Alfred Hili & Co Limited, C3610, of 17, Guze Galea Street, Qormi, QRM 2106, Malta (Phone No.: Email:email@example.com), (‘the Company’, ‘We’, ‘Us’, ‘Our’), has obtained Your personal data in the process of doing business with the entity whom you represent, ‘the Entity’, and will process the personal data as necessary in particular, the Company may communicate with You and send the relevant notifications to You on behalf of the Entity as designated contact person in the agreement between the Company and the Entity.
- What personal data does the Company collect, purpose and legal basis?
We will process the following personal data as provided by the Entity (a) Your Name and surname, (b) Your Email, (c) Your Telephone No., (d) Your Mobile No.; (e) CCTV footage. This personal data is processed in order to perform our contract and provide the services to the Entity. Furthermore, when visiting the Company’s premises, you are advised that said premises are monitored by CCTV and access control systems for security purposes and that recordings from such systems may be used as evidence in case of any investigation. This is carried out in order to protect your vital interests as well as in furtherance of our legitimate interest to protect our premises.
- Third Parties Receiving Data
The Company may share your personal data with any parent, subsidiary, sister or related company (‘Group Company’) as necessary in its legitimate interests to provide information to other members of the group including for the purpose of the preparation and submission of consolidated accounts. The Company will also share details of the agreement between the Entity and the Company (which may include your personal details) in order to discuss, negotiate and place an order on behalf of the Entity. In particular cases the Company may need to share details of the agreement between the Company and the Entity (which may include your personal data) with its legal and/or tax advisors or with the legal and/or tax advisors of a Group Company. The sharing of personal data with third parties (other than mandatory sharing of personal data with competent/regulatory authorities) shall be governed by agreement between the Company and said third party containing the relevant provisions concerning privacy.
- Location of Data & Transfers to Third Countries
Any personal data processed by the Company is stored on servers situated in Malta. When sharing your personal data with a Group Company or with principals or agents said companies may be based or have branches in countries not recognised as granting equivalent protection. You are advised that the processing of your personal data in such countries may give rise to additional risk of a personal data breach. The Company shares your personal data subject to the necessary safeguards being in place, namely, that any such transfer is subject to an agreement with the recipient based on the Standard Data Protection Clauses approved by the European Commission. The Company will ensure that the exercise of your rights in terms of the Privacy Statement and at law shall not be effected.
- Data Retention Period
Any personal data concerning Your contact details is retained for as long as you remain the Entity’s contact person. In the event that You cease to be the Entity’s contact person while the agreement with the Entity is still in force, Your details will be archived and replaced with those of the new contact person. The agreement between the Company and the Entity will be retained throughout the duration of the agreement and for a period of five (5) years thereafter so as to enable the Company to establish or defend any legal claim. Thereafter, certain documents, such as the agreement, invoices and receipts may be kept for up to ten (10) years from termination of the Agreement (or from date of invoice/receipt) in order for the Company to comply with its book-keeping, tax and VAT record keeping obligations.
- Rights of the Data Subject
You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at [firstname.lastname@example.org] at any time. You have the following rights:
- Access to your information: You may, at any time submit a request to know what information is held in your regard, if any. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the European Economic Area (“EEA”).
- Rectification: We will use our best endeavours to update and maintain the data as accurate as possible within a reasonable time. You may, at any time, submit a request to have any inaccuracies corrected. We assume no responsibility or liability for the accuracy or correctness of any data provided if changes are not communicated to us.
- Right to be forgotten: where processing is based on consent and in other specific circumstances You may request to have any or all of your details erased. You can ask us for further information on these specific circumstances by contacting us using the details below. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details below.
- Restriction of processing: You may, at any time, submit a request to restrict the processing of your data. You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details below. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details below.
- Right to data portability – You may request to receive your personal information in a structure commonly used and machine readable format and have it transferred to another controller. This right only applies where we use your personal information on the basis of your consent or performance of a contract and where our use of your information is carried out by automated means.
- Right to object and automated individual decision-making – where processing is based on the performance of a task in the public interest or based on our legitimate interests, You may object to the processing, however, this is subject to any of our overriding interests including in particular compliance with legal requirement on our part. In such case we will aim for a result that is mutually satisfactory such as taking your personal information off the live environment and archiving it for the necessary period to enable us to comply with our legal requirements.
- Right to object to direct marketing: You may object to the processing of your personal data for the purpose of direct marketing. In the event of such an objection, We will no longer be able to provide the Entity with updates regarding our products and services. You may, provide an alternative email address to which direct marketing should be sent.
We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
You are advised that should you feel that We have breached our commitments in terms of this Privacy Statement you may file a complaint with the Company on email@example.com or directly with the Malta Information and Data Protection Commissioner.
- Transitory Provisions
This Privacy Statement is being issued on the date below stated following a review of the relevant processes in compliance with the GDPR and shall apply to the processing of Your personal data as from the date of issue.