Privacy policy

Version 2026-10-27-v1 · Effective 27 October 2026

1. Who is responsible for your information

FRCEM Progress is an independent revision service operated by a sole trader trading as FRCEM Progress in England, United Kingdom, who is the controller of the personal information used to operate this website. Contact support@frcem.app or use our privacy request form. Business postal address available by email on request.

FRCEM Progress is independent. It is not affiliated with, endorsed, approved, sponsored or operated by the Royal College of Emergency Medicine (RCEM) or any Royal College, and does not represent them. We do not give your revision records to RCEM or any Royal College as part of this service.

2. Information we collect

• Account details: username, email, optional profile names, password hash, verification and sign-in information, and records of the terms presented and accepted.
• Revision activity: question identities, selected answers, scores, answer order, timings, confidence, flags, optional private notes and error classifications, session progress and mock results.
• Access and transactions: trial allowance, vouchers, sitting/product details, price and discount snapshots, payment/checkout references, payment status, refunds, disputes and contract confirmations. Stripe handles card and bank credentials. Payment-event records may contain billing/contact information returned by Stripe.
• Support and rights requests: contact details, messages, question reports, correspondence, identity checks where necessary and our response.
• Technical and security records: IP address, request time/path, browser or device information where supplied, session identifiers and staff audit events.

You supply most of this information through registration, revision and requests. Stripe supplies payment-event information. The website produces activity and security records during use. Do not include identifiable patient details, unnecessary health information or confidential third-party information in free-text fields.

3. Purposes and lawful bases

• Contract: create and operate your account, provide revision and progress reporting, verify email, manage access, process your purchases and answer service requests.
• Legitimate interests: protect accounts and the question bank, prevent fraud and misuse, investigate faults, improve educational quality using proportionate activity analysis, and establish or defend legal claims. We consider these interests against your rights; you can object where this basis applies.
• Legal obligation: keep necessary tax/accounting records, handle statutory consumer and data-protection requests, and respond to lawful official requirements.

Accepting the terms or acknowledging this notice is not consent to unrelated marketing. We currently send transactional/service emails, not an optional marketing programme. If we introduce a use that requires consent, we will request it separately and explain how to withdraw it.

Account credentials and necessary service/payment information are needed to provide the relevant features. Private notes, confidence responses and extra profile details are optional. Without required registration or payment information we may be unable to supply an account or paid access.

4. Revision analysis and confidentiality

Your activity generates study statistics and topic suggestions, and contributes to aggregate question-quality analysis. These are educational aids, not official assessment, clinical advice or decisions with legal or similarly significant effects. Access checks use verification, allowance, payment and expiry records; contact support to query a result. Refund usage counts assist staff review and do not automatically decide statutory rights.

Your notes and reports are not public. Authorised personnel may access relevant records to operate the service, respond to your request or investigate a problem. Access is restricted according to role; “private” does not mean inaccessible to the operator. We do not currently send your account, answers or private notes to AI services for personalised generation.

5. Hosting, recipients and transfers

The application and its primary database are hosted on the operator's own equipment in the United Kingdom. Access to backups is restricted. Service providers may process information outside the UK; UK hosting does not mean every provider operation is UK-only.

• Brevo: delivers transactional email and processes recipient addresses, message content and delivery/security information under its applicable terms. See Brevo's privacy information.
• Stripe and Stripe Managed Payments: handle checkout, payment security, merchant-of-record functions, refunds and disputes. Stripe may act as an independent controller for its own processing as well as under applicable contractual arrangements. See Stripe's privacy information and the notices shown at checkout.
• Authorised professional advisers and public authorities, where necessary for accounting, legal advice, claims or a lawful requirement.

Where our provider arrangements involve a restricted transfer, we must use an applicable UK adequacy arrangement or appropriate safeguards, such as the UK International Data Transfer Agreement or UK Addendum, with the required assessment. Contact us for information about the safeguards relevant to your data. We do not sell personal data or provide it to Royal Colleges for examination decisions.

6. Cookies and browser storage

We use essential first-party session cookies to keep you signed in and CSRF cookies to protect forms. The normal session lifetime is up to two weeks; CSRF cookies may last up to one year. Logging out clears the active sign-in session. Browser settings can block or remove cookies, but required account features may then stop working.

The service worker caches static interface assets and an offline information page on your device. It does not cache question pages, answers, payment pages or private account responses for offline use. Static storage remains until the worker updates its cache or you clear site data. We do not currently use advertising cookies or third-party behavioural analytics. Our study statistics are generated from activity stored for your account. Any future non-essential tracking will be assessed and, where required, offered with appropriate controls before use.

7. Retention and deletion

We keep account and revision records while they are needed to provide your account, progress history and valid access. You may request erasure at any time. Closing an account disables access immediately; erasure is reviewed separately so that legal obligations, refund claims and other applicable exceptions can be addressed. When erasure is approved, study sessions, answers, notes and question reports are removed and the account is reduced to a disabled record without its original profile/contact details. Necessary transaction references may remain linked to that record for the purposes below.

• Financial, contract-acceptance, refund and necessary rights-handling evidence: normally six years after the end of the relevant UK tax year or contract, as appropriate, and longer only for a documented legal requirement or unresolved claim.
• Successfully processed payment-event payloads: normally 90 days; minimal event identifiers/status remain for duplicate prevention. Unresolved failed events remain until investigated.
• Resolved support messages: normally two years after resolution. The detailed text/contact information in completed privacy requests is reduced after 90 days, while minimal compliance evidence is retained as above.
• Operational server logs: rolling storage limited by log rotation and reviewed for continuing security need. Staff audit records are retained for up to six years where needed for accountability and legal claims.
• Backups: retained according to the configured backup cycle, up to 12 monthly copies plus short daily/weekly recovery copies. Data removed from the live service may remain in restricted backups until rotation. It is not used for routine purposes, and erasure records must be reapplied if an older backup is restored.

These periods may be shortened where the data is no longer needed. We review necessary exceptions rather than keeping every record indefinitely. The retained transaction record is not fully anonymous merely because profile information has been removed.

8. Your rights and requests

Depending on the circumstances, you may request access, correction, erasure, restriction, portability, or object to processing based on legitimate interests. Download your account/study data from settings, or use the privacy request form/email for a full rights request. The download does not replace your right to ask for other personal information we hold. We may need proportionate identity verification to protect your data.

We respond without undue delay and normally within one calendar month of a rights request. If the law permits an extension or pause, we will explain why and when to expect a response. If we cannot fulfil all of a request, we will explain the applicable reason, retained categories and your complaint options. You can complain to the Information Commissioner's Office; contacting us first may help resolve the issue but is not a condition of that right.

9. Security and updates

We use HTTPS, password hashing, authenticated access, private response caching controls and restricted staff permissions. No online service can eliminate every risk. Tell us promptly about suspected unauthorised access. We will investigate incidents and make notifications where legally required.

This notice has a fixed version and effective date. Material changes will be explained through the site or an appropriate service notice. We will not describe a new purpose as authorised merely because you accepted an earlier version.