Legal
Privacy notice
Last updated: . This notice explains how Threesixo Consultancy Ltd uses personal data collected through threesixo.com.mt.
Who we are
Threesixo Consultancy Ltd is a private limited liability company registered in Malta (company number C 64942, Malta Business Registry), with its registered office at 265, Triq iż-Żebbuġ, Mellieħa MLH 2723, Malta. We decide how and why your personal data is used on this website, which makes us the “controller” under data protection law.
For anything about your data, email info@threesixo.com.mt. We have not appointed a data protection officer, as the law does not require one for a business like ours.
This notice covers this website only. If you become a client, our agreement with you explains how we handle data in that work.
What we collect, why, and on what basis
| When | What we collect | Why, and our legal basis | How long we keep it |
|---|---|---|---|
| You visit any page | Your IP address, browser type, the page requested and the time | To deliver the site and keep it secure. Legitimate interest: running a working, secure website. | We can see these logs for one hour. Our hosting provider keeps them only as long as it needs to, under its data processing terms (it publishes no fixed period) |
| We count visits | The page, the site you came from, your country, region and city, your browser, operating system and type of device. A visit is recognised by a code made from your request, not by a cookie, and the code is deleted after 24 hours. Nothing is stored on your device. | To see which pages are useful and where visitors come from, as anonymous totals. Legitimate interest: improving the website. | The code: 24 hours. We see only anonymous totals, not linked to you or your IP address, for one month |
| You send the contact form | Name, email, your message and the help you’re interested in; optionally business name and phone | To reply and handle your enquiry. Steps you asked us to take before any agreement; otherwise our legitimate interest in answering enquiries. | 24 months after our last contact, unless you become a client |
| You call us or message us on WhatsApp | Your phone number, your name if you give it, and your messages | To reply and handle your enquiry, on the same basis as the contact form. WhatsApp is run by Meta under its own terms and privacy policy. | 24 months after our last contact, unless you become a client |
| You book a call | Your name, email address and business name, and your website if you give it | To hold the call you asked for. Steps you asked us to take before any agreement. The booking page is Google Calendar’s, run by Google under its own privacy policy. | 24 months after our last contact, unless you become a client |
| You use the 3sixty Health Check | Your answers | To work out your scores on screen. Your answers stay in your browser’s memory and are never sent to us; closing or reloading the page clears them. | Not kept by us |
| You ask for your results by email | Your email address and your scores | To email you the PDF you asked for. Providing a service you requested. | See the next row |
| (same) | A copy: your email address, your scores, your choices in the two boxes, and the date and time | To know who used the Health Check and to show what you agreed to. Legitimate interest: understanding interest in our services and keeping a record of consent. | 12 months; longer only if it becomes an enquiry (then 24 months) |
| You open or click our results email | Whether the email was opened and which link was clicked, counted only in anonymous totals. To count opens, your email app loads a tiny image from Brevo; links pass through Brevo before reaching our site. | To know whether our emails arrive and which links are useful. Legitimate interest. | Not linked to you: anonymous totals only |
| You tick “Contact me to talk through my results” | Your email address and scores (from the copy above) | To contact you by email or phone about your results. Your consent. | Until you withdraw consent, and within the 12 months above |
| You tick “Send me occasional news” | Your email address and the record of your consent | To send you occasional news and practical ideas from Threesixo. Your consent. | Until you unsubscribe |
If you unsubscribe or object, we keep your email address on a short “do not contact” list, only so that we don’t contact you again.
Giving us your details is your choice. Without a name, email and message we can’t reply to an enquiry. Without an email address we can’t send your results, but you can still see them on screen.
Who receives your data
We don’t sell your data or share it for others’ marketing. These service providers process it on our behalf, under data processing agreements:
- Vercel Inc. (United States): hosts the website and keeps its request logs, and counts visits as anonymous totals (Vercel Web Analytics).
- Brevo SAS (France): our email service. It sends the contact-form messages, your results and the copy to our mailbox, and counts opens and clicks as anonymous totals. Brevo keeps data in the EU (France and Belgium).
- Google (Google Workspace): our mailbox and calendar, where enquiries, bookings and the results copies are kept.
- Sanity: the system we use to edit the site. It holds no visitor data.
We may also disclose data where the law requires it, for example to a court or a public authority.
Transfers outside the EU
Vercel and Google are US companies, and some of Brevo’s own providers are in the US, so some data may be processed in the United States. These transfers rely on the EU-US Data Privacy Framework, where the provider is certified under it, and on the European Commission’s standard contractual clauses in each provider’s data processing terms. You can ask us for a copy of the safeguards at info@threesixo.com.mt.
Your rights
You can ask us to give you a copy of your data, correct it, delete it, limit how we use it, or (where we rely on your consent or on providing a service you asked for) give it to you in a portable format. Where we rely on your consent, you can withdraw it at any time; this doesn’t affect what we did before. Email info@threesixo.com.mt. We reply within one month, free of charge.
Your right to object
You can object at any time to us using your data for direct marketing, and we will stop. You can also object to any use based on our legitimate interests; we will then stop unless we have compelling grounds or need the data for a legal claim. Every news email has an unsubscribe link, or email info@threesixo.com.mt.
Complaints
If you’re unhappy with how we handle your data, please tell us first. You also have the right to complain to Malta’s data protection authority:
Information and Data Protection Commissioner (IDPC), Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, Malta. Tel. +356 2328 7100. idpc.info@idpc.org.mt. Complaints are filed online at idpc.org.mt.
Automated scores
The 3sixty Health Check calculates scores from your own answers. It is a self-assessment about your business. We make no decisions about you based solely on automated processing.
Cookies
This website sets no cookies and stores nothing on your device. We count visits with Vercel Web Analytics, which works without cookies, and our results email counts opens and clicks as anonymous totals. See our Cookies page.
Security, children and changes
We use reputable providers and limit access to your data to the people who need it. This website is for businesses and is not directed at children. If we change this notice, we’ll update the date at the top.