Privacy policy
Last updated: 21 October 2026. Version 1.0
Privacy Policy
This Privacy Policy explains how Ivory World, Lda. ("IVORY", "we", "us") processes personal data when you visit our website ivory-therapy.com (the "Store"), buy from us, subscribe to our communications, or use our online psychology services (the "Psychology Services"). It has two main parts that are kept separate: Part A (Store and commercial communications) and Part B (Psychology Services). They are followed by Part C (Cookies), Part D (Your rights), Part E (Regional notices), Part F (Other individuals) and Part G (Changes and versions).
Contents
- Summary
- 1. Who is responsible and how to contact us
- 2. Scope and structure
- 3. Separation between clinical and commercial processing
- Part A: Store and commercial communications
- Part B: Psychology Services (health data)
- Part C: Cookies and similar technologies
- Part D: Your rights
- Part E: Regional notices (United States, consumer health data, United Kingdom)
- Part F: Other individuals
- Part G: Changes and versions
Summary
- Who is responsible: Ivory World, Lda. (tax number NIPC 516 906 739) is the controller of your personal data. Contact details are in section 1.
- Two activities, two parts: Part A covers the online store and our commercial communications. Part B covers the Psychology Services and the health data they involve. They use different data, purposes, systems and recipients.
- Health data stays in Part B: health data is used only to provide and manage your care. It is never used for marketing, advertising, profiling or training artificial intelligence systems.
- Psychology Services start date: from 1 November 2026 the psychology consultations will be provided by IVORY as a health establishment registered with the Portuguese Health Regulatory Authority (ERS). Until then IVORY only puts clients in touch with independent psychologists, who provide the sessions under their own professional responsibility (see B1).
- Session vouchers: each paid item you buy, other than a gift card, includes one session voucher. The store passes only the voucher code and its status to the clinical side. The clinical side does not tell the store whether, when or by whom a voucher was used.
- Cookies and tracking: the Store uses analytics, session-recording, advertising and email-marketing tools of partner companies, which are listed in Part C. We ask for your consent to them through the cookie banner, and they should work only with your consent. Until we complete the changes described in C2, however, a few of them still load on every page, including the pages about therapy, before you make a choice and even if you reject (see the transitional exceptions in C2). You can reject the other tools, and the Store works the same way if you do.
- Recipients: the companies that process data for us are listed in A3 (store) and B7 (Psychology Services).
- Your rights: you can access, correct, erase, restrict, port and object, and you can object to direct marketing at any time (Part D). You can complain to the Portuguese data protection authority (CNPD).
- Contact: privacy requests and questions about the Psychology Services go to care@ivory-therapy.com. We have not appointed a Data Protection Officer.
- Regional notices: extra information for residents of the United States (including consumer health data) and the United Kingdom is in Part E.
1. Who is responsible and how to contact us
- Controller: Ivory World, Lda. (a limited liability company), trading as "Ivory Therapy".
- Tax and company number (NIPC): 516 906 739 (VAT number PT516906739).
- Commercial registry: registered at the Commercial Registry (Conservatória do Registo Comercial) under the single registration and tax number 516 906 739.
- General and store enquiries: care@ivory-therapy.com.
- Email (Psychology Services, privacy and data protection requests): care@ivory-therapy.com.
- Data Protection Officer (DPO): we have not appointed a Data Protection Officer; contact us about data protection at care@ivory-therapy.com.
- How to reach us: by email. IVORY does not offer phone support. Please do not describe your symptoms or your situation by email or through the website contact form.
2. Scope and structure
- Part A, Store and commercial communications: customers, visitors and subscribers of the online store.
- Part B, Psychology Services: clients of the Psychology Services, and people who use the matching questionnaire or book a session.
- Part C, Cookies and similar technologies: how we use cookies, pixels and local storage, and how to manage your choices.
- Part D, Your rights: applies to Parts A and B.
- Part E, Regional notices: United States, consumer health data and United Kingdom.
- Part F, Other individuals: applicants and business contacts.
- Part G, Changes and versions.
- Separate notices at the point of collection (for example forms and the booking platform) refer to this policy. If one of them is more specific, it applies to the data collected through it.
- Which data you must give: the fields marked as required at checkout, in your account and in the booking form are needed to conclude and perform the contract (and, for invoices, by tax law). Without them we cannot process your order or book your session. For the Psychology Services, your age, your location and your informed consent are also needed for your safety and for our professional duties. Everything else (marketing, reviews, optional cookies, optional booking fields such as the emergency contact) is voluntary, and refusing it does not affect your order or your care.
3. Separation between clinical and commercial processing
Separation between our clinical and commercial activities. IVORY carries out two distinct activities: the online store and commercial communications (Part A), and the online psychology care that will be provided, from 1 November 2026, as a health establishment registered with the Portuguese Health Regulatory Authority (Part B). Data processed under Part B are never used for marketing, advertising, profiling or commercial analysis, are not shared with advertising platforms, and are not used to train artificial intelligence systems. We are completing the technical separation of our systems. Until that is complete, some contact details of people who requested sessions may still be held in our email marketing tool, and our internal management system (described in B7) holds a copy of booking data; we are removing what is not needed and you can ask us to delete your data at any time (Part D). The only intended link between the two activities is the Session Voucher code generated when you buy a paid item other than a gift card: the store tells the clinical side only the code and its status (including cancellation if the item is returned before its session), and the clinical side does not tell the store whether, when or by whom the voucher was used. We use only aggregated, anonymous data to run the business. Part A applies to store customers and subscribers; Part B applies to clients of the Psychology Services.
Part A: Store and commercial communications
A1 Categories of data
- Identification and contact: name, email address, postal and delivery addresses, phone number where you give it for delivery.
- Orders and invoicing: items bought, prices, dates, tax number (NIF) if you ask for it on the invoice.
- Payment: processed by our payment providers. IVORY does not have access to your full card details.
- Customer account: login details, order history, preferences.
- Browsing and device data: IP address, browser, device, pages viewed, interactions. Collected through cookies and similar technologies. Cookies that are not strictly necessary should be subject to your choices in the cookie banner, except for the transitional exceptions in C2 (Part C).
- Messages and contact requests: what you send us. Please do not include clinical or health information.
- Returns and exchanges: the order, items, reason and, if you choose instant refund through our returns portal (Reveni), your bank account number (IBAN).
- Reviews: name, rating, text and photographs you submit through our review app (Loox).
- Marketing preferences and consent records: what you subscribed to, when and how, and your opt-outs.
- In-person sales: data collected at our physical points of sale and events when you buy or return an item.
A2 Purposes, legal bases and retention
| Purpose | Data | Legal basis | Retention |
|---|---|---|---|
| Process orders, payments, deliveries and after-sales support | Identification, contact, addresses, order, payment | Performance of a contract (Art. 6(1)(b) GDPR) | Up to 3 years after delivery (legal guarantee period), without prejudice to tax records |
| Invoicing and accounting and tax obligations | Invoicing data, tax number, amounts | Legal obligation (Art. 6(1)(c) GDPR) | 10 years |
| Withdrawal, returns, exchanges and guarantees (including Reveni); cancelling a Session Voucher when an item is returned before its session | Order, items, reason, IBAN (instant refund), voucher code | Contract and legal obligation (Art. 6(1)(b) and (c) GDPR) | Until the end of the legal guarantee period (3 years) and limitation periods |
| Customer account | Credentials, history, preferences | Contract (Art. 6(1)(b) GDPR) | While the account is active; deleted after 3 years of inactivity |
| Send the Session Voucher and booking instructions (a service message, not marketing) | Email, order number, voucher code | Contract (Art. 6(1)(b) GDPR) | Until 12 months after the voucher is used or cancelled |
| Answer contact requests and customer support | Identification, contact, content of the request | Contract or pre-contract steps; legitimate interest in answering (Art. 6(1)(b) and (f) GDPR) | 3 years after the last contact |
| Newsletter and marketing communications (email and SMS) | Email, phone, preferences, interactions with messages | Consent (Art. 6(1)(a) GDPR; Law 41/2004, Art. 13-A). Existing customers: legitimate interest for similar products, with a right to object | Until you withdraw consent or object; inactive profiles deleted after 24 months; proof of consent or objection kept for 5 years |
| Website statistics and improvement | Browsing and device data (see Part C) | Consent (Art. 6(1)(a) GDPR; Law 41/2004, Art. 5) | See the cookie table in Part C; at partners, according to the retention settings of each tool and the partner's policy |
| Personalised advertising, remarketing and measurement | Browsing data, purchase events, identifiers, hashed email where shared | Explicit consent (Art. 6(1)(a) and 9(2)(a) GDPR; Law 41/2004, Art. 5) | See Part C; at partners, according to their policies |
| Product reviews (Loox) | Name, rating, photographs, email | Consent (Art. 6(1)(a) GDPR) | While published or until you ask for removal |
| Security, fraud prevention and anti-spam (Shopify, hCaptcha) | IP address, device, transaction patterns | Legitimate interest (Art. 6(1)(f) GDPR) | As short as the provider's fraud-prevention purpose allows, under the provider's own terms |
| Complaints (including the Complaints Book) | Identification, complaint, reply | Legal obligation (Art. 6(1)(c) GDPR) | 3 years |
| Handling requests to exercise your rights | Identification, request, reply | Legal obligation (Art. 6(1)(c) GDPR) | 5 years |
| Establishing, exercising or defending legal claims | Data necessary for the claim | Legitimate interest (Art. 6(1)(f) GDPR) | Applicable limitation periods |
A3 Recipients and transfers
We share data only with the companies below, for the functions described. Where data is transferred outside the European Economic Area, we rely on an adequacy decision, on the EU-US Data Privacy Framework where the recipient participates in it, or on Standard Contractual Clauses (Commission Decision (EU) 2021/914). You can ask us for a copy of the safeguards using the email address in section 1.
| Recipient | Function | Role | Location and transfer |
|---|---|---|---|
| Shopify (Shopify International Ltd., Ireland; Shopify Inc., Canada) | Store hosting, checkout, accounts, fraud detection; Shopify Audiences (advertising audiences) | Processor; independent controller for Shop and Shop Pay and for enhanced features such as Shopify Audiences | EU to Canada (adequacy decision) and USA (Data Privacy Framework or Standard Contractual Clauses) |
| Stripe (Stripe Payments Europe Ltd., Ireland) | Card payments, Apple Pay and Google Pay | Processor and independent controller (fraud prevention, regulatory duties) | EU; USA (Data Privacy Framework or Standard Contractual Clauses) |
| PayPal (Europe) S.à r.l. et Cie, S.C.A. (Luxembourg) | PayPal payments | Independent controller | EU; USA |
| Klarna Bank AB (publ) (Sweden) | Deferred payment and credit | Independent controller | EU |
| Revolut (Revolut Pay) | Revolut Pay payments | Independent controller | EU |
| Apple and Google (wallets) | Apple Pay and Google Pay | Independent controllers | EU and USA |
| Reveni (Spain) | Returns portal and instant refund (collects your IBAN) | Processor; independent controller for the instant refund service | EU |
| Shiptimize (shipping app); carriers CTT Expresso, DPD, InPost, DHL and FedEx | Shipping and pick-up points | Shiptimize: processor; carriers: independent controllers | EU and country of delivery |
| Klaviyo, Inc. (USA) | Email and SMS marketing, forms, post-purchase emails (including the Session Voucher email) | Processor | USA (Data Privacy Framework or Standard Contractual Clauses) |
| Meta Platforms Ireland Ltd. | Meta Pixel and Conversions API (advertising and measurement) | Joint controller for collection and transmission (CJEU C-40/17 Fashion ID); independent controller afterwards | EU to USA (Data Privacy Framework) |
| Google Ireland Ltd. | Google Ads, Google Analytics 4, Merchant Center, YouTube | Google Analytics 4: processor; Google Ads and remarketing: independent or joint controller, depending on the product | EU to USA (Data Privacy Framework) |
| TikTok Technology Ltd. (Ireland) | TikTok pixel (advertising and measurement) | Joint controller for collection and transmission; independent controller afterwards | Transfers outside the EEA, including to the USA and to other countries where the TikTok group operates, under Standard Contractual Clauses (see TikTok's privacy policy) |
| Pinterest Europe Ltd. (Ireland) | Pinterest tag (advertising and measurement) | Joint controller for collection and transmission; independent controller afterwards | EU to USA |
| Microsoft Ireland Operations Ltd. | Microsoft Clarity (heatmaps and recordings of how pages are used) and Microsoft Advertising | Independent controller or processor, depending on the product | EU to USA (Data Privacy Framework) |
| Triple Whale, Inc. (USA) | Marketing attribution and analytics | Processor | USA |
| PageFly | Page builder and page analytics | Processor | See the provider's privacy information; safeguards on request |
| Loox Ltd. (Israel) | Requesting and displaying reviews | Processor | Israel (adequacy decision) |
| Instafeed | Instagram feed on the Store (receives your IP address) | Independent controller or processor, depending on the feature | See the provider's privacy information |
| Intuition Machines, Inc. (hCaptcha, USA) | Anti-spam protection on forms | Processor | USA (Standard Contractual Clauses or Data Privacy Framework) |
| Other store apps (size guide, free-gift and offer apps, restock alerts, wholesale) | Store features | Processors | According to each provider's privacy information |
| Google Workspace | Email (care@ mailbox) | Processor | EU and USA (Data Privacy Framework) |
| Moloni | Invoicing | Processor | According to the provider's privacy information |
| Our external accountant | Accounting | Processor | Portugal |
| Tax Authority, courts and public authorities, Complaints Book authorities | Legal obligations | Legal recipients | Portugal |
Where a partner is a joint controller with us for the collection of data by its pixel (for example Meta), the arrangement is limited to collection and transmission of the data. The essence of the arrangement is available on request, and the partner's own privacy policy applies to what it does afterwards (Art. 26(2) GDPR).
A4 Direct marketing
We send email and SMS marketing only with your prior consent, or, for existing customers, about similar products with a clear chance to opt out when we collect your email and in every message (Law 41/2004, Art. 13-A). You have an absolute right to object to direct marketing at any time (Art. 21(2) and (3) GDPR); every message has an unsubscribe link, or you can write to the email address in section 1. Marketing never uses Part B data. The voucher email is a service message, not marketing.
A5 Automated decisions
We do not take decisions based solely on automated processing that have legal or similarly significant effects. Our provider Shopify uses limited automated fraud filters, for example temporary blocks of IP addresses or cards after repeated failed payments, which last hours or days.
A6 Children
The Store is not directed at children. Marketing subscriptions are for people aged 16 or over. The Psychology Services are for adults aged 18 and over only.
A7 Website analytics and advertising
The Store uses analytics, session-recording, advertising and email-marketing tools of the partners listed in A3 and Part C (Shopify's store statistics, Google Analytics, Microsoft Clarity, PageFly, Meta, Google Ads, TikTok, Pinterest, Triple Whale and Klaviyo). We ask for your consent to them through the cookie banner, and they should be subject to your consent; see the transitional exceptions in C2, because some tools still load before you choose and even if you reject. You can reject the other tools, and the Store works the same way if you do. Shopify, our store platform, may also process some data for essential purposes, such as security and fraud prevention, whatever your choice. Our pages about therapy and mental health are part of the Store: see C3 for what this means for you. Details, tool names and durations are in Part C.
Part B: Psychology Services (health data)
B1 Who is responsible
From 1 November 2026, IVORY (Ivory World, Lda.) will be the controller of the clinical data described in this Part B, as the entity responsible for the health establishment "Ivory Therapy" (telemedicine unit, Clinical Psychology), whose registration with the Portuguese Health Regulatory Authority (ERS) will be shown in our Legal Notice once issued.
From 1 November 2026, a Clinical Director (Technical Director), a psychologist registered with the Ordem dos Psicólogos Portugueses (the Portuguese Order of Psychologists, OPP), will be responsible for the clinical activity of the establishment. You can reach the clinical team and our data protection contact at care@ivory-therapy.com. We have not appointed a Data Protection Officer.
Until 1 November 2026, IVORY does not operate as a clinic or health establishment: it only puts clients in touch with independent psychologists, who provide the sessions under their own professional responsibility.
For sessions held before that date, the psychologist who provided the session is responsible for the clinical data in their own records, and IVORY handled the matching questionnaire, booking and payment data described in this Part B as controller of that data. If you want access to the record of an earlier session, write to care@ivory-therapy.com and we will tell you which psychologist holds it and how to ask for it.
B2 Role of the psychologists
From 1 November 2026, the psychologists of the IVORY team are registered with the OPP and act under the authority of IVORY and its Clinical Director. They are bound by professional secrecy under the OPP Code of Ethics and handle your data as authorised persons (Art. 29 GDPR).
B3 Categories of data
- Identification and contact: name, email, age.
- Location: your country and the place where you tell us you are during each session.
- Emergency contact: the name and contact details of a person you choose, only if you give them (optional).
- Matching questionnaire: your answers (reason for seeking help, preferences, language), which are health data.
- Booking data: date and time, type of session, psychologist, attendance, absence or cancellation, and the answers you give in the booking form.
- Informed consent: version, date and time, name.
- Clinical record: notes and records written by the psychologist.
- Communications with the clinical team.
- Technical data of the video call: connection metadata.
- Payment and invoicing: name, tax number if you ask for it, amount, date, payment method.
- Session Voucher code and its status.
- Complaints.
B4 Sources
The data come from you; from the psychologist who sees you; from the person who gave you a voucher (only the voucher code, never any data about its use); and, in the corporate programme (Therapy 4 Business), from your employer (only your eligibility, as required by Art. 14 GDPR).
B5 Purposes, legal bases and retention
| Purpose | Data | Legal basis (Art. 6 and Art. 9 GDPR) | Retention |
|---|---|---|---|
| Matching questionnaire and matching with a psychologist | Identification, contact, language, preferences, reason for seeking help | Pre-contract steps at your request (6(1)(b)); provision of health care (9(2)(h) and 9(3)) | Without a booking: 6 months; with a booking: becomes part of the clinical record |
| Booking, rescheduling, reminders, absences and cancellations | Identification, contact, date and time, type, psychologist, status | 6(1)(b); 9(2)(h) | Aligned with the clinical record |
| Delivering sessions by video call | Technical connection data; declared location | 6(1)(b); 9(2)(h) | Connection metadata: for the period set in our video platform account and its terms |
| Clinical record and record of informed consent | Clinical records, consent (version, date and time), emergency contact | 6(1)(b) and (c) (legal and ethical duty to keep records); 9(2)(h) | For the minimum period required by Portuguese law and the OPP Code of Ethics for clinical records, and no longer than necessary; then deleted or anonymised. You can ask us for the current period at care@ivory-therapy.com |
| Payment and invoicing of sessions | Name, tax number if requested, amount, date, payment method; no clinical information beyond the legal description of the service | 6(1)(b) and (c) | 10 years |
| Validating Session Vouchers | Code and status | 6(1)(b) | Until 12 months after the voucher is used or cancelled |
| Service messages (confirmations, reminders, changes) | Contact | 6(1)(b); 9(2)(h) | Same as bookings |
| Complaints handling and communication to the ERS (SGREC) | Complaint, reply, clinical data strictly necessary | 6(1)(c); 9(2)(h) | 3 years after the complaint is closed, or longer where the law or the ERS requires |
| Protecting life in an emergency | Identification, location, emergency contact | Vital interests: 6(1)(d); 9(2)(c) | Only what is strictly necessary; recorded in the clinical record |
| Internal management of the establishment (scheduling, remuneration of psychologists, quality) | A copy of booking data, including name, contact details and the answers you give in the booking form | Legitimate interest in managing the establishment (6(1)(f)); management of health services (9(2)(h)) | Tax data 10 years; the rest for as long as needed to schedule sessions and calculate the psychologists' remuneration, then deleted or anonymised |
| Clinical supervision | Anonymised or pseudonymised data | 9(2)(h) | Not kept outside the clinical record |
| Corporate programme (Therapy 4 Business) | Eligibility (name, work email); aggregated and anonymous statistics for the employer | 6(1)(b) and (f); 9(2)(h) | While the employer's contract is in force and for 12 months afterwards |
| Establishing, exercising or defending legal claims (including disciplinary proceedings) | Data necessary for the claim | 6(1)(f); 9(2)(f) | Applicable limitation periods |
B6 Legal basis for health data and professional secrecy
Data about your health, including the fact that you are seeking or receiving psychological support, your answers to the matching questionnaire and the information in your clinical record, are special categories of personal data. We process them on the basis of Article 9(2)(h) GDPR (provision of health care and management of health services, under a contract with a health professional) and Article 9(3) GDPR, read with Article 29 of Law 58/2019 of 8 August: they are handled only by psychologists registered with the OPP and bound by professional secrecy, or by other persons bound by a duty of confidentiality, under the responsibility of the Clinical Director and strictly as needed. The underlying basis is performance of the contract for the Psychology Services and the pre-contract steps you request (Article 6(1)(b) GDPR). Informed consent to remote psychological intervention is an ethical requirement and your right; it is not the legal basis for processing your data.
In exceptional situations of serious and imminent risk to your life or physical integrity, or that of others, where your consent cannot be obtained, we may pass the strictly necessary information to the emergency services or to the emergency contact you gave us (Art. 6(1)(d) and 9(2)(c) GDPR), as permitted by the OPP Code of Ethics.
B7 Recipients
Your Part B data are accessible only to the recipients below.
| Recipient | Function | Role | Location and transfer |
|---|---|---|---|
| Psychologists of the IVORY team (registered with the OPP) | Providing sessions, clinical records | Authorised persons under IVORY's authority (Art. 29 GDPR), bound by professional secrecy | Portugal and the place where the psychologist works |
| Clinical Director and authorised staff (matching and booking), under a duty of confidentiality | Matching clients and psychologists, scheduling, complaints | Authorised persons | Portugal |
| Squarespace (Acuity Scheduling) | Bookings, intake form, session payments, reminders | Processor | USA (Data Privacy Framework or Standard Contractual Clauses) |
| Zoom Video Communications, Inc. | Video sessions | Processor | USA, with EU data centres for meeting traffic where available |
| Provider of our form tool | Matching questionnaire | Processor | According to the provider's privacy information |
| Payment processor connected to the booking platform | Payment of sessions | Processor or independent controller | EU and USA |
| Provider of the clinical record system | Clinical record | Processor | European Union where available; otherwise with the safeguards described in B8 |
| Google Workspace (care@ mailbox) | Emails about the Psychology Services | Processor | EU and USA (Data Privacy Framework) |
| Supabase, Inc. (hosted on AWS in Ireland) and Vercel, Inc. | Internal management system for sessions and psychologists' remuneration | Processors | Data in the EU; US providers (Standard Contractual Clauses or Data Privacy Framework) |
| Moloni | Invoicing of sessions (no clinical information beyond the legal description of the service) | Processor | According to the provider's privacy information |
| ERS (through SGREC), OPP, courts, Public Prosecutor, emergency services (112 or local equivalents) | Legal obligations; vital interests | Legal recipients | Portugal and the client's country |
Internal management system. An internal management system (hosted in the European Union by Supabase, with an application hosted by Vercel) receives a copy of booking data, including your identification, contact details and your answers on the booking form, to manage the calendar and pay psychologists. Access is limited to a small number of administrators bound by confidentiality. We are reducing this copy to the pseudonymised data that is needed (see section 3).
We do not give Part B data to our analytics and advertising partners (Meta, Google Ads and Google Analytics, TikTok, Pinterest, Microsoft Clarity, Triple Whale) and we do not use it for marketing. Shopify receives only the status of the Session Voucher code (see section 3). While the technical separation described in section 3 is being completed, some contact details of people who requested sessions may still be held in our email marketing tool, Klaviyo, and we are removing them.
B8 International transfers
Acuity Scheduling and Zoom are provided from the United States. We rely on the EU-US Data Privacy Framework where the provider participates in it, or otherwise on Standard Contractual Clauses, with additional measures such as encryption in transit and minimisation of the fields we ask for in the intake form. You can ask us for a copy of the safeguards using the email address in section 1.
B9 Retention
Retention periods are in the table in B5. We keep clinical records for as long as the law, the OPP Code of Ethics or the defence of legal claims requires, and then delete or anonymise them.
B10 Security
Data are encrypted in transit (TLS). Access is limited to those who need it, and everyone with access is bound by professional secrecy or a duty of confidentiality. If a breach affects your data, we notify the CNPD within 72 hours and, where there is a high risk, we tell you without undue delay (Art. 33 and 34 GDPR).
B11 Specific rights
You can ask for access to the health information in your clinical record (Law 12/2005). Erasure may be refused where the law requires us to keep the data or where we need them to establish, exercise or defend legal claims (Art. 17(3)(b), (c) and (e) GDPR). On request we can give you proof of attendance for a session.
B12 Minors
The Psychology Services are for adults aged 18 and over. Each Session Voucher must be used by an adult. If we find that data of a minor were provided to us for the Psychology Services, we delete them, unless the law requires us to keep them.
B13 No marketing and no artificial intelligence training
Part B data are never used for marketing, advertising, profiling for commercial purposes, building advertising audiences or training artificial intelligence systems, and they are not sold or shared with advertising platforms. Any other purpose that requires health data (for example non-anonymised research) would depend on your explicit, separate and optional consent.
B14 Corporate programme (Therapy 4 Business)
If your employer offers the Psychology Services, the employer never receives individual data: not whether, when or how often you had sessions, nor their content. It receives only aggregated and anonymous statistics, and only when a minimum number of clients is reached (at least 5 clients per report).
Part C: Cookies and similar technologies
This Part explains which cookies and similar technologies IVORY uses on ivory-therapy.com, why, for how long, and how you can choose. Part A7 gives a short summary. Part B (Psychology Services) describes data that we do not use for any of the tools described here.
C1 What these technologies are
- Cookies are small text files that a website saves on your device.
- Pixels and tags are small pieces of code or images that send information about your visit (for example which page you viewed or what you bought) to the company that provides them.
- Local storage is a similar space in your browser that keeps information until you delete it.
- SDKs and scripts are code from other companies that runs on our pages (for example to show reviews or to measure visits).
In this Part we call all of them "cookies", unless we say otherwise.
C2 When we ask for your consent
- Strictly necessary cookies are needed for the Store to work: your cart, checkout, security, language and country, and remembering your cookie choices. We do not need your consent for these.
- All other cookies (preferences, analytics and marketing) should be subject to your consent, which we ask for through the cookie banner; see the transitional exceptions below. Rejecting is possible, and the Store works the same way if you reject.
- Our legal basis is your consent (Article 6(1)(a) GDPR and Article 5 of Law 41/2004 of 18 August, as amended, which implements Article 5(3) of the ePrivacy Directive 2002/58/EC), except for the transitional exceptions below, which we are switching to work only with your consent.
- If you withdraw your consent, the tools covered by it stop and, where we can, we delete what they stored. The transitional exceptions below are not yet covered.
Transitional exceptions. Until we complete the changes described here, some tools load on every page, including the pages about therapy, before you make a choice and even if you reject: the Google tag installed through the Google & YouTube app, Microsoft Clarity, and the Klaviyo and Triple Whale site scripts. We are switching them to work only with your consent. Until then, the choices in the cookie banner do not stop them; you can block cookies and scripts in your browser settings (C6).
C3 Pages about therapy and mental health
Our Store has pages about therapy, psychological support and mental health. They include the therapy page, the "how it works" page, the SOS page, the "reasons to stay" page, the page for companies, the frequently asked questions, our contact page, our mental health blog and its articles, the pages that present our psychologists and our psychology services, and searches that look for these topics, in every language version.
Visiting these pages can show that you are interested in mental health services, which may be data concerning health. The analytics, session-recording, advertising and email-marketing tools described in this Part can run on these pages in the same way as on the rest of the Store, according to your choices in the cookie banner, except for the transitional exceptions in C2: until those changes are complete, the Google tag installed through the Google & YouTube app, Microsoft Clarity, and the Klaviyo and Triple Whale site scripts also load on these pages before you make a choice and even if you reject. If you do not want information about your visits to these pages to be collected by the other tools, reject the Analytics and Marketing categories in the banner.
If you accept Analytics or Marketing cookies, you give your explicit consent (Article 9(2)(a) GDPR and Article 5 of Law 41/2004) to the collection of your browsing data and its sharing with the partners in the table below, for the purposes described there. This involves transfers outside the European Economic Area, in particular to the United States. If you reject, or withdraw your consent, you can use the whole Store, including the pages about therapy, as usual. We do not use information about consultations, bookings, questionnaires or clinical records for advertising or analytics, and we do not send it to our advertising partners (Part B).
Shopify, our store platform, operates the Store on every page. Strictly necessary Shopify cookies work everywhere. Shopify may also process some data for essential purposes, such as security and fraud prevention, whatever your choice.
C4 Categories
The cookie banner uses these categories.
- Strictly necessary: always on. They keep the cart and checkout working, protect forms and payments, remember your country and language and store your cookie choices.
- Preferences: optional features provided by outside companies, such as customer reviews and our Instagram feed.
- Analytics: help us understand how the Store is used (visits, pages, errors) and improve it. They include Shopify's store statistics, Google Analytics, PageFly page statistics, and Microsoft Clarity, which produces heatmaps and recordings of how pages are used.
- Marketing: measure our campaigns and show advertising that is relevant to you on other sites and apps (Meta, Google Ads, TikTok, Pinterest), play embedded videos from YouTube or Vimeo, and let us recognise you in our email and SMS marketing tool (Klaviyo).
- Sale or sharing of data (United States): some US state laws treat sharing browsing data for targeted advertising as a "sale" or "sharing". Where this applies, the Marketing category and your Global Privacy Control signal (C7) are how you opt out, except for the transitional exceptions in C2. See also Part E.
C5 Cookie table
The table lists the cookies and similar technologies we know about. "Observed" means we saw the duration in a test of the Store; other durations come from the providers' documentation and may change.
| Name | Provider | Purpose | Banner category | Duration | Party | Transfer |
|---|---|---|---|---|---|---|
| _shopify_essential | Shopify | Session, cart, checkout and security | Strictly necessary | 1 year (observed) | First | Canada and USA |
| _tracking_consent | Shopify | Stores your cookie choices | Strictly necessary | 1 year | First | None |
| localization | Shopify | Country and language | Strictly necessary | 1 year (observed) | First | None |
| cart_currency | Shopify | Currency of your cart | Strictly necessary | 14 days (observed) | First | None |
| hCaptcha (for example hmt_id) | Intuition Machines | Spam protection on forms | Strictly necessary | See provider | Third | USA |
| _shopify_analytics | Shopify | Store statistics | Analytics | 1 year (observed) | First | Canada and USA |
| shopify_client_id | Shopify | Visitor identifier for store statistics | Analytics | See provider | First | Canada and USA |
| _ga, _ga_LYEXMVX159 | Google (Google Analytics 4) | Statistics on visits | Analytics | 2 years | First (set by Google code) | USA |
| _clck, _clsk, CLID, MUID | Microsoft Clarity | Heatmaps and recordings of how pages are used | Analytics | _clck 1 year (observed); _clsk 1 day; CLID 1 year; MUID about 13 months | First and third | USA |
| PF_CUSTOMER_EVENTS_TRACKER, pf_client_id (local storage) | PageFly | Page statistics | Analytics | Until deleted (observed) | First | See provider |
| _shopify_marketing | Shopify | Marketing and attribution | Marketing | 1 year (observed) | First | Canada and USA |
| _fbp, _fbc | Meta | Advertising and measurement | Marketing | 90 days | First (set by Meta code) | USA |
| _gcl_au (and doubleclick.net cookies) | Google Ads | Conversions and remarketing | Marketing | 90 days | First and third | USA |
| _ttp, _tt_enable_cookie | TikTok | Advertising and measurement | Marketing | 13 months | First (set by TikTok code) | Outside the EEA, including the USA |
| _pin_unauth | Advertising and measurement | Marketing | 1 year | First (set by Pinterest code) | USA | |
| __kla_id | Klaviyo | Recognises you in email and SMS marketing and shows our sign-up forms | Marketing | 2 years | First (set by Klaviyo code) | USA |
| TriplePixelU, TriplePixelData, di_pmt_wt (local storage) | Triple Whale | Marketing attribution | Marketing | Until deleted (observed) | First storage, third sending | USA |
| Loox scripts (loox.io) | Loox | Customer review widget | Preferences | See provider | Third | Israel |
| Instafeed scripts (cdn.nfcube.com) | Instafeed | Instagram feed (receives your IP address) | Preferences | See provider | Third | See provider |
| YSC, VISITOR_INFO1_LIVE, vuid | YouTube and Vimeo | Playing embedded videos (only on pages with a video) | Marketing | Session to 2 years | Third | USA |
Shopify also runs its own measurement pixels (Shopify Collabs attribution, active only when a link carries a Collabs identifier, and a Shopify price-testing measurement), which follow your choices in the cookie banner.
Notes on the table:
- Microsoft Clarity records how pages are used, including mouse movements and clicks. Its settings are managed by us in the Clarity dashboard.
- The list of partners, their roles and transfer safeguards are in Part A3 of this policy.
C6 How to manage or withdraw your consent
- In the Store: the cookie banner asks for your choice on your first visit. If you delete our cookies, the banner asks you again.
- In your browser: you can block or delete cookies and local storage in your browser settings. Strictly necessary cookies may be needed for the cart and checkout to work.
- With our partners: you can also manage advertising choices in the settings of your Meta, Google, TikTok and Pinterest accounts and through the opt-out tools of the advertising industry.
- Marketing emails and SMS: unsubscribe through the link in every message (Part A4).
- United States: use the Your Privacy Choices page (see Part E).
- If you reject or withdraw, we do not treat you differently and you keep full access to the Store.
C7 Global Privacy Control and other signals
If you visit the Store with the Global Privacy Control (GPC) signal enabled, then, depending on where you are, we treat it as a request to opt out of the sale or sharing of personal data and of targeted advertising for the device and browser you used, except for the transitional exceptions in C2, which do not yet respond to this signal. We do not respond to "Do Not Track" signals, because there is no common standard for them. Part E explains how this applies to residents of the United States.
C8 How long we keep your choice
We store your choice in the strictly necessary cookie _tracking_consent, which lasts 1 year. After it expires, or if you delete your cookies, the banner asks you again. Shopify keeps a technical record of your choice for the same purpose.
C9 Changes to this table
We check the table at least every 6 months and whenever we install a new app or change a tool that uses cookies, and we update this Part. The date at the top of this policy shows the last update.
Part D: Your rights
This Part applies to Parts A and B.
You may exercise, free of charge and at any time, the rights of access, rectification, erasure, restriction of processing, portability and objection, and you may withdraw any consent you gave without affecting the lawfulness of processing carried out before (Articles 15 to 22 and 7(3) GDPR). You may object at any time, without giving a reason, to the processing of your data for direct marketing (Article 21(2) and (3) GDPR), in particular through the unsubscribe link in every message. Send requests about Part A and Part B to care@ivory-therapy.com; Part B requests are handled only by people bound by secrecy. Access to the health information in your clinical record also follows Law 12/2005. Erasure of clinical data may be refused while the law requires it to be kept or while it is needed to defend legal claims (Article 17(3) GDPR). We answer within one month, which may be extended by two further months where the complexity or number of requests justifies it, and we will tell you if we extend. We may ask for extra information to confirm your identity.
You also have the right to lodge a complaint with the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD), Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, www.cnpd.pt, or with the supervisory authority of the EU Member State where you habitually reside, where you work, or where the alleged infringement took place (Article 77 GDPR). Rights under other laws (United States, United Kingdom) are described in Part E.
Part E: Regional notices
These notices add information for people in certain places. They complete the rest of this Privacy Policy and do not replace it. Where a notice gives you a right that the rest of the policy does not, the notice applies to you. Portuguese and European Union law governs our processing in general.
E1 United States: US State Privacy Notice
This notice is for residents of the United States, to the extent the privacy laws of their state apply to us. We are a company based in Portugal and not every US state law applies to us; some depend on revenue or on the number of consumers. We offer the rights below to all US residents, whether or not a state law applies.
Information we collect, in the last 12 months. The table uses the categories common in US state laws. Part A explains the purposes and Part C the cookies.
| Category | Examples | Where it comes from | Why we use it | Who receives it |
|---|---|---|---|---|
| Identifiers | Name, email, postal and delivery address, phone number if you give it for delivery, IP address, cookie identifiers | You; your device | Orders, delivery, support, marketing you chose, security | Payment, shipping, email marketing and store platform providers (Part A3) |
| Commercial information | Items bought, order history, returns, voucher code | You; our systems | Orders, returns, invoicing, sending your Session Voucher | The same providers |
| Internet or network activity | Pages viewed, clicks, device and browser data | Your device, through cookies, according to your choices in the cookie banner, except for the transitional exceptions in C2 (Part C) | Statistics, advertising measurement, email marketing | Analytics, advertising and email-marketing partners listed in Part C, according to your cookie choices |
| Approximate location | Country, region and city derived from your IP address | Your device | Store version, currency, fraud prevention | Store platform |
| Inferences | Interests drawn from your browsing or purchases | Our systems and advertising partners, according to your cookie choices | Advertising and marketing you chose | Advertising partners |
| Sensitive information, including consumer health data | Matching questionnaire, bookings, clinical records and similar data of the Psychology Services (Part B) | You; your psychologist | Providing and managing your care only | Clinical providers listed in Part B7. Not used for advertising or marketing |
We do not collect precise geolocation. Payment details are handled by payment providers.
Sale, sharing and targeted advertising. If you accept the Marketing category in the cookie banner, our advertising, attribution and email-marketing partners (Meta, Google, TikTok, Pinterest and Klaviyo) receive browsing and purchase events. Under some state laws this can be a "sale", "sharing" or "targeted advertising". You can opt out with the cookie banner, with the Your Privacy Choices page or with the Global Privacy Control signal, except as described in the transitional exceptions in C2 (until we remove them, some tools load on every page, including the pages about therapy, whatever you choose). We do not sell or share Part B data. We do not knowingly sell or share the personal data of anyone under 16.
Your rights. Depending on your state, you can:
- know and access the personal data we hold about you, and receive a copy in a portable format;
- correct inaccurate data;
- delete your data;
- opt out of the sale or sharing of your data, of targeted advertising and of profiling that has legal or similarly significant effects;
- limit our use of sensitive data, where the law gives you this right;
- withdraw consent you gave;
- appeal our decision on your request (see below);
- not be treated worse for using these rights.
How to use your rights. Use the Your Privacy Choices page, or write to care@ivory-therapy.com. Until we remove the transitional exceptions in C2, the Your Privacy Choices page and the cookie banner do not stop them; you can block cookies and scripts in your browser settings, or write to us. We may need to verify your identity, by matching the information you give us with what we hold. An authorised agent may act for you with your written permission; we may ask you to confirm it with us. We reply within 45 days, and we may extend this once by a further 45 days if needed, and we tell you why.
Global Privacy Control. If your browser sends the Global Privacy Control signal, we treat it as an opt-out of the sale or sharing of personal data and of targeted advertising for that browser and device, as Part C7 explains.
Appeals. If we refuse your request, you can appeal by replying to our decision within 45 days. We answer the appeal in writing within 60 days. If we deny the appeal, you can contact the Attorney General of your state.
Children. The Store is not directed at children under 13 and we do not knowingly collect their personal data. The Psychology Services are for adults aged 18 and over only.
Email and text messages. Every marketing email carries an unsubscribe link, and we honour opt-outs within 10 business days. We send marketing text messages only to people who have agreed to receive them (for US numbers, with prior express written consent), and you can withdraw consent by replying STOP.
Psychology Services and the United States. The psychologists of IVORY are registered with the Ordem dos Psicólogos Portugueses (the Portuguese Order of Psychologists, OPP) and work from Portugal, under Portuguese law. They are not registered or authorised to practise by any US state. Please read the section on eligibility and location in the terms for the Psychology Services before you book, and call local emergency services (911 in the United States) in an emergency.
Consumer health data. The Consumer Health Data Privacy Policy (see E2) applies to residents of Washington, Nevada and Connecticut, and we apply it to all US residents.
E2 Consumer health data (United States)
Some US states (including Washington, Nevada and Connecticut) have specific rules for "consumer health data": information that identifies your past, present or future physical or mental health status, including that you are looking for or using health services. IVORY publishes a Consumer Health Data Privacy Policy that explains what we collect, why, with whom we share it, and your rights and choices. It is published on its own page: Consumer Health Data Privacy Policy.
E3 United Kingdom
If you are in the United Kingdom, the UK General Data Protection Regulation and the Data Protection Act 2018 also protect you. The rest of this policy applies to you, and your rights are those in Part D.
- Complaints: you can complain to the UK Information Commissioner's Office (ICO) at https://ico.org.uk/make-a-complaint/, as well as to the Portuguese authority (CNPD) named in Part D.
- Transfers: your data is processed in Portugal and in the European Economic Area, which the UK recognises as providing adequate protection for transfers from the UK. Where we use providers in other countries, Parts A3 and B8 describe the safeguards.
- Psychologists and titles: the psychologists of IVORY are registered with the OPP and are not registered with the UK Health and Care Professions Council (HCPC). We use only titles recognised in Portugal, such as "psychologist registered with the OPP".
E4 Brazil
If you are in Brazil, the Brazilian General Data Protection Law (LGPD) may also protect you. You can ask us to confirm that we process your data, to access, correct, anonymise, block or delete it, to port it, and to give or withdraw consent, using the contact in section 1 of this policy. You can complain to the Brazilian data protection authority (ANPD). Our psychologists are registered in Portugal and are not registered with the Brazilian Federal Council of Psychology (CFP).
E5 Other countries
Our processing is governed by Portuguese and European Union law. If the law of the country where you live gives you mandatory rights that go further than this policy, we respect them. You can always use the rights in Part D and contact us at the address in section 1.
Part F: Other individuals
- F1 Applicants for psychologist roles: if you apply by writing to care@ivory-therapy.com, we process your CV, OPP professional registration (cédula) number and contact details to assess your application and to verify your registration (Art. 6(1)(b) and (c) GDPR). We keep them for up to 12 months after the process, or 24 months if you agree to be contacted about future openings. Recipient: Google Workspace.
- F2 Business contacts (B2B): we process professional contact details of partners, suppliers and prospective corporate clients on the basis of legitimate interest (Art. 6(1)(f) GDPR).
- F3 Psychologists and collaborators: they receive a separate internal privacy notice.
Part G: Changes and versions
This policy shows its date and version at the top. If we make material changes, we will notify account holders and clients with an active relationship by email. Earlier versions are available on request. This policy is currently published in English only; Portuguese and Spanish versions will follow. Once a Portuguese version is published, it prevails in case of divergence, and information for consumers in Portugal is available in Portuguese (Law 24/96, Art. 7).