Full Halo Privacy Notice
Company Name & Details: Full Halo Ltd, Company number: 17255853, Registered office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Company Contact Details: Sebastian Payne, Email: admin@fullhalo.com
Document: Privacy Notice (Including for use on the company website)
Topic: Data Protection
Date: 01/08/2026
Version: 1
The Company provides an online platform that connects individuals seeking wellbeing support with independent professionals, such as therapists, counsellors, coaches and other practitioners and/or advisers. The Company processes personal data, including special category data where relevant, so that it can operate the platform, facilitate enquiries and bookings, manage accounts, support communications between users and professionals, and provide related services. In doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from other sources such as online directories. The Company must have a legal basis for processing your personal data. For the purposes of work finding services, connecting you with independent professionals, their services and/or information, we will only use your personal data in accordance with this privacy statement. We will comply with current data protection laws at all times.
Contents
- Collection and use of personal data
- A) Purpose of processing and legal basis
- B) Legitimate interest
- C) Statutory/contractual requirement
- D) Recipients of data
- Information to be provided when data is not collected directly from the data subject
- Overseas transfers
- Data retention
- Your rights
- Cookies
- Login files
- Links to external sites
- Sale of the business
- Data security
- Changes to this privacy statement
- Complaints or queries
1. Collection and use of personal data
- Purpose of processing and legal basis
The Company will collect your personal data, which may include special categories of personal data, and will process your personal data for the purpose of providing access to its platform and related services. This includes, for example, creating and managing user and professional accounts, helping individuals search for and connect with professionals, facilitating enquiries, bookings and communications, managing professional profiles and availability, processing payments where relevant, updating our records, supporting customer service, improving our platform, and developing and managing our services and relationship with you.
If you have opted in, we may also send you marketing information and news via email/text. You can opt out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.
On some occasions we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
We must have a legal basis to process your personal data. The legal bases we rely upon to offer our support-finding services to you are:
- Your consent
- Where we have a legitimate interest
- To comply with a legal obligation that we have
- To fulfil a contractual obligation that we have with you
- Legitimate interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- Managing our platform, database and keeping records up to date;
- Providing access to the Company platform and related services;
- Helping users connect with professionals;
- Facilitating enquiries, bookings and communications;
- Contacting you to seek your consent where we need it;
- Giving you information about similar products or services to those that you will have used from us recently;
- Improving and managing our services and relationship with you;
- Protecting the security and integrity of the platform.
- Statutory/contractual requirement
The Company has certain legal, contractual and operational requirements to collect and process personal data. This may include information needed to create and manage your account, verify professional profiles, facilitate enquiries and bookings, process payments, manage communications, comply with applicable legal and regulatory obligations, respond to complaints or disputes, and meet safeguarding or safety-related requirements where relevant. Where special category data is processed, the Company will only do so where necessary and where a lawful basis and special category condition applies under data protection law.
We may need your personal data to enter into or perform a contract with you, to provide access to the platform and related services, and to comply with our legal obligations. If you do not provide the personal data we need, we may be unable to create or maintain your account, facilitate bookings or communications, process payments, verify professional information, or continue providing services to you.
- Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
- Professionals where this is necessary to facilitate enquiries, bookings, communications or the provision of services;
- Users of the platform where this is necessary to manage enquiries, bookings or communications;
- Payment service providers or payment intermediaries who process payments on our behalf;
- Technology, hosting, software and platform service providers who help us operate and maintain the platform;
- Auditors who are assessing the compliance and processes of the business to ensure its adherence to all relevant legislation and good practice guidance;
- Regulators, law enforcement agencies, safeguarding bodies or other authorities where we are legally required or permitted to share information.
2. Information to be provided when data collected not from the data subject
Categories of data: The Company has collected the following personal data on you:
Personal data:
- Name;
- Email address;
- Mobile number;
- Address or general location;
- Account login details;
- Profile information, including information provided by professionals about their qualifications, experience, services, availability and fees;
- Booking, enquiry and communications;
- Payment and transaction information;
- Reviews, feedback or support requests;
- Technical information, such as IP address, device information, browser type and how you use the platform;
- Any other information you choose to provide when using the platform.
Special categories of personal data:
- Information about mental health, emotional wellbeing, disabilities or support needs, where you choose to provide it;
- Health data, where you choose to provide it;
- Information about your sex life, where you choose to provide it;
- Information about sexual orientation, where you choose to provide it;
- Any other sensitive information you choose to provide through the platform or in communications with the company.
The Company sourced your personal data/special categories of personal data:
- You directly, when you create an account, complete a profile, make an enquiry, booking or otherwise use the Company platform;
- Professionals, where they provide information about their services, qualifications, experience, availability and fees;
- Users of the platform, where they submit enquiries, bookings, reviews or communications with the Company;
- Publicly available sources, including professional websites, online directories, social media profiles and public registers;
- Professional bodies, regulators or membership organisations, where we check or verify a professional’s registration, accreditation, membership, qualifications or professional status;
- Software, hosting, analytics, payment and other service providers who help us operate the platform;
- Cookies and similar technologies, as set out in our cookies section.
3. Overseas Transfers
The Company may transfer the information you provide to us to countries outside the UK and/or the European Economic Area (‘EEA’) where necessary to operate the platform and provide our related wellbeing services. We will take appropriate steps to ensure suitable safeguards are in place to protect your personal data in accordance with applicable data protection laws. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
4. Data retention
The Company will retain your personal data only for as long as is necessary for the purpose for which it was collected, including to provide access to the platform and related services, manage accounts, facilitate enquiries and bookings, process payments, respond to support requests, and comply with legal, regulatory, accounting or reporting requirements.
Different types of personal data may be retained for different periods depending on the nature of the data and the reason we hold it. For example, we may retain account, booking, payment and communication records with the Company for as long as necessary to manage our relationship with you, resolve disputes, comply with our legal obligations, and maintain accurate business records.
Where we process personal data or special category data based on your consent, we will retain that data only for as long as the consent remains valid or until the information is no longer required for the purpose for which it was collected, subject to any legal or regulatory obligations that require us to retain it.
Where a professional provides information about their qualifications, experience, services, registration, accreditation or professional status, we may retain this information for as long as their professional profile remains active and for a reasonable period afterwards where necessary for record-keeping, compliance, complaints handling, fraud prevention, or dispute resolution.
When personal data is no longer required, we will securely delete it, anonymise it or otherwise dispose of it in accordance with our data-retention practices and applicable legal requirements.
5. Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company processes on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Where you have consented to the Company processing your personal data and/or sensitive personal data, you have the right to withdraw that consent at any time by contacting Sebastian Payne, Email: admin@fullhalo.com. Please note that if you withdraw your consent to further processing, that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.
There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
6. Cookies
We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.
The table below explains the cookies we use and why.
Necessary and security cookies
| Cookie | Provider/domain | Duration | Purpose |
|---|---|---|---|
__cf_bm | fullhalo.com / Cloudflare | Session | Supports website security, traffic management and the identification of automated or malicious activity. |
cf_clearance | fullhalo.com / Cloudflare | Session | Records that a visitor has passed a Cloudflare security check so that repeated security challenges may not be required during the session. |
m | m.stripe.com / Stripe | 10 years | Supports Stripe’s payment, security and fraud-prevention functionality. |
wpl_user_preference | fullhalo.com | 1 year | Stores relevant user or platform preferences so they can be remembered on later visits. |
__stripe_mid | fullhalo.com / Stripe | 1 year | Supports payment processing, security and fraud prevention by distinguishing browser sessions or devices. |
__stripe_sid | fullhalo.com / Stripe | Session | Supports Stripe payment processing and fraud prevention during the current session. |
Analytics cookies
| Cookie | Provider/domain | Duration | Purpose |
|---|---|---|---|
sbjs_migrations | fullhalo.com | 6 months | Supports Sourcebuster tracking functionality and maintains compatibility between versions of its stored information. |
sbjs_current_add | fullhalo.com | 6 months | Stores information about the current source through which a visitor reached the website. |
sbjs_first_add | fullhalo.com | 6 months | Stores information about the first recorded source through which a visitor reached the website. |
sbjs_current | fullhalo.com | 6 months | Stores current website traffic-source and campaign information. |
sbjs_first | fullhalo.com | 6 months | Stores the visitor’s first recorded website traffic-source and campaign information. |
sbjs_udata | fullhalo.com | 6 months | Stores limited visitor and referral information used for website attribution and analytics. |
sbjs_session | fullhalo.com | Session | Stores information relating to the visitor’s current website session for analytics and attribution purposes. |
_ga | fullhalo.com / Google Analytics | 2 years | Helps distinguish users and collect statistical information about how the website is used. |
_ga_EZ8QJ6KNX8 | fullhalo.com / Google Analytics | 2 years | Helps maintain session information and measure use of the Full Halo website through Google Analytics. |
Functional and similar technologies
| Technology | Provider/domain | Duration | Purpose |
|---|---|---|---|
bmdb-worker-version | fullhalo.com | Persistent | Supports the operation or version management of browser-based messaging functionality. |
wpEmojiSettingsSupports | fullhalo.com / WordPress | Session | Checks whether the visitor’s browser can display emojis correctly and supports appropriate WordPress content display. |
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, please refer to our Cookie policy. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.
7. Login Files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
8. Links to external websites
The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.
9. Sale of business
If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business. Where the sale of the business results in the transfer of your details to a different data controller we will notify you of this.
10. Data Security
The Company takes every precaution to protect users’ information. The Company has implemented technical and organisational measures designed to protect personal data from unauthorised access, loss, misuse, alteration or disclosure. These measures include, where appropriate:
- Website protection and traffic filtering;
- Bot and spam protection;
- Secure managed website hosting;
- Website security monitoring and firewall protection;
- Role-based access controls;
- Restricted administrator access and permission controls;
- Strong password requirements for administrator and relevant user accounts;
- Secure messaging functionality, including encryption features, such as Browser Database Encryption and End-to-End Encryption;
- Limiting access to personal data to authorised persons who need it for their role;
- Ongoing website maintenance, plugin updates and security monitoring.
Only employees who need the information to perform a specific job (for example, admins, our accounts clerk or a marketing assistant) are granted access to your information.
The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/the Internet.
If you share a device with others, we recommend that you do not select the “remember my details” function when that option is offered.
If you have any questions about the security at our website, you can email Sebastian Payne, Email: admin@fullhalo.com
11. Changes to this privacy statement
We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.
12. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Sebastian Payne, Email: admin@fullhalo.com
You also have the right to raise concerns with the Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/make-a-complaint/, or any other relevant authority should your personal data be processed outside of the UK and you believe that your data protection rights have not been adhered to.