In compliance with the obligations set out in the European Privacy Regulation UE / 2016/679 (GDPR) with this purpose, we intend to inform you that the company "EBS - E-Learning Business Solutions Ltd" (hereinafter also called EBS), located in via Giuseppe Calleja 23 , Plan 2 Swatar, MSD2270 Msida (MT), VAT N. MT21529824, website www.e-learningbs.com and e-mail email@example.com as Owner will process your personal data which may be collected by you, by you and / or by other subjects communicated, during the navigation and use of the EBS E-Learning Platform accessible at www.e-learningbs.com (hereinafter also referred to as the EBS Platform) , at the time of the request for registration and / or subscription to the EBS Platform subscription agreement and which may subsequently be collected and processed for all the operations necessary for the completion of the registration process, for the ion and administration of the EBS Platform and for the promotion, sale and provision of the related products and / or services.
Complying with and sending us your registration to join our Portal EBS, you declare your acceptance, without limits or reservation, that your data ca be used by EBS for all the obligations necessary (both pre-contract and contractually) necessary and connected to the registration, the management, the promotion and the administration of the EBS Portal, the sales and delivery of products and services provided by EBS, as well as, all of the other activities inherent in your participation in the EBS Portal.
The treatment of data freely given by you to us, otherwise collected by us in the course of navigation, will be dealt with under the current norms of privacy; particularily in terms of correctness, lawfulness, and transparency; the data will be relevant, complete, and not in excess of our needs; the data will collected and recorded for the sole purposes detailed in points 1), 2), 3) and 4); and will be kept on record for a period not exceeding that necessary for our purposes,as mentioned above, not exceeding the duration of our contract whilst you are connected to our EBS Portal.
Therefore, according to the provisions of article 13) of the European Regulation EU / 2016/679 (GDPR) we inform you that:
1) During the course of your navigation and use of our EBS Portal, it could be that we will retrieve and use, for essential security purposes, and for the improvement of our services, the following information:
a) Access page to the site (using query parameters relating to URL)
b) Original pages that bring visitors to the EBS Portal
c) Data and time of access
d) The quantity of data transferred
e) The type of access (translated pages, pages not found , etc )
g) The system operated by the browser used
h) The IP address of the client and possibly the dominion name or name of the internet service provider.
i) The date of registration, statistics on the pages visited, the traffic data and publicity data “for these previously mentioned details please refer to the cookies policy of the EBS Portal“.
2) Whenever you decide to register with the EBS Portal to take advantage of our products or services, you will be asked to sign the contract of registration with the EBS Portal and accept obligatorially the general and special conditionsin the contract. You will also be asked for the following obligatory personal data to complete the registration process:
- Username, e-mail and password.
In case of publication of an E-course or E-book or participation in activities relative to the EBS Portal in terms of E-teacher or E-tutor, you will also be requested to provide your CV, and further personal data and you are permitted by us to insert a photo or video, and a brief description of your personal and professional profile.
If you intend to use one of our products or services that require payment you will be asked to supply us with your credit card details, your paypal account, and the following personal data:
- Name , surname, place and date of birth, tax code, telephone numbers and address. (Obligatory to receive the invoice , certificate of attendance, and your Certificate on the completion of your course).
- Company name, address, telephone number, e-mail, VAT number and tax code. (Essential to obtain the invoice).
Besides this information, during your usage of the EBS Portal and the fruition of the relative products and services, it could be necessary for us to request, collect and use further personal and professional information relative to whichever activities you are participating in.
This data is required for the following purposes:
- Registration, acceptance, utilisation and participation of the EBS Portal.
- The administration and management of the EBS Portal.
- The promotion, sale and delivery of EBS portal products and services.
- Our up-dating of news relating to our EBS portal products and services.
- Proper delivery of products and services requested, and requirements relating to our contractual obligations and stipulations, and further modifications or variations, and for any other requirements necessary for the fulfilment of the above.
- For operational, organisational, management, tax, financial, insurance, and accounting requirements relating to pre-contract and contractual obligations.
- Fulfillment of each type of obligation required by law, regulations, or those imposed by the regulatory community.
- Registration, management, and conservation of the log recording eventual accesses to the EBS Portal.
- For security purposes in relation to the use of the EBS Portal and its relative products and or services.
- Statistical analyses, market surveys, and monitoring of the usage of the EBS Portal services.
- Professional relations, commercial and personal, between registrants and/or members using the EBS Portal .
- Other pre-contractual and contractual obligations stipulated with members and subscribers to the EBS Portal.
- Monitoring the methods of delivery of the types of products/services, the progress of relations with the suppliers, and analysis and management of risks related to contracts.
3) In case of the need of assistance or of information related to our products and services or using the EBS Portal, you will be requested to supply the following personal data to fill-in an “on-line form“:
- Your email address and a request message (Obligatory)
- Your name, surname, and telephone number (Optional).
This data will only be used to supply the services of technical support requested, or following your request for information.
4) In the case where you have given full and free consent, during the process of registration; requests for assistance, information, or during the usage of our products and services, the personal data which is relative to the preceding points can be used also for the following additional purposes not provided for in the membership contract:
- The sending of newsletters and commercial communications on behalf of third parties.
- Traditional marketing activities on behalf of third parties such as: mailing of brochures, catalogues, and commercial or technical documents sent by mail or telephone calls from an operator.
- Automatic marketing activities via SMS, MMS and automated phone-calls.
- On-line marketing, web marketing, and web advertising, on behalf of third parties.
- Statistical analyses, market surveys, and the monitoring of the utilisation of services.
The communication of personal data to third parties.
5) The processing can be effected using the following methods:
- The processing can consist of the collection, registration, organisation, conservation, consultation, elaboration, modification, selection, extraction, comparison, utilisation, interconnection, blocking, communication, spreading, cancellation and destruction of data through the use of electronic instrumentation, computer and the internet, suitable for the purpose of guaranteeing the security and confidentially of data as required by the Data Protection Act of 2001.
The data collected can also be written, where necessary, for the achievement of the above purposes.
The processing of the treatment will adopt all the technical, IT, organisational, logistical, and security procedures necessary to guarantee the minimum level of protection of data as required by law.
6) In confirmation of the data contained in points 1) ,2) and 3) it is:
- Required for the achievement of the purposes related to obligations dictated by law, and other Community rules and regulations.
- Necessary for the correct installation, management, and execution of the business relationship and or contractual completion.
We give notice that even a legal refusal to provide us, either in total or in part, with personal data defined above as “obligatory“ or the lack of consensus in the case of sensitive or judicial personal data transmission, makes it impossible for you to register membership or join the EBS Portal and the use of the services and products reserved for our members / subscribers.
7) The conferral of personal data for the purposes defined in point 4), is optional .
8) The people or types of people who can access this information or communicate this information from the data supplied are as follows:
- Legal Representative of the Data Controller.
- Internal employees involved in administration, the technical department and the Commercial department.
- External employees: Consultant , freelancers, collaborators and external technicians.
- Data Processors: IT companies responsible for the supply,management, administration and maintenance of the information infrastructure, consultation firms, freelancers, banking institutions, credit recovery companies, Legal firms, firms, commercial firms, Employment consultants and company auditors.
This data can be communicated to EBS Portal members for the purposes of institutional activities and for the development of activities contained within the membership contract.
The data can be communicated to local authorities, the Police Forc , or other private and public bodies, but only and exclusively where we are required to do so under legal obligations, regulations and community requirements.
The data may be used, as well, to achieve the finalisation of the membership requirements.
9) If the processing could also concern personal data included in the category of "Particular Categories of Personal Data" (ie data suitable to reveal the racial and ethnic origin, religious beliefs, philosophical or otherwise, political opinions, the adhesion to parties, unions, associations or organizations of a religious, philosophical, political or trade union nature, as well as personal data capable of revealing the state of health and sex life) or "judicial" (that is, data capable of revealing measures in the matter of criminal records, the register of administrative sanctions depending on the offense and the related pending charges or the quality of defendant or suspect) the treatment will be carried out within the limits indicated by the Control Authority, according to the procedures set out in the European Regulation EU Privacy / 2016/679 (GDPR) and for the purposes strictly necessary for the regular performance of the company's activity, of the works information relating to the provision of products / services and the fulfillment of contractual obligations and / or the law / regulation.
The people, or types of people, that can access this sensitive data or can access this data, are the following:
- Legal Representative of the Data Controller.
- Internal Employees: Management and the technical department.
- External employees: Consultants , freelancers, collaborators and external technicians.
- Data Processors: IT companies supplying the management, administration and maintenance of the information infrastructure, Consultant companies, Legal firms and studios, Commercial studios and employment consultants.
The data could also transferred at the specific request of local authorities, the police or other public or private entities; but only to satisfy our legal obligations, regulations, and community relations.
10) The treated data can be communicated to third parties, (see points 8 and 9), that could also be situated in other countries apart from the European Union, in accordance with the requirements under the Data Protection Act 2001 according to the purposes of points 1), 2), 3) and 4) and the methods relating to point 5).
In case of the termination of EBS’ business activities the personal data belonging to our subscribers which EBS owns, can be ceded to another owner, even against payment, only if this information is going to be used in a manner compatible with which it was first intended and collected.
The data collected for the purposes referred to in point 4) may be transferred to third parties, even against payment.
11) The updated list with the identification of all Data Processors, can be requested by you at any time, from the representative of the owner indicated above, who will render the information immediately.
At any time, you can freely revoke the consent given, without any charge and prejudice to the lawfulness of the treatments carried out up to that time, and exercise the rights of the data subject to the Data Controller as provided by the European Regulation EU / 2016 / 679, writing to firstname.lastname@example.org
Msida, Malta - May 2018