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Privacy Policy

Last updated: 29 September 2026

This notice describes implemented data flows and their limitations. It is not a certification of legal or clinical compliance. Retention schedules, processor arrangements and legal bases require qualified human review.

Who is responsible

Harbour Hubs Community CIC operates Harbour. For privacy requests, corrections, complaints or the status of a deletion request, contact admin@harbourhubs.com. This address is not an emergency service; delivery and response arrangements require owner verification.

What is processed

Account data includes email, password hashes, preferences and new-account 18+ self-declaration. Optional tools store saved memories, mood entries and notes, journal entries, calendar events, safety plans and assessment answers. Professional services may store bookings, messages, registration evidence, client records, notes, supervision records and financial references. Support enquiries, newsletter consent, notification settings, security logs and administrative audit records may also be stored.

AI messages and memories

Messages, bounded conversation context, preferred name and relevant memories may be sent to the AI provider to generate replies. Harbour does not provide a full server-side AI transcript history, but eligible user messages and short AI-generated summaries may be retained as persistent memories. Do not interpret this as a promise that message content is never stored. Optional persistent-memory controls affect future saving; turning them off does not erase earlier memories. Session-only and learning modes are distinct from persistent memory.

Temporary session memory is held in server processes and cleared through session controls; caches in another worker may survive until recycling. AI content can be sensitive health information. Harbour does not promise human monitoring or reliable risk assessment.

Providers and access

Professional notes are separate from the AI companion. An implemented portal is not evidence of an operating therapist network. Sponsors are not given access to private app or participant data through the support options.

Purpose, legal basis and international processing

Processing supports the requested account/tools, service communications, security and financial administration. Some content may be special-category health data. The controller must confirm the applicable legal bases, special-category condition, consent records and international-transfer safeguards with appropriate advice. Account creation alone must not be described as proof of valid explicit consent for every purpose. Provider copies may be processed outside the UK; locations and safeguards require verification.

Retention and deletion

Persistent memories, moods and journal entries remain until deleted; there is no comprehensive automatic retention-expiry schedule. Individual memory and mood deletion is account-scoped and also removes matching legacy copies. Active-account deletion removes account/profile, messages, moods, journal, calendar, safety data, access tokens and client file copies.

Retained exclusions: bookings, ledger/refund/referral/invoice records, professional clinical notes and treatment plans, safeguarding reports, audit records and deletion-request records remain restricted for human retention review, with identifiers still present. Professional clinical files can also remain. These records are not claimed to be anonymised. Record-specific retention periods, hold criteria and disposal responsibilities require owner approval; indefinite retention is not asserted to be lawful.

Submitting a deletion request is not confirmation of completed erasure. The operational aim is review within 30 days, not a coded automatic guarantee. File and database erasure are not one transaction; failures require retry. Provider copies, backups and device-only drafts require separate handling. No fixed seven-year automatic schedule or automatic provider/backup erasure is implemented.

Access and other rights

The account export combines implemented account and service records with both known client file stores. It excludes credentials and access secrets. Professional clinical records, safeguarding reports and audit data require a separate access review to protect other people's information; provider-held data and device-only drafts are not included. Contact us for a fuller access response, correction, erasure, restriction, portability, objection or withdrawal of consent where applicable.

You can raise concerns with the Information Commissioner's Office. Statutory rights and response obligations are not replaced by the technical limits described here.

Cookies, local storage and newsletters

Session cookies support authentication. Browser and mobile storage may hold per-account drafts, caches and preferences. Newsletter subscription is separate and optional, with occasional updates and no fixed sending schedule. Contact us to stop receiving updates.

Changes

The current notice is available at this address. Material changes and notification arrangements require owner review.