![A secure stone vault with a warm interior](https://viacara.com/img/content/privacy-feature-light.webp)

# Privacy Policy

How ViaCara collects, uses and protects your personal data. Plain English, no legalese.

## Who we are

ViaCara Ltd is a referral platform that connects people in the United Kingdom with therapists, counsellors, coaches and hypnotherapists.

- **Company number:** 17138185 (England and Wales)
- **ICO registration:** ZC116531
- **Registered office:** 66 Paul Street, London, EC2A 4NA, United Kingdom
- **Data protection contact:** [dataprotection@viacara.com](mailto:dataprotection@viacara.com)

We are the data controller for the personal data described in this policy.

## Which laws apply

ViaCara is a UK-based service and we process personal data under the UK General Data Protection Regulation (UK GDPR) and the [Data Protection Act 2018](https://www.legislation.gov.uk/ukpga/2018/12/contents).

We offer ViaCara to people in the United Kingdom and the Channel Islands. We do not yet target the European Union or the European Economic Area. If you use ViaCara from there, we process your personal data under UK GDPR as set out below. When we begin to actively serve the EU or EEA, we will also comply with the EU General Data Protection Regulation (EU GDPR, Regulation 2016/679).

The UK holds an [adequacy decision](https://commission.europa.eu/document/download/ce635d68-1f0d-4a8f-bd02-f49029c03c90_en) from the European Commission (valid until December 2031), meaning personal data flows freely between the UK and the EU without additional safeguards.

### The Channel Islands

The Channel Islands are two jurisdictions with their own data protection laws. The Bailiwick of Guernsey includes Guernsey, Alderney, Sark and Herm. The Bailiwick of Jersey is separate.

If you use ViaCara from anywhere in the Bailiwick of Guernsey, we process your personal data under the [Data Protection (Bailiwick of Guernsey) Law, 2017](https://gov.gg/CHttpHandler.ashx?id=110559&p=0), regulated by the [Office of the Data Protection Authority](https://www.odpa.gg/) (ODPA). If you use ViaCara from Jersey, we process your personal data under the [Data Protection (Jersey) Law 2018](https://www.jerseylaw.je/laws/enacted/Pages/L-03-2018.aspx), regulated by the [Jersey Office of the Information Commissioner](https://jerseyoic.org/) (JOIC).

Both laws are modelled on the EU GDPR and give you the same rights set out in this policy, including the right to explicit consent before we process health-related information (see "Legal basis" below).

We have no office, staff or equipment in the Channel Islands. Neither island's local registration duty, nor Jersey's duty to appoint a local representative, applies to a service offered to island residents on that basis alone. We still meet the substantive protections in both laws.

The [Privacy and Electronic Communications Regulations 2003](https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guide-to-pecr/) (PECR) cover storage on your device and access to stored information. This includes cookies and browser storage.

Schedule A1 paragraph 4 allows storage that is strictly necessary for a service you request. We use this exemption for authentication, app security, conversation continuity and interface choices.

PECR regulation 22 governs marketing email. We send marketing email only to clients who opted in, and every such email has a one-click way to stop.

You can join our email updates with an email address alone. We create an account for that address and send you a confirmation link. Confirm your address through that link without signing in.

The link works for 24 hours. We send updates only after you confirm your address. You can submit your address again for a new link.

### EU representative

When we actively serve clients in the EU or EEA, we will appoint a representative under [Article 27 of the EU GDPR](https://eur-lex.europa.eu/eli/reg/2016/679/art_27/oj). Their contact details will be published here. In the meantime, EU and EEA residents can contact us directly at the data protection contact above.

## What we collect and why

### When you have a conversation with us

- **What you share**: the content of your conversation (text or voice). We use this to understand your needs and find the right professional for you
- **Voice data**: if you choose to speak with us, your audio is processed in real time by our speech-to-text service. Raw audio is not stored after the conversation ends. Only the text understanding is retained
- **Extracted preferences**: communication style, service type, practical requirements (such as availability, location and language), and optional preferences you express about the practitioner themselves (such as gender, sexuality, age bracket, ethnicity, faith, neurodivergence, or physical disability). You can decline to give any of these. Your preferences about the practitioner themselves guide our recommendations rather than exclude people outright. Retained while your account is active
- **What would make sessions easier, if you tell us**: adjustments such as a quieter room, step-free access, longer sessions or notes in writing, and whether you need each one every time. Only your own answer records them; we never work them out from what you say. You can decline. Retained while your account is active
- **Whether a reduced rate would help, if you tell us**: we may ask if a lower fee would help you. You do not have to answer. We do not ask why, and you never need to prove anything. We use your answer to check which fees fit your budget: a practitioner's reduced rate counts only if you said yes. A practitioner decides who their reduced rate is for. Retained while your account is active
- **Context about you that you choose to share**: when you disclose things about yourself, we keep what you asked for separate from what you disclosed, so you remain in control of how it is used. We will not use disclosed context to infer unstated preferences without surfacing what we've inferred to you first

### When you create an account

- **Email address**: to send you your recommendations and keep you updated. We do not share this with professionals until you choose to connect
- **Name**: if you provide one. Optional
- **Phone number**: optional, unless you book a telephone session, when it becomes required. We verify it with a one-time code sent by SMS. A verified number lets you recover your account if you lose access to your email, and your practitioner receives it on each booking so they can reach you directly. If you delete your account, we remove it from your booking history

### Before you book

- **What a professional sees first**: when your recommendations include someone, we ask whether they can take you on. We send them a short summary of what you are looking for and your preferred times. We also tell them why we came to them, such as that their fee fits your budget
- **How we check the summary**: before we send it, we check the summary for anything that could identify you, such as a name or a place. If we cannot take it out, we send no summary
- **What we hold back**: we do not send your email address or phone number before you book. An identity or experience preference shows only as one line saying they fit it. It never says which preference it was

### When you book a session

- **The session you booked**: the practitioner, the date, the time and the length of the session
- **How the session runs**: the format you chose, such as online, in person or by telephone
- **Whether it went ahead**: whether the session was completed or cancelled. Your practitioner sees the same record
- **How we connected you**: the shortlist that led to the booking and why your practitioner was on it. This is the same explanation you can open in the "How we connected you" drawer on your recommendations
- **Times your professional proposes**: after an introductory call, the dates, times, formats and prices your professional proposes for your first session. We keep them with your recommendation until you book, the times lapse or your professional withdraws them
- **How your mind works, if you told us**: when you shared a neurotype, such as being autistic or having ADHD, your practitioner sees it on the booking so they can prepare. If you also said how you know, they see that too: diagnosed, waiting for an assessment or recognised in yourself. You never need a diagnosis, and this never changes who we recommend
- **What would make sessions easier, if you told us**: your practitioner sees the adjustments you asked for on the booking, and which you need every time, so they can prepare

### When you send us feedback

- **Your note**: you can send us a note from your account or from a recommendation link, or tell us that a recommendation feels off. We add the address of the page and the reference of any error that just happened. For a recommendation, we add the parts you ticked. You can add a screenshot of the page, which you see before you send it. A note or a screenshot can hold details about your health, so we ask for your explicit consent each time. An AI language model sorts your words and the parts you ticked by type, such as a fault, a feature idea or a question, and notes their tone. We remove email addresses and phone numbers from your words before it reads them, and it never receives your account details or your screenshot. Apart from that, only the ViaCara team reads your note, to fix what went wrong and to answer you. The email that tells the team about a note carries this context, never your words or your screenshot. To withdraw your consent, write to the data protection contact and we delete your notes and screenshots

### When you browse our site

- **Browser context at the moment you start talking to us**: when you begin a conversation, we also receive a snapshot of your preferred language, approximate time of day, device type (mobile, tablet or desktop) and the referring page. This helps us make the conversation feel relevant: we can start in your language, suggest times that fit your day, and not ask questions the context already answers. None of this is sent to us unless you start a conversation, and it is treated as triage data under the retention rules below
- **Marketing campaign parameters (UTM)**: if you arrived from a link that contains `utm_source`, `utm_medium`, `utm_campaign`, `utm_term` or `utm_content`, we capture those values so we can see which content is actually helping people find support. We use this for our own tuning decisions, nothing more. These values are also only sent when you start a conversation and follow the same retention rules
- **Analytics**: we use a cookieless analytics service to count visits and button presses on our site and in your account. It processes your IP address and browser information to create a daily identifier. It does not store raw IP addresses

The analytics identifier changes each day and cannot link your visits across days. It is not linked to your ViaCara account.

In your account, the service receives only the kind of page, such as a booking page. It also receives the button name and the website you came from. It never receives which booking or person the page is about, or anything you type.

The provider keeps event and session records for up to three years to calculate statistics. Daily rotation does not delete those records.

- **Where you are, roughly**: the network that delivers our pages estimates your country from your IP address. Inside the UK it estimates which nation. The page you receive carries that estimate. A page listing helplines can then put the right nation first, because the numbers differ. Where a page uses it, every nation stays listed and you can pick another. The estimate is worked out while the page is sent to you. We never store it, never attach it to your account and never let it decide anything you cannot change

### To keep the service safe from misuse

- **Your IP address**: when you start a conversation, recover your account or join our updates, we count the requests from your IP address. A limit then stops one address from overloading the service or trying many guesses. Our conversation service keeps only a one-way code made from the address, and the secret behind that code changes every day

## What we do not collect

- We do not buy data from third parties
- We do not use tracking cookies or advertising cookies
- We do not use your data for advertising. UTM parameters we capture are used for our own tuning decisions (understanding which pages help people find support); we do not build advertising profiles from them, and we do not share them with ad networks. Separately, we sometimes run our own paid campaigns as a channel to reach people who need support; when we do, the ad platform receives only our account and campaign configuration, never your data
- We do not sell or share your data with anyone beyond what is needed to provide the service

## Practitioners: see the dedicated privacy notice

If you are a practitioner, this client policy does not cover the data flows that apply to you (waitlist signup, public-register discovery, profile import, billing, introductions). Those are documented separately in our [practitioner privacy notice](https://viacara.com/for/privacy/), alongside the [practitioner terms of service](https://viacara.com/for/terms/).

## Legal basis

| Purpose | Legal basis |
| --- | --- |
| Providing recommendations | [Article 6(1)(b)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): performance of a contract |
| Processing health-related information | [Article 9(2)(a)](https://eur-lex.europa.eu/eli/reg/2016/679/art_9/oj): explicit consent |
| Improving the service | [Article 6(1)(f)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): legitimate interests |
| Keeping a record of a booked session | [Article 6(1)(f)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): legitimate interests |
| Sending service updates | [Article 6(1)(b)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): performance of a contract |
| Sending ViaCara news you asked for | [Article 6(1)(a)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): consent |
| Researching published stories for our campaigns | [Article 6(1)(f)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): legitimate interests |
| Inviting feedback on the service | [Article 6(1)(f)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): legitimate interests |
| Reading a screenshot you add to your feedback | [Article 6(1)(a)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): consent, with [Article 9(2)(a)](https://eur-lex.europa.eu/eli/reg/2016/679/art_9/oj): explicit consent |
| Sorting a note or a recommendation you tell us feels off by type and tone | [Article 6(1)(f)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): legitimate interests, with [Article 9(2)(a)](https://eur-lex.europa.eu/eli/reg/2016/679/art_9/oj): explicit consent for any detail about your health |
| Reading and answering a note you send from your account | [Article 6(1)(f)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): legitimate interests, with [Article 9(2)(a)](https://eur-lex.europa.eu/eli/reg/2016/679/art_9/oj): explicit consent for any detail about your health |
| Protecting the service from misuse and abuse by limiting the requests from one IP address | [Article 6(1)(f)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): legitimate interests |
| Reviewing a recommendation you tell us feels off | [Article 6(1)(c)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): legal obligation, with [Article 9(2)(a)](https://eur-lex.europa.eu/eli/reg/2016/679/art_9/oj): explicit consent for any detail about your health |
| Keeping a record the law requires us to keep | [Article 6(1)(c)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): legal obligation |
| Telling you, within three months of an introduction, that we suspended that practitioner or could no longer confirm their registration | [Article 6(1)(c)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): legal obligation |
| Acting on a safeguarding concern where someone may be at risk | [Article 6(1)(d)](https://eur-lex.europa.eu/eli/reg/2016/679/art_6/oj): vital interests, with [Article 9(2)(g)](https://eur-lex.europa.eu/eli/reg/2016/679/art_9/oj): substantial public interest under paragraph 18 of Schedule 1 to the Data Protection Act 2018 |
| Keeping health-related evidence for a legal claim | [Article 9(2)(f)](https://eur-lex.europa.eu/eli/reg/2016/679/art_9/oj): establishing, exercising or defending a legal claim |

## Who processes your data

We use a small number of carefully selected service providers to operate the platform. All core infrastructure is hosted in the European Union.

| Category | Purpose | Data residency |
| --- | --- | --- |
| Content delivery and security | Serves pages, protects against attacks, manages DNS and estimates your country and UK nation from your IP address so a page can put the right helplines first | Global network (request metadata only) |
| WebRTC relay | Relays voice connections when direct peer-to-peer fails. Sees your IP address and connection metadata; does not process audio content | Global network (EU points of presence preferred) |
| Static content hosting | Hosts marketing site pages | EU |
| Object storage | Stores uploaded files (e.g. profile photos, booking documents and practitioners' training and insurance documents) | EU |
| Cloud hosting | Runs the application | EU (Frankfurt) |
| Database | Stores your account and profile data | EU (Frankfurt) |
| Language understanding | Processes your conversation to extract preferences, sorts the feedback you send by type and tone and reads training and insurance documents a practitioner uploads | EU and EFTA |
| Practitioner research | Researches a practitioner's public professional presence during onboarding, with their consent, so we can pre-fill their profile | Global network (public professional information only) |
| Outreach research | Finds practitioners' own public websites so that we can introduce our service to them. Receives a postcode district and a type of practice, never personal data from us. It reads public websites as a separate controller | Global network (public professional information only) |
| Voice processing | Converts speech to text in real time | EU and EFTA |
| Analytics | Measures page visits and button presses without cookies; processes IP addresses and browser information without storing raw IP addresses | EU |
| Error and service monitoring | Records technical faults and service logs so we can diagnose problems quickly (no conversation content) | EU |
| Email delivery and SMS | Sends booking confirmations, invitations, other service emails and the marketing emails you asked for on our behalf. Sends the one-time code that verifies your phone number by SMS | EU |
| Authentication | Manages your login securely via passkeys | EU |
| IP geolocation | Infers approximate country from your IP address for routing | Local offline database (no data sent to provider) |
| Postcode geocoding | Converts your postcode to approximate coordinates so we can recommend nearby practitioners | Open-source geocoding service (postcode only) |
| Address lookup and venue maps | Our servers send a practice address as a practitioner types it, to suggest addresses. When you view a venue, your browser loads the venue map picture from its EU servers | EU |
| Typography | Loads fonts for the website | Self-hosted (same-origin, no third-party CDN) |
| Advertising platforms | Runs our own paid campaigns to reach people who need support. Receives account and campaign configuration only, never audience lists or client/practitioner personal data | Global network (varies by platform) |

A detailed sub-processor list is available on request. Use the contact address at the top of this page.

Every provider we share your personal data with signs a written agreement that meets the requirements of [Article 28](https://eur-lex.europa.eu/eli/reg/2016/679/art_28/oj) of the UK GDPR and the EU GDPR. Most keep your data inside the UK or the European Economic Area, where no further safeguard is required by law. Where a provider may move your data further, its agreement puts a recognised UK transfer safeguard in place. That safeguard is often the International Data Transfer Addendum.

## People named in stories we research

To prepare our own campaigns, we read published news and research. A story can name a person, such as the author of a study or someone quoted in an article. We use only what the published source says, to check its facts and write about it. We never link it to a client or practitioner record. The research service we use receives this information under its own terms, as a separate controller.

We do this in our legitimate interest in telling people about our service. Telling each person directly would take a disproportionate effort, so we publish this notice instead. To object or to ask what we hold, use the contact address at the top of this page.

## How we use artificial intelligence

Our service uses artificial intelligence to help understand what you are looking for and connect you with someone who fits. Here is how it works and what it does not do.

**What the AI does.** When you have a conversation with us (by text or voice), an AI language model processes what you share to understand your needs, preferences and practical requirements. It extracts structured information, such as the type of support you are looking for, your communication style preferences and your availability, which is then used to find suitable professionals.

**Before a practitioner reads your summary.** An automatic check looks for anything in the summary that could identify you. When it finds something, an AI language model rewrites the summary without it, and the check runs again. If the check cannot clear the summary, the practitioner gets no summary.

**What the AI does not do.** The AI does not diagnose, treat or make clinical decisions. It does not assess your mental health. It does not decide who you should see. It does not recommend a therapy for a condition. When it describes an approach, it tells you what that approach is like, not whether it will help you. Its role is to listen carefully and understand what matters to you, so that the right information reaches the algorithm that ranks practitioners.

**How we connect you.** Once your preferences have been extracted, the ranking is performed by a rule-based, deterministic algorithm. AI does not perform the ranking. This algorithm scores practitioners against your stated needs using transparent, auditable logic. Every scoring factor and its weight can be inspected and explained. There are no opaque machine learning models anywhere in the ranking pipeline.

**Quality review.** We keep a short record of how the conversation progressed (which questions were asked, which signals were detected, how long each turn took) so we can improve the system. This record does not store the words you said. Your conversation itself is also kept for a short time for this review, and a team member may read it during that window. See the retention table below.

**Crisis safety.** If anything in your conversation suggests you may be at risk, we show you emergency contact details. When the signs look serious, they appear in the conversation straight away. We also keep a brief flag on your profile, never the words you said. It lets the professional you book with know to be attentive to your wellbeing.

Your conversation and your route to recommendations always continue. We never close the door on someone who has asked for help. This safety check is automatic and runs on each message you send; nobody watches your conversation as it happens.

**EU AI Act.** The [EU AI Act](https://eur-lex.europa.eu/eli/reg/2024/1689/oj) sets rules for AI systems offered in the EU. It can also apply when output from an AI system outside the EU is used there. This scope is set by [Article 2](https://eur-lex.europa.eu/eli/reg/2024/1689/art_2/oj).

We offer our client service in the United Kingdom and the Channel Islands. This does not by itself put us outside the Act.

We reviewed our current client conversation and referral service against the practices [Article 5](https://eur-lex.europa.eu/eli/reg/2024/1689/art_5/oj) prohibits. Our assessment did not identify a prohibited practice in that service. We do not infer emotion from your face or voice.

Our system helps you find a professional based on your stated preferences. It does not provide healthcare, make clinical assessments or replace professional judgement.

This is our own assessment, not independent certification or a legal opinion. It does not settle the risk classification of every part of our service. We review it when our service or the law changes.

## Automated decisions and how we connect you

When you finish a conversation with us, we suggest only practitioners who offer what you asked for. Their registration is checked and their insurance is current. Their account is active and can take an introduction. They offer the type of service you chose, for the people the sessions are for. You share a language, they work in a format you chose and their lowest single-session fee is within your budget or up to 15% above it. When you said your times are fixed, their times overlap yours, and for sessions in person they work close enough to you. A deterministic, rule-based algorithm then ranks those practitioners against the preferences you shared. It is not an AI decision and it does not make a healthcare or clinical judgement. You can open the "How we connected you" drawer on any practitioner's profile to see the main factors that contributed to that ranking, and you can tell us if a recommendation feels off.

The ranking decision is significant and taken by automated processing, so the UK GDPR requires safeguards around it. Under Articles 22A to 22C of the UK GDPR you have the right to be told about the decision, to make representations about it and to contest it. The "How we connected you" drawer is where you do those things. You also have the right to obtain human intervention on our part: if you want a person to look at how you were connected rather than the automated explanation, email the data protection contact at the top of this page and we will review it by hand.

### Ranking transparency

The main parameters that affect ranking are: how the practitioner works (how warm, structured and direct they are) against the working style you prefer, which counts most; their areas of focus against what you raised, which counts next; how fully you share a language; how much room the practitioner has in the coming week (the hours they set aside, less the calls already booked through ViaCara); the practitioner's booking and response history; distance, for sessions in person; and the therapy approaches you chose, with how well the practitioner's record backs each one. Smaller adjustments come from any identity or affinity preferences you chose to share, your first choice of format, availability overlap and budget fit. When you ask for more than one type of service, the top practitioner for each type moves up a little. Booking and response history has two parts: how often an introduction led to a first session and how often the practitioner answered our availability requests before they ran out (declining counts as an answer). It describes how a practitioner uses ViaCara, not how therapy went. Until a practitioner has had five introductions, it stays at a neutral value. A practitioner's lived experience of what you raised, or of a related condition, also counts. We do not use hidden numeric scores or opaque machine-learning models to order results. The "How we connected you" drawer explains every dimension that compares you with the practitioner. Booking and response history is about the practitioner alone, so this page describes it and the drawer does not show it.

Our page on [how we rank the professionals we suggest](https://viacara.com/how-ranking-works/) explains every factor in plain words.

### Artificial intelligence in your recommendations

Artificial intelligence is used to understand and structure what you tell us during the conversation. When you refine your recommendations, it can also describe therapy approaches that fit the way you have said you want to work. It never suggests an approach because of a condition or difficulty you have described, and an approach becomes one of your preferences only if you choose it. The ranking itself is performed by the deterministic algorithm described above. See the "How we use artificial intelligence" section for more detail on how AI handles your conversation.

## International data transfers

All core data (your profile, account and recommendations) is stored in the EU (Frankfurt, Germany). See "Who processes your data" above for how we safeguard data that travels beyond this. We never send your data to a country without adequate protection or an equivalent safeguard in place.

## Your rights

Under the UK GDPR and the [Data Protection Act 2018](https://www.legislation.gov.uk/ukpga/2018/12/contents), you have the right to:

- **Access**: request a copy of your data
- **Correction**: fix anything that is wrong
- **Deletion**: have your data removed. Deleting your account is one act, and we cannot undo it. The retention table below marks every record that stays
- **Restriction**: pause processing while you raise a concern
- **Portability**: receive your data in a machine-readable format
- **Objection**: tell us to stop processing for a specific purpose
- **Withdraw consent**: for health data, at any time. For marketing email, turn it off in your account at any time. Every marketing email also has a one-click link to stop

To exercise any of these rights, email the data protection contact at the top of this page. We will respond within one calendar month.

### What deletion does

Deleting your account closes it in the same act. Your conversation, its recommendations, the reasons behind them and your sign-in are destroyed together. We cannot undo it, and nobody can restore them.

If you come back to ViaCara later, you start a new conversation from the beginning. Your phone number leaves your booking history straight away.

Nine kinds of record stay behind, each for the period the table below gives:

- the record of each introduction to a practitioner
- your past bookings
- the documents shared for those bookings
- any payment record
- the security record of your sign-ins
- a dispute record
- a safeguarding record
- a request not to be contacted
- the record of this deletion request

Ask us and we will list what we kept for your account. Nothing that stays lets anyone rebuild your conversation or your recommendations.

## Data retention

| Data | Retention |
| --- | --- |
| Voice audio | Not stored; processed in real time and discarded |
| Triage conversation transcripts | Deleted within 30 days |
| The words you typed or said at each step | Removed within 14 days |
| Incomplete triage | Deleted within 14 days of last activity |
| Conversation quality records (no raw text) | Deleted within 90 days |
| What you send when a recommendation feels off | Deleted within 90 days |
| Feedback you send from your account | Deleted within 90 days |
| A screenshot you add to your feedback | Deleted within 30 days |
| Extracted preferences | While your account is active, deleted on request |
| Profiles in the deferred recommendations queue | Held for up to 60 days without renewal, then deleted |
| Records of a session you booked | Kept for six years after the session is completed or cancelled, in case either side raises a dispute. It stays if you delete your account, with your phone number removed |
| Documents for a session you booked | A signed intake form, contract or invoice is kept for six years after the session is completed or cancelled, in case either side raises a dispute. It stays if you delete your account |
| Record of an introduction | Which practitioner we introduced you to, your first name and when. Employment agency law requires us to keep it for one year after their last introduction. It holds nothing about your needs. It stays if you delete your account |
| Record of a notice we sent you about a practitioner | Which practitioner, when and why. Kept for one year after that practitioner's last introduction, like the record of an introduction. It stays if you delete your account |
| Payment records | ViaCara is free to you, so there is usually nothing here. Where a payment does exist, UK tax and accounting law require us to keep the record for six years from the end of that financial year. It stays if you delete your account |
| Email address | While your account is active, deleted on request |
| Name | While your account is active, deleted on request |
| Phone number | While your account is active. Removed from your booking history if you delete your account |
| Authentication credentials | Retained for the duration of your account and deleted on account closure |
| Phone verification codes | A record of each code we send is deleted within 30 days. We never store the code itself in readable form |
| Security record of sign-ins and account changes | Each event is kept for six years, then deleted. It stays if you delete your account, so we can investigate suspicious activity |
| IP addresses counted to limit misuse | Our conversation service keeps a one-way code, never the address, and the code changes every day. Our forms keep the address with a one-minute count, then delete it within two weeks |
| Live update delivery copies | Eligible for deletion after one day. An hourly cleanup removes expired copies. |
| Analytics | Event and session records are kept for up to three years. The daily identifier changes each day and is not linked to your account |
| Marketing consent and its withdrawal | Held until withdrawn; the withdrawal is kept as evidence |
| Updates-only account | If you join our email updates and never start a conversation, we delete the account when you stop the emails, or 24 months after you last confirmed the emails |
| Unconfirmed updates signup | If you never confirm your address, we delete it after 30 days |
| Marketing delivery log | The log of marketing emails we sent you is kept for 24 months, then deleted |
| Request not to be contacted | Kept for as long as we could otherwise contact you again, so that we do not. It stays if you delete your account |
| Record of a data rights request | Kept for three years after our final response. It stays if you delete your account, because it is the evidence we answered you |
| Dispute records | Where a dispute is raised, the related evidence is kept for six years after it is resolved or closed. It stays if you delete your account |
| Safeguarding records | Where a safeguarding concern is raised, the related records are kept for eight years after the case closes or the last safeguarding contact, whichever is later. This is our policy, not a legal minimum. It stays if you delete your account, and it keeps your name, so the concern can still be acted on |

## Cookies and browser storage

We do not use tracking cookies or advertising cookies. We use the cookies and browser storage below.

| Name | Purpose | Retention |
| --- | --- | --- |
| `hanko` cookie | Our sign-in service sets this first-party cookie. It keeps you signed in | 12 hours |
| `_viacara_session` cookie | Protects form submissions and carries short-lived app notices. It does not keep you signed in | Your current browser session |
| `vc_resume` browser storage | Holds your profile ID and private resume token. This lets you continue or refine your conversation | Used for up to 30 days. It stops working sooner if we delete the related profile. We remove an expired value when the site next checks it |
| `viacara-mic-tooltip-dismissed` browser storage | Remembers that you dismissed microphone help | Until you clear this site's data |
| `vc_nav_search_opener` browser storage | Carries your site-search query to a conversation when no search result fits | Until the home page opens the conversation, or you close the browser tab |
| `vc-theme` browser storage | Remembers your light or dark theme choice | Until you change the choice or clear this site's data |

Each item supports a feature you request. Schedule A1 paragraph 4 covers automatic authentication, security and saved website choices.

These uses are strictly necessary under that clause. PECR Regulation 6 therefore does not require consent. We do not show a consent banner.

None of these items tracks you across other websites.

Our analytics service uses no cookies or persistent visitor identifiers. It does not write to browser storage. It processes IP addresses as described above, without storing them.

To keep this promise, we do not embed third-party review widgets, which would set their own cookies. Where we show our review standing, it is a static figure with a plain link out to the review platform.

## Keeping in touch

Near the end of your conversation with us, after you give us your email address, we ask one question. Would you like occasional emails about ViaCara and new ways we can help? The choice is unselected until you make it. If you say nothing, we record nothing.

You can also join our email updates on our site with your email address alone, as described above.

If you say yes, or join that way, we email you now and then about ViaCara and what we offer. These emails never use what you shared in a conversation with us. We send them only to an email address you have confirmed.

You can stop at any time from your profile page or from the one-click link in any email. Stopping changes nothing about your recommendations or the service you receive.

## Reviews and feedback

After you book your first session we may email you once to ask how it felt to find support with us. This is optional, the email carries a one-click unsubscribe, and you can decline at any time. We ask only about your experience of the service, not about your health or your sessions.

If you choose to leave a review, you do so on an independent public review platform under its own terms. That platform, not us, controls the review you publish there, so please keep what you write to your experience of finding support and avoid sharing personal health details on a public page.

## Changes to this policy

We will update this page when our practices change. Significant changes will be communicated by email to active users.

## Complaints

If you are not satisfied with how we handle your data, you can contact us at the data protection contact at the top of this page or lodge a complaint with the [Information Commissioner's Office](https://ico.org.uk/make-a-complaint/) (ICO). If you are resident in the Bailiwick of Guernsey, including Alderney and Sark, you may lodge a complaint with the [ODPA](https://www.odpa.gg/). If you are resident in Jersey, you may lodge a complaint with the [JOIC](https://jerseyoic.org/).

**Last updated: October 2026**

**This policy is written in plain language and is periodically reviewed for accuracy.**

*These legal disclosures reflect the UK data protection framework, including the UK General Data Protection Regulation, the [Data Protection Act 2018](https://www.legislation.gov.uk/ukpga/2018/12/contents) and the [Data (Use and Access) Act 2025](https://www.legislation.gov.uk/ukpga/2025/18/contents).*