This Privacy Notice sets out how ALX Training Ltd processes data, whether on individuals (including personal data in respect of individuals who are clients, intermediaries or other third parties ALX Training Ltd interact with, or any individual who is connected to those parties) or otherwise. Where the data held are on individuals, this document also sets out the rights of those individuals in respect of that personal data.
Any questions in relation to this Privacy Notice or requests in respect of personal data should be directed to [email protected] in the first instance.
ALX Training Ltd is a provider of education, training and administration.
Please note that ALX Training Ltd operates a global Data Protection Policy.
ALX Training Ltd processes data in order to provide education, training and administration. The type of data we may collect and process includes:
– Contact details (including names, postal addresses, email addresses and telephone numbers);
– Financial information, such as payment related information;
– Professional interests and events attended;
– Meetings/training sessions attended and visits to our offices;
– Any other information you may provide to us.
We use data (including personal data of individuals) for the following purposes (the below also confirming the lawful basis we are relying on in each case):
To enter into client relationships and provide training, administration and consultancy services.
Any one or more of the following:
– The legitimate interest of ALX Training Ltd as a provider of training, administration and consultancy services to process personal data for the purpose of providing those services
– In instances where an individual has been provided with this Privacy Notice and provides personal data thereafter, the processing may be carried out on the basis of consent. Consent may be withdrawn at any time by writing to [email protected]
– The processing is necessary for training, administration of courses and consultancy services.
To manage our client, intermediary and other business relationships.
To ensure the security of ALX Training systems, staff and premises (including the use of CCTV equipment)
– The legitimate interests of ALX Training Ltd in protecting its systems, staff and premises from being misused or the victim of any criminal activity
To provide access to our Website
– The legitimate interests of ALX Training Ltd and the user of the Website for the communication and storage of relevant material (such use being subject to the terms and conditions of the relevant Website)
– In instances where any user of any Website has been provided with this Privacy Notice and provides personal data thereafter, the processing may be carried out on the basis of consent. Consent may be withdrawn at any time by writing to [email protected]
To provide our contacts with marketing material and to invite contacts to events which may be of interest to them, and to manage such mailings and events
– The legitimate interests of ALX Training Ltd as a provider of training, administration and consultancy services to process personal data to communicate with persons on topics and events which may be of interest to those individuals.
– The right of those individuals to unsubscribe from mailings and/or manage preferences will be noted within all mailings and any requests to unsubscribe may be made via links available in the mailings or by writing to [email protected]
To meet all legal, regulatory and ethical obligations applicable to ALX Training Ltd
– The legitimate interests of ALX Training Ltd as a provider of training, administration and consultancy services to process data to the extent necessary to ensure it meets all legal, regulatory and ethical obligations incumbent on it.
– In certain instances, the processing of data may also be necessary for the exercise of functions of public authorities and/or necessary for compliance with a legal obligation to which ALX Training Ltd is subject
For the purposes of internal know-how and training
– The legitimate interests of ALX Training Ltd as a provider of training, administration and consultancy services to process data for the purposes of internal know-how and staff training. ALX Training Ltd will use reasonable endeavours to ensure any personal data contained in the material which is not integral to the understanding of the material is redacted.
In certain instances, personal data processed may include “Special Category Data” (which includes information on a person’s race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data processed for the purpose of uniquely identifying a natural person, health data, data on a person’s sex life or sexual orientation or data relating to a person’s criminal record or alleged criminal activity). In such instances, legal bases for processing that data may include explicit consent (where the Special Category Data has been provided to ALX Training Ltd by the data subject for any of the above-listed purposes) or the processing being necessary for compliance with a legal obligation or the purposes of legal proceedings or legal advice.
The sources of data may include clients, intermediaries, data subjects directly, third parties connected to the data subject (for example, their employer or another service provider who provides services to the data subject) or open-source material.
The provision of data to one entity in ALX Training Ltd may result in that data being accessible by all other members of ALX Training Ltd. Reasonable endeavours are made to ensure that data is only accessible by those with a need for access to fulfil the purposes set out above. Requests for access to be restricted in any particular manner should be made to
[email protected] and will be considered and, where possible with reference to legal and regulatory obligations, actioned.
The following is a list of potential recipients of data (in each case including respective employees, directors and officers):
– Other members of ALX Training Ltd;
– Other providers of services (legal, governance or otherwise, including any bank or financial institution providing services in relation to any matter on which ALX Training Ltd is instructed) where disclosure to that provider of services is considered necessary to fulfil the purposes set out above;
– Any sub-contractors, agents or service providers of ALX Training Ltd;
– Courts or tribunals;
– Third parties with whom ALX Training Ltd engages for the hosting of events or other marketing initiatives;
– Law enforcement agencies where considered necessary for ALX Training Ltd to fulfil legal obligations applicable to it;
– Regulators or other governmental or supervisory bodies with a legal right to the material or a legitimate interest in any material;
– Any registrar of a public register where the data is to be included in a public registry;
– Potential parties with whom ALX Training Ltd intends to merge or sell any part of ALX Training Ltd.
Where ALX Training Ltd is entering into an engagement with a third party pursuant to which data may be processed by that third party, we will seek to enter into an agreement with that third party setting out the respective obligations of each party and will seek to be reasonably satisfied that the third party has measures in place to protect data against unauthorised or accidental use, access, disclosure, damage, loss or destruction.
In the event that any such third party is outside of the European Union and where the data being transferred would include personal data which would be protected under applicable Data Protection regulation we will ensure we meet the relevant requirements of that Data Protection regulation prior to carrying out any such transfer. This may include only transferring the data where we are satisfied that:
– the non-European Union country has Data Protection laws similar to the laws in the European Union;
– the recipient has agreed through contract to protect the information in the same Data Protection standards as the European Union;
– we have obtained consent from relevant data subjects to the transfer; or
– if transferred to the United States of America, the transfer will be to organizations that are part of the Privacy Shield.
Data subjects in the European Union (or any jurisdiction with equivalent legislation to the European Union General Data Protection Regulation) have certain rights in respect of their personal data.
Any such data subject wishing to exercise any rights under applicable data protection laws (including the right to withdraw any consent to processing previously given; the right of access to data; or to have data corrected, updated, rectified or erased; or for access to data to be restricted or provided to any third party; or to object to any particular processing) should send the request in the first instance to [email protected].
In any case in which a data subject chooses not to provide any personal data or where any of the rights set out above are exercised to limit the processing of personal data ALX Training Ltd may be unable to provide relevant services, or there may be a restriction on the services which can be provided.
ALX Training Ltd only keeps data for as long as necessary to fulfil the purposes (as set out above) for which we collected it. ALX Training Ltd policy is to retain data in relation to a client matter for 11 years from the conclusion of that matter. This is subject to certain exceptions in instances where the personal data is relevant to a dispute after closure of the matter or where the data cannot be deleted for legal, regulatory or technical reasons.
Any requests for further information in relation to the continued processing of specific data, and requests for destruction of data, should be made to [email protected].
ALX Training Ltd has a Data Protection Officer and all enquiries in respect of this Privacy Notice or any request to exercise any of the rights set out above should be directed to the Data Protection Officer via [email protected] or by post at:
Data Protection Officer, ALX Training Ltd, Hilary House, St. Helier, Jersey, JE2 4SX, Channel Islands.
We keep this Privacy Notice under review and any updates will appear on our website at www.alxtraining.com.
We last updated this Privacy Notice on 21 May 2018.
If you have any questions about this Privacy Notice or any data which we hold about you, please contact: [email protected].
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