PRIVACY POLICY


Retail International Limited, which is a member of the Retail International Group (the “Group”) that is also made up of NAM Limited, PRM Limited, Quadron Establishment Limited and Supermarkets 1960 Limited, believes the privacy and confidentiality of an individual’s personal data is important. We provide the following updated privacy policy (“Privacy Policy”) in order to demonstrate our firm commitment to privacy.

Please read this Privacy Policy carefully to understand our practices with respect to your personal data.

References to “data controller”, “data subject”, “personal data”, “process”, “processed”, “processing” and “Data Protection Officer” in this Privacy Policy have the meanings set out in, and will be interpreted in accordance with applicable laws, including but not limited to the Data Protection Regulation (EU) 2016/679 and the Data Protection Act, Chapter 440 of the Laws of Malta and subsidiary legislation thereto, as may be amended from time to time.

1. The Data Controller
Retail International Limited (hereinafter referred to as “we”, “us” or “our” in this Privacy Policy) is a private limited liability company with registration number C-38864 and having its registered office at 14, Lascaris Buildings, Lascaris Wharf, Valletta, Malta.

2. Queries about our Privacy Policy
If you have any questions about this Privacy Policy, including concerns about your personal data or our data collection practices, please feel free to contact us by post on the above mentioned address or by email at dpo@retail.com.mt. You may also wish to contact us by telephone on (356) 21234017.

3. Updates
If there are any changes to this Privacy Policy, we will replace this page with an updated version on the website at www.retail.com.mt/privacy-policy/. It is therefore in your own interest to check this page any time you access our website so as to be aware of any changes which may occur from time to time. We will notify you of changes to this Privacy Policy by email or other means, where such data is available.

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
If you are chosen become an employee within the Group after submitting an application through the function on our website, the legal basis for the processing of personal data shall be subject to the specific privacy policy provided to employees (“Employee Privacy Policy”) which shall be made available to you.

9. Recipients
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).
The personal data provided to us by means of the job application function would need to be deleted once the application is processed, or for not more than two years after if the applicant has specifically consented thereto. If the applicant is chosen to carry out employment within the Group, the data retention clause within the Employee Privacy Policy would become applicable.

12. Links to other Web Sites

Users should be aware that our site has a number of links to other local and international organisations and agencies. In some cases, for the benefit of the visitor, it may be required that we link to other websites of other organisations after permission is obtained from them respectively. It is important for you to note that upon linking to another site, you are no longer on our site and you become subject to the privacy policy of the new site.

13. Marketing
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 dpo@retail.com.mt.

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.

14. Use of Cookies
Our website uses cookies which are pieces of information that a website transfers to your computer’s hard disk or to your browser’s memory for record-keeping purposes. They are useful because they help arrange the content and layout of our site and allow us to recognize those computers or other devices that have visited our sites before. For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider. They also allow our website to remember your preferences thereby helping us to enhance the usability and performance of our site and your experience while using it. Cookies do not personally identify users but they simply identify a user’s computer or other device.
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.
Most browsers are initially set to accept cookies. However, if you prefer, you can set your browser to block all, or certain, cookies. Please be aware that without cookies you may not be able to use the full functionality of our site. Users can also set their browser to prompt them each time a cookie is offered.  You can find a guide on how to block cookies in the main browsers below:

Delete Cookies in Microsoft Internet Explorer

Delete Cookies in Mozilla Firefox browser

Delete Cookies in Google Chrome browser

Delete flash cookies (all browsers)

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.