2. For the purpose of the DPA and GDPR we, namely Arkadia Marketing Limited, a private limited liability company with registration number C11113 and having its registered office at Mizzi Organisation Corporate Office, Testaferrata Street, Ta’ Xbiex XBX 1407, Malta, are the data controller and any enquiry regarding the collection or processing of your data should be addressed to Mr. Alan Alden,who is our Data Protection Officer, and maybe contacted by email at firstname.lastname@example.org or by telephone at 356 2759 5000 ext 601.
Data we collect
4. We will collect personal data on this Website only if it is directly provided to us by you the user, e.g. your e-mail address, name, home or work address and telephone number, and therefore has been provided by you with your consent. Normally you will only provide such details if you wish to subscribe for marketing communication e-mails, customer feedback or submitting an online job application. Generally, you would have provided your personal data to us. This privacy Notice applies to Arkadia Marketing Limited’s website and also to official presence on any social media (e.g. Facebook and LinkedIn). We at Arkadia take your privacy seriously. Where we refer to the “Website”, we also refer to data collection via these these third-party platforms.
5. We also use analytical and statistical tools that monitor details of your visits to our website and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data (but this data will not identify you personally).
Use of your information
6. We may hold and process personal data that you provide to us in accordance with the DPA and GDPR.
7. The information that we collect and store relating to you is primarily used to enable us to provide our services to you, and to meet our contractual commitments to you. In addition, we may use the information for the following purposes:
(a) To notify you about any changes to our website, such as improvements or service/product changes, that may affect our service;
(b) If you are an existing customer, we may contact you with information about goods and services similar to those that were the subject of a previous sale to you;
(c) Where you have consented to receive such information, to provide information on other parties’ products or services that we feel may be of interest to you;
(d) Where you have consented to receive our marketing communications, from time to time to provide that to you.
Legal bases for processing your data
8. We process your personal data on the basis of your explicit consent, in which case, our processing shall be limited to the purposes specifically indicated when your consent was requested. Where our processing is based on your consent, you have the right to withdraw your consent. Withdrawal of your consent shall not affect the lawfulness of the processing based on your consent prior to the withdrawal of your consent
Disclosure of your information
9. We may disclose your information to third parties as a result of legal obligations imposed on us, such as the Police..
10. Where you have consented for us to do so, we may provide your data to selected third parties who may contact you about their goods or services that you may be interested in. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
11. If you do not to use your data for our [or third parties’] use, you will have the opportunity to withhold your consent to this when you provide your details to us on the form on which we collect your data, or you can do so by writing to us at the address detailed in clause 2, or sending us an email to email@example.com at any time.
12. Please be advised that we do not reveal information about identifiable individuals to our advertisers but we may, on occasion; provide them with aggregate statistical information about our visitors.
Controlling the use of your data
13. If you have given us consent to use your data for a particular purpose you can revoke or vary that consent at any time. If you do not want us to use your data or want to vary the consent that you have provided you can write to us at the es detailed in clause 2 or email us at firstname.lastname@example.org any time.
Storage, retention and transfer of your data
14. As part of the services offered to you, for example through our Website, the information you provide to us may be transferred to and stored as we use remote website server hosts to provide the website and some aspects of our service – this is generally the nature of data stored in “the Cloud”. It may also be processed by staff operating our servers who work for one of our suppliers, e.g. our website server host.
15. We retain your personal data exclusively for the period which is lawfully permissible to retain your personal data. Thereafter, your personal data shall be immediately and irrevocably destroyed, unless we are required to keep that data due to a statutory obligation imposed on us and/or due to accepted standards (including where processing may be necessary for the establishment, exercise or defence of legal claims).
16. We do not process sensitive personal data, such as race, religion, or political affiliations, without your explicit consent
17. We may disclose your personal data outside of our group:
(a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and
18. Otherwise, we will process, disclose or share your personal data only if required to do so by law or in the good faith belief that such action is necessary to comply with legal requirements or legal process served on us or the website.
19. You have the right to opt out of our processing your personal data for marketing purposes by contacting us at email@example.com
20. The transmission of information via the Internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data while you are transmitting it to our site; any such transmission is at your own risk. Once we have received your personal data, we will use appropriate procedures and security features to try to prevent unauthorised access.
Third party links
21. You might find links to third party websites on our website. These websites should have their own privacy policies, which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
Most browsers are initially set to accept cookies. However, if you prefer, you can set your browser to block all, or certain, cookies. Please be aware that without cookies you may not be able to use the full functionality of our site. Users can also set their browser to prompt them each time a cookie is offered. You can find a guide on how to block cookies in the main browsers below:
23. For as long as we retain your personal data, you have certain rights in relation to your personal data, including:
– Right of access – you have the right to ascertain the personal data we hold about you and to receive a copy of such personal data;
– Right to Lodge a Complaint – you have the right to lodge a complaint regarding the processing of your personal data with the supervisory authority for data protection matters. In Malta this is the Information and Data Protection Commissioner (contact details provided below);
– Right to Erasure – in certain circumstances you may request that we delete the personal data that we hold about you;
– Right to Object – you have a right to object and request that we cease the processing of your personal data where we rely on our, or a third party’s legitimate interest for processing your personal data;
– Right to Portability – data subjects may request that we provide personal data provide by the data subject in a structured, commonly used and machine-readable format. Where technically feasible, data subjects may also request that we transmit their personal data to a third party controller indicated by the data subjects; and
– Right to Restriction – data subjects have the right to request that we stop using their personal data in certain circumstances, including if they believe that we are unlawfully processing their data.
Please note that in terms of the applicable laws, your rights in relation to your personal data are not absolute. Nonetheless, you may exercise the rights indicated in this section by contacting us or our Data Protection Officer at the details indicated above. If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In Malta the supervisory authority is the Information and Data Protection Commissioner, at the following link https://idpc.org.mt/en/Pages/contact/complaints.aspx.
Please do not hesitate to contact us at The Arkadia Marketing Limited, Fortunato Mizzi Street, Victoria, Gozo, Malta or firstname.lastname@example.org
Version: September 2018