Privacy Statement & Cookie Policy

Introduction

Welcome to the Franklin Covey's privacy notice.

Franklin Covey respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website and use our services (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1.  Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Franklin Covey collects and processes your personal data through your use of this website and the services on it, including any data you may provide through this website when you make use of the services we provide.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Franklin Covey is made up of different legal entities, details of which can be found here https://www.franklincovey.com/About/global-offices.html.  This privacy notice is issued on behalf of the Franklin Covey Group so when we mention "Franklin Covey", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Franklin Covey Group responsible for processing your data. Unless otherwise stated, Franklin Covey (Malta) Limited is the controller and responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Franklin Covey (Malta) Limited

Name of data protection officer: Malcolm J. Naudi

Email address: info@franklincovey.com.mt

Postal address: 44/7, Dingli Circus, Sliema SLM1912 - Malta.

You have the right to make a complaint at any time to the Office of the Information and Data Protection Commissioner (IDPC), the Maltese supervisory authority for data protection issues (www.idpc.org.mt). We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on May 23, 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2.  The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, or your employer on your behalf, and you fail to provide that data when requested, we may not be able to perform the contract we have with you, or your employer. In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

3.  How is your personal data collected?

We use different methods to collect data from and about you including through:

 

4.  How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Click https://idpc.org.mt/en/Pages/dp/legalcriteria.aspx to find out more about the types of legal criteria that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or by clicking on the unsubscribe link in our emails.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new user

(a) Identity

(b) Contact

Performance of a contract with you or your employer

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(a) Performance of a contract with you or your employer

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, services, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our business strategy)

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use see below.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.  Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.  International transfers

We share your personal data within the Franklin Covey Group. This will involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.  Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after the last use of the website and/or services for liability and tax purposes

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. More information about the following rights can be found from IDPC, however, if you believe we have breached any of these please contact us first to give us the opportunity to put things right.

If you wish to exercise any of the rights set out above, please contact us.   Please note, these rights are subject to certain exceptions and exclusions and we may not be able to comply, in full, with any request you make.  In such circumstances we will explain to you

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.                Glossary

Legitimate Interestmeans the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contractmeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligationmeans processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Internal Third Parties

Other companies in the Franklin Covey Group acting as joint controllers or processors and who are based in countries all over the world (a list can be found here: https://www.franklincovey.com/About/global-offices.html) and provide IT and system administration services and undertake leadership reporting.

 

Cookie Policy

This website www.franklincovey.com.mt or www.franklincovey.mt (“Our Site”) uses Cookies and similar technologies in order to distinguish you from other users. By using Cookies, We are able to provide you with a better experience and to improve Our Site by better understanding how you use it. Please read this Cookie Policy carefully and ensure that you understand it. Your acceptance of Our Cookie Policy is deemed to occur if you continue using Our Site OR [when you press the X button on Our Cookie banner. If you do not agree to Our Cookie Policy, please stop using Our Site immediately.

  1. Information About Us

Our Site is owned and operated by Franklin Covey Malta Ltd, a limited company registered in the Maltese Islands under company number C-60394, whose registered address is 44/7, Dingli Circus, Sliema SLM1912, Malta. Our Data Protection Officer is Malcolm J. Naudi and can be contacted by email at info@franklincovey.com.mt.

  1. How Does Our Site Use Cookies?

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our [products] and/or [services]. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times. All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie: Strictly Necessary Cookies A Cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions. Analytics Cookies It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it. Functionality Cookies Functionality Cookies enable Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category. Targeting Cookies It is important for Us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make Our Site and advertising more relevant to your interests. [Some information gathered by targeting Cookies may also be shared with third parties.] Third Party Cookies Third party Cookies are not placed by Us; instead, they are placed by third parties that provide services to Us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on Our Site, or by third parties providing analytics services to Us (these Cookies will work in the same way as analytics Cookies described above). Persistent Cookies Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site. Session Cookies Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser. Cookies on Our Site are not permanent and will expire after 30 days OR [as indicated in the table below]. For more details of the personal data that We collect and use, the measures we have in place to protect personal data, your legal rights, and our legal obligations, please refer to our Privacy Policy. For more specific details of the Cookies that We use, please refer to the table below.  

  1. What Cookies Does Our Site Use?

The following first party Cookies may be placed on your computer or device:

Name of Cookie

Purpose & Type

Strictly Necessary

catAccCookies

To Track Cookie Acceptance

No

  Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the [products] AND/OR [services] offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you. The analytics service(s) used by Our Site use(s) analytics Cookies to gather the required information. The analytics service(s) used by Our Site use(s) the following analytics Cookies:  

Name of Cookie

Purpose & Type

Provider

Strictly Necessary

_ga

Google Analytics

Google

No

_gid

Google Analytics

Google

No

_gat

Google Analytics

Google

No

AMP_TOKEN

Google Analytics

Google

No

_gac_

Google Analytics

Google

No

  1. Consent and Control

Before Cookies are placed on your computer or device, you will be shown a banner prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies [unless those Cookies are strictly necessary]; however certain features of Our Site may not function fully or as intended. [You will be given the opportunity to allow and/or deny different categories of Cookie that We use.] In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. The links below provide instructions on how to control Cookies in all mainstream browsers: Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835 Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge Safari (macOS): https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB Safari (iOS): https://support.apple.com/en-gb/HT201265 Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en

  1. Changes to this Cookie Policy

We may alter this Cookie Policy at any time. Any such changes will become binding on you on your first use of Our Site after the changes have been made. You are therefore advised to check this page from time to time. In the event of any conflict between the current version of this Cookie Policy and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.

  1. Further Information

If you would like to know more about how We use Cookies, please contact Us at info@franklincovey.com.mt or by telephone on +356 3550 0345 or by post at FranklinCovey (Malta) Ltd, 44/7, Dingli Circus, Sliema SLM1912, Malta. For more information about privacy, data protection and our terms and conditions, please see above.

  1. Glossary

In this Cookie Policy, unless the context otherwise requires, the following expressions have the following meanings: “Cookie” means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site; “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 [and of EU Regulation 2016/679 General Data Protection Regulation (“GDPR”)]; “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by [the Data Protection Act 1998] OR [EU Regulation 2016/679 General Data Protection Regulation (“GDPR”)]; and “We/Us/Our” means Franklin Covey (Malta) Ltd , a limited company registered in the Maltese Islands under company number C-60394, whose registered address is 44/7, Dingli Circus, Sliema – SLM1912, Malta.