Privacy Policy
Welcome to the privacy notice for risingmalta.mt
Rising Malta respects your privacy and is committed
to protecting your personal data. This privacy notice will inform you as to how
we look after your personal data when you visit our website (regardless of
where you visit it from) and tell you about your privacy rights and how the law
protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on
how risingmalta.mt collects and processes your personal data through your use
of this website, including any data you may provide through this website when
you sign up to our newsletter, purchase a product or service or take part in a
competition or sign up as a user.
This website is not intended for children and we do
not knowingly collect data relating to children.
It is important that you read this privacy notice
together with any other privacy notice or fair processing notice we may provide
on specific occasions when we are collecting or processing personal data about
you so that you are fully aware of how and why we are using your data. This
privacy notice supplements the other notices and is not intended to override
them.
Any processing of personal information gathered by Rising
Malta as a result of your use of this website, Rising Malta social media pages
or our apps is governed by the provisions of the Maltese Data Protection Act.
2. Controller
Rising Malta Ltd is the controller and responsible
for your personal data.
We have appointed a data privacy manager 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 data privacy manager using the
details set out below.
3. Contact details
Rising Malta Ltd
Data Privacy Team
You have the right to make a complaint at any time
to the Data Protection Commissioner (DPC), the Maltese supervisory authority
for data protection issues (https://idpc.org.mt). We would, however, appreciate the chance to deal
with your concerns before you approach the DPC so please contact us in the
first instance.
4. Changes to the privacy notice and your duty to
inform us of changes
This version was last updated on 21 May 2018.
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.
We may change this privacy notice from time to
time, when we do we will we will post the changes here and on the Website.
Where the changes are significant, we will inform all our registered users by
email. Where required by law, will we obtain your consent to make these
changes.
5. 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.
6. 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 follows:
We do not collect any Special Categories of
Personal Data about you (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.
7. 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 goods or
services). In this case, we may have to cancel a product or service you have
with us but we will notify you if this is the case at the time.
8. How is your personal data collected?
We use different methods to collect data from and
about you including through:
9. 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:
10. Purposes for which we will use 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 and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(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) |
|
To manage
our relationship with you which will include: (a) Notifying you about changes to our terms or
privacy policy (b) Asking you to leave a review or take a survey |
(a)
Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a)
Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to
keep our records updated and to study how customers use our
products/services) |
|
To enable
you to partake in a prize draw, competition or complete a survey |
(a)
Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a)
Performance of a contract with you (b) Necessary for our legitimate interests (to
study how customers use our products/services, to develop them and grow our
business) |
|
To
administer and protect our business and this website (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 on our website,
third party websites and social media channels, and measure or understand the
effectiveness of the advertising we serve to you |
(a)
Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) 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 (e) Profile |
Necessary
for our legitimate interests (to develop our products/services and grow our
business) |
11. Marketing
We strive to provide you with choices regarding
certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage
and Profile Data 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 services from us or if
you provided us with your details when you entered a competition or registered
for a promotion and, in each case, you have not opted out of receiving that
marketing.
Third-party marketing
We will get your express opt-in consent before we
share your personal data with any company outside Rising Malta for marketing
purposes.
Opting out
You can ask us or third parties to stop sending you
marketing messages at any time by contacting us at any time or clicking
“unsubscribe” at the bottom of the emails.
12. Cookies
13. Cookie Policy
14. 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.
15. Disclosures of your personal data
We may have to share your personal data with the
parties set out below for the purposes set out in the table in paragraph 4
above.
16. International transfers
To deliver the Websites and our Services to you, it
is sometimes necessary for us to share your personal information outside the
European Economic Area (EEA), eg: with your and our service providers located
outside the EEA if you are based outside the EEA
These transfers are subject to special rules under
European and UK data protection law.
The following countries to which we may transfer
personal information have been assessed by the European Commission as providing
an adequate level of protection for personal information: Andorra, Argentina,
Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of
Man, Jersey, New Zealand, Switzerland, Uruguay and the USA (limited to the
Privacy Shield framework).
Except for the countries listed above, non-EEA
countries do not have the same data protection laws as the United Kingdom and
EEA. We will, however, ensure the transfer complies with data protection law
and all personal information will be secure. Our standard practice is to use
standard data protection contract clauses that have been approved by the
European Commission (as permitted under Article 46(2) of the General Data
Protection Regulation) and that are designed to help safeguard your privacy
rights and give you remedies in the unlikely event of a misuse of your personal
information. If you would like further information please contact us.
Please contact us if you want further information
on the specific mechanism used by us when transferring your personal data out
of the EEA.
17. 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.
18. 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, accounting, 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 us.
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 research or
statistical purposes in which case we may use this information indefinitely
without further notice to you.
19. Your legal rights
Under the General Data Protection Regulation you
have a number of important rights free of charge. In summary, you have the
right to access your personal data and require that we rectify any errors in
the data that we hold, or request that we erase your personal data subject to
certain limitations. In some circumstances, you can also require that we
restrict the way we process your personal data, object to its processing or
request a copy of your personal data for the purposes of transmitting
elsewhere. Where we have requested and obtained your consent to process
particular information, you may withdraw that consent at any time. However if
we do not hold all the data we need to administer contracts, orders, competitions
or challenges you entered into, we may not be able to provide you with these
benefits any longer.
For further information on each of those rights,
including the circumstances in which they apply, see the Guidance from the DPC
on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights,
please:
• email, or write to us – see below: ‘How to
contact us’; and
• let us have enough information to identify you
(eg your full name, address and customer or matter reference number);
• let us have proof of your identity and address (a
copy of your driving licence or passport and a recent utility or credit card
bill); and
• let us know what right you want to exercise and
the information to which your request relates.
If you would like to unsubscribe from any email
newsletter you can also click on the ‘unsubscribe’ button at the bottom of the
email newsletter. It may take up to 14 days for this to take place.
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. 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.
20. Glossary
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.
Performance of Contract means processing your data
where it is necessary for the performance of a contract to which you are a
party or to take steps at your request before entering into such a contract.
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
Internal Third Parties
Other companies in the LMG Group acting as joint
controllers or processors such and who are based Ireland and the UK and provide
IT and system administration services and undertake leadership reporting.
External Third Parties
Service providers acting as processors based
Ireland or the UK who provide IT and system administration services.
Professional advisers acting as processors or joint
controllers including lawyers, bankers, auditors and insurers based Ireland or
UK who provide consultancy, banking, legal, insurance and accounting 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
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.