1. IMPORTANT INFORMATION AND WHO WE ARE
Our full details are:
Full name of legal entity: Arkadia Marketing Limited
Company registration number: C11113
Email address: email@example.com
Postal address: Arkadia Commercial Centre, Fortunato Mizzi Street, Victoria, Gozo
2. THE DATA WE MAY COLLECT ABOUT YOU
We may collect personal data from you because of a legal reason or because you have consented us to do so for a specific purpose. We collect your personal data including but not limited to when you create an account on our website, purchase our products, sign-up to our newsletter, send us an email and when you visit our premises.
Depending on your relationship with us, we collect, use, store and transfer different categories of personal data about you, which we have grouped together as follows:
- Identity Data includes name, username or similar identifier.
- Contact Data includes postal address, email address and telephone number(s).
- Financial Data includes payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- CCTV Data which includes recordings which are used for public safety interests and the prevention and detection of crime. Recordings also provide enforcement agencies with evidence of criminal activity, for formal actions including prosecutions in court and identification of offenders in investigations. These recordings contain images of the public going about their daily business as well as offenders, persons wanted and missing.
- CV Data includes identification data, contact data, your qualification and experience and any data you provide voluntarily in your CV when applying for a job with us.
We do not collect any Special Categories of Personal Data about you. Nor do we collect any information about criminal convictions and offences.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We collect your personal data through different methods, including:
- Direct interactions. you may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
- create an account on our website
- purchase products through our website
- subscribe to our newsletter
- send us your CV should you be interested in joining our team
- provide us with any feedback
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- Publicly available sources. We may receive personal data about you from various public sources such as social media.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with information related to your query).
4. HOW WE USE YOUR PERSONAL INFORMATION
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email, text message or by post. You have the right to withdraw consent to marketing at any time by either unsubscribing from our mailing list or by contacting our DPO.
PURPOSE FOR PROCESSING YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity (b) Contact||Performance of a contract with you|
|To process purchases: Manage payments, fees and chargesCollect and recover money owed to usProcess delivery||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|Subscribing to our newsletter||(a) Contact (b) Marketing & Communications||Consent|
|Job applicant||Personal data included in a CV such as Identity data, Contact data, qualification, skills, experience and employment history; Information about your entitlement to work in Malta (where applicable). Any other information, voluntarily disclosed by you, for which the Company needs to make reasonable adjustments during the recruitment process.||All of the information you provide during the process will only be used for the purpose of assessing your suitability for the role you have applied for; progressing your application with a view to offering you an employment contract with us; and to fulfil our legal or regulatory requirements where necessary. Processing is necessary in order to take steps at the request of the data subject prior to entering into a contractual agreement.|
|To administer and protect our business and this portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage||Necessary for our legitimate interests (to develop our products/services and grow our business)|
We may use your Identity Data, Contact Data, Transaction and Marketing and Communication Data details to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you never informed us that you wish to stop receiving such information. You have the right to withdraw consent to marketing or ask us to stop sending you marketing at any time by either unsubscribing from our mailing list or by contacting our DPO.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our DPO.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. SHARING OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Professional advisers including lawyers, bankers, auditors and insurers based in Malta who provide consultancy, banking, legal, insurance and accounting services.
- Any service providers that may have access to your personal data in rendering us with their support services, for example, IT service providers, payment service providers, marketing service providers etc.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Generally, we do not transfer your personal data outside the European Economic Area (EEA) except in the case of our website users and the personal data collected through the website. The website hosting service is provided by a third-party service provider company which is based in the United States of America hence, the personal data is transferred outside EEA. In such case the data is procesed in accordance with the requirements of the data protection legislation, which may include having appropriate contractual undertakings in legal agreements with the service provider who processes the personal data on our behalf.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our Retention
Policy which you can request from us by contacting our DPO.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
RIGHT TO COMPLAINT
You have the right to make a complaint at any time to the Information and Data Protection Commissioner Office (IDPC), the Maltese supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance. The IDPC’s contact details are as follows,
Address: Level 2, Airways House, High Street, Sliema
Landline: 2328 7100
This version was last updated on 11th December 2020 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.