For the purposes of the General Data Protection Regulation ((EU) 2016/679) (the “GDPR”) the data controller is Physiopedia Plus Ltd, trading as Plus Ltd (company number 07878211), which has its registered address at 10 Queen Street Place, London, England, EC4R 1BE.
Third party websites
3. The information PPL collects and how it is used
3.1 The information PPL collects is set out in this section 3.1. Failure to provide such information may mean that you are unable to receive the Plus Services or register as a Member.
3.2 You do not need to register for a Plus Services account in order to visit the Site, however, you must subscribe to use the Plus Services. For these no-registration-required services PPL collects the following information:
- 3.2.1 General: You may give us personal information about you by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you apply for a an account, subscribe to the Plus Services, register for an online course or event, or other social media functions on our Site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and professional information.
- 3.2.3 E-mail Messages: Note that if you send an e-mail to PPL we may retain those communications and your e-mail address in order to reply to your enquiries, fulfil your requests and to improve our services.
Additional information collected from Members
3.4 In order to use the Site content you must subscribe as a “Member” (see the Terms and Conditions (https://members.physio-pedia.com/home/physiopedia-plus-terms-and-conditions/). PPL collects the personal information described above at Section 3.1 from Members, and in addition, PPL collects the following types of personal information from Members:
- 3.4.2 Profile Information: Members must disclose in their profiles their professional licence or registration details and the organisation that governs this license or registration. This enables PPL to provide you with written detail of appropriately earned credits for your completed learning activities related to your professional governing jurisdiction.
- 3.4.3 Your IP Address: In addition to your profile, you may also be identified in the PPL system by your IP address, the numerical address of the location from which you are connecting to the Site. That IP address may be traceable specifically to your computer, or it may only be traceable to the Internet Service Provider (ISP) you use to access the Internet, depending on what type of connection you have. In either case, PPL will have the ability to link your IP address to your contributions on the Site, which helps to prevent abuse and fraud.
- 3.4.4 Contributions: When Members submit content to the Site (such as in the discussion forum), that information becomes publicly available to other Members throughout the world via the Site, and each such “post” will be attached to the Member’s profile. Deleting or cancelling your account may not permanently delete that content. This does not affect any of your rights under applicable law.
- 3.4.5 Learning Log: When Members log learning activities that information will be attached to the Member’s profile. We will store this information for as long as the account is active to ensure that it is always available for your professional development records.
- 3.4.6 Email: Other Members may send messages to you through the Site, however your email address will not be revealed to them unless you respond, or possibly if their email to you is “bounced” back to them. PPL may use Members’ email address to communicate with them periodically.
- 3.4.7 Invitation emails: You may choose to opt-in to the PPL invitation emails when you register as a Member. You can choose to opt-out of PPL invitation emails by clicking the unsubscribe link at the bottom of the invitation email.
- 3.4.8 Links: We may present links in a format that lets us keep track of when these links are clicked. We uses this information to improve the quality of the Plus Services, to estimate traffic we send to third party sites and to customise content and advertising.
4. The basis on which we process your information
4.1 We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information if: it is necessary to perform or enter into our contract with you (as a member of PPL); we have a legitimate interest for processing your data; you have provided your consent; or we are under a legal obligation to do so.
4.2 Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” in section 12 below.
Please refer to our Physiopedia terms and conditions (https://www.physio-pedia.com/Physiopedia:Terms_of_Service) which set out how we use the personal information you provide to us for the purpose of receiving the Physiopedia services.
6. When we may share your information
We may share your personal and non-personal information with certain third parties in the circumstances set out below. 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.
Sharing of information between Physiopedia companies
6.1 If you subscribe to our Plus Services, information (both personal and non-personal information) is shared between Physiopedia companies and us in order for Physiopedia companies and us to provide or improve services.
Sharing of information with professional organisations
6.2 We may share personal information with professional organisations that have provided you with access to the Plus Services (such as professional member associations, educational institutions and service providers such as clinics and hospitals) in order to demonstrate your engagement with the Plus Services.
Sharing of information with accrediting organisations
6.3 We may share personal information with accrediting organisations to validate the award of continuing professional development points or continued education units.
Operations and Maintenance Contractors
Advertising and Promotions
6.6 We may share non-personal information (such as anonymous website use data) with third-parties to assist them in understanding the Site, including usage of the Site and the services PPL provides and the success of advertisements and promotions.
Plus Email Newsletter
6.7 We use a third party provider, Sendy, to deliver our Plus email newsletter. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our content. For more information, please see Sendy’s privacy notice here (https://sendy.co/privacy-policy).
6.8 We may have to share personal and non-personal information in order to comply with the Terms and Conditions (https://members.physio- pedia.com/home/physiopedia-plus-terms-and-conditions/) and other agreements or to protect the rights, property, or safety of PPL and its users or others.
Breach of the Terms and Conditions
6.9 We also reserve our right to disclose information that we believe is appropriate or necessary to enforce the Terms and Conditions, take precautions against liability, to investigate and defend ourselves against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site, and to exercise or protect the rights, property, or personal safety of Site users or others.
6.11 In the unlikely event of PPL’s bankruptcy, insolvency, reorganisation, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used.
6.13 Please contact us for any additional questions about the management or use of personal information.
7. Your choices
8. Where we store your personal information
8.1 The data that we collect from you may be transferred to, and stored at, a destination outside the UK. It may also be processed by staff operating outside the UK who work for us or for one of our suppliers, including Kinsta. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- 8.1.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- 8.1.2 Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
8.2 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. 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 confidential. We ask you not to share a password with anyone.
9. Information security
9.1 Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our Site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
9.2 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.
10. How long we store your personal information
We will store your personal information:
10.1 in respect of Members:
for as long as the Member’s profile remains active, unless you ask us to remove it; and
10.2 in respect of personal information collected for any other purposes:
only for such period as it is required to provide the services to you.
11. Updating personal information
You may update your personal information or prevent or restrict processing of your personal information by visiting your profile page or contacting us at the email address at [email protected].
12. Your Rights
Under data protection law, you have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact our general support team using the contact details set out above. For additional information on your rights please contact your data protection authority and see below.
The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.
The right of access. You have the right to request certain information about, access to and copies of your personal information (if we’re processing it). Please note that you are entitled to request one detailed summary of that personal information at no cost, but for any further costs we reserve the right to charge a reasonable fee based on administration costs.
The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete.
The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of certain of the information that we hold about you. However, please note that this will not apply if we are required to retain the information for compliance with a legal obligation.
The right to restrict processing. You have rights to request that we stop using your personal information or limit the way in which we use it. When processing is restricted, we can still store your information, but will not use it further.
The right to data portability. You have the right to request that we return your personal information in an accessible and transferrable format, or that we send it directly to another company, where technically feasible;
The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. where we rely on consent as a legal basis for processing your information), you have the right to withdraw that consent at any time.
The right to object to processing. You have the right to object to certain types of processing where we use it for our legitimate interests or for marketing purposes.
12.1 You can exercise your rights free of charge, but we reserve the right to charge a reasonable fee for such requests which are repetitive, manifestly unfounded or excessive, in accordance with applicable law.
12.2 Under certain circumstances, you can request transfer of your personal information directly to a third party where this is technically feasible. 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.
12.3 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.
13. Deleting your personal information
The account cancellation facility allows you to request that all personal information relating to you be deleted from the Site and our database. We will honour your request provided the personal information is not required for compliance with a legal obligation under English law or for the establishment, exercise or defence of a legal claim.
14. Complaints, problems and correcting and removing personal information
14.1 If you have a complaint or problem or would like any personal information relating to you corrected or deleted, please e-mail us at [email protected]. We will forward your complaint, problem or request to the appropriate internal PPL department for a response or resolution.
14.2 Personal information will be corrected or deleted, as applicable as soon as possible following receipt of the request. We try to answer every e-mail within 2 business days, but may not always able to do so.
14.3 If you do not receive adequate resolution of a privacy related problem, you may write to the PPL Privacy Office at:
Plus, 10 Queen Street Place, London, EC4R 1BE, United Kingdom.
14.4 We will notify you within 30 days of receipt of your letter to confirm your personal identifiers have been corrected or removed.
14.5 You may also lodge a complaint with the UK Information Commissioner’s Office (https://ico.org.uk).
15. Limitations on removing or changing information
Upon your request, we will delete your personal information from our active databases and where feasible from our back-up media. You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our servers, and this action will prevent the Member from downloading activity data following the deletion of their data.
16. Notification of data breaches
In the event of a data breach we will endeavour to alert all affected Members within 72 hours after we become aware of the full details of the data breach.
17. Our Commitment to Children’s Privacy
Protecting the privacy of young children is especially important. No part of the Site is intended for persons under 16. If you are under 16 years of age, then please do not use or access the Site at any time or in any manner. We do not knowingly collect personal information on the Site from persons under 18 years of age.
18. International Users
19. Changes to this Policy
Plus, 10 Queen Street Place, London, EC4R 1BE, United Kingdom.
What is personal information?
21.1 We define “personal information” as information that enables us to identify you directly or indirectly.
What is non-personal information?
21.2 We define “non-personal information” as information which does not identify individuals, whether on its own or in conjunction with other information collected by us. This includes information that is collected from many people, anonymised and aggregated into groups so that individual users cannot be identified.
What is collected information?
21.3 We define “collected information” as both the personal and non-personal information that we collect from users.
What is opt-in?
21.4 “Opt-in” means you are actively indicating your preference to participate in a program, email, feature, tool, or enhancement on a web site. Typically, if you “Opt-in” you must provide certain information, usually personal nformation, to the website or otherwise actively indicate your choice or preference to participate in the website program.
What is opt-out?
21.5 “Opt-out” means that if you do not take some action you are indicating your preference to participate in a program, email, feature, tool or enhancement on a website. Typically, if you “opt-out” you must uncheck a box next to a stated preference or otherwise take some indicate action to indicate your preference not to participate in a program.
What is a Plus Account?
Last updated: [October] 2022