This Privacy Notice complies with Data Protection Legislation. It serves as a notice for those visiting and using the website http://thehubmalta.com/. It notifies the users about the personal data that the company holds relating to their experience in the website, for what purpose it is processed and for how long it is expected to be used.
INTRODUCTION
Welcome to the privacy notice of The Hub’s website.
We respect the privacy of all of this website’s users and are committed to protecting their personal data. This privacy notice will inform the website’s users as to how we look after their personal data when they visit our website (irrespective of where they visit it from) and also informs them about their privacy rights and how the law protects them.
Those reading this privacy notice should make sure that they refer to the Glossary at the end of this privacy notice to understand the meaning of some of the terms used here.
This notice will give the information listed hereunder. Returning users may wish to scroll down to the section which is most of interest rather than reading through all the policy thus the following lists highlights the main sections of this privacy notice.
1.IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how we collect and processes your personal data through your use of this website, including any data you may provide through this website when you request a quote or send us a message through the form in the website.
We do not provide services or products for children on this website and thus we do not knowingly collect data relating to children.
It is important that you read this privacy notice before you send us any personal data through the website.
CONTROLLER
This website is owned by GX4 Projects Ltd(referred to as the “Company”, “we”, “us” or “our” in this privacy notice)which is the controller and responsible for your personal data.
We have appointed a Data Protection Lead (DPL) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPL using the details set out below.
CONTACT DETAILS
Our full details are:
Full name of legal entity: GX4 Projects Ltd
Name or title of DPL: Andrea MAgro
Email address:andrea@thehubmalta.com
Postal address:Suite 003, The Hub Workspace, Triq Sant Andrija, San Gwann SGN 1612
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This privacy notice was set out on 25th May 2018. We reserve the right to make any changes to this privacy notice. If this happens when we are holding your personal data we will inform you accordingly with all the changes that wold have taken place.
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.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name and last name.
• Contact Data includes email address and telephone numbers.
We do not collect any Special Categories of Personal Data about you through this website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences through this website.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data and you fail to provide that data when, we may not be able to perform what is being requested from us (for example, to provide you with a quote). In this case, we may have to cancel your request but we will notify you, if we have the Contact Data to, if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use Direct interactions only to collect personal data about you. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or mail. This includes personal data you provide when you:
• Request a quote;
• Call us;
• Email us; or
• Send us a message through the Send us a Message form.
4. HOW WE USE YOUR PERSONAL DATA
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 reply to any request or message you have sent us.
• 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.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We will use your Identification Data and Contact Data to reply to any request for a quote you might send us. We will also use the same Data to answer to any message you have sent us or to call you back if necessary.
MARKETING
We do not send any marketing material, either by electronic or postal mail. Should this change we will inform you accordingly and seek your consent to send you such material.
COOKIES
Our website does not make use of cookies.
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 us.
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. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out above.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the Data Protection Legislation. 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
We do not transfer your personal data outside the European Economic Area (EEA).
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.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for 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 Legislationin relation to your personal data. You have the right to:
• be informed
• request access
• request rectification
• request erasure
• restrict processing
• data portability
• object to processing
• withdraw consent
Should you wish to exercise any of the rights above please contact our DPL. For in-depth information about each right please see the Glossary below.
You also have the right to complain to a Supervisory Authority. You have the right to complain to the Information and Data Protection Commissioner (IDPC) if you feel that we have not responded to your requests to solve a problem. The supervisory authority in Malta is the Office of the Information and Data Protection Commissioner which is at Floor 2, Airways House, Triqil-Kbira, Tas-Sliema and can be reached on 2328 7100.
We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us on any of the above contact details in the first instance.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
10. GLOSSARY
Data Protection Legislation means (i) unless and until the General Data Protection Regulation is no longer directly applicable in Malta, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in Malta and then (ii) any successor legislation to the GDPR or the Data Protection Act (Ch. 440 of the Laws of Malta).
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
EXTERNAL THIRD PARTIES
• Service providers acting as processors based in Germany who provide web hosting.
• Service providers in the US and/or Europe who may have their own processing requirements to provide security services.
• Professional advisers based in Malta who provide professional services.
YOUR LEGAL RIGHTS
You have the 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 Data Protection Legislation. 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.
