Hartley Privacy Policy

Last updated: July 18th, 2025

This Privacy Policy explains how Hartley collects, uses, stores, and protects your personal data when you use the Hartley mobile app.

Version history

1.0 June 12th, 2025 Initial version of the Hartley Privacy Policy created.

1.1 July 18th, 2025 Company number added

1. Data Controller

The data controller responsible for your personal information is:

HARTLEY TECHNOLOGY LIMITED

Company number: 16471418

Davidson House, The Forbury

Reading, Berkshire United Kingdom

RG1 3EU

info@hellohartley.co.uk

2. Purpose of this Policy

Hartley collects data via its app solely to help users run a smoother, more efficient household. Any information or documents you provide are used exclusively within your own account to deliver personalised features such as reminders, task tracking, and smart document insights.

We are committed to:

  • Keeping your personal data accessible only to your individual account

  • Maintaining secure household boundaries within the platform

  • Never using your data for external commercial purposes

Your uploaded information is used only to improve your personal experience within the app and is not shared outside your household context.

3. Who This Applies To

This Privacy Policy applies to all users of the Hartley mobile application within the United Kingdom.

4. What We Collect & Why

4.1 Types of Data We Collect

When you use the Hartley app, we may collect the following types of personal data:

  • Account & identity information: name, email address, and postcode

  • Household information: property type, ownership status, car registration (optional), and related metadata

  • Uploaded content: documents related to your household, such as insurance policies, warranties, utility bills, service receipts, etc.

  • Tasks & reminders: actions you create within the app to help manage your home

  • Usage data: app usage patterns, feature engagement, and interaction analytics

  • Chat data: questions, commands, and responses exchanged with Hartley (the assistant), used to personalise and improve your experience

This information is collected solely to support your household’s use of the app and to enhance the accuracy and usefulness of features such as document-based reminders, task suggestions, and AI-powered answers.

4.2 How We Collect Your Data

We collect data in the following ways:

  • Information you enter directly during account creation or onboarding

  • Responses you provide in in-app prompts or forms

  • Documents you upload manually

  • Data generated automatically through your use of the app (e.g. creating tasks, browsing features)

  • Conversations you initiate in the chat interface with Hartley

  • When applicable, public or open APIs (e.g. bin collection schedules or MOT records) may be used to enhance your household profile using location or vehicle data you provide

4.3 Legal Basis for Processing

We rely on the following lawful bases under UK GDPR to process your data:

  • Contract: We have entered into an agreement with you regarding usage of our app.

  • Consent: You provide consent when signing up and using core features of the app as we then connect you with the services of choice.

  • Legitimate interests: We have a legitimate interest in processing app usage data to analyse and improve the functionality and security of our service

5. How We Store & Share Your Data

5.1 Where Your Data Is Stored

Hartley stores your data using secure, cloud-based infrastructure provided by Amazon Web Services (AWS). Our primary hosting environment is located in the EU (Ireland region). In specific cases, such as when processing AI queries, we may use AWS AI services based in the United States. We transfer this data under the UK-US Data Bridge adequacy decision, and/or the International Data Transfer Agreement (IDTA) ensuring your data is protected to a standard equivalent to the UK GDPR. These services are only accessed when EU-based equivalents are not available, and we take steps to ensure that your data remains protected in line with applicable data protection laws.

5.2 Use of Third-Party Services

To deliver Hartley’s features, we make use of selected third-party providers. These include:

  • Cloud hosting & storage via Amazon Web Services (AWS)

  • AI processing APIs, such as LlamaIndex, to power intelligent features within the app

All third-party processors operate under strict Data Processing Agreements (DPAs) and are required to meet high standards of security and compliance.

5.3 Data Sharing

We do not sell or commercially share your data with third parties. However, we may share limited data in the following cases:

  • With infrastructure and processing providers under GDPR-compliant terms, solely for operating the app

  • With Yell (or other trusted service partners), only when you have provided explicit consent in the app. For example, if you search for a plumber and choose to connect with a service provider, we may share your contact details (email, phone, WhatsApp, etc.) with that provider for the specific purpose of helping you resolve a task.

You are always in control of whether and how this information is shared.

5.4 Data Retention

We retain your personal data only as long as you have an active Hartley account. If you choose to delete your account:

  • All personal data, documents, tasks, and household information are permanently deleted

  • We do not retain backups or archived copies after deletion

Your data is removed from our systems in line with our commitment to privacy and user control.

6. Your Rights & Choices

We believe your data should remain under your control. As a Hartley user, you have the following rights:

6.1 Access and Updating Your Information

You can access and update your personal information at any time via the Profile section of the app. This includes:

  • Your name, postcode, and household details

  • Uploaded documents, which can be added or deleted with immediate effect on your household profile

6.2 Data Deletion

If you no longer wish to use Hartley, you may request that your account and all associated data be permanently deleted.

  • Currently, deletion can be requested by contacting our support team at info@hellohartley.co.uk

  • We are working to introduce a self-service account deletion feature within the app in the near future

Once your account is deleted, all documents, tasks, and personal data will be erased and cannot be recovered.

6.3 Marketing Communications

Hartley does not currently send marketing communications. If we introduce marketing emails or messages in the future, we will ensure:

  • You can opt out at any time

  • All emails will include an unsubscribe link

  • You will retain full control over notification settings within the app

6.4 Data Portability & Access Requests

You have the right to request a copy of the personal data we hold about you. While we do not yet offer a self-service download option, you can:

  • Email us at info@hellohartley.co.uk to request a data export

  • We will respond to your request within 30 days, in accordance with UK GDPR requirements

6.5 Subsequent rights

You furthermore have the right to:

  • Restrict processing by requesting a temporary halt to the processing of personal data.

  • Object to direct marketing and processing.

  • Not to be subject to a decision with regards to automated processing that produces legal or similar effects.

  • The right to complain to the Information Commissioner's Office (ICO) if you are unhappy with how we have handled your data.

7. Security & Contact Information

7.1 How We Protect Your Data

Hartley takes your data security seriously. We use a combination of technical and organisational measures to protect your information, including:

  • App-level security: access to your Hartley account is protected by a personal passcode or biometric login (e.g. Face ID)

  • Encryption: all data is encrypted in transit and at rest

  • Access control: internal access to your data is restricted strictly to personnel who need it for operational purposes

  • Application monitoring: we actively monitor system health and security to detect and respond to threats quickly

While no system can ever guarantee 100% protection, we are committed to maintaining strong safeguards and improving them continuously.

7.2 Contacting Us

If you have any questions about this Privacy Policy, or if you would like to make a data request, please contact us at: info@hellohartley.co.uk

We will do our best to respond promptly and in line with our legal obligations.

7.3 Data Protection Oversight

Hartley has not appointed a formal Data Protection Officer at this time. However, privacy and data security are central to our product, and we treat all data-related requests with care, diligence, and respect.