Privacy & Cookie Policy

1. Who we are

CareRight (“we”, “us”, “our”) provides training to the care sector across the United Kingdom, including the Oliver McGowan Mandatory Training programme.

CareRight and CareRight Training are trading names of Lotus Home Care Limited. We are the data controller for the personal data described in this policy. That means we decide what data is collected and why, and we are responsible for looking after it.

• Registered company name: Lotus Home Care Limited
• Company number: 09540376
• Registered office: Unit 2, Navigation Yard, Wakefield, West Yorkshire, WF1 5PQ
• ICO registration number: ZA174196
• Email: hello@carerighttraining.com
• Telephone: 0800 0 54 84 34
• Data protection contact: our Data Protection Lead, reachable at hello@carerighttraining.com

If you have any question about this policy, or want to exercise any of the rights in section 9, email us at hello@carerighttraining.com or write to us at the address above.

This policy covers carerighttraining.com, the enquiry forms on it, and the training and related services we deliver under the CareRight name. It is written to meet our obligations under the UK GDPR, the Data Protection Act 2018, the Data (Use and Access) Act 2025 and the Privacy and Electronic Communications Regulations 2003.

If you need this policy in an alternative format, please contact us.

2. What we collect

2.1 What you give us

Enquiry forms. Our enquiry and consultation forms collect your name, email address, telephone number, organisation name, the training you’re interested in, and anything you add in the comments field. Our training enquiry form also asks for your preferred dates, location and delegate numbers.

Correspondence. If you email, call or message us, we keep a record of that exchange and the contact details you used.

Bookings. If you book training, we collect what we need to deliver and certificate it: delegate names, job roles, work contact details, employer details, attendance records and assessment outcomes, plus billing and purchase order information.

We ask you to provide only information that is necessary for your enquiry or booking.

2.2 Health and accessibility information

If a delegate tells us about a disability, health condition, dietary requirement or anything else so we can make reasonable adjustments, that may count as special category data under Article 9 of the UK GDPR — a category the law protects more strictly.

We use it only to make the adjustment, we keep it to the minimum needed, and we delete it once the training has been delivered. Our basis for using it is your explicit consent under Article 9(2)(a).

We don’t need, and ask you not to send us, any information about the people in your care.

If you include special category data in a free-text field (for example in “comments”), we will treat it in accordance with this section and may remove it from our systems where it is not needed.

2.3 What we collect automatically

Subject to the cookie choices you make, we may collect:

• IP address
• Device type, operating system and browser
• Pages viewed, time on page, and what you clicked
• The page or advert that brought you to us, including campaign parameters in the web address
• Google click identifiers (gclid, gbraid, wbraid) added to the address when you arrive from a Google advert
• Approximate location at city or region level, derived from IP address
• A randomly generated identifier stored in a cookie

We don’t use this to work out who you are by name.

Some of this data may be collected via third-party cookies or similar technologies depending on the choices you make in the cookie banner.

3. Why we use it, and our legal basis

We may also use your personal data where necessary to comply with a legal obligation (Art. 6(1)(c)) and to establish, exercise or defend legal claims (Art. 6(1)(f)).

Where we rely on legitimate interests, we’ve weighed our interests against your rights and concluded ours don’t override them. You can ask us for a summary of that assessment at any time.

Note on your enquiry data. We collect and use your enquiry details on the basis of contract or legitimate interests, not consent. This means that declining cookies, or later withdrawing cookie consent, doesn’t stop us from replying to an enquiry you’ve sent us — but it does stop us using your data for the analytics and advertising purposes described in sections 4 and 5.

4. Cookies and your choices

4.1 How consent works here

We use CookieYes to ask for and record your cookie choices. On your first visit a banner appears, and no non-essential cookies are set until you make a choice.

When you respond, we record which categories you accepted, the date and time, and a consent reference, so we can evidence your choice if asked. You can change or withdraw your choice at any time using the Cookie settings link in the footer of every page. Withdrawing doesn’t affect anything that happened before you withdrew.

You can also control cookies through your browser settings, but blocking some cookies may affect how the site works.

4.2 Categories

The full itemised list of cookies, with names, providers, purposes and durations, is in the preference centre reachable from the Cookie settings link in the footer of every page.

4.3 Google Consent Mode v2

We use Google Tag Manager with Google Consent Mode v2. This tells Google’s tags what you’ve agreed to, and they behave accordingly. Before you choose, all of these are set to denied:

While denied, Google’s tags don’t read or write cookies on your device and don’t use advertising identifiers.

Where consent is denied, Google’s tags may still send a cookieless signal recording that a page was viewed. It contains no cookies or advertising identifiers and doesn’t identify you — only a timestamp, basic technical information about your browser, the referring page and your consent status. Google uses these to produce aggregated estimates of overall campaign performance. Our basis is our legitimate interests in measuring advertising effectiveness in a privacy-preserving way (Art. 6(1)(f)), and you can object at any time using the contact details in section 1.

We configure Consent Mode so that it respects the choices you make in our cookie banner.

4.4 Google Analytics 4

With your consent, we use Google Analytics 4 to understand how people find and use the site. It assigns a random identifier to your browser and records pages viewed and actions taken, such as submitting an enquiry form.

IP addresses are used to work out approximate location and aren’t stored by Google Analytics 4. Traffic from the UK and EEA is routed through domain-based servers before reaching Google. Where you have consented to advertising cookies, we may also enable Google Signals, which allows Google to associate your activity with a signed-in Google account that has ads personalisation turned on. We keep Analytics data for 14 months.

You can opt out of Google Analytics by declining analytics cookies in our cookie banner (or changing your choice later).

4.5 Google Ads

With your consent, Google Ads tags record when you’ve arrived from one of our adverts and whether you go on to enquire, so we can see which campaigns work. Where you’ve also consented to personalisation, we may show you our adverts again elsewhere.

Google acts as an independent controller for some of this. See policies.google.com/privacy, and manage your own ad settings at myadcenter.google.com.

If you consent to advertising cookies, we may also measure performance using Google’s conversion measurement tools, including where available privacy-preserving measurement such as aggregated or modelled reporting.

4.6 reCAPTCHA

Our forms are protected by Google reCAPTCHA v3, which distinguishes genuine visitors from automated spam. It analyses your interaction with the page and may collect device and behavioural information. It runs on our forms because without it they’d be unusable, so we treat it as strictly necessary for security and fraud prevention. Google’s privacy policy and terms apply.

5. Using your email address in advertising

Alongside our enquiry forms there’s an optional tickbox, unticked by default, asking whether you’re happy for us to use your details for marketing and to measure and improve our advertising. If you tick it, we may do the following. If you don’t, we won’t.

If you tick the box, you can withdraw your consent at any time by contacting us (see section 1).

5.1 Customer Match

We may use your email address and telephone number to build advertising audiences in Google Ads, a feature called Customer Match. Before anything leaves our systems it’s converted into an irreversible scrambled form using a technique called hashing, so Google never receives your actual email address. Google compares the scrambled version against its own account holders and, where there’s a match, we can show you our adverts, reach people with similar characteristics, or exclude you from campaigns aimed at people who aren’t yet customers. Google is contractually restricted in what it may do with this and must delete it after the applicable retention period.

You can withdraw this at any time by emailing hello@carerighttraining.com. We’ll remove you from our uploaded audiences within 30 days.

Withdrawal will not affect the lawfulness of processing carried out before you withdrew.

5.2 Measuring which adverts lead to bookings

When you arrive from a Google advert, a click identifier is added to the web address. Where you’ve consented to advertising cookies, we store it with your enquiry. If your enquiry becomes a booking, we may send that identifier back to Google Ads with a date and a value, so Google can connect the booking to the advert that produced it.

We don’t send Google your name, your enquiry, or details of the training you booked. We may also send a scrambled version of your email address for the same purpose.

If you do not tick the optional tickbox described above, we will not use your email address or telephone number for Customer Match.

6. Who we share it with

We don’t sell your personal data. We share it with:

Every processor is engaged under a written contract meeting Article 28 of the UK GDPR and can only act on our instructions.

Some suppliers may act as independent controllers for their own purposes (for example, Google for certain measurement and security purposes). Where they do, their own privacy policies apply.

7. Sending data outside the UK

Some providers are based outside the UK, mainly in the United States. Where data is transferred, we rely on the UK extension to the EU–US Data Privacy Framework where the recipient is certified, or on the International Data Transfer Agreement, or the EU Standard Contractual Clauses with the UK Addendum, supported by a transfer risk assessment. Ask us at hello@carerighttraining.com which applies to a particular transfer.

We may also take additional technical measures where appropriate, such as encryption and access controls, to protect data transferred internationally.

8. How long we keep it

After that we securely delete it or anonymise it so it can no longer identify you.

We may retain data for longer where necessary to establish, exercise or defend legal claims, or where we are required to keep it by law.

9. Your rights

You have the right to be informed about how we use your data, to get a copy of it, to have inaccurate data corrected, to have it erased in certain circumstances, to restrict how we use it, to receive it in a portable format, to object to processing based on our legitimate interests, and to withdraw consent where we rely on it. You have an absolute right to object to direct marketing at any time.

We don’t make decisions about you by automated means alone.

To use any of these rights, email hello@carerighttraining.com. We’ll reply within one month and may ask you to confirm your identity first. There’s no charge in almost all cases.

Marketing. Every marketing email has an unsubscribe link, and you can email us at any time instead.

Complaints. Please tell us first so we can put it right — email hello@carerighttraining.com and we’ll acknowledge your complaint and respond to it. You can also complain to the Information Commissioner’s Office at ico.org.uk, on 0303 123 1113, or at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

If you are unhappy with our response, you also have the right to apply to the court for a remedy.

10. Keeping it safe

We use appropriate technical and organisational measures: encryption in transit, access controls and multi-factor authentication, limiting access to those who need it, and contractual security obligations on our suppliers. No internet transmission is completely secure, so we can’t guarantee absolute security. We have a procedure for handling suspected breaches and will notify the ICO and affected people where the law requires.

Where we share data with suppliers, we limit what we share to what they need to perform their services.

11. Children

Our services are aimed at organisations and professionals. We don’t knowingly collect data from anyone under 18. If you think a child has given us their details, tell us and we’ll delete them.

12. Changes

We may update this policy. The current version is always on our website, and the date at the top shows when it last changed. Where changes are significant, we’ll tell you directly, and we may also highlight them on the website or contact you by email where appropriate.

CareRight — Website Terms of Use

Last updated: 6 August 2026

1. About us and these terms

This website, carerighttraining.com, is operated by Lotus Home Care Limited, a company registered in England and Wales under company number 09540376, whose registered office is at Unit 2, Navigation Yard, Wakefield, West Yorkshire, WF1 5PQ. We trade as CareRight and CareRight Training.

By using this website you accept these terms. If you don’t accept them, please don’t use the site.

You can contact us at hello@carerighttraining.com or on 0800 0 54 84 34.

If you are using this site on behalf of a business or other organisation, you confirm that you have authority to bind that organisation to these terms.

2. Changes

We may update these terms at any time, and the version on this page at the time you use the site is the one that applies.

We may also change or withdraw any part of the site without notice. We don’t guarantee the site will always be available or uninterrupted.

We may suspend, withdraw or restrict access to the site (or any part of it) for business and operational reasons.

3. Using the site

You may use this site for your own lawful, personal or business purposes.

You must not:

• Use it in any way that breaks any applicable law or regulation
• Attempt to gain unauthorised access to the site, its server, or any connected system
• Introduce viruses, trojans, worms or any other malicious material
• Attack the site through a denial-of-service attack
• Use any automated system to scrape, harvest or extract data from the site, except for legitimate search engine indexing
• Submit false information through our forms, or submit an enquiry on someone else’s behalf without their knowledge
• Reproduce, duplicate, copy or resell any part of the site in breach of these terms

Breaching this section may be a criminal offence under the Computer Misuse Act 1990. Where it is, we’ll report it to the relevant authorities and cooperate with them, including by disclosing your identity. We may suspend or withdraw your access to the site immediately for any breach.

You are also responsible for ensuring that anyone who accesses the site through your internet connection is aware of these terms and complies with them.

4. Our content

All intellectual property rights in this website and its content — including text, images, logos, course descriptions, branding and layout — belong to us or our licensors, and are protected by copyright and trade mark law.

You may print off one copy and download extracts of any page for your own reference. You must not modify anything you copy, use any illustrations, photographs or graphics separately from the accompanying text, or use any part of the site for commercial purposes without a licence from us. Our status as authors must always be acknowledged.

“CareRight” and “CareRight Training”, together with our logo, are trade marks used by us in the course of our business. They are not registered trade marks, and we assert our rights in them accordingly.

The Oliver McGowan Mandatory Training on Learning Disability and Autism is a national training programme. The programme name and any associated marks belong to their respective owners, and we use them only to describe the training we deliver.

If you would like permission to use any part of our content, please contact us using the details in section 1.

5. Information on this site

The content on this site is provided for general information only. It isn’t advice you should rely on for any particular purpose, and it isn’t a substitute for taking professional advice on your own regulatory obligations.

We take reasonable care to keep the site accurate and current, particularly in relation to regulatory requirements such as those under the Health and Care Act 2022. But regulations change, and we make no representations or warranties that the content is accurate, complete or up to date. Check the current position with the relevant regulator before acting on anything you read here.

Course details, availability and prices shown on the site are indicative and do not constitute a contractual offer. Prices are exclusive of VAT unless we say otherwise, and are confirmed at the point of quotation.

Where the site refers to third-party standards, guidance, or legislation, those references may be summarised and are not a substitute for reading the original sources.

6. Enquiries made through this site

Submitting an enquiry form doesn’t create a contract or a booking. It’s a request for information, and we’ll respond with details and a quotation where appropriate.

Our training and professional services are supplied to organisations under our General Training and Professional Services Agreement, which is a business-to-business agreement. A binding contract is formed when you sign that agreement or a Service Schedule under it, accept a quotation or booking confirmation in writing, issue a purchase order referring to the services, pay an invoice or deposit, permit us to begin work, or otherwise communicate unequivocal acceptance. Oliver McGowan Mandatory Training Tier 2 is supplied under a separate agreement.

Bookings are governed by those agreements rather than by these website terms.

Where you provide information about another person (for example a colleague or a delegate), you confirm that you have their permission to share their details with us and that you have made them aware of our Privacy & Cookie Policy.

7. Your privacy

We handle personal data in accordance with our Privacy & Cookie Policy, which explains what we collect, why, and what your rights are.

8. Links

Where we link to other sites, that’s for information only and doesn’t mean we endorse them. We have no control over their content and accept no responsibility for any loss arising from your use of them.

You may link to our home page provided you do so fairly and legally, and in a way that doesn’t damage our reputation or suggest any association or endorsement that doesn’t exist. You must not frame our site on any other site. We may withdraw linking permission at any time.

If you wish to link to pages other than our home page, please contact us first.

9. Our liability

Nothing in these terms excludes or limits our liability for death or personal injury caused by our negligence, for fraud or fraudulent misrepresentation, or for anything else that can’t lawfully be excluded.

We exclude all implied conditions, warranties and representations relating to this website to the fullest extent permitted by law.

We won’t be liable for any loss or damage arising from your use of, or inability to use, this site, or from reliance on any content on it. In particular, we won’t be liable for loss of profits, sales, business or revenue, business interruption, loss of anticipated savings, loss of business opportunity, goodwill or reputation, or any indirect or consequential loss.

We won’t be liable for any loss or damage caused by a virus or other technologically harmful material that infects your equipment through your use of this site or anything downloaded from it. You’re responsible for configuring your own equipment and using your own virus protection.

This section doesn’t affect your rights under our General Training and Professional Services Agreement or our separate Oliver McGowan Tier 2 agreement if you book training with us, or any statutory rights you have as a consumer. Nothing in these terms is intended to exclude liability that cannot be excluded under the Consumer Rights Act 2015.

10. Governing law

These terms are governed by the law of England and Wales, and the courts of England and Wales have exclusive jurisdiction.

If you are a consumer, you may also be able to bring proceedings in the courts of the part of the United Kingdom where you live.