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- ABOUT THIS POLICY
Castille Staffing Limited (Company Registration Number C46062) having its registered address at Casa Leone, Pjazza Robert Sammut, Floriana, (herein “we”, “us”, “our” or “Castille”) committed to protecting and respecting your privacy.
The purpose of this Policy is to set out the basis on which any personal data is processed by us and make you aware of how we will handle your personal data, our obligations in regard to processing your personal data responsibly as well as your data protection rights.
Castille Staffing Limited operates Castille Institute which provides courses and lectures.
In order to provide these services we process personal data (which may be held on paper, electronically, or otherwise) and we recognise the need to treat it in an appropriate and lawful manner, in accordance with The Data Protection Act (Chapter 440 of the Laws of Malta) and the General Data Protection Regulation (Regulation (EU) 2016/679, herein “GDPR”) when it comes into force on 25th May 2018.
DATA PROTECTION CONTACT POINT
We have appointed a Data Protection Contact Point who can be contacted via the following address firstname.lastname@example.org. You can address any comments, queries or complaints to this address with words ‘Data Protection Matter’ in the subject line.
- DEFINITION OF TERMS
- “Course Registration Form” refers to the form provided by Castille which you must fill out and submit in order to attend the courses and lectures provided by Castille.
- “Data subjects” for the purposes of this policy include all living individuals about whom we hold personal data;
- “Data controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed;
- “Data processor” means any entity or individual that processes data on our behalf and on our instructions;
- “EEA” means European Economic Area;
- “Personal data” means data relating to a living individual who can be identified from the data we possess. This includes the details you provide us in the Course Registration form such as your name and surname, address, job title, contact details (including mobile and home phone number and personal email address) and bank account details.
- “Processing” means any activity that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
- INFORMATION WE COLLECT
- Information you give us
In order to register your attendance at any of the courses of lectures which we offer we need to process the following personal data:
- Your name, surname and contact details: If you choose to register for any course offered by us you shall be asked to provide your job title, the company in which you work, your address, telephone number and email. These details are necessary in order for us to reserve a place for you at the course and to send confirmation of your reservation.
- Payment information: In order to effect transfer of funds following your reservation we need to process your banking and financial information, including your bank account and credit card information
- Information we collect about you
Whenever you visit our Website we will automatically collect the following information which is necessary in order for the Website to function properly and to allow you to register your details for us to be able to provide our recruitment services:
- Technical information: This includes the IP address used to connect your computer to the Internet, your login information, browser type and version, the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time) as well as other information regarding your experience on our Website such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
- Location Information: We may receive information about your location. We may determine your location through your IP address and, when accessing the Website through a mobile device, by using the data that we collect from this device. This includes precise location information from GPS or information about the wireless networks or cell towers near your mobile device at the time of access.
- Visit and Search Information: With regards to your visits to the Website, we collect and process information about the searches that you have placed and the jobs you might have saved or in which you have indicated an interest. This information enables us to ascertain your preferences and be able to provide you with other relevant job listings which may be appropriate for you.
- LAWFUL BASIS FOR PROCESSING
Information you give to us
- We shall only process your personal data insofar as it is necessary for the provision of the services which we offer, namely the provision of course and lectures. In line with this purpose, your personal data may be processed for the following reasons:
- Registering the details you provide in order to reserve your place at the appropriate course or lecture;
- Transmitting payment;
- Confirming your reservation at the course of lecture;
- We shall also process your personal data insofar as this is necessary for Castille to comply with its legal obligations including but not limited to tax, internal revenue and related purposes.
- We may also process your data where this is necessary for any legitimate reason recognised at law, including ensuring network security and for internal administrative purposes.
Information we collect about you. We shall use this information:
- to ensure Website functionality allowing you to submit the details necessary for us to provide the Services you request;
- as part of our efforts to keep our site safe and secure; and
- to ensure that content displayed on the Website is presented in the most effective and user-friendly manner.
- DATA SECURITY
- We will ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
- All data is stored in a secure server environment that uses a firewall and other advanced technology to protect against interference or unauthorised access. Usernames and passwords are issued to persons authorised to access the data who are bound by confidentiality not to disclose any data.
- Whenever possible and it is not necessary that your data can be used to identify you, such as for research or internal analysis purposes, we pseudonymise (anonymise) your personal data so that it can no longer be used to identify you.
YOUR RIGHTS AS A DATA SUBJECT
- RIGHT OF ACCESS
- You have the right to request information as to whether or not your personal data is being processed by us as well as information as to how and why it is processed;
- You may send an email to email@example.com requesting information as the personal data which we process. You shall receive one copy free of charge via email of the personal data which is undergoing processing. Any further copies of the information processed shall incur a charge of €50;
- This right to access your personal data is without prejudice to the integrity and confidentiality of the personal data of other persons and only data which is solely related to you can be divulged.
- RIGHT TO OBJECT
- You may ask us not to process your personal data for marketing purposes. We shall always obtain your consent by means of a Consent Form in order for us to process your data for any purpose other than those outlined in Clause 4 above. You can withdraw your consent pursuant to the Consent Form at any time;
- Where you object to processing for direct market purposes, your personal data shall no longer be processed for these purposes.
- ACCURATE DATA AND RIGHT TO RECTIFICATION
- We are committed to keep your personal data accurate and up to date. Data that is inaccurate shall be updated or erased;
- You have the right to request the rectification of any of your personal data. You can contact us on firstname.lastname@example.org to notify us if your personal details have changed or if you notice that any personal data we have is inaccurate.
- DETENTION AND ERASURE OF YOUR PERSONAL DATA
- If you have subscribed to receive information about any of the courses of lectures which we offer, we shall need to store your personal details in order to be able to send you such updates. If you choose to unsubscribe from such updates or you wish to request that we erase your personal data we shall comply with such requests. Your personal data shall not be stored for longer than is necessary.
- You also have the right to request the erasure of your personal data in any of the following cases:
- Where the accuracy of your personal data is contest until such time as the inaccuracy is verified by us; or
- Where your data has been unlawfully processed;
- RIGHT TO RESTRICT PROCESSING
- You may restrict our processing in any of the following cases:
- Your data is inaccurate however only until such time as we have verified the accuracy of your personal data;
- The processing we have carried out is unlawful however you do not wish to erase the data pursuant to Clause 9.2(b) above;
- DATA PORTABILITY
- As from 25th May 2018, you shall have the right to receive your personal data in a structured and machine-readable format and transmit this data to another controller.
- THIRD PARTY ACCESS TO YOUR PERSONAL DATA
When registering your attendance for any of the courses or lectures offered by us, you shall be requested to submit payment by cheque. In order to process such payment, the bank in question may process your personal data. This is necessary in order to remit payment and book your attendance in any of our courses or lectures.
- INTRA-COMPANY TRANSFERS
- Castille Staffing Limited may also transfer your personal data to its affiliated company Castille Resources Limited (C 36907) having its registered address at Casa Leone, Pjazza Robert Sammut, Floriana
- We shall only process this data to the extent that is necessary for the purposes listed in Clause 4.1 and Clause 4.2 above.
- We may also transfer your personal data to another Castille entity for internal administrative reasons pursuant to Clause 4.3 above.
- The provisions of this Policy apply to any transfer between different Castille entities and you may exercise your rights against any of the Castille entities which direct how and why your personal data is processed.
- DATA RETENTION
- We shall hold your data for as long as it is necessary to provide the services you request. Should you request the deletion of your personal data or should you no longer wish to receive updates about the courses and lectures we provide, we shall immediately delete your personal data.
- If you feel have any complaints or queries about your data protection rights and how we process your data you may contact us at email@example.com;
- If we fail to address your concerns you have the right to lodge a complaint with the Information and Data Protection Commissioner (“IDPC”) as the relevant national supervisory authority on data protection matters.
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