Privacy Policy

/Privacy Policy
Privacy Policy2018-12-04T16:30:53+00:00

Privacy Policy Statement

A. General 

CCM Limited, as the Data Controller for the collection and processing of data on its website www.thecompliancetraining.com, is strictly committed to the protection of users’ personal data, according to applicable legislation, including the EU – General Data Protection Regulation [Regulation (EU) 2916/679]. This Privacy Policy Statement describes how CCM Limited processes personal data and notifies users on their related rights.

Personal data means any information relating to an identified or identifiable natural person.

Processing of data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Personal data will solely be processed by CCM Limited in case the user has given consent to such processing, the processing is necessary for the provision of the offered services, the processing is performed to fulfil mandatory legal requirements applying to CCM Limited, or the processing is required for the pursuit of the legitimate interests of CCM Limited, third parties or the public, when such legitimate interest is not overridden by the particular user’s fundamental rights.

By accepting this Privacy Policy Statement, the user expresses its consent to the collection and processing of its personal data as described in this Privacy Policy Statement.

B. Inquiries & Data Protection Officer

For any privacy issues, for inquiries and/or for further information on CCM Limited’s data processing activities, please contact the Data Protection Officer at:

CCM Limited

189/1, The Strand

Gzira, GZR 1024 – Malta

You may contact CCM Limited Data Protection Officer via: info@thecompliancetraining.com

C. How CCM Limited Processes Personal Data

1. Legitimate Interests

Except for the fulfilment of mandatory legal requirements or when the user has consented in such processing, CCM Limited processes personal data solely for the pursuit of its legitimate interests or for the pursuit of the legitimate interests of third parties or the public.

As a general rule and not anticipating the results of a proportionality assessment to be performed when appropriate, CCM Limited’s legitimate interests for the collection and processing of personal data may be:

  • The enabling, optimisation and improvement of the services offered by CCM Limited.
  • The detection of abuse of the websites operated and/or the services provided by CCM Limited.
  • The identification and solution of dysfunctions on the Websites of CCM Limited.
  • The enforcement of contractual agreements and/or legal duties.
  • The promotion of the services offered.

The legitimate interest for the processing of data in particular will be declared in the relevant section of this Privacy Policy Statement.

2. Principles for the Processing of Personal Data

CCM Limited processes personal data solely according to the principles laid down in art. 5 (1) a. to f. of the EU – General Data Protection. These principles are:

a. Lawfulness, Fairness and Transparency: Personal data will solely be processed in a lawful, fair and transparent manner.

b. Limitation of Purpose: personal data will solely be processed for the specified, explicit and legitimate purposes these data was collected and not further, when such processing is incompatible with the purpose of collection.

c. Minimisation: personal data will solely be processed in an adequate, relevant and limited extent in relation to the purpose of processing.

d. Accuracy: personal data will be processed in an accurate manner and kept up-to-date where necessary.

e. Storage Limitation: personal data will not be kept longer than necessary for the purpose for which the data will initially collected.

f. Integrity and Confidentiality: personal data will solely be processed in a reasonably secure manner and utilising appropriate organisational and technical measures, in order to protect these data against accidental or malicious loss, destruction or damage.


3. Collection and Processing of Data within the Offers of CCM Limited

a. When Visiting the Website

During the visit of the websites of CCM Limited, the learning platform, by automated means, may collect information generated by the browsers of the visitors of the websites and may store them in logfiles on a temporary basis. This may include, but is not limited to:

  • The IP address of the accessing computer.
  • Date and time of accessing.
  • The operating system accessing.
  • The browser deployed by the visitor.

The logfiles may contain IP addresses allowing to identify a particular user.

Legitimate interest for such collection are:

  • The personalisation and optimisation of the services offered by CCM Limited.
  • The detection of abuse of the websites operated and/or the services provided by CCM Limited.
  • The identification and solution of dysfunctions on the Websites of CCM Limited.

b. When Registering with CCM Limited

CCM Limited collects any users’ personal data at registration stage. This may include, but is not limited to:

  • First name and last name
  • Date of birth
  • Email address

User are required to keep up-to-date their personal details at any time.

Legitimate interest for such collection are:

  • The personalisation and optimisation of the services offered by CCM Limited.
  • The detection of abuse of the websites operated and/or the services provided by CCM Limited.
  • The enforcement of contractual agreements and/or legal duties, and the promotion of the services offered.

c. For the Purpose of Processing Payments

CCM Limited offers the facility to process payments in favour of the trainings provided to the users. Depending on the payment method chosen by particular user, and, if applicable, further criteria, the personal information required may vary.

These data will be transmitted to third party payment providers in order to process a particular payment request.

Legitimate interests for such processing are:

  • The personalisation and optimisation of the services offered by CCM Limited.
  • The detection of abuse of the websites operated and/or the services provided by CCM Limited.
  • The enforcement of contractual agreements and/or legal duties.

d. For the Purpose of Creating User Profiles

CCM Limited processes information that is collected by cookies, logfiles, clear gifs, and/or by third parties’ support in order to create user profiles. A profile contains information on individual users including results of trainings performed, or further, concerning the particular user’s activities.

Legitimate interest for such collection are:

  • The personalisation and optimisation of the services offered by CCM Limited.
  • The promotion of the services offered.

e. Via Logfiles

CCM Limited uses logfiles on its websites. These may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp and the number of clicks to analyse trends for administration of the website, to track a particular users’ movements on the website, and to gather comprehensive demographic information. IP addresses are related to the provision of web-based services with personally identifiable information.

Legitimate interest for such collection are:

  • The personalisation and optimisation of the services offered by CCM Limited.
  • The enforcement of contractual agreements and/or legal duties.

f. User Communication

CCM Limited may store communication with users with the customer support and further.

Legitimate interest for such collection are:

  • The personalisation and optimisation of the services offered by CCM Limited.
  • The enforcement of contractual agreements and/or legal duties.

g. For the Purposes of Marketing Activities

Depending on the account settings set by a particular user, its personal data may be used for marketing activities across various channels including email, and further.

The consent in the use of the user’s personal data for marketing activities may be cancelled or restricted by the user at any time.

Legitimate interest for such collection are:

  • The personalisation and optimisation of the services offered by CCM Limited.
  • The promotion of the services offered.

h. For Other Purposes

In exceptional cases, it may become necessary for CCM Limited to process personal data for other purposes. However, the conditions set out in section A. above apply to any case; no processing will take place unless the said conditions of section A. above are met.

i. Third Party Content and Tracking Software

CCM Limited uses tracking software and website analytics tools on its websites, allows the use of social media plugins and may provide third party content on its websites.

(1) Social Media Plugins

CCM Limited uses social media plugins for the purpose of enabling the user to interact between social media and the CCM Limited websites and therefore
share the learning experience with others.

Social media plugins allow the user to login to both social media and CCM Limited account and to link content provided by CCM Limited to the user’s social media profile.

Social media plugins collect user data such as IP address, login data, accessing website and cookie data.

The following social media plugins are integrated to the websites of CCM Limited:

  • Instagram
  • Facebook
  • Youtube
  • LinkedIn

Legitimate interest for such collection are:

  • The personalisation and optimisation of the services offered by CCM Limited.

j. Via Cookies

CCM Limited uses cookies. Cookies are small files that are automatically created by the user’s browser and are stored locally (on the accessing laptop, tablet, smartphone, etc.) when visiting the websites of CCM Limited.

For more information about the use of cookies on the websites of CCM Limited, please refer to our Cookie Policy.

4. Sharing and Disclosure of Personal Data

CCM Limited will, in no event, transfer data to states outside of the European Economic Area provided unless the recipient guaranties a standard of data protection comparable to European standards (e.g. by agreeing to approved contractual clauses, binding corporate rules or further measures applied and accepted to ensure that the recipients of personal data obtain an appropriate level of data protection and privacy at any time).

CCM Limited shares data within the framework of the EU – General Data Protection Regulation:

a. With Services Providers

Under the circumstances set out in subsection 4. above, CCM Limited may make use of third party companies to process users’ personal data. In such event, the sharing of personal data collected by CCM Limited may be necessary.

CCM Limited requires any service provider to act with a reasonably high level of diligence and care, imposes contractual obligations to treat any data shared accordingly, to any service provider and ensures that data shared will solely be utilised for the purpose of collection and to the extent necessary to fulfil the respective task.

Legitimate interest for such transmission are:

  • The personalisation and optimisation of the services offered by CCM Limited.
  • The detection of abuse of the websites operated and/or the services provided by CCM Limited.
  • The enforcement of contractual agreements and/or legal duties.
  • The promotion of the services offered.

b. For Measures of KYC and Prevention of Fraud and Further Criminal Activities

For the purpose of a users’ identity verification, to carry out security checks, to assess a users’ compliance with the applicable Terms and Conditions and legal obligations including the prevention of money laundering, the financing of terrorism and enforcement of economic sanctions, user data may be matched against third party databases.

Upon any indication of transactions and/or activities that may give rise to suspicions of criminal activities, CCM Limited will report to the relevant parties in charge (e.g. police, sporting associations, private associations aiming at the prevention of criminal and fraudulent activities in games of chance).

With the acceptance of the applicable Terms and Conditions and this Privacy Policy Statement, the user grants its explicit consent to these procedures including the matching of data provided against databases of third parties.

The sharing of users’ data may also be necessary to protect the users and the operation of CCM Limited from crime and to comply with legal obligations.

Legitimate interest for such transmission are:

  • The personalisation and optimisation of the services offered by CCM Limited.
  • The detection of abuse of the websites operated and/or the services provided by CCM Limited.
  • The enforcement of contractual agreements and/or legal duties.
  • The promotion of the services offered.

c. For Other Purposes

It may be necessary share personal data for other purposes. However, CCM Limited solely discloses personal data in case and to the extent that one or more conditions set out in this Privacy Policy and according to the general rules declared in section A. above are met.

Legitimate interest for such transmission are:

  • The personalisation and optimisation of the services offered by CCM Limited.
  • The detection of abuse of the websites operated and/or the services provided by CCM Limited.
  • The enforcement of contractual agreements and/or legal duties.
  • The promotion of the services offered.

d. Of Anonymised Data

Notwithstanding CCM Limited’s commitment to the protection of personal data, CCM Limited reserves the right to publish and/or disclose to third parties data related to users, as long as the user remains, directly and indirectly, unidentifiable by the publication or disclosure of this information.

Such publication is performed in order to promote the services offered.

5. Retention

Personal data is kept by CCM Limited for the term of the contractual relationship. Whenever a user closes its user account with CCM Limited, the personal data stored in the learning platform will remain stored for the minimum length of time required to comply with the purposes set out in this Privacy Policy Statement and relevant legal requirements. Personal Data may also be stored for a longer term, in case it cannot a deletion is not possible for technical and/or legal reasons.

D. Data Security

All data will be processed by automated means. CCM Limited takes all adequate technical and organisational efforts to protect users’ data from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration or damage.

Additionally, payment information will be encrypted when being processed.

Sensitive information is protected online by SSL encryption. Furthermore, CCM Limited takes any reasonable effort to ensure the protection of users’ data in all other areas.

Only authorised personnel of CCM Limited or of third-party companies contractually bound to CCM Limited and to the compliance with the principles of data protection and the terms of this Privacy Policy Statement, obtain access to the users’ information.

CCM Limited monitors the trustworthiness and reliability of all personnel and service providers. At regular intervals, any employee will be trained on the applicable security and data protection standards. Relevant servers are located in a secure environment.

1. Data Encryption

In order to protect the users’ personal data when communicating with the web browser, CCM Limited uses encryption technology of its trusted certification partner company. In addition, online transactions are shielded by the security system of a worldwide-accredited partner.

2. Other Technical Security Measures

In addition, all user data will be protected from unauthorised or damage access by firewall and intrusion prevention systems.

E. Rights of the User Regarding its Personal Data

The user, at any time, has the right to:

  • Request access to its personal data.
  • Request correction of its personal data.
  • Withdraw the consent to the processing of its personal data fully or in part (e.g. for marketing activities).
  • Request erasure of its personal data.
  • Receive its persona data upon request in a structured, commonly used and machine-readable format (data portability).
  • Request the restriction of processing its personal data.
  • To object to the processing of personal data.

Some of these rights may only apply under certain circumstances as set forth in data protection legislation including the General Data Protection Regulation.

F. Inquiries

For inquiries or complaints regarding the handling and collection of data on the websites of CCM Limited, please contact the Data Protection Officer through info@thecompliancetraining.com or the relevant data protection authority.

G. Amendments to this Privacy Policy Statements

This Privacy Policy Statement may be subject to change from time to time, of which users will be informed without undue delay and upon their next login to the user account with CCM Limited at the latest. Anyhow, CCM Limited recommends the user to review this Privacy Policy Statements for potential changes and/or amendments in regular terms.

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Cookie Policy

This Cookie Policy applies for the visit and use of the websites at www.thecompliancetraining.com, operated by CCM Limited, 189/1, The Strand, Gzira, GZR 1024 - Malta, as the Data Controller. CCM Limited uses cookies on websites. Cookies are small files that are automatically created by the user’s browser and are stored locally (on the accessing laptop, tablet, smartphone, etc.) when visiting the websites of CCM Limited. Cookies do not harm the device and do not contain viruses, trojans or other malicious software. About cookies: Cookies may store information of a user’s visit of the websites of CCM Limited. However, cookies do not serve to identify a particular user on the websites of CCM Limited. The use of cookies serves to make the use of CCM Limited’s offers more pleasant for the visitor and allows CCM Limited to tailor the content of its websites to the particular customers’ needs and preferences. Types of cookies: CCM Limited uses different types of cookies on its websites: CCM Limited uses so-called session cookies to recognise that a user has already visited individual pages on the websites. These cookies are automatically deleted after leaving the websites. In addition, in order to improve usability, CCM Limited also uses temporary cookies that are stored on the user’s device for a specified period of time. When visiting the websites of CCM Limited again, it will automatically recognise that the particular user has already been with CCM Limited and what settings have been made, so that it is not necessary to re-enter them. Furthermore, CCM Limited uses cookies to statistically record the use of its websites and to evaluate it for the purpose of optimizing the offered services. These cookies allow to automatically recognise that a particular user has already been with CCM Limited when visiting the websites again. These cookies are automatically deleted after a defined time. Also, CCM Limited allows third party cookies on its websites. These cookies are provided by third party companies placing content and/or running advertisement on the websites of CCM Limited and survey the user’s behaviour regarding the placed content and/or running advertisements. How to manage cookies: Most browsers accept cookies automatically. However, one can configure the browser in a way that no cookies are stored on its computer or always a hint appears before a new cookie is created. Please see the particular operator’s advice for the deactivation of cookies. Disabling cookies completely may lead to decreased functionality regarding certain features of CCM Limited’s websites. More information on cookies, their functioning and how to manage them can be found at http://www.allaboutcookies.org/. Legitimate interest: The data processed by using cookies are necessary for the purposes mentioned above. CCM Limited’s legitimate interest for the collection of data via cookies are: • the enabling, optimisation and improvement of the services offered by CCM Limited, and • the promotion of the services offered. Third parties may have own legitimate interests for the use of cookies provided by them. Inquiries: For inquiries regarding the use of cookies and the information collected by CCM Limited, please contact our Data Protection Officer at info@thecompliancetraining.com
© CCM Limited - Birkirkara BKR 9077, Malta
© CCM Limited | Birkirkara BKR 9077, Malta