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Privacy policy

Last updated: 6 August 2026 (version 0.4)

1. Introduction

1.1 This Privacy Policy (together with our terms and conditions and any other documents referred to in it) describes the types of information that we collect from you (“you/your”) through your use of our website haloraapp.co.uk (the “Website”), how that information may be used or disclosed by us, and the safeguards we use to protect it. This policy covers haloraapp.co.uk only, and does not cover actualisedliving.com.

1.2 This policy applies to the Website only. It does not cover the Halora application, which is not yet publicly available. A separate privacy policy will be published for the application before anyone uses it, and will be provided to every participant in any pilot beforehand.

1.3 Halora is a shared care-coordination service, currently in development. Our Website explains what it is, and allows you to contact us, join our waiting list, or ask to take part in a pilot.

1.4 Our Website may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

1.5 We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our Website, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Website is deemed to be acceptance of such changes, so please check periodically for updates.

1.6 This Privacy Policy was last updated on 6 August 2026.

1.7 If you have any comments on this Privacy Policy, please email them to admin@actualisedliving.com.

1.8 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. Who we are

2.1 Halora is owned and developed by Actualised Living Limited. We are a private limited company registered in England and Wales. We are not a charity, a community interest company or a public body. Here are the details that the UK General Data Protection Regulation (“UK GDPR”) says we must give you as a ‘data controller’:

  • Our company name is Actualised Living Limited, company number 07805219.
  • Our registered address is 55 Loudoun Road, St. John’s Wood, London, NW8 0DL.
  • Our Website address is haloraapp.co.uk. Our email address is admin@actualisedliving.com.
  • Our nominated representative for data protection is Barbara Marchant, who can be contacted at admin@actualisedliving.com.

2.2 We respect your right to privacy and will only process personal information about, or provided by, you in accordance with the Data Protection Legislation, which for the purposes of this Privacy Policy shall mean the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (as amended), and any successor or other applicable privacy legislation, in each case as amended or updated from time to time.

2.3 In respect of everything described in this policy, Actualised Living Limited is the data controller.

3. What we may collect

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

  • Identity Data includes first name, last name, and, where you tell us, your role or organisation, and your relationship to a person who might be supported through Halora.
  • Contact Data includes email address, telephone number and postal address.
  • Enquiry Data includes the content of any message you send us through a form on the Website or by email, and our reply.
  • Waiting List Data includes your name, your email address and any optional details you choose to give us, such as your postcode area, your role, or whether you would like to take part in a pilot.
  • Pilot Application Data includes your contact details, your relationship to the person who would be supported, and enough about the situation for us to judge whether a pilot would be a fit.
  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and approximate location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website.
  • Usage Data includes information about how you use the Website, including pages visited and how you arrived.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences. We do not currently track whether you have opened or clicked one of our emails. If we introduce that in future, we will update this policy before we begin.
  • Cookies Data. Like many websites, our Website uses cookies to gather information about visitors and visits. Please refer to section 5 for information about the cookies we use.
  • Recruitment Data. Where you apply for a role with us, this includes your name, contact details, working history, references and any relevant records checks.
  • Analytics. We may use third-party analytics services to evaluate use of the Website, compile reports on activity, and analyse performance. These third parties use cookies and similar technologies to provide us with that data.

3.3 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 in law, as it does not directly or indirectly reveal your identity. If we combine Aggregated Data with your personal data so that it can identify you, we treat the combined data as personal data and use it in accordance with this Privacy Policy.

3.4 We do not seek Special Categories of Personal Data through the Website. This includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, and genetic or biometric data. Nor do we seek information about criminal convictions and offences, except where a records check is required in the course of recruitment.

3.5 Please do not send us health information, or details about a named person’s care, through the Website. If you need to tell us something sensitive, contact us at admin@actualisedliving.com and we will arrange a more appropriate way. Where you do include such information in an enquiry, we will hold it only for as long as we need to reply to you, and we will handle it in accordance with the Data Protection Legislation.

3.6 Under the UK GDPR we will ensure that your personal data is processed lawfully, fairly and transparently, without adversely affecting your rights. We will only process your personal data where at least one of the following applies:

a) you have given consent to the processing of your personal data for one or more specific purposes;

b) processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract;

c) processing is necessary for compliance with a legal obligation to which we are subject;

d) processing is necessary to protect the vital interests of you or of another natural person; and/or

e) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where those interests are overridden by your fundamental rights and freedoms.

3.7 If you give us personal information about another person, for example when enquiring on behalf of a relative, you are responsible for ensuring that the contents of this Privacy Policy are brought to their attention.

4. How we may collect and use your data

4.1 We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information through:

a) direct interactions: information you give us by filling in a form on the Website, or by corresponding with us by post, telephone, email or otherwise, including when you make an enquiry, join our waiting list, ask to take part in a pilot, request marketing, give us feedback or complete a survey;

b) automated technologies: as you browse the Website, through cookies, server logs and similar technologies; and

c) third parties: including our suppliers and analytics providers, and, where you apply for a role with us, recruitment consultants, previous employers, referees and records-check agencies.

4.2 We may use your information in the following ways:

a) to reply to your enquiry;

b) to add you to our waiting list, and to tell you when Halora becomes available;

c) to assess an application to take part in a pilot, and to contact you about it;

d) to present the content of the Website effectively to you, and to personalise your experience of it;

e) to administer a survey, feedback exercise or other feature of the Website;

f) where you have opted in, to send you periodic emails about Halora. If you no longer wish to receive them, see section 9;

g) to understand how the Website is used, and to improve it;

h) to consider your application for a role with us; and

i) to comply with the law, and to assist a government, regulatory or law enforcement body where we are required or authorised to do so.

4.3 We do not use any information collected through the Website to train, develop or improve any artificial intelligence model.

4.4 If you are already in contact with us, we will only contact you electronically about matters similar to those we have already discussed. If you are new to us, you will only be contacted if you have agreed to it.

4.5 If you do not want us to use your personal data for any of the purposes set out in this section, you can tell us at any time by contacting us at admin@actualisedliving.com, and we will delete your data from our systems. You acknowledge that this may limit our ability to reply to you or to keep you informed about Halora.

4.6 We will only use your personal data when the law allows us to. Most commonly this will be where it is necessary for our legitimate interests, replying to you, and running and improving the Website, and your interests and fundamental rights do not override those interests; where we need to comply with a legal or regulatory obligation; or where you have given consent.

4.7 We do not rely on consent as a legal basis for processing your personal data other than in relation to marketing communications and optional cookies. You have the right to withdraw consent at any time by contacting us at admin@actualisedliving.com, and we will either delete your data from our systems or move your data to our unsubscribe list, as appropriate. Withdrawing consent does not affect the lawfulness of processing carried out beforehand.

4.8 With your permission, and where permitted by law, we may use your data for marketing purposes, which may lead to us contacting you by email or telephone with information and news about Halora. We will not send you unsolicited marketing or spam, and we will not disclose your information to a third party so that they can market to you. We will take all reasonable steps to comply with our obligations under the UK GDPR and the Privacy and Electronic Communications Regulations 2003, as amended.

5. Cookies

5.1 All cookies used by and on our Website are used in accordance with current UK cookie law.

5.2 The Website itself sets no cookies. There is no login, so there is no session cookie. Your cookie choice is kept in your browser’s local storage, on your device only, and is never sent to us. This is strictly necessary and does not require your consent.

5.3 Optional cookies, including analytics and any embedded video or maps, are set only if you agree on the cookie banner. You may change your mind at any time using the “Cookie settings” link in the Website footer, and you may block or delete cookies through your browser, although parts of the Website may then not work properly.

5.4 Our analytics provider is Google Analytics 4, supplied by Google. With your consent it sets two cookies, _ga and _ga_M38W2VQGCD, each retained for two years unless you remove them sooner. If you withdraw consent, collection stops and both cookies are deleted. Google Analytics 4 does not record or store IP addresses.

5.5 The only other third party that may set cookies is YouTube, and only if you consent to embedded video and then play our video. The player is loaded from youtube-nocookie.com. Our fonts are served from this Website rather than from a third party, and we use no maps, chat or advertising technologies.

6. Where we store your data, and security

6.1 Personal data that you send us through the Website, such as an enquiry or a waiting list sign-up, is stored in the United Kingdom, and processing takes place in the United Kingdom or the European Economic Area. Analytics data is handled differently, and is described in section 6.2.

6.2 One supplier processes personal data outside the United Kingdom and the EEA. If you consent to analytics cookies, Google Analytics receives the data at a regional collection centre in the UK or the EEA, where your IP address is used to derive an approximate location and is then discarded, and forwards the remaining data to Google’s global infrastructure for processing. No other supplier we use processes personal data outside the United Kingdom.

6.3 Where it is necessary for a supplier to process personal data outside the United Kingdom or the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be here. Such steps include the use of the UK International Data Transfer Agreement, or the International Data Transfer Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment. For Google we rely on the data protection terms that Google provides to its Analytics customers, which incorporate the International Data Transfer Addendum to the EU Standard Contractual Clauses.

6.4 Data security is of great importance to us. To protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the data collected through the Website. The Website is served over HTTPS, and personal data is encrypted in transit and at rest.

6.5 We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality. Access is protected by multi-factor sign-in.

6.6 We have put in place procedures to deal with any suspected personal data breach. We will assess a suspected breach within 24 hours, notify the ICO within 72 hours where we are legally required to do so, and tell you in plain language if there is a risk to you.

6.7 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure. You are advised to take suitable precautions when transmitting data to us via the internet.

6.8 If you set a password on the Website, you must keep it confidential and must not share it.

6.9 We will keep personal data for no longer than is necessary. Our current retention periods are: enquiries and our replies, 24 months after the conversation ends; waiting list subscribers, until you unsubscribe and then 6 months so that we do not contact you again in error; pilot applications not taken forward, 12 months; server and security logs, 12 months; analytics, 2 months for event data and 14 months for user data, the latter reset each time you visit again; unsuccessful recruitment applications, 12 months. Records that we are required to keep for legislative, regulatory or accounting reasons are retained for as long as the law requires. We review our retention obligations to ensure we are not holding data for longer than we need to.

7. Disclosing your information

7.1 We are allowed to disclose your information in the following cases:

7.1.1 to a potential buyer, if we wish to sell our business or our company;

7.1.2 to other businesses in our group, if we have any;

7.1.3 where we have a legal obligation to do so, or in order to protect other people’s property, safety or rights; and

7.1.4 to others, in order to protect against fraud or credit risk.

7.2 We may contract with third parties to supply services to us or on our behalf. In some cases those third parties require access to some of your data. The third parties who have access to your information are:

  • Website hosting: Amazon Web Services (AWS), United Kingdom.
  • Form handling and email: Microsoft Azure, London, United Kingdom.
  • Analytics: Google Analytics, supplied by Google.
  • Mailing list: we do not currently use a mailing list provider.
  • Error monitoring: we do not currently use an error monitoring provider.

7.3 Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data is handled safely, securely, and in accordance with your rights, our obligations and the obligations of the third party under the Data Protection Legislation.

7.4 We do not sell personal information, and we do not use it to build advertising profiles.

8. Your rights

8.1 When you submit information through the Website, you may be given options to restrict our use of your data. We aim to give you strong controls over our use of your data, including the ability to opt out of receiving emails from us by using the unsubscribe link in any message.

8.2 Under the UK GDPR you have the right to:

a) request access to your personal data held by us, at no cost to you;

b) request the correction of your personal data;

c) request the deletion of your personal data, where we are not required to retain it;

d) request that your personal data be transferred to another person (data portability);

e) be informed of what processing is taking place;

f) restrict processing;

g) object to the processing of your personal data;

h) withdraw consent; and

i) complain to a supervisory authority.

8.3 You also have rights in respect of automated decision-making and profiling, as set out in section 11.

8.4 You have the right to ask us not to process your personal data for marketing purposes. We will usually tell you, before collecting your data, if we intend to use it for such purposes.

8.5 To exercise any of these rights, or if you have any other question about the Website or this Privacy Policy, please contact us at admin@actualisedliving.com. Please include your name, your contact details and a clear description of your request. We will acknowledge your request promptly and respond within one month. There is no charge. We may need to verify your identity first, so that information is not disclosed to the wrong person. If we are unable to do what you have asked, we will explain why.

9. Marketing and how to opt out

9.1 Every marketing email we send carries an unsubscribe link. You may also reply to any message, or write to us at admin@actualisedliving.com, and ask us to stop.

9.2 Opting out of marketing does not stop us replying to an enquiry you have made, or contacting you about a pilot application you have submitted.

10. Links to other sites

10.1 Please note that our terms and our policies do not apply to other websites that you reach via a link from our Website. We have no control over how your data is collected, stored or used by other websites, and we advise you to check the privacy policy of any such website before providing data to it.

11. Automated decision-making and profiling

11.1 Nothing on the Website makes an automated decision about you. Enquiries and pilot applications are read and assessed by a person.

11.2 In the event that we were to use personal data for the purposes of automated decision-making, and those decisions had a legal or similarly significant effect on you, you would have the right to challenge such a decision, to request human intervention, to express your own point of view, and to obtain an explanation of the decision from us.

11.3 The right described in section 11.2 does not apply where the decision is necessary for the entry into, or performance of, a contract between you and us; where the decision is authorised by law; or where you have given your explicit consent.

11.4 Where we use your personal data for profiling purposes, the following shall apply:

a) clear information explaining the profiling will be provided, including its significance and its likely consequences;

b) appropriate mathematical or statistical procedures will be used;

c) the technical and organisational measures necessary to minimise the risk of errors, and to enable any errors to be easily corrected, will be implemented; and

d) all personal data processed for profiling purposes will be secured in order to prevent discriminatory effects arising out of profiling.

12. Changes

12.1 If we change this Privacy Policy, we will post the changes on this page and update the version and date at the head of this document. If we decide to, we may also email you.

13. Your consent

13.1 By using our Website, and by way of acknowledgment, you consent to this Privacy Policy.

14. Governing law

This Privacy Policy is governed by the law of England and Wales.