Last update: 1st January 2021
Who we are
For the purpose of the Data Protection Act 2018 and the EU General Data Protection Regulation (the “GDPR”) (together, the “Data Protection Legislation”), the data controller is RAVEN, registered company number C89503 with registered address Flat 5, 185, Howard Court, Triq San Pietru, Mgarr, Malta.
We take your privacy seriously and we are committed to keeping your information private. To the extent we are required by law, we have notified the Office of the Information and Data Protection Commissioner that we will process your personal information in accordance with the Malta Data Protection Act (as defined above).
- What personal information we collect about you and how we collect it
- Our legal basis for collecting and using your personal information
- How we will use your personal data
- Automated Processing of your personal data, including Profiling
- Data retention, data security and transfers of personal information outside of the European Economic Area (EEA)
- Your rights – Accessing, erasing and updating your personal information
- How to unsubscribe from any email alerts that you receive
- Legal and Contact Information
What personal information we collect about you and how we collect it
We collect personal information whenever you contact us and provide us with information that we are able to identify you by, including when you contact us by phone, email, live messaging or when you sign up to use any of our services.
In particular, we collect and use your personal, contact and user account information when you:
- Enrol, complete and claim your certificate for a RAVEN course;
- Create an account on RAVEN;
- Subscribe to receive email updates from us;
- Take part in market research or surveys; and
- Every time you e-mail or contact RAVEN support.
We also collect information about the payment methods that you use for any transactions that you make.
When you work for a third party that purchases products and services direct from RAVEN or its training providers, they are required to provide information about you in order to deliver your training. It is that third party’s responsibility to ensure that it has informed you, and where necessary, obtained your consent to do this. Should you have any questions about how third parties use your data, you should direct these to that party.
Information that we automatically collect (including use of “cookies”)
If you don’t want cookies to be stored on your device, you should make the necessary changes to your device or the relevant browsers or apps. Please note that if you disable cookies, some services or website functionality may not be available.
We use the following cookies:
- Essential cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, and to use online forms.
- Marketing cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences. These cookies also record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website, the advertising displayed on it and communications sent more relevant to your interests.
By continuing to use this site, you are accepting our use of these cookies that make advertising and communications more relevant to you and your interests, and further help us to improve the site.
Legal Basis for collecting and using your personal information
Data Protection Legislation mandates that any personal information can only be used where there is a lawful basis to do so. At RAVEN, we rely on one or more of the following grounds to legally collect and use your personal information:
- The data is necessary for the performance of the contract which we have with you (i.e. to provide our services to you);
- We are using your personal information where it is in our legitimate interests to do so;
- We have a legal obligation to process your personal information;
- You have consented to the use of your personal information by us.
Where we rely on your consent to process any of your personal information, you may revoke your consent at any time. Any such revocation will not affect the lawfulness of any prior use of that personal information.
Where your data is provided to us by a third party who you work for, they are the Data Controller for that information and have the obligation to set their own Lawful Basis for processing.
How we use your personal information
We will use your personal information to enable us to provide our Services to you and enable you to use the Sites, including, for the following purposes:
Performance of a Contract
We will use your personal information for the following purposes where it is necessary to perform a contract, or enter into a contract, with you:
- To authenticate your identity and administer your RAVEN account;
- To deal with your enquiries and requests;
- To process your orders for any services or products that you purchase from us;
- To provide you with updates about developments on our Sites;
- To enable our data processors (such as our group companies and hosting providers) to provide services (or components thereof) requested by you.
We may use your personal information where we have a legitimate business interest to do so. These legitimate interest are:
- To personalise aspects of our services to you;
- To carry out market research or surveys about our products and services;
- For marketing and strategic development purposes, for example to identify trends usage;
- To enable our data processors (such as our group companies and hosting providers) to provide services (or components thereof) requested by you;
- For the proper keeping of records;
- To analyse and create statistical reports based on the services we provide and our performance of those services.
We will use your personal information where we are legally obliged to do so, this includes:
- For financial reporting and auditing purposes,
- For anti-money laundering or fraud prevention, detection and reporting;
- To maintain records of actions taken on your account.
We will use your personal information where we have your consent to do so:
- To provide you direct marketing information related to information about the products and services we offer;
It is your responsibility to ensure that any information submitted as part of the registration process to your RAVEN account is accurate and up to date.
Automated Processing of your personal data, including Profiling
RAVEN does not undertake and automated decision making or profiling on the data which is provided to us.
Data retention, data security and transfers of personal information outside of the European Economic Area (EEA)
We take steps to protect your personal information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. We will only keep your personal information for as long as we reasonably require and for the activities we have detailed above. This means we will retain personal information for the duration of any contract we have with you, in line with any legal obligation for data retention (such as that for HMRC) or, primarily, until erasure is requested by you.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your personal information, we cannot guarantee the security of your data transmitted via email and/or our website; any transmission is at your own risk.
The personal information that we collect from you will be stored and processed within Malta and the EEA.
Your rights – Accessing, erasing and updating your personal information
Should you have any queries or complaints in relation to how we use your information please contact us via the details set out at section 9 below. You have the right to access the personal information we hold about you and to ask us to:
- make any changes to ensure that any personal information we hold about you is accurate and up to date;
- erase or stop processing any personal information we hold about you where there is no longer a legal ground for us to hold it; or
- transfer any information we hold about you to a specified third party.
Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office regarding such issues.
How to unsubscribe from any email alerts that you receive
If you have elected to receive information about our products or services, and would like, at any time to unsubscribe from this service, please email make an enquiry through our contact page or click on the “unsubscribe” link at the bottom of an email.
Legal and Contact Information
The registered address of RAVEN is:
185, Flat 5, Howard Court, Triq San Pietru, Mgarr, Malta.
We will use all reasonable efforts to answer any questions or resolve any concerns regarding your privacy promptly.
All comments, queries and requests relating to our use of your personal information are welcomed. If you would like to contact us, queries should be addressed to the Data Protection team by emailing us at firstname.lastname@example.org.