We respect your privacy and we are committed to protecting your personal data. This privacy policy is broken up into two sections, our privacy policy and our cookie policy.
We will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or interact with any of our IT systems, and tell you about your privacy rights and how the law protects you.
We comply with UK data protection law (UK GDPR and the Data Protection Act 2018), as amended from time to time, which applies to data subjects who reside in the UK.
This policy aims to give you information on how we collect and process your personal data through your use of our website and application, including any data you may provide when you purchase a product or service, or create a user account.
It is important that you read this policy together with any other notices or fair processing policy we may provide from time to time when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.
We are GP Update Limited - a company registered in England and Wales. Our company registration number is 7135974 and our registered office is at One Canada Square, London, E14 5GS.
We operate https://redwhale.co.uk and associated subdomains.
We are the data controller and responsible for your personal data (collectively referred to as, "we", "us" or "our" in this policy). If you have any questions about this privacy and cookie policy, including any requests to exercise your legal rights, please contact us using the details set out below.
You can contact us by telephone on 03330 093 090 (charged at the same rate as standard landline numbers starting with 01 or 02) Monday to Friday 9.00am to 5.00pm or by writing to us at mail@redwhale.co.uk.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you do not provide that data when requested, we may not be able to perform the contract or deliver our services to you. In this case, we may have to cancel your order for a product or service, but we will notify you if this is the case at the time.
Please keep us informed if your personal data changes during your relationship with us.
As per NHSE and GMC guidance when recording CPD entries, you should not include any personal identifiable information (whether patient, colleague or another person) or include specific information about role or health condition that could make a person identifiable. To do so is in breach of information governance rules.
Our website and app may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or application, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect different kinds of personal data about you, which we have grouped together as follows:
Identity Data includes first name, last name and title.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Employment Data includes your employment status, job title, department or specialism, employer or any organisations/surgeries you may work with.
Professional Data includes your professional status, professional registration numbers and continued professional development information that you might enter on the site.
Financial Data includes bank account and payment card details. (We only collect these to process payments of your orders and do not store any payment card details on our own systems).
Transaction Data includes details about payments to and from you, other details of products and services you have purchased from us and any correspondence, negotiations or meetings we have with you in relation to our business.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and geo-location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our app or website. This may also include the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system and the type of mobile browser you use.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences and feedback.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
CPD information includes information that you might choose to enter as evidence of your learning on the site, your reflections on this learning and your potential further development requirements.
We also collect Aggregated Data such as statistical or demographic data, which is not considered personal data in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
The only Special Categories of Personal Data that we may collect about you are in relation to:
We only request the above data when it is strictly necessary in order to comply with a contract we have with you, for example, if we are providing refreshments during a seminar as part of our service or making sure a venue we book has appropriate access. We will only collect and process special categories of sensitive personal data where you have disclosed this information to us.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by phone, email, live chat or otherwise. This includes, but is not limited to, personal data you provide when you:
Automated technologies or interactions. As you interact with our website append IT systems, we will automatically collect data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties. We will receive personal data about you from various third parties as set out below:
Publicly available sources. We may receive personal data about you from publicly available sources as set out below:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
In most circumstances, we will get your consent before sending direct marketing communications to you via email or text message. Occasionally we may send you marketing communications where we feel there is a legitimate reason for doing so. You can opt out at any time by amending your communication preferences in your account, using the link at the bottom of our emails or by contacting us.
Please note, if you opt out of marketing communications, you will still receive essential information for using your product/service (such as course joining instructions) from us by email.
We have set out below, in a table format, the main examples of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| PURPOSE/ACTIVITY | TYPE OF DATA | LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST |
|---|---|---|
| When you create a user account with us to view our content (whether provided free of charge or subject to payment of fees). | (a) Identity (b) Contact (c) Employment (d) Professional | (a) Performance of a contract with you. (b) Necessary for our legitimate interests to gather business insights about our market, promote our products and services. |
| To install any of our applications and register you as a new application user. | (a) Identity (b) Contract (c) Technical | (a) Your consent. |
| To process and deliver your order including any in-application purchases: (a) Manage payments, fees and subscription charges (b) Collect and recover money owed to us (c) Providing training (whether face to face, live stream or pre-recorded webinar) (d) Providing our CPD record system. | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (d) Employment (f) Professional | (a) Performance of a contract with you. (b) Necessary for our legitimate interests (to recover debts due to us and manage your order for products or services). |
| To manage our relationship with you, which will include: (a) Notifying you about changes to our terms and conditions or privacy and cookie policy (b) Keeping a record of your requirements (e.g. meeting notes) (c) Notifying you of any updates or changes to our application (d) Notifying you of the date, time and location of any courses you have booked (including instructions to join online courses) (e) Asking you to leave a review or provide feedback. | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Technical | (a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to keep our records updated, to understand how clients use our products and services and to enable us to give you the best possible service). |
| To administer and protect our business, website and application (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | (a) Identity (b) Contact (c) Technical (d) Profile | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, spam detection, to prevent fraud and in the context of a future business reorganisation or group restructuring exercise). (b) Necessary to comply with a legal obligation. |
| To improve our application, website, products and services, marketing, client relationships and user experiences. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Transactional | (a) Necessary for our legitimate interests (business insight to inform future developments). |
| To deliver marketing communications and advertising. | (a) Identify (b) Contact (c) Technical (d) Usage (e) Transactional (f) Profile | (a) Your consent (b) Necessary for our legitimate interests (to support you in using a product or service, respond to an enquiry, and inform you of services that may be of interest). |
We may share your personal data with the parties set out below for the purposes set out in the table above, at clause 11 or in accordance with our cookie policy:
We require all third parties we have arrangements with to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
However, despite this there are unavoidable risks with any personal data you share online. It is therefore your responsibility to make sure you have secure settings on your browser and operating systems and take necessary precautions.
We may be required to transfer your data outside of the UK or the EEA (depending on the area that is applicable to you as a data subject). When we are required to do this, we ensure a similar degree of protection is afforded to it (in accordance with the protections set out by UK data protection laws and EU GDPR, depending on where you reside as a data subject) by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific safeguards used by us when transferring your personal data internationally.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We hold your personal information for as long as is necessary to fulfil the purposes we've outlined in this privacy policy, and to comply with our own legal obligations (whichever is longer). For example, we will retain purchase information and transactional data for 7 years from the date of your last purchase. Where we retain data for longer for business purposes, we will aggregate and anonymise this. Please contact us if you have a specific query about the length of time we hold certain data.
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. You also have the right to ask us to delete or remove certain personal data. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. Where technically feasible, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Please click: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/individual-rights/ to find out more about these rights. If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If we cannot resolve your issue to your satisfaction, you have the right to raise a complaint to the UK's supervisory authority for data protection, the Information Commissioner's Office (ICO) at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Alternatively, you can email the ICO at casework@ico.org.uk or call 0303 123 1113.
We keep our privacy and cookie policy under regular review. This version was last updated on 29th August 2024. We will notify you of any significant changes.
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By using our website, you accept our cookies. Please note that if you use your browser settings to block all cookies you may not be able to access all or parts of our website.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive, smartphone or other smart device. In this document, we use the term 'cookie' interchangeably with similar technologies such as Local Storage, Session Storage and IndexedDB, which provide the functionality to store data in a web browser.
We may use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website and access your user account. The vast majority of cookies on our website are strictly necessary cookies (also referred to as essential cookies).
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences.
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests.
Materials on our website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if you have visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Please note that the following third parties use cookies on our website, over which we have no control. We do not accept any liability for their compliance with their legal obligations and recommend that you review their respective privacy policies. These third party cookies are likely to be analytical cookies, performance cookies or targeting cookies:
| COOKIE OWNER | PURPOSE | DURATION |
|---|---|---|
| Freshdesk/Freshchat | Supports chat history, settings and session data. | 1 year |
| HubSpot | Platform usage, monitoring and analytics. | 6 months |
| On24 | Consumption of content, monitoring and analytics. | Up to 1 year |
| Analytics. | Up to 1 year | |
| New Relic | Platform usage and performance monitoring. | 1 week |
| Vimeo | Webinar video streaming settings and preferences. | 2 years |
| Typeform | Forms and surveys. | 6 months |
| Pigeonhole Live | Online event Q and A, polls and chat. | 2 years |
| Font Awesome | Platform graphics | 1 week |
| Rollbar | Platform error logging | 1 week |
You can opt-out of the use of each category of cookie by changing the settings on your browser and you can also clear your browser of existing cookies at any time.
These Privacy and Cookie policies were last reviewed on 29th August 2024.