal data only where we have an appropriate lawful basis. Depending on the circumstances, this may include:

Contract
Where processing is necessary to:

• Process your application

• Enrol you on a programme

• Deliver education or training

• Provide services you have requested

• Fulfil our contractual obligations

Legitimate Interests
Where processing is necessary for our legitimate interests, provided that your rights and freedoms do not override those interests. This may include:

• Improving our programmes and services

• Managing enquiries

• Maintaining security

• Preventing fraud

• Developing our business

• Quality assurance

• Protecting our legal interests

• Communicating with current or prospective learners where appropriate

Legal Obligation
Where processing is necessary to comply with applicable legal, regulatory, professional, accounting or reporting obligations.

Consent
Where you have provided consent for a specific purpose.

Where we rely on consent, you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.

7. Marketing Communications
We may send you information about:

• Courses and qualifications

• Training programmes

• Fellowships

• Events

• Educational opportunities

• Professional development

• Relevant services

• News from Harley Institute of Aesthetics

Where required by law, we will obtain your consent before sending direct marketing communications.

You may unsubscribe from marketing communications at any time by:

• Using the unsubscribe option included in our communications

• Contacting us at [email protected]

Please note that even if you opt out of marketing communications, we may still send you important administrative, academic, contractual or service-related communications.

8. Sharing Your Personal Data
We may share personal information where necessary with trusted third parties and service providers. These may include:

• Educational and academic partners

• Universities and validating institutions

• Accreditation and awarding organisations

• Online learning platform providers

• Payment service providers

• Information technology providers

• Website and hosting providers

• Professional advisers

• Clinical partners and training venues

• Assessment and examination providers

• Regulatory or professional bodies

• Insurance providers

• Government authorities

• Other organisations where disclosure is required by law

We only share personal information where there is a legitimate reason to do so and where appropriate safeguards are in place.

We do not sell your personal data to third parties.

9. International Transfers
Some of our service providers, partners or systems may process personal information outside the United Kingdom.

Where personal data is transferred internationally, we will take appropriate steps to ensure that the transfer is carried out in accordance with applicable data protection legislation and that appropriate safeguards are implemented.

10. Photographs, Videos and Clinical Images
During training, events, practical sessions or clinical activities, photographs, videos or other recordings may be created. Depending on the circumstances, these may be used for purposes including:

• Clinical documentation

• Academic assessment

• Training and education

• Quality assurance

• Professional portfolios

• Research

• Marketing and promotional activities

Where images are intended for marketing, promotional or other non-essential purposes, we will obtain appropriate permission or consent where required.

Clinical images and records will be handled in accordance with applicable confidentiality and data protection requirements.

You should not assume that your image will be used publicly unless you have been informed of the intended use and appropriate permission has been obtained.

11. How Long We Keep Your Information
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected.

Retention periods may depend on:

• The nature of your relationship with us

• Academic requirements

• Contractual obligations

• Legal or regulatory requirements

• Professional standards

• Clinical governance requirements

• Financial and accounting obligations

• The need to establish, exercise or defend legal claims

When personal data is no longer required, we will securely delete, anonymise or otherwise dispose of it in accordance with our retention procedures.

12. Data Security
We take appropriate organisational and technical measures to protect personal data against:

• Unauthorised access

• Unauthorised disclosure

• Accidental loss

• Misuse

• Alteration

• Destruction

• Other unlawful processing

These measures may include access controls, secure systems, staff procedures and other appropriate safeguards.

However, no method of transmitting information over the internet or storing electronic information can be guaranteed to be completely secure. While we take reasonable steps to protect your information, we cannot guarantee absolute security.

13. Your Data Protection Rights
Subject to applicable law, you may have rights in relation to your personal data. These may include the right to:

Access — Request access to the personal information we hold about you.
Rectification — Request correction of inaccurate or incomplete information.
Erasure — Request deletion of your personal information in certain circumstances.
Restriction — Request that we restrict the processing of your information in certain circumstances.
Objection — Object to certain types of processing, including processing based on legitimate interests and direct marketing.
Data Portability — Request the transfer of certain personal data to another organisation where technically feasible and legally applicable.
Withdrawal of Consent — Withdraw consent where we rely on consent as the legal basis for processing.

To exercise any of these rights, please contact us using the contact details provided in this Privacy Policy.

We may need to verify your identity before responding to a request.

14. Cookies and Similar Technologies
Our website may use cookies and similar technologies to improve functionality, analyse website performance and enhance your user experience.

Cookies may be used for purposes including:

• Essential website functionality

• Security

• Remembering preferences

• Website analytics

• Understanding visitor behaviour

• Improving our website and services

You can control or delete cookies through your browser settings.

Please note that disabling certain cookies may affect the functionality of our website.

Where required, we will provide appropriate information and obtain consent before placing non-essential cookies on your device.

15. Third-Party Websites
Our website may contain links to third-party websites, platforms or services.

We are not responsible for the privacy practices, content or security of third-party websites.

We encourage you to review the privacy policy of any third-party website before providing personal information.

16. Children and Young People
Our programmes and services are generally designed for adults and professionals.

Where we process the personal information of children or young people, we will take appropriate steps to comply with applicable legal and safeguarding requirements.

17. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in:

• Our services

• Our educational activities

• Technology

• Legal requirements

• Regulatory guidance

• Our data processing practices

Any updated version will be published on our website with a revised "Last updated" date.

We encourage you to review this Privacy Policy periodically.

18. Complaints and Concerns
If you have concerns about how we handle your personal data, we encourage you to contact us first so that we can attempt to resolve your concerns.

You can contact us at:
Email: [email protected]
Telephone: 020 3475 3758

You may also have the right to make a complaint to the relevant data protection supervisory authority.

For individuals in the United Kingdom, this is generally the Information Commissioner's Office (ICO). Our ICO number is ZC230341.

19. Contact Us
If you have any questions about this Privacy Policy or our handling of personal data, please contact:

Harley Institute of Aesthetics
Hamilton House
4 Mabledon Place
4th Floor, Bloomsbury
London WC1H 9BB
United Kingdom

Email: [email protected]
Telephone: 020 3475 3758