Who we are and what this Policy covers
This site is operated by Perceptive Agency Ltd trading as CETpoints.com. You can contact CETpoints.com;
- By email: firstname.lastname@example.org
- By telephone: 0131 526 3800
- By post: CETpoints.com, Thornhill House, 39 Thistle Street Lane South West, Edinburgh, EH2 1EW
Perceptive Agency Ltd is a limited company registered in England and Wales. Registered number 07703527. Registered office: Prince Albert House, King Street, Maidenhead, SL6 1DT, UK.
When we refer to our trading name, "CETpoints.com" or "we", "us" or "our" in this policy, we are referring to Perceptive Agency Ltd. We are the data 'controller', which means we determine the purposes and the way in which your personal data is, or will be, processed and are the company that is responsible for your data.
- Sets out the types of personal data we collect
- Explains how and why we collect and use your personal data
- Explains when and why we share data with other organisations and,
- Explains your rights and choices when it comes to your personal data.
Purpose of this Policy
How is your personal data collected?
We use different methods to collect data from and about you including:
1. Direct interactions. You may give us your personal data:
- By filling in forms on our website; and
- By corresponding with us in person, by email, by phone, by post or otherwise.
This includes when you register with our site, purchase credits or subscriptions, or book courses or conferences with us (whether on your own behalf or on behalf of someone else).
3. Third parties or publicly availabled sources. We may receive personal data about you from various third parties and public sources. For example, this includes information someone else provides about you when they book a subscription, course or conference on your behalf.
Personal data we collect
We may collect and process the following data about you:
- Contact data. This includes your full name, postal address, email address and telephone number.
- Communication data. This is details of any correspondence that we have with you.
- Booking data. Information of the subscription or credits you purchased, or course or conference you have booked or are scheduled to attend.
- Completion data. Information relating to the courses you complete on our website and the sessions you attend at courses or conferences we run.
- Professional data. This includes your professional registration and profession type.
- Review data. This is the details of any review or other feedback that you choose to provide to use related to a course or other service.
- Dietary and mobility data. This includes any special dietary or mobility requirements you share with us.
- Transaction data. This is details of your financial transactions processed by us. This includes your credit or debit card details (although we do not store these details).
- Marketing data. This includes your name, email address and marketing preferences.
How we use the personal data we collect
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 (i.e. when you purchase something from us).
- Where we have your prior consent to use your personal data (for example, where you have consented to receiving marketing).
- 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. 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.
- Where we need to comply with a legal or regulatory obligation.
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.
Please 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.
|How we use your personal data||Why? (i.e. our lawful basis)||What type of personal data do we process for this?|
|To process your subscription or book you onto an event.||To perform our contract with you||Contact data, booking data|
|To confirm your booking, send joining instructions, to remind you to attend events booked for you and to remind you when your subscription expires.||To perform our contract with you; Legitimate interests (of running our business)||Contact data, booking data|
|To provide you with materials you have requested from our website (e.g. download information).||To perform our contract with you; Legitimate interests (of running our business)||Contact data|
|To manage our relationship with you (including to identify you when you get in touch and communicate with you regarding any questions about your booking or complaints about any products or services you have purchased).||To perform our contract with you; Legitimate interests (of running our business)||Contact data, communication data, booking data, completion data|
|To tailor your subscription or check that the course or conference you booked is suitable for you.||To perform our contract with you; Legitimate interests (of running our business)||Professional data, booking data, completion data|
|To award CET points to you via the General Optical Council (GOC) CET scheme.||Legal obligation; Legitimate interests (of running our business)||Contact data, completion data|
|To carry out analysis on the types of subscriptions, online courses and events delegates book and complete (however, please note that we aggregate data so that results are anonymised and won't identify you).||Legitimate interests (of running our business)||Professional data, booking data, completion data|
|To ensure that event tutors/venues provide you with appropriate service.||To perform our contract with you; Legitimate interest (so that we can provide the best possible service to you); Consent; Public interest (necessary to ensure that the venue has suitable access)||Contact data, Dietary and mobility data, booking data|
|To help us manage and improve the user experience of our website.||Legitimate interests (to ensure our website works) (for essential cookies); Consent (for non-essential cookies)||Technical data|
|To process your payment for bookings, orders and refunds.||To perform our contract with you||Contact data, transaction data|
|To keep a record of financial transactions processed through our website or over the telephone.||To perform our contract with you; Legal obligation||Contact data, transaction data|
|To send you our newsletter and other marketing information.||Consent; Legitimate interests (of marketing and promoting our business)||Marketing data|
|To pass on details of your completion data to your employer (where your employer pays for your subscription).||Legitimate interests (of ensuring our services remain relevant); Consent||Contact data, professional data, completion data|
|Fraud prevention and detection (e.g. to detect misuse of our services).||Legal obligation; Legitimate interests (to protect our business and ensure you can use our service safely)||Contact data, transaction data|
We may sometimes request additional information from you for a specific purpose. For example, when we conduct a survey or you enter a competition. When additional information is requested, we will explain to you at the time of collection how we intend to use it and what the lawful basis for processing is.
How we share your personal data
Sharing your personal data with service providers
We may share your information with selected third parties who help us provide services to you and to keep your data safe. When we share personal data with these companies we require them to keep it safe, and they must not use your personal data for their own marketing purposes.
We share personal data with the following third parties:
- The event venue
- Event tutor(s)
- PayPal (our secure payment provider)
- Keap (our cloud-based CRM database provider)
- Google Analytics (for metrics and performance analytics)
- Google Adwords (for marketing)
- IT services providers, including ConsiderIT Ltd and 3 Feet High Ltd (who help us to run our IT systems)
- The General Optical Council (GOC) (who approve and audit our CET courses and who award CET points to you)
- Your employer (where your employer pays for your subscription).
Sharing your personal data with other organisations
We do not share your information with any direct mail organisations or other third parties unconnected with the provision of our activities without first gaining your express permission.
We may disclose your personal information to some third parties:
- Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or other agreements; or to protect our rights, property, or safety or the rights, property and safety of others. This includes HM Revenue & Customs and other regulators and authorities who require reporting of processing activities in certain circumstances, and also exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
How we protect personal data
Where we store your information and international transfers
The data that we collect from you are held on our secure server provided by ConsiderIT Ltd in the United Kingdom. We also store information about you, your bookings and purchases in a secure, cloud-based CRM database provided by Keap. To do this it may be necessary to transfer your data to, and store them at, a GDPR-compliant destination outside the European Economic Area (“EEA”).
If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- The country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- If we use certain service providers based outside the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
- In any other case, we will obtain your explicit consent before any transfer takes place.
The table below sets out details of transfers to third parties that may involve a transfer of data outside the EEA and the relevant safeguards in place.
|Service provider||Description of service||Safeguards|
|Keap||CRM database provider||Privacy Shield|
|Google Analytics||Metrics and performance analytics provider||Privacy Shield|
How long we keep your information
As a general rule we keep your data for seven years after your last transaction with us. We are legally required to keep details of financial transactions for seven years and CET completion details we hold, such as certificates of attendance at events and online CET course completions for 6 years as part of your CET portfolio.
We perform an annual data check every year in June/July. If at that check, we find you have not purchased goods and/or services from us for more than seven years we will contact you to ask if you wish to keep your account active. If we do not hear back from you after 30 days, we will archive your data into a non-processable format.
You can request that we delete the data we hold about you at any time. You can find out more in how to remove your data.
How we protect your information
We take the security of your personal data very seriously and have put in place appropriate security measures to ensure that your data is treated securely and in accordance with this policy. All information you provide to us is stored on our secure servers. All the information transmitted by you to our site is encrypted using SSL (Secure Sockets Layer) protocols. We use a secure payment provider (PayPal (Europe) S.à r.l. et Cie, S.C.A.) to process all electronic payment transactions. We never store your payment details.
You should be aware that whilst we do our utmost to protect your personal data, the transmission of information via the internet is never completely secure and so any transmission is at your own risk. However, we use strict procedures and the industry-standard security features mentioned above to prevent unauthorised access.
Please note that where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password secure and confidential. If you think it might have been compromised, then please let us as know as soon as you can.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note this may allow third parties to collect or share data about you. We do not control these third-party websites, which have their own privacy policies, and we are not responsible for these policies. Please check these policies before you submit any personal data to these websites. We would encourage you to read the privacy notice of every website you visit.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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 may 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 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 may 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.
To be informed
To access your data
You have the right to ask for a copy of the information which we hold on you (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.
You can see most of the details we hold about you by logging into your account on our website. There you will find the contact details we hold for you plus details of your purchases, subscriptions, event bookings, CET course completions, certificates etc. If you require a full copy of all the information we hold about you, please send an email to email@example.com requesting a copy of all your data.
To correct your data
You can update personal details we hold about you, including your name, address, email address, phone number, speciality, grade and dietary and mobility requirements by logging into your account on our website. You can also send an email to firstname.lastname@example.org requesting us to update any data we hold about you. We may need to verify the accuracy of any new data that you provide to us first.
To remove your data
You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. 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.
Please note, however, that we may not always be able to comply with your request to delete or remove all personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
To restrict your data
This right 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; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
You have the right to ask us not to process your personal data for direct marketing purposes. You can exercise your right to opt out of marketing communication by clicking unsubscribe in any email. This will remove your details from all newsletters and marketing campaigns. You will still receive an email from us to confirm any orders you place with us and we may contact you with further information relating directly to your booking such as if a course you booked is cancelled or moved to another venue.
You may also object to us processing 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Transferring your personal data
In certain circumstances, you may 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.
Please 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.
Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.
Review by an independent authority
You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. However, if you do have a complaint, we would appreciate the chance to deal with your concerns, so please contact us in the first instance if possible.
- email@example.com or
- CETpoints.com, Thornhill House, 39 Thistle Street Lane South West, Edinburgh, EH2 1EW.