“PERSONAL DATA” means any information that identifies You as an individual or that relates to an identifiable individual.
Whenever it is not possible or feasible for Us to make use of anonymous and/or anonymised data (in a manner that does not identify any Users of the Site or customers of Our services), We are nevertheless committed to protecting Your privacy and the security of Your Personal Data at all times.
1. Personal data
We collect Personal Data in various ways both digitally via the Site (either when You choose to provide Us with certain data or in some cases, automatically or from third parties) as well as non-digitally (for example when You fill in a physical form to benefit from one or more of Our services).
2. Personal data we collect about you
There are various categories of Personal Data that We collect about You, namely:
Telephone or mobile phone
& other information
In some cases, (for example, if You are a client [or prospective client] of Our services, via the Site, any App or otherwise) We may request additional Personal Data as a means of securely identifying You or for another similar lawful purpose.
For a detailed description of the reasons why We process the categories of Personal Data above (and any other specific Personal Data We process) as well as the corresponding legal ground(s) for doing so please see the ‘What We Use Your Personal Data For (Purpose of Processing)’ below. For information/Personal Data that We may collect automatically via the Site, please see the Cookies section below.
3. How and when we collect personal data
Unless otherwise specified and subject to various controls, as a general rule, We only collect Personal Data from You that We:
Need to be able to provide You services You request from Us
Are legally required to collect/use and to keep for a predetermined period of time
Believe to be necessary for Our legitimate business interests
For a detailed description of the reasons why we process specific categories of personal data as well as the corresponding legal ground(s) for doing so, please see the ‘What We Use Your Personal Data For (Purpose of Processing)’ below.
The personal information which We may hold (and/or transfer to any affiliates/partners/subcontractors as the case may be) will be held securely in accordance with Our internal security policy and the law.
We use reasonable efforts to safeguard the confidentiality of any and/or all Personal Data that We may process relating to You and regularly review and enhance Our technical, physical and managerial procedures so as to ensure that Your Personal Data is protected from:
Improper use or disclosure
Unlawful destruction or accidental loss.
To this end We have implemented security policies, rules and technical and organisational measures to protect the Personal Data that We may have under Our control. All our members, staff and data processors (including specific subcontractors, including cloud service providers established within the European Union), who may have access to and are associated with the processing of Personal Data, are further obliged (under contract) to respect the confidentiality of Our Users’ or clients’ Personal Data as well as other obligations as imposed by the Data Protection Laws.
Despite all the above, We cannot guarantee that a data transmission or a storage system can ever be 100% secure. For more information about Our security measures please contact Us in the manner described below.
As stated above, the said service providers (Our data processors) are also bound by a number of other obligations in line with the Data Protection Laws (particularly, Article 28 of the GDPR).
5. Retention periods
We will retain Your Personal Data only for as long as is necessary (taking into consideration the purpose for which it was originally obtained). The criteria We use to determine what is ‘necessary’ depends on the particular Personal Data in question and the specific relationship We have with You (including its duration).
We would also have to determine whether there are any laws and/or contractual provisions that may be invoked against Us by You and/or third parties and if so, what the prescriptive periods for such actions are. In the latter case, We will keep any relevant Personal Data that We may need to defend Ourselves against any claim(s), challenge(s) or other such action(s) by You and/or third parties for such time as is necessary.
Where Your Personal Data is no longer required by Us, We will either securely delete your Personal Data in question.
7. Your right under data protection laws
Before addressing any request You make with Us, We may first need to verify Your identity. In all cases We will try to act on Your requests as soon as reasonably possible.
As explained in the Retention Periods section above, We may need to keep certain Personal Data for compliance with Our legal retention obligations but also to complete transactions that You requested prior to the change or deletion that You requested.
Your various rights at law include:
Your Right of Access
You may, at any time request Us to confirm whether or not We are processing Personal Data that concerns You and, if We are, You shall have the right to access that Personal Data and to the following information:
What Personal Data We have,
Why We process them,
Who We disclose them to,
How long We intend on keeping them for (where possible),
Whether We transfer them abroad and the safeguards We take to protect them,
What Your rights are,
How You can make a complaint,
Where We got Your Personal Data from and
Whether We have carried out any automated decision-making (including profiling) as well as related information.
Upon request, We shall (without adversely affecting the rights and freedoms of others including Our own) provide You with a copy of the Personal Data undergoing processing within one month of receipt of the request, which period may be extended by two months where necessary, taking into account the complexity and number of the requests. We shall inform You of any such extension within one month of receipt of the request, together with the reasons for the delay.
Your Right to Rectification
You have the right to ask Us to rectify inaccurate Personal Data and to complete incomplete Personal Data concerning You. We may seek to verify the accuracy of the data before rectifying it.
Your Right to Erasure (The Right to be Forgotten)
You have the right to ask Us to delete Your Personal Data and We shall comply without undue delay but only where:
The Personal Data are no longer necessary for the purposes for which they were collected; or
You have withdrawn Your consent (in those instances where We process on the basis of Your consent) and We have no other legal ground to process Your Personal Data; or
You shall have successfully exercised Your right to object (as explained below); or
Your Personal Data shall have been processed unlawfully; or
There exists a legal obligation to which We are subject; or
Special circumstances exist in connection with certain children’s rights.
In any case, We shall not be legally bound to comply with Your erasure request if the processing of Your Personal Data is necessary:
For compliance with a legal obligation to which We are subject (including but not limited to Our data retention obligations); or
For the establishment, exercise or defence of legal claims.
There are other legal grounds entitling Us to refuse erasure requests although the two instances above are the most likely grounds that may be invoked by Us to deny such requests.
Your Right to Data Restriction
You have the right to ask Us to restrict (that is, store but not further process) Your Personal Data but only where:
The accuracy of Your Personal Data is contested (see the right to data rectification above), for a period enabling Us to verify the accuracy of the Personal Data; or
The processing is unlawful and You oppose the erasure of Your Personal Data; or
We no longer need the Personal Data for the purposes for which they were collected but You need the Personal Data for the establishment, exercise or defence of legal claims; or
You exercised Your right to object and verification of Our legitimate grounds to override Your objection is pending.
Following Your request for restriction, except for storing Your Personal Data, We may only process Your Personal Data:
Where We have Your consent; or
For the establishment, exercise or defence of legal claims; or
For the protection of the rights of another natural or legal person; or
For reasons of important public interest.
Your Right to Data Portability
You have the right to ask Us to provide Your Personal Data (that You shall have provided to Us) to You in a structured, commonly used, machine-readable format, or (where technically feasible) to have it ‘ported’ directly to another data controller, provided this does not adversely affect the rights and freedoms of others. This right shall only apply where:
The processing is based on Your consent or on the performance of a contract with You; and
The processing is carried out by automated means.
Your Right to Withdraw Consent (when We rely on consent)
See Our Special Note on Consent for detailed information on this right (which You may exercise at any time).
Your Right to Object to Certain Processing
In those cases where We only process Your Personal Data when this is 1.) necessary for the performance of a task carried out in the public interest or 2.) when processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party, You shall have the right to object to processing of Your Personal Data by Us. Where an objection is entered, the processing of data shall cease, unless We as data controller provide compelling and legitimate grounds requiring the continuation of the data processing which outweigh the objections You may have raised.
When Your data is processed for direct marketing purposes, You have the right to object at any time to the processing of Your Personal Data, which includes profiling to the extent that it is related to such direct marketing.
For the avoidance of all doubt, when We process Your Personal Data when this is necessary for the performance of a contract, when necessary for compliance with a legal obligation to which We are subject or when processing is necessary to protect Your vital interests or those of another natural person, this general right to object shall not subsist.
Your Right to lodge a Complaint
You also have the right to lodge complaints with the appropriate Data Protection Supervisory Authority. The competent authority in Malta is the Office of the Information and Data Protection Commissioner (OIDPC).
We kindly ask that You please attempt to resolve any issues You may have with Us first (even though, as stated above, You have a right to contact the competent authority at any time).
What we may require from you
As one of the security measures We implement, before being in the position to help You exercise Your rights as described above We may need to verify Your identity to ensure that We do not disclose to or share any Personal Data with any unauthorised individuals.
Time limit for a response
We try to reply to all legitimate requests within one month from receiving them. In some particular cases (for example, if the matter is particularly complex or if You send Us multiple requests), it may take Us longer than a month. In such cases, we will notify You accordingly and keep You updated.
Malta Transfer Limited is a company registered in Malta with Company Registration Number C99698 and whose registered office address is Malta Transfer Limited, Triq il-Kappella ta’ Santa Maria, Maghtab l/o Naxxar NXR6511, Malta is the data controller responsible for processing Your Personal Data that takes place via the Site or in the manner explained above.
Data Protection Office
Malta Transfer Limited
Triq il-Kappella ta’ Santa Maria
Maghtab l/o Naxxar NXR6511
If You have any questions/ comments about privacy or should You wish to exercise any of Your individual rights, please contact Us at: firstname.lastname@example.org.