Privacy Policy

Welcome to CPD Hub, our CPD course directory for Osteopaths and Chiropractors located at www.cpdhub.co.uk (our “Directory”). At CPD Hub, we respect your privacy and are committed to being transparent about what data we collect when you visit and use our Directory at www.cpdhub.co.uk and/or our services and how it is used.

GENERAL INFORMATION

1. What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.

1. What is processing?

“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

1. What law applies?

In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular the UK’s Data Protection Act (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”).

1. Who is responsible for data processing?

The responsible party for data processing is CPD Hub, London, UK (“CPD Hub”, “we”, “us”, or “our”). If you have any questions about this policy or our data protection practices, you can reach us via email using jane@cpdhub.co.uk, or call us on +44 7828 171228.

1. What are the legal bases of processing?

We only process your Personal Data if we at least one of the following applies:

• you have given your consent,
• the data is necessary for the fulfilment of a contract / pre-contractual measures,
• the data is necessary for the fulfilment of a legal obligation or
• the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

DATA WE COLLECT AUTOMATICALLY

1. Log data

For the continued operation and security of our services we record basic logs and event records until such time as they are no longer needed. These logs may contain a) Players Username, b) IP address, c) The clients servers IP, d) Timestamps and e) the referral URL. In this it is technically possible that an IP address can be combined with external data and to identify an individual using the services during a specific usage period. As such we treat all log data and specific event log data whether it is from end user requests or automated requests, as Personal Data. The legal basis is the provision of a contractual service.

1. Hosting

To provide our Directory, we use the services of Hostinger who process all data to be processed in connection with the operation of our Directory on our behalf. The legal basis for the data processing is our legitimate interest in providing our Directory.

1. Content Management System

We use the Content Management System (CMS) of WordPress, a service provided by Automattic Inc to publish and maintain the created and edited Content and texts on our Directory. This means that all content and texts submitted to us by users for publication is transferred to WordPress. In addition to texts, this also includes, for example your data in our forms. The legal basis for this processing is our legitimate interest.

1. WooCommerce

To provide our shop, we use the WooCommerce service developed and operated by Automattic Inc. WooCommerce provides us with their online e-commerce platform through which we can offer our goods for sale to you. Both your inventory data and your usage data are stored on WooCommerce’s servers. The legal basis for processing is our legitimate interest.

1. Fonts

We have integrated Google Fonts by Google LLC, and Font Awesome of Fonticons Inc. To enable the display of fonts, a connection to Font Awesome’s and Google’s server is established when our Directory is accessed. This enables Google and Fonticons to determine which website sent the request and to which IP address the display of the font is to be transmitted. The integration is based on our legitimate interest.

1. Economic analyses and market research

For business reasons, we analyse the data we have on web and server traffic patterns, website interactions, browsing behaviour etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymised values. For this purpose we use Google Analytics from Google, Jetpack by Automattic, SourceBuster JS. The legal basis is our legitimate interest and your consent. For further information on our use of analytics, please refer to our Cookie Policy.

1. Cookies

For the processing of personal data using cookies and similar technologies on our Directory, please refer to our Cookie Policy. The legal basis for the use of cookies is our legitimate interest or your consent when you agree to the use of technically non-essential cookies as further explained in our cookie policy.

1. Cookie consent

As set out in the UK`s Privacy and Electronic Communications Regulations (“PECR”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of technically non-essential cookies. For this purpose we use a cookie consent tool, to obtain your consent to the storage of cookies and to document this consent. When you enter our Directory, the following Personal Data is transferred to us via our cookie consent tool: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our Directory. The basis for processing is our legitimate interest and your consent.

Data we collect directly

1. General

We may ask you for Personal Data when you:

• use our directory and services,
• request services, support, or information,
• participate online or otherwise in marketing and advertising activities,
• subscribe to CPD Hub`s marketing and promotional emails or other materials,
• interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or
• contact us.

In order to provide you with a more consistent and personalised user experience in your interactions with CPD Hub, data collected through one source may also be linked to other data collected by CPD Hub through other sources. This may include data that helps us identify you when you access our Directory through several different devices.

1. Contacting us

In addition to your name, e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and Contract.

1. Registration of a user account

On our Directory, we offer users (Inserted Parties and CPD Course Provider) the opportunity to register an account. The data is entered into our registration form and transmitted to us and stored. The data is not passed on to third parties. The following data is collected as part of the registration process: i) First name/ last name, ii) Email address, iii) Password, iv) the IP address of the user and v) date and time of registration. The legal basis for processing is consent and the fulfilment of a contract. The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. As a user, you have the option at any time to delete your registration with us. You can change your data stored with us at any time independently and / or delete or have deleted. If the data is necessary for the fulfilment of a contract or for the execution of pre-contractual measures, an early deletion of the data is only possible, as far as contractual or legal obligations do not oppose a deletion.

1. Use of our listing services

If you wish to use our listing services and its features, we process the Personal Data you voluntarily provide for the purpose of providing our listing services. Depending on how you use our listing services, you may provide images, contact information, company information, location data etc. and upload content such as text, photographs etc. This content will be made public and may be viewed and otherwise accessed by others.

Some of the Personal Data you provide may be considered “special” or “sensitive”. This includes Personal Data concerning for example your health, racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data. You have choices about the data you provide and how you share it. You don’t have to provide Personal Data or Special Category Data; however, information about you helps you to get more from our Services. It’s your choice whether to include Personal Data or Special Category Data and to make that information available to us. Please do not share information that you would not want to be available.

The legal basis for processing of your Personal Data and Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent.

1. When using our Directory

We process the data of our users in order to be able to provide our services as well as to ensure the security of our Directory and to be able to develop it further. This includes in particular our support, correspondence with you. Your data will not be used by us for automated decision making or profiling. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfil our legal obligations.

1. Information that we share with others

You share information with other users when you voluntarily disclose information on the service (including your profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible. The legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your consent.

1. Information that we receive from others

In addition to the information you provide to us directly, we receive information about you from others, including other users who provide us with information about you. For example, when they leave a review about your services. The legal basis is the fulfilment of the user contract for the use of our Directory as well as your consent.

1. Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

1. Payment Data

If you make payment, your payment data will be processed via our payment service provider PayPal through our website. Payment data will solely be processed by PayPal and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.

1. Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose including improving our website and services. 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. 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.

1. Promotional use of your data

We use your data (email address) within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers using the services of . In addition, we may draw your attention to comparable offers by email, e.g., we may inform you about exclusive sales, promotions, or special events. The legal basis for processing is our legitimate interest.

1. Social Media

We have a presence on social media based on our legitimate interests. If you contact or interact with us via social media websites, we and the respective social media website are jointly responsible for the processing of your data and enter into a so-called joint-controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual performance, if any.

MARKETING

Insofar as you have given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving marketing communication based on your interactions or contractual relationship with us.

Our Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

PRINCIPLES OF PROCESSING PERSONAL DATA

1. Storage and Retention

We will retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy, and in accordance with UK`s retention periods for up to 6 years.

1. Security

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

1. Sharing and Disclosure

We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfil our legitimate interests.

1. International Transfer

In the course of my website operation, we process data. We usually do not transfer Personal Data to countries outside the UK and the EEA. However, if we do, we will make sure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses for a high level of data protection.

1. What we do not do

• We do not request Personal Data from minors and children;
• We do not use Automated decision-making including profiling; and
• We do not sell your Personal Data.

YOUR RIGHTS AND PRIVILEGES

You can exercise the following rights:

• Right to information
• Right to rectification
• Right to object to processing
• Right to deletion
• Right to data portability
• Right to withdraw consent
• Right to complain to a supervisory authority
• Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

1. Updating your information and withdrawing your consent

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object (including withdrawing of consents you have given us) to its processing, please do so in your account or by contacting us.

1. Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

1. Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner’s Office (ICO) located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk

HOW DO WE MAKE CHANGES TO THIS POLICY?

We may change our Privacy Policy from time to time. When we change our Privacy Policy, we will publish the updated policy on our Directory. Please check this Privacy Policy regularly. Subject to applicable law, all changes will take effect as soon as we publish the new Privacy Policy, but where we have already collected information about you and/or where legally required to do so, we may take additional steps to inform you of any material changes to our Privacy Policy and may request that you agree to these changes.

EFFECTIVE DATE

Friday, 14th of June, 2024