Consumer Health Data Privacy Policy

Effective date: 21 October 2026. Last updated: 21 October 2026. Version 1.0

1. Who we are

This policy is published by Ivory World, Lda. ("IVORY", "we", "us"), tax number NIPC 516 906 739. We sell products at ivory-therapy.com (the "Store").

From 1 November 2026 we will provide online psychology consultations (the "Psychology Services") as a health establishment registered with the Portuguese Health Regulatory Authority (ERS); until that date, IVORY does not operate as a clinic or health establishment and only puts clients in touch with independent psychologists, who provide the sessions under their own professional responsibility.

This policy is part of our Privacy Policy and does not replace it. Contact: care@ivory-therapy.com. IVORY does not bill health insurers and is not, to our knowledge, a covered entity or business associate under the US Health Insurance Portability and Accountability Act (HIPAA).

2. Scope and what "consumer health data" means

This policy applies to consumers in Washington, Nevada and Connecticut, and we apply it to all residents of the United States. It also applies to anyone whose consumer health data we collect while they are in those states.

"Consumer health data" means personal information that is linked or reasonably linkable to you and that identifies your past, present or future physical or mental health status, including that you are seeking or using health services. For IVORY, examples are:

  • visits to our pages about therapy, our SOS page and our mental health blog, which our analytics and advertising tools can record, according to your cookie choices except for the transitional exceptions in section 3;
  • your answers to the matching questionnaire;
  • your bookings, your attendance and the clinical records of the Psychology Services;
  • the use of a Session Voucher to book a session.

3. What we collect and why

  • Browsing of health-related pages. Our Store has pages about therapy and mental health, and our contact page. The analytics, session-recording, advertising and email-marketing tools of our partners (such as Google, Meta, TikTok, Pinterest, Microsoft Clarity and Klaviyo) can run on these pages, as on the rest of the Store, according to the choices you make in the cookie banner, except for the transitional exceptions described below (Part C of our Privacy Policy). A visit to these pages can show an interest in mental health services. We use this browsing data for statistics, measuring our campaigns and advertising, only according to your cookie choices, except for the transitional exceptions below. Strictly necessary Shopify cookies work everywhere.
  • Transitional exceptions. Until we complete the changes described in Part C2 of our Privacy Policy, 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.
  • Matching questionnaire, bookings and clinical data. We collect your answers, booking details, informed consent and clinical record to match you with a psychologist, deliver and manage your sessions, keep the legal and ethical records of the service, issue invoices, handle complaints and protect life in an emergency. These purposes are described in Part B of our Privacy Policy.
  • Payments and invoices. Name, amount, date and payment method, without clinical details.
  • Session Voucher. The Store tells the clinical side only the voucher code and its status. The clinical side does not tell the Store whether, when or by whom a voucher was used.

We do not use the information of the Psychology Services (the matching questionnaire, bookings, clinical records and voucher use) for advertising, profiling for commercial purposes or training artificial intelligence systems.

4. Sources

We collect consumer health data from you; from your device, through cookies, according to your choices in the cookie banner, except for the transitional exceptions in section 3; and from the psychologist who sees you.

5. What we share and with whom

  • Advertising and analytics partners: we do not share the information of the Psychology Services (the matching questionnaire, bookings, clinical records and voucher use) with Meta, Google, TikTok, Pinterest, Microsoft Clarity, Triple Whale or other advertising or analytics partners. Browsing data collected through cookies, which can include visits to our pages about therapy and mental health, is shared with these partners, and with Klaviyo, according to your choices in the cookie banner (Part C of our Privacy Policy), including the "Marketing" and "Sale or sharing of data" choices, except for the transitional exceptions described below. If you accept these categories, these partners may collect browsing data about you over time and across different websites. If you reject them, you can use the whole Store as usual.
  • Transitional exceptions: until we complete the changes described in section 3 and in Part C2 of our Privacy Policy, browsing data collected on every page, including the pages about therapy, by the Google tag installed through the Google & YouTube app, Microsoft Clarity, and the Klaviyo and Triple Whale site scripts is sent to Google, Microsoft, Klaviyo and Triple Whale before you make a choice and even if you reject. We are switching these tools to work only with your consent.
  • Service providers that act for us (processors), for the Psychology Services only: the booking platform (Squarespace Acuity Scheduling), the video platform (Zoom), the tool behind the matching questionnaire, the clinical record system, Google Workspace for email about the Psychology Services, our internal management system for scheduling and the remuneration of psychologists (Supabase and Vercel, which holds a copy of booking data), and our invoicing provider (invoices without clinical details). These providers may use the data only to serve us. The full list with locations and safeguards is in Parts B7 and B8 of our Privacy Policy.
  • Email marketing provider (transitional): until the separation described in section 3 of our Privacy Policy is complete, our email marketing provider (Klaviyo, Inc., a processor) may still hold contact details of people who requested a session; we are removing them and do not use them for advertising.
  • Legal recipients: the ERS, the Ordem dos Psicólogos Portugueses (the Portuguese Order of Psychologists, OPP), courts, public authorities and emergency services, where the law requires or to protect life.
  • Affiliates: none. We share no consumer health data with affiliates.

We do not sell the information of the Psychology Services, and we have never asked for a signed authorisation to sell consumer health data. We do not use a geofence around any place that provides health services.

6. Your consent

  • Collection: in the Store, the "Analytics" category of the cookie banner is the consent to collect browsing data by analytics tools, except for the transitional exceptions in section 3, which do not yet depend on your choice. The information you give for the Psychology Services is collected only to provide your care, as explained in Part B of our Privacy Policy. If we ever wanted to use consumer health data for another purpose, we would ask for your separate consent first.
  • Sharing: the "Marketing" category and the "Sale or sharing of data" choice of the cookie banner are the consent to share browsing data with advertising partners, except for the transitional exceptions in section 5. We do not share the information of the Psychology Services with advertising partners.
  • You can withdraw consent at any time, as easily as you gave it: delete our cookies and answer the cookie banner again, use the Your Privacy Choices page, or write to us (section 7). Withdrawing does not yet stop the transitional exceptions in sections 3 and 5.

7. Your rights and how to use them

You have the right to:

  • confirm that we collect, share or sell your consumer health data, and access it, including a list of all the third parties and affiliates with whom we shared it, with their contact details;
  • withdraw your consent to collection or sharing;
  • review your consumer health data and ask us to correct it, as described in Part D of our Privacy Policy;
  • delete your consumer health data. We delete it from our records and tell our processors and the third parties we shared it with to do the same. Where data are in archive or backup systems, we delete them when those systems are next restored or accessed, and in any case within the period the law allows;
  • not be treated worse for using these rights.

How to ask: write to care@ivory-therapy.com. We may verify your identity and, because we handle clinical records, we may ask for additional information first. We answer within 45 days, and we may extend this once by a further 45 days if needed, and we tell you why. Some clinical records must be kept by law or the OPP Code of Ethics for a minimum time (Part B of our Privacy Policy); in that case we tell you what we kept and why.

Appeal. If we refuse your request, reply to our decision within 45 days and tell us you wish to appeal. We decide within 45 days and explain our decision in writing. If you are not satisfied, you can contact the Attorney General of your state: for Washington, the Washington State Attorney General's Office; for Nevada, the Nevada Attorney General; for Connecticut, the Connecticut Attorney General.

8. Security and access

We encrypt data in transit. Access to the data of the Psychology Services is limited, by role, to the psychologists who see you, the Clinical Director and a few authorised staff who are bound by professional secrecy or confidentiality. More detail is in Part B10 of our Privacy Policy.

9. Psychology Services for people in the United States

Our psychologists are registered with the OPP and provide the Psychology Services from Portugal under Portuguese law. They are not registered or authorised to practise by any US state. The terms for the Psychology Services (section on eligibility and international availability) explain what this means and ask you to state where you are for every session.

10. Changes and contact

If we change this policy in a material way, we show the new date and, before we collect or share any new category of consumer health data, we ask for your consent where the law requires it. Earlier versions are available on request. The English version of this policy prevails for residents of the United States.

Contact for questions about this policy: care@ivory-therapy.com.