2. What is Personal Data?
1. Personal data refers to any information relating to an identified or identifiable natural person, whom the latter can be identified, directly or indirectly, in particular by reference to an identifier. This personal information may be processed – such processing refers to any operation which is performed on personal data such as collection, recording, organisation, structuring and storage.
3. Processing of Personal Data:
1. We will process personal data fairly and lawfully, and only to the extent necessary as may be allowed in terms of law or in terms of our agreement or our terms and conditions. When processing your personal data, we will make sure that the processing shall be lawful and only, if and to the extent that at least one of the following applies:
1. To provide you with the Services requested and, any ancillary actions related thereto;
2. You have given your clear affirmative consent, signifying agreement to the processing of your personal data for one or more specific purposes;
3. To send informational newsletters that you have opted-in to;
4. Processing is necessary for compliance with a legal obligation to which we are subject;
5. Processing is necessary in order to protect your vital interests;
6. Processing is necessary to operate, maintain, enhance and provide our Services;
7. Processing is necessary for communication purposes;
2. We may sometimes contract with third party service providers to perform functions or services on our behalf and these third party service providers may have access to your personal information, such as names and email address required to perform their functions. We will make sure that such third party providers have undertaken to use any personal data legitimately and in accordance to our written instructions or agreements.
4. Information we collect about you
1.We only collect personally identifiable information (i.e. information identifying one individual from the other) which would have been provided to us to provide you with our Services or when you receive communications from us, or when you send us an email or other communication. We may also acquire personal data from or through third parties with whom we have an agreement in order to provide our services. Examples of personally identifiable information may include but are not limited to, the name, physical address, email address and phone number.
2. 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).
3. We may also collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
1. Identity Data includes first name, last name or similar identifier.
2. Contact Data includes email address.
4. Some of the data mentioned above is collected from our Contact Form such as name and surname, email address and also phone number.
5. Rights of Data Subjects
1. In terms of the aforementioned regulations we protect the fundamental rights and freedoms of natural persons and in particular their right to the protection of personal data.
2. As a data subject you have the following rights:
1. Right of access – You have the right to obtain for us confirmation as whether or not personal data concerning you is being processed, and where that is the case, access to the personal data and the additional information as outlined in the regulations. Limitations to this right will only be applicable if provided in terms of law such as anti-money laundering regulations.
2. Right to rectification – You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you.
3. Right to erasure (‘right to be forgotten’) – You have the right to obtain from us the erasure of your personal data in terms of law. This right is limited by, and subject to all our compliance, regulatory and legal obligations, including anti-money laundering regulations, whereby we are obliged to hold your personal data for such period stipulated at law, after the termination of our relationship or any other such longer time which may be necessary in view of the particular services provided to you,
4. Right to restriction of processing – You shall have the right to obtain from us restriction of processing where, in terms of the aforementioned regulations, one of the following applies: the accuracy of personal data is contested by yourself for a period enabling us to verify the accuracy of your personal data; the processing is unlawful and you oppose to the erasure of your personal data and request the restriction of their use instead; we no longer need the personal data, but are required by yourself for the establishment, exercise or defence of legal claims; you object to processing pursuant to your right to object pending the verification whether our legitimate grounds override yours;
5. Right to data portability – You shall have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format.
6. Right to object – You have the right to object, on grounds relating to your particular situation to processing of your personal data. We shall no longer process your personal data unless we have a compelling legitimate ground for the processing. You have the right to object at any time to the processing of personal data concerning you for direct marketing purposes.
7. Right to lodge a complaint – Should you require any clarification or need to discuss matters relating to data protection, you may contact DPO (Data Protection Officer) by email at email@example.com. In the case you are not satisfied with the outcome, as a data subject, you also have a right to lodge a complaint with the Information and Data Protection Commissioner, Level 2, Airways House, High Street, Sliema SLM 1549, Malta through their website https://idpc.org.mt/.
1. We are committed to protecting our visitors’ privacy and we will not collect any personal information about you as a visitor unless you provide it voluntarily. When you fill the form on the “CONTACT US”, we use the personal information submitted in the form only to respond to your message. This personal information will not be kept longer than necessary and will be deleted once the feedback requirement is met.
8. Links to other Websites
2. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
1. what the purpose(s) was for which your information was collected in the first place;
2. whether there are any statutory obligations, obliging us to continue to process your information;
3. whether we have a legal basis in place to continue to process your information, including but not limited to consent;
4. what the value attached to your information is;
5. whether there are any industry practices stipulating how long information should be retained;
6. the risk, cost and liability attached to such retention; and
7. any other relevant circumstances.
10. Data Security
1. To prevent unauthorised access, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate technical and organisational measures, controls and internal policies to protect your Personal Data against loss, misuse and unauthorised access, alteration, disclosure or destruction. Moreover, all efforts are taken to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing Personal Data. This includes requiring service providers to use appropriate measure to protect the confidentiality and security of your Personal Data.
2. If we learn of a Personal Data Breach, we will inform you of the occurrence of the breach in accordance with Applicable Laws.
12. Accuracy of Information While we strive to ensure the accuracy of the personal data, it shall be your responsibility to ensure that the personal data provided is correct and to notify us should such information change. In line with GDPR, if you wish to rectify your personal information you may do so by contacting the Data Protection Officer (‘DPO”) on firstname.lastname@example.org.