Website Privacy Standard

 

  1. Definitions
  • I/Me/My and grammatical variations thereof means Julia Buckel
  • You/Your/Yourself means the User of the website
  • Privacy Standard means this Privacy Standard
  • Data Protection Legislation means i) unless and until the General Data Protection Regulation (GDPR) is no longer directly applicable in Malta, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in Malta and then (ii) any successor legislation to the GDPR or the Data Protection Act (Ch. 586 of the Laws of Malta).

 

  1. Terms of this Privacy Standard

I am committed to protecting Your privacy as a visitor to the website. To better protect such rights, I provide this Privacy Standard, explaining the information practices and the choices that You can make about the way in which I may collect and further process Your personal information.

I would like to inform You that by providing Your personal information, You mean that You are giving Me consent to process Your personal data in accordance with Data Protection Legislation. Your information will be processed in strict confidence and in accordance with the requirements of Data Protection Legislation. I thus kindly invite You to go through, read and understand the information in this Website Privacy Notice. This way You will be informed how I will process and safeguard Your information.

  1. Third Party Links

 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about You. I do not control these third-party websites and am not responsible for their privacy statements. When You leave the website, I encourage You to read the privacy notice of every website You visit.

  1. The Data I Collect About You

 

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).

I may collect, use, store and transfer different kinds of personal data about You which I have grouped together as follows:

  • Identity Data includes first name, maiden name, last name and title.
  • Contact Data includes billing address, email address and telephone numbers.
  • Communications Data includes Your preferences in receiving information emails and Your communication preferences.

I do not 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 I collect any information about criminal convictions and offences.

  1. How is Your Personal Data Collected?

 

Through this website I only collect information about You through direct interaction. This means that I only collect Your information which You expressively give through the website’s booking form, or by sending me emails.

  1. How I Use Your Personal Data

 

Your personal data will only be used where the law allows. Most commonly, Your personal data will be used in the following circumstances:

  • Where I need to perform the contract we are about to enter into or have entered into with You.
  • Where it is necessary for My legitimate interests (or those of a third party) and Your interests and fundamental rights do not override those interests.
  • Where I need to comply with a legal or regulatory obligation.
  1. Purpose For Which Your Personal Data Will be Used

 

Below, in a table format, please find a description of all the ways I plan to use Your personal data, and which of the legal basis I rely on to do so. I have also identified what My legitimate interests are where appropriate.

Note that I may process Your personal data for more than one lawful ground depending on the specific purpose for which I am using Your data. Please contact Me if You need details about the specific legal ground I am relying on to process Your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To request information about the services

(a) Identity

(b) Contact

Performance of a contract with You
     

 

 

  1. Opting Out 

 

You can ask Me to stop sending You any information through emails or other means of communication at any time. This can either be done by contacting Me or else by clicking on the unsubscribe link at the bottom of the information emails.

  1. Disclosure of Your Personal Data 

 

I may have to share Your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties as set out in the Glossary below.
  • External Third Parties as set out in the Glossary below.
  • Third parties to whom I may choose to sell, transfer, or merge parts of the My business and assets. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to My business, then the new owners may Use Your personal data in the same way as set out in this document.

All third parties shall respect the security of Your personal data and to treat it in accordance with the law. I do not allow 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 My instructions.

Note that when You apply for a (training session/event??) I am organising in conjunction with a third party (excluding the event’s sponsor, if any) I may share Your information with the third party.

  1. International Transfers

I limit the transfer of any data to third-parties, and I limit such transfer to exceptional circumstances and for support services only such as bulk mailing.

Whenever I transfer Your personal data out of the EEA, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • I will only transfer Your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where I use providers based in the US, I 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, contingent on any developments as directed by the European Commission.

Please contact Me if You want further information on the specific mechanism used by Me when transferring Your personal data out of the EEA.

  1. Data Security

 

I 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, I limit access to Your personal data to those employees and other third parties who have a business need to know. They will only process Your personal data on My instructions and they are subject to a duty of confidentiality.

I 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 I am legally required to do so.

  1. Data Retention

 

By law, I am obliged to keep basic information about My clients (including Contact, Identity, Financial and Transaction Data) for ten years after they cease being clients for fiscal purposes. Data related to attendance and completion of any courses, training sessions etc. (including Contact, Identity data) will be kept for five years and will only be accessed if and when You request a copy of the certificate.

In some circumstances You can ask Me to delete Your data. In some circumstances I may anonymise Your personal data (so that it can no longer be associated with You) for research or statistical purposes in which case I may use this information indefinitely without further notice to You.

  1. Your Legal Rights 

 

Under certain circumstances, You have rights under data protection laws in relation to Your personal data. Further details about each of Your rights listed below may be found in the Glossary:

  • 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 Me.

You will not have to pay a fee to access Your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if Your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with Your request in these circumstances.

I may need to request specific information from You to help 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. I may also contact You to ask You for further information in relation to Your request to speed up the response.

I try to respond to all legitimate requests within one month. Occasionally it may take Me longer than a month if Your request is particularly complex or You have made a number of requests. In this case, I will notify You and keep You updated.

  1. Glossary

 

  • Legitimate Interestmeans the interest of My business in conducting and managing the business to enable Me to give You the best service/product and the best and most secure experience. I make sure I consider and balance any potential impact on You (both positive and negative) and Your rights before I process Your personal data for My legitimate interests. I do not use Your personal data for activities where My interests are overridden by the impact on You (unless I have Your consent or am otherwise required or permitted to by law). You can obtain further information about how I assess My legitimate interests against any potential impact on You in respect of specific activities by contacting Me.
  • Performance of Contractmeans 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 or regulatory obligation means processing Your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.
  • Third Parties
    • EXTERNAL THIRD PARTIES (examples)
      • Service providers acting as processors based in the United Staes who provide storage and mailing services.
      • Professionals acting as joint controllers based in the EEA who co-host events.
  • INTERNAL THIRD PARTIES (examples)
      • My employees and contracted service providers.

 

  1. Your Legal Rights

 

You have the right to:

  1. 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 I hold about You and to check that I am lawfully processing it.

 

  1. Request correction of the personal data that I hold about You. This enables You to have any incomplete or inaccurate data I hold about You corrected, though I may need to verify the accuracy of the new data You provide to Me.

 

  1. Request erasure of Your personal data. This enables You to ask Me to delete or remove personal data where there is no good reason for Me continuing to process it. You also have the right to ask Me to delete or remove Your personal data where You have successfully exercised Your right to object to processing (see below), where I may have processed Your information unlawfully or where I am required to erase Your personal data to comply with local law. Note, however, that I 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.

 

  1. Object to processing of Your personal data where I am 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 I am processing Your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process Your information which override Your rights and freedoms.

 

  1. Request restriction of processing of Your personal data. This enables You to ask Me to suspend the processing of Your personal data in the following scenarios: (a) if You want Me to establish the data’s accuracy; (b) where My use of the data is unlawful but You do not want Me to erase it; (c) where You need Me to hold the data even if I no longer require it as You need it to establish, exercise or defend legal claims; or (d) You have objected to My use of Your data but I need to verify whether I have overriding legitimate grounds to use it.

 

  1. Request the transferof Your personal data to You or to a third party. I 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 Me to use or where I have used the information to perform a contract with You.

 

  1. Withdraw consent at any time where I am 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, I may not be able to provide certain products or services to You. I will advise You if this is the case at the time You withdraw Your consent.