Privacy Notice

1. What we need

Our Personal Data Protection Policy governs the use and storage of your data. You can see our Personal Data Protection Policy at http://tfork.com/personal-data-protection-policy/ Tuning Fork Ltd (Company Registration C28787) is a Controller of the personal data you (data subject) provide us.

This Privacy Notice is intended to set out your rights and answer any queries you may have about your personal data.

We collect the following types of personal data from you.

  • your name and surname
  • your home or work address
  • your email address and phone number;
  • your identity card number
  • your nationality
  • your nutritional or dietary requirements where necessary
  • information related to the browser or device you use to access our website;

We 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 we collect any information about criminal convictions and offences.

2. Why we need it

 

We need your personal data:

  • to establish and fulfil a contract with you, for example, if you enter into an agreement to provide or receive services. We require this information to enter into a contract with you and are unable to do so without it;
  • to maintain an effective communication channel with you throughout the execution of a service/job, to manage our relationship with you as our customer and to improve our services and enhance your experience with us in the future;
  • to respond, with your express consent, to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our products or services;
  • to personalise (i) our communications to you; provide you with (ii) updates on standards and directives that affect your work and sector (iii) training courses and events; and (iv) products or services for you, in accordance with our legitimate interests;
  • to protect Tuning Fork’s legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
  • to monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests

Where applicable and allowed, you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic communications at any time by following the instructions in the relevant communication.

We may also collect your IP address automatically as you interact with our website. This is in the interest of ensuring that there is no malicious use of the website and maximum protection to your data.

3. What we do with it 

Your personal data is processed in our offices in St. Julian’s located in Malta. Hosting and storage of your data takes place in our Zoho Cloud-based system which is located in the EU and US.

Zoho is ISO 27001:2013 and SOC 2 Type II certified (proving its system is designed to keep its clients’ sensitive data secure) and has certified its compliance with the EU-U.S. Privacy Shield Framework, subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

We may also share your personal data with the below third parties:

  • our professional advisors such as our auditors and external legal and financial advisors;
  • certifying bodies, training organisations and approved tutors working in collaboration with Tuning Fork Ltd for the delivery and certification of courses
  • marketing and communications agencies where they have agreed to process your personal data in line with this Privacy Notice;
  • search engine and web analytics.

No other third party providers have access to your data, unless specifically required by law.

4. How long we keep it

Under Maltese law, we are required to keep your documents according to the Data Retention Policy. After this period, your personal data will be irreversibly destroyed. Any personal data held by us for marketing and service update notifications will be kept by us until such time that you notify us that you no longer wish to receive this information.

We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.

Where you are a customer, we will keep your information for the length of any contractual relationship you have with us and after that for a period of 10 years due to fiscal laws that impinge on Tuning Fork Ltd. In cases of legal issues, these are retained until the relevant court case is resolved.

Where you are a prospective customer and you have expressly consented to us contacting you, we will only retain your data (a) until you unsubscribe from our communications; or, if you have not unsubscribed, (b) while you interact with us and our content; or (c) for 12 months from when you last interacted with us or our content.

In the case of any contact you may have with our customer services team, we will retain those details for as long as is necessary to resolve your query and for two weeks after the query is closed.

5. What are your rights?

Should you believe that any personal data we hold on you is incorrect or incomplete, you have the ability to request to see this information, rectify it or have it deleted, please contact our Business Administrator at [email protected].

Where you have consented to us using your personal data, you can withdraw that consent at any time.

In the event that you wish to complain about how we have handled your personal data, please contact our Business Administrator, in writing, at [email protected] or at 135/2, Kyle Buildings, Mediterranean Street, STJ 1870, Malta. Our Business Administrator will then look into your complaint and work with you to resolve the matter.

If you still feel that your personal data has not been handled appropriately according to the law, you can contact the Information & Data Protection Office (IDPC) located in Sliema and file a complaint with them.