1. The Data Controller
4. What amounts to personal data?
The term “personal data” refers to all personally identifiable information about you, such as your name, surname and address, and includes all information which may arise that can be identified with you personally.
We may collect and process personal data that you voluntarily give us when you use our website. For example, you may use this website to contact us with questions and comments or to submit an application for employment with us.
5. How do we collect personal data?
We collect personally identifiable data about you only when you voluntarily provide such data. When you contact us from the website, we use the personal data submitted in the form only to respond to your message or act on your request.
Generally, you would have provided your personal data to us. However, in some instances, we may collect personal data about you from third party sources, such as in cases where you would have subscribed with one of our partners.
6. What personal data do we process?
The personal data we typically collect and process are:
⦁ Your identity details such as your name and surname;
⦁ Your contact information such as your email address;
⦁ Further data you may provide to us for the purposes of applying for employment with us, such as your mobile number and your curriculum vitae; or
⦁ Personal data provided to us by, or on behalf or in relation to third parties.
7. How do we use your personal data?
We will not sell or otherwise transfer or disclose personally identifiable information to third parties not affiliated with it without your prior consent (except as may be required by law, such as a court-ordered subpoena, search warrant, or other court order; or required by exigent circumstances). That means that we will never disclose your personal data to third parties not affiliated us without your consent.
Irrespective of the manner in which we have collected your personal data, we will only process such data for the purposes of our functions and services, or purposes which are inherently related thereto, including the fulfillment of any legal or regulatory obligation imposed on us.
Typically, your personal data will be processed for the purpose of:
⦁ acting upon any request you may have posted to us by means of the contact form; and
⦁ acting upon any application you may have filed on the website by means of the job application function for purposes of employment within the Group.
We might also process your personal data on the basis of your explicit consent, in which case we will process your data for the purposes for which your explicit consent was requested.
8. Legal Basis of Processing Personal Data
We process your personal data on the basis of your explicit consent, in which case, our processing shall be limited to the purposes specifically indicated when your consent was requested. Where our processing is based on your consent, you have the right to withdraw your consent. Withdrawal of your consent shall not affect the lawfulness of the processing based on your consent prior to the withdrawal of your consent
The recipients of the personal data are:
a) Selected individuals within our company and within the Group companies on a need-to-know basis;
b) Agents and third parties that provide services to us within the EU/EEA; and
c) Third parties to whom disclosure may be required as a result of legal obligations imposed on us, such as the Police.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
Unless specifically instructed and consented by you, we do not share your personal data with any entity located outside of the EU or EEA.
10. Automated Decision-Making and Profiling
“Automated decision-making” refers to decisions that are taken solely through a software algorithm, without human involvement and which produce legal effects or significant effects on the individual.
“Profiling” is a subset of “automated decision-making” and refers to automated processing of personal data in which the personal data is used to evaluate personal aspects of a particular individual, particularly analysing and predicting aspects such as preferences, interests, behaviour, location or movements.
Your personal data will not be used for any decision solely taken on the basis of automated decision-making processes, including profiling, without human intervention.
11. Data Retention
We retain your personal data exclusively for the period which is lawfully permissible to retain your personal data. Thereafter, your personal data shall be immediately and irrevocably destroyed.
The personal data provided to us by means of the contact form will not be kept for longer than necessary and will be deleted once the feedback requirement is met, unless we are required to keep that data due to a statutory obligation imposed on us and/or due to accepted standards (including where processing may be necessary for the establishment, exercise or defence of legal claims).
12. Links to other Web Sites
Marketing will be carried out through the circulation of e-mails. Other means of communication may also be used, however we shall always seek your prior consent.
You may withdraw consent to the processing of personal data for marketing purposes at any time by sending us an e-mail on email@example.com.
However, withdrawal of consent for marketing communication does not affect the lawfulness of the processing of personal data based on such consent prior to its withdrawal.
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15. Your Rights
For as long as we retain your personal data, you have certain rights in relation to your personal data, including:
⦁ Right of access – you have the right to ascertain the personal data we hold about you and to receive a copy of such personal data;
⦁ Right to Lodge a Complaint – you have the right to lodge a complaint regarding the processing of your personal data with the supervisory authority for data protection matters. In Malta this is the Information and Data Protection Commissioner (contact details provided below);
⦁ Right to Erasure – in certain circumstances you may request that we delete the personal data that we hold about you;
⦁ Right to Object – you have a right to object and request that we cease the processing of your personal data where we rely on our, or a third party’s legitimate interest for processing your personal data;
⦁ Right to Portability – data subjects may request that we provide personal data provide by the data subject in a structured, commonly used and machine-readable format. Where technically feasible, data subjects may also request that we transmit their personal data to a third party controller indicated by the data subjects; and
⦁ Right to Restriction – data subjects have the right to request that we stop using their personal data in certain circumstances, including if they believe that we are unlawfully processing their data.
Please note that in terms of the applicable laws, your rights in relation to your personal data are not absolute. Nonetheless, you may exercise the rights indicated in this section by contacting us or our Data Protection Officer at the details indicated above. If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In Malta the supervisory authority is the Information and Data Protection Commissioner, at the following link https://idpc.org.mt/en/Pages/contact/complaints.aspx.