Privacy Policy

Privacy Policy

Date: 26th February, 2020

PRIVACY POLICY 1

  1. Introduction
  2. Definitions and interpretation
  3. Scope of this privacy policy
  4. Our usage of Data
  5. Who we share Data WITH?
  6. Site users
  7. How we collect Data
  8. Data that is collected automatically
  9. Data that is given to us by you
  10. How we collect Data
  11. Data that is collected automatically
  12. Keeping Data secure
  13. Data retention
  14. Your rights
  15. Transfers outside the European Economic Area
  16. Links to other websites
  17. Changes of business ownership and control
  18. Cookies
  19. General
  20. Children's Privacy
  21. Changes to this privacy policy

1. INTRODUCTION

Welcome to this website Privacy policy. We take your privacy very seriously and being compliant with the GDPR is a top priority for us.

This privacy policy between you, the user of this Website and the owner of this website and provider of this Web portal. This privacy policy to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions.

Please read this privacy policy carefully.


2. DEFINITIONS AND INTERPRETATION

In this privacy policy, the following definitions are used:

Data collectively all information that you submit

via the Website. This definition incorporates, where web portal applicable, the definitions provided in the Data Protection Laws;

Cookies Details of the cookies used by this Website are set out in the clause below (Cookies);

GDPR the General Data Protection Regulation (EU) 2016/679;

The Owner, or us/we

The owner is the person listed as the owner of this website, and may be contacted through the email address provided on the website.

  • In this privacy policy, unless the context requires a different interpretation:
  • The singular includes the plural and vice versa;
  • References to sub-clauses, clauses, schedules or web portal entices are to sub-clauses, clauses, schedules of this privacy policy;
  • A reference to a person includes firms, companies, government entities, trusts and partnerships;
  • "Including" is understood to mean "including without limitation";
  • Reference to any statutory provision includes any modification or amendment of it;
  • The headings and sub-headings do not form part of this privacy policy.


3. SCOPE OF THIS PRIVACY POLICY

This privacy policy web portal applies only to the actions of this website and Users with respect to this Web portal. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the web portal applicable Data Protection Laws, the owner is the "data controller". This means that the owner determines the purposes for which, and the manner in which, your Data is processed.


4. OUR USAGE OF DATA

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

  1. Internal record keeping;
  2. Improvement of our products / services;
  3. Transmission by email of marketing materials that may be of interest to you (if you have opted to receive marketing materials from us);
  4. Contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customize or update the Website;

In each case, in accordance with this privacy policy.

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft- opt-in:

Soft opt-in consent is a specific type of consent which web portal applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out;

For other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide;

If you are not satisfied about our web portal reach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.

When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.


5. WHO WE SHARE DATA WITH?

We may share your Data with the following groups of people for the following reasons:

  1. Any of our group companies or affiliates – to ensure the proper administration of our website, and for business marketing procedures;
  2. Our employees, agents and/or professional advisors - for accounting purposes and for marketing research;
  3. Third party service providers who provide services to us which require the processing of personal data - to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the website runs smoothly;
  4. Relevant authorities - to facilitate the detection of crime or the collection of taxes or duties; in each case, in accordance with this privacy policy.


6. SITE USERS

Data collected

We may collect the following Data, which includes personal Data, from you:

  1. Name of Contact person;
  2. Contact Information such as email addresses and telephone numbers;
  3. Social Accounts information
  4. IP address (automatically collected);
  5. Web browser type and version (automatically collected);
  6. Operating system (automatically collected);
  7. A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

In each case, in accordance with this privacy policy.


7. HOW WE COLLECT DATA

We collect Data in the following ways:

  1. Data is given to us by you; and
  2. Data is collected automatically.


8. DATA THAT IS COLLECTED AUTOMATICALLY

To the extent that you access the Website, we will collect your Data automatically, for example:

We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies".


9. DATA THAT IS GIVEN TO US BY YOU

The owner will collect your Data in a number of ways, for example:

  1. When you fill up the contact form found online;
  2. When you use our services;

In each case in accordance with this privacy policy.


10. HOW WE COLLECT DATA

We collect Data in the following ways:

  1. Data is given to us by you; and
  2. Data is collected automatically.


11. DATA THAT IS COLLECTED AUTOMATICALLY

To the extent that you access the Website, we will collect your Data automatically, for example:

We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies".


12. KEEPING DATA SECURE

We will use technical and organizational measures to safeguard your Data, for example:

  1. We store your Data on secure servers.
  2. We use high quality firewalls to make sure that your data is safe.
  3. All data is encrypted

Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us via the e-mail address provided on this website of the owner.


13. DATA RETENTION

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until we receive your request that the Data be deleted.

We will make sure that once we receive your request to cancel your information will be cancelled. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.


14. YOUR RIGHTS

You have the following rights in relation to your Data:

  1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information, we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive.” In the event where the requests are manifestly unfounded or excessive, the company may charge you for such requests. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
  2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
  3. Right to erase - the right to request that we delete or remove your Data from our systems.
  4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
  5. Right to data portability - the right to request that we move or copy or transfer your data.
  6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via the e-mail address found on this website.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For more information, please contact your local data protection authority in the European Economic Area (EEA).

It is important that the Data we hold about you is accurate and current. Please keep us informed if your data changes during the period for which we hold it.


15. TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA

Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.

We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organization in receipt of the Data is based in the United States of America.

To ensure that your Data receives an adequate level of protection, we have put in place web portal safeguards and procedures with the third parties we share your Data with to ensure your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.


16. LINKS TO OTHER WEBSITES

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to  your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them. 


17. CHANGES OF BUSINESS OWNERSHIP AND CONTROL

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part thereof. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.


18. COOKIES

This Website may place and access certain Cookies on your computer. We may utilize Cookies to improve your experience of using the Website/web portal and to improve our range of services.

All Cookies used by this Website are used in accordance with current Laws and EU Cookie Law. This Website may place the following Cookies:

Type of Cookie

Purpose

Strictly necessary cookies

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, example, filling up the contact form.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalization settings.

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete Cookies from your computer.


19. GENERAL

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the laws of Malta. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Maltese courts.


20. CHILDREN'S PRIVACY

We do not knowingly collect personally identifiable information from minors. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.


21. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this privacy policy, as may be deemed necessary from time to time or as may be required by law. We will always indicate the date when the last changes where published, and we also offer access to archived versions for your review. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the website following the changes. Shall such changes be significant, we’ll provide you with a more prominent notice, (including, for certain services, email notification of Privacy Policy changes).