Privacy Policy

Harbour Lights Community Ltd is the data controller responsible for the personal information described in this Privacy Policy.

Harbour Lights Community Ltd
16 Duke Shore Wharf
106 Narrow Street
London
E14 8BU
United Kingdom

For questions about this Privacy Policy or the way we use your personal information, contact: contact@harbourlightscommunity.co.uk

When you contact us

When you use our contact form, we may collect:

• your name;
• your email address;
• the name of your organisation, if you choose to provide it;
• the type of enquiry you select; and
• any information you choose to include in your message.

We only ask for the information we need to understand and respond to your enquiry.

When you visit our website

We collect statistics about how our website is used. These show:

• how many people visit our website, how many visits take place and how many times each page is viewed;
• how long visitors spend on individual pages, articles, guides and resources;
• how visitors move between pages, including which pages are commonly viewed next and the most common routes through the website;
• which pages visitors leave the website from, and how often;
• how these figures change over time, by day, week, month and year; and
• how often our downloadable resources are downloaded, which are most popular and which pages they are downloaded from.

We use these statistics in aggregate to understand and improve Harbour Lights Community. We do not use them to identify visitors, build individual profiles or make decisions about particular people.

To produce these statistics, we use Matomo Analytics, which we host ourselves on our website's Hostinger server. Matomo uses first-party analytics cookies set by Harbour Lights Community. It also processes technical information sent by your browser, including your IP address, browser and device information, and information about the website pages and resources accessed.

We have configured Matomo to mask two bytes of visitors' IP addresses before storing them in its analytics database. Geographical statistics are calculated using these shortened IP addresses. The results are approximate.

Matomo processes information about individual visits to calculate our statistics. We have disabled individual visit logs and visitor profiles in the reporting interface. The underlying visit records are subject to the retention arrangements explained in Section 8.

Our analytics are designed to exclude anything entered into our diagnostic and information applications, including answers, results and free-text responses. We do not intentionally send names, email addresses, contact-form contents or other information entered into those applications to Matomo.

We use the resulting statistics solely to understand and improve our website and its resources.

We use statistical analytics to understand how Harbour Lights Community is used so that we can improve it. For example, the statistics help us decide how to organise the website, which guides and resources to develop, and where people may be having difficulty finding what they need.

We do not use Matomo analytics for advertising. We do not use Matomo to follow visitors across other websites, and we do not combine its statistics with information that identifies individual visitors.

UK law provides a statistical purposes exception that can allow qualifying website analytics cookies to be used without prior consent. The exception requires clear information about the analytics and a simple, free way for visitors to object. It is contained in Schedule A1 of the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended by the Data (Use and Access) Act 2025.

We intend to operate our statistical analytics within this exception and the applicable requirements of UK data protection law.

The cookies we use for statistical analytics

Matomo may set the following first-party cookies:

These are Matomo's standard cookie durations. We may configure shorter durations before activating analytics, in which case this table will be updated to reflect the settings actually in use.

Matomo is installed on our Hostinger hosting account. We operate the analytics software ourselves rather than using Matomo's hosted analytics service. Hostinger provides the server and database infrastructure on which the analytics information is processed and stored.

How to object

You can object to statistical analytics at any time using the Object to Statistical Analytics control in our website's privacy settings.

When you object, we stop collecting Matomo analytics information from your browser and stop using Matomo's analytics cookies for tracking. We will also remove existing Matomo analytics cookies where technically possible.

Matomo uses an opt-out cookie called mtm_consent_removed to remember an objection. Its standard expiry is 30 years, although browsers may remove it much sooner. This cookie is used solely to remember that statistical tracking has been declined.

If you clear your cookies or use a different browser or device, you may need to object again. You can change your preference using the same privacy control.

Objecting does not affect your ability to use our website or applications.

We use information submitted through the contact form to:

• receive, understand and respond to your enquiry;
• respond to questions about Harbour Lights Community and its resources;
• communicate with organisations and professionals interested in our work;
• consider research, evidence or resources brought to our attention;
• receive and respond to feedback about our website and resources;
• respond to media and other professional enquiries; and
• maintain appropriate records of our correspondence.

We will not use information submitted through the contact form to add you to a marketing mailing list.

If we introduce newsletters or other marketing communications in the future, we will provide separate information about how personal information is used for those purposes and, where required, obtain appropriate consent.

Under UK data-protection law, we must have a lawful basis for processing personal information.

For ordinary enquiries submitted through the contact form, Harbour Lights Community Ltd intends to rely on its legitimate interests in receiving and responding to enquiries, communicating with people and organisations interested in its work, receiving feedback and operating and developing Harbour Lights Community.

We consider this use of personal information to be something someone contacting us would reasonably expect and limit the information requested through the form to what is necessary to respond to the enquiry.

The ICO explains that organisations relying on legitimate interests should identify the interest being pursued, establish that the processing is necessary and balance that interest against the individual's rights and interests. Harbour Lights Community should document that assessment internally.

Some types of personal information receive additional protection under data-protection law. These are known as special category data and can include information about health, racial or ethnic origin, religious or philosophical beliefs, sexual orientation and certain other sensitive matters.

Harbour Lights Community does not ask you to provide special category information through its general contact form.

Because of the subject matter of our work, however, information voluntarily included in a message could sometimes contain sensitive personal information.

We therefore ask you not to provide sensitive personal information unless it is necessary for your enquiry.

Where special category information is received, we will handle it with particular care and will only retain or otherwise process it where we have an appropriate lawful basis and condition under applicable data-protection law.

We do not sell your personal information.

Information submitted through the contact form is used by Harbour Lights Community Ltd for the purposes described in this policy.

We will not disclose your information to another organisation unless:

• it is necessary for the purpose for which you contacted us;
• you have asked or authorised us to do so;
• we are required to do so by law; or
• disclosure is otherwise permitted under applicable data-protection law.

Contact form information:

Information submitted through the contact form will normally be retained for up to one year from the date of the enquiry.

We may delete information sooner where it is no longer required.

In limited circumstances, we may need to retain particular correspondence for longer where there is a legal or regulatory requirement to do so or where it is necessary for the establishment, exercise or defence of legal claims.

When information is no longer required, it will be securely deleted or destroyed.

Analytics information:

Matomo temporarily retains underlying visit and activity records so that we can generate and verify our aggregate statistics.

Our current Matomo configuration schedules deletion of raw visit records older than 180 days. We will review and, where necessary, shorten this period to ensure that individual-level information is kept only for as long as needed to calculate and verify the statistics.

We intend to preserve aggregate statistical reports for longer periods so that we can compare how Harbour Lights Community is used over time, including from year to year. We will ensure that published or retained aggregate reports do not identify individual visitors.

Personal information collected through the contact form is not transferred outside the United Kingdom.

If this changes in the future, we will update this Privacy Policy and ensure that any international transfer is made in accordance with applicable UK data-protection law.

We take reasonable organisational and technical measures to protect personal information against unauthorised access, alteration, disclosure, loss or misuse.

Access to information submitted through the contact form is limited to people who need it for the purposes described in this Privacy Policy.

No method of transmitting or storing information electronically can be guaranteed to be completely secure, so we also encourage you to limit the personal information included in your message to what is necessary for your enquiry.

Depending on the circumstances, UK data-protection law gives you rights in relation to your personal information. These may include the right to:

• ask for access to the personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to erase your personal information in certain circumstances;
• ask us to restrict the way we use your information in certain circumstances; and
• object to our processing of your personal information where we rely on legitimate interests.

You have the right to object to processing based on legitimate interests.

Not every right applies in every circumstance. The rights available depend partly on the lawful basis on which information is being processed. The ICO requires organisations to explain the applicable rights and, when relying on legitimate interests, to bring the right to object clearly to people's attention.

To exercise any of these rights, contact: contact@harbourlightscommunity.co.uk

We may need to ask for information to confirm your identity before acting on a request.

If you have concerns about how Harbour Lights Community Ltd has handled your personal information, please contact us first at: contact@harbourlightscommunity.co.uk

You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK's data-protection regulator.

Information Commissioner's Office ↗

We may update this Privacy Policy as Harbour Lights Community develops or if the way we collect or use personal information changes.

The latest version will be published on this website with the date on which it was last updated.