Welcome to our privacy and cookie policy.
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 download and use our mobile application (app) when available 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. We also comply with EU GDPR as amended from time to time which applies to data subjects who reside in the European Economic Area (EEA).
This policy aims to give you information on how we collect and process your personal data through your use of our website and app, including any data you may provide when you purchase a product or service, or create a user account.
Our website and app are not intended for children and we do not knowingly collect data relating to children.
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 this is the website in which you can create an account with us and access, or make an order for, our products and content.
We are the 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) or by writing to us at mail@red-whale.co.uk.
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.
We keep our privacy and cookie policy under regular review. This version was last updated on 13 September 2023 . We will notify you of any significant changes that affect our website or app. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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 app, 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, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We may also collect unique application numbers when you want to install or uninstall our app or when searches are carried out for automatic updates. That number and information about your installation, for example, the type of operating system, may be sent to us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but 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 disabled access. We will only collect and process special categories of sensitive personal data where you have disclosed this information to us and provided your explicit consent for us to process it.
You are not under any obligation to consent to us processing your sensitive personal data and if you are happy to consent to our use of your sensitive personal data, you will be able to withdraw your consent at any time. Please be aware, however, that without your consent, we may not be able to perform the contract we have with you in whole or in part.
We do not collect any other special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products or services). 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.
We use different methods to collect data from and about you including through:
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:
Generally, we do not rely on consent as a legal basis for processing your personal data, unless it relates to personal data provided through our app. We will also get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time either amending your preferences in your account, using the link at the bottom of our emails or by contacting us.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We have set out below, in a table format, a description of all 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| 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 subscription fees). |
(a) Identity (b) Contact (c) Employment (d) Professional |
(a) Performance of a contract with you. (b) Necessary for our legitimate interests to promote our products and services. |
| To install our app and register you as a new app user. |
(a) Identity (b) Contract (c) Technical |
(a) Your consent. |
|
To process and deliver your order including any in-app 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 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 app (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 app (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 deliver relevant website or app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy). |
| To use data analytics to improve our app, website, products and services, marketing, client relationships and experiences. |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website and app updated and relevant, to develop our business and to inform our marketing strategy). |
| To make suggestions and recommendations to you about products or services that may be of interest to you. Including providing clinical updates. |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products and services and grow our business). |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have opted into receiving that marketing..
You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences on your user account, by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase or other transactions.
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 we recommend that you should take necessary precautions, for example, avoid uploading images with embedded location data (EXIF GPS) included.
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 mechanism 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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Generally, we will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
We store the personal information users provide when they register on our website which users can access to review, edit, or delete this personal data at any time. We can also access that information, for review or editing.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for several years to comply with HMRC’s record keeping guidelines for tax purposes. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
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.
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:
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 |
| Analytics | Up to 1 year | |
| New Relic | Platform usage and performance monitoring | 1 week |
| Vimeo | Webinar video streaming settings and preferences. | 2 years |
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 13 September 2023