CPDmatch Privacy Policy

CPDmatch Privacy Policy (Last updated: 28-10-2023)

We’re Golden Haze Ltd, the brains behind CPDmatch! We’re committed to protecting and respecting your privacy.

This policy applies to your use of CPDmatch (our ‘Website’), and is for:

healthcare and other professionals that sign up to create an account on our Website, to access continuing professional development opportunities (‘CPD Opportunities’);
organisations that provide CPD Opportunities to Users (‘Providers’) and;
any other third parties that signs up to or enters details in to our Website.

This policy sets out the basis on which we’ll process your personal data – that is, data you enter into our Website or otherwise provide us with, that can be used to identify you.

It’s really important that you read this policy to ensure you understand how we’ll use and handle your information. If you have any questions about your data or this policy at any time, get in touch! You can contact us at cpdmatch@gmail.com.

What’s in this Privacy Policy?

You’ll need to read this Privacy Policy in full to understand how we look after your personal data.

1. Important information and who we are

Controller

Golden-Haze Ltd (CRN: 11106135, registered address: SME Centre of Excellence, 17 Main Street, Ponteland, Newcastle Upon Tyne, NE20 9HN) is the controller (collectively referred to as "Golden-Haze", "we", "us" or "our" in this privacy policy) and we’re responsible for personal data that you share with us when using CPDmatch.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It’s important that the personal data we hold about you is accurate and current. If your personal data changes during your relationship with us, we’d love to hear from you. Let us know by contacting us at cpdmatch@gmail.com.

Third Party links

If you are a User, our Website includes links to the websites of Providers. By clicking on a link to a Provider’s website, you may allow Providers to collect or share data about you. We do not control our Provider’s websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy and cookie policies of every website you visit.

2. The data we collect about you

Personal data

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:

From Users:

Identity Data includes your first name and last name.
Contact Data includes your email address.
Base Location Data in order to providing listings from Providers that are convenient based on your location. We call this Location Data. We ask for this so that we can filter CPD Opportunities by location, and display results that are convenient for you based on the filters that you’ve selected. If you don’t want to give us your Location Data you will still be able to use CPDmatch, but you will not be able to register, save searches and receive notifications.
Subjects of Interest Data which enables us to match you with relevant education.
Profile Data includes your username and password
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

From Providers:

Identity Data includes the first name and last name of the account holder, and the name of Provider (which may in some instances be personal data).
Contact Data includes your email address and telephone number.
Profile Data includes your username and password, address, contact telephone number, email and website addresses, Twitter (X) handle, CPD provider type, brief description of your organisation and default listing categories (subjects).
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Financial Data such as the Provider’s credit card details for payment for the services that we provide (and which in some cases may be personal data).

Data that isn’t personal data

If you are a User, we may collect and use the following data, which is not in law considered to be personal data, as it will not directly or indirectly reveal your identity:

We may use Location Data to create hotspot maps, which in some cases we will share with Providers in order to help them improve the service they provide and understand more about the needs of Users. We will always anonymise this data before we share.
Aggregated data could be derived from your personal data, for example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. We will not combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you.

Data we don’t collect

We don’t collect any 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.
Our Website is not intended for children and we do not knowingly collect data relating to children.
We don’t collect data about you from third parties, including (in the case of Users) from Providers.

If you fail to provide personal data

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 the services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Location or (in the case of Providers) Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

create a CPDmatch account;
request marketing to be sent to you;
request technical assistance;
in the case of Providers, pay for our services, or
give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
We may collect technical data in relation to your usage of CPDmatch from Google Analytics or a similar provider, to improve the services that we offer.

4. How we use your personal data

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:

where we need to perform the contract we are about to enter into or have entered into with you;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We’ve set out below 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’ve 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.

For Users:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a User	(a) Identity (b) Contact	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(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 and to study how Users use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content 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 our Users use our services, to develop the services, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, User relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of Users for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

For Providers:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including:	(a) Identity (b) Contact	(a) Performance of a contract with you
(a) Manage payments, fees and charges (b) Collect and recover money owed to us	(c) Financial (d) Transaction (e) Marketing and Communications	(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(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 and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

If you are a Provider, we may use your Identity, Contact, 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. This is how we decide which products, services and offers may be relevant for you.

You’ll receive marketing communications from us if you’ve requested information from us or purchased products or services from us and haven’t opted out of receiving that marketing.

We may market new features to you, but only where you have requested that we do so.

Opting out

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. You can also use the unsubscribe link which can be found at the bottom of our emails.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We’ll 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 at cpdmatch@gmail.com.

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.

5. Disclosures of your personal data

Dependent on whether you are a User or Provider, we may share your personal data with the parties set out below for the purposes set out in the table above.

Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties 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.

6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA) (or, in the event of Brexit, the EEA and the UK).

7. Data security

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.

8. Data retention

How long will we use your personal data for?

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.

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.

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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see section 10, glossary for further information.

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at cpdmatch@gmail.com.

No fee usually required

You won’t 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.

What we may need from you

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.

Time limit to respond

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’ll notify you and keep you updated.

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at cpdmatch@gmail.com.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

In respect of both Users and Providers, this means service providers acting as processors based in the United Kingdom who provide IT, system and (in the case of Providers) financial administration services.
Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide banking, legal, insurance and/or accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

Your legal rights

You have the right to:

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. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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:

If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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.