The aim of this Policy is:
- For you to understand what is personal data, what personal data we collect about you, the reasons for collection and the use and disclosure of such personal data;
- Explain your rights in relation to the personal data we collect and process about you and how we handle the privacy of your data.
The Controller of the Personal Data is C+M Marketing Limited (registration number C11803) and with registered address at 3, Ferdinand Inglott Street, Attard Malta.
What is Personal Data?
Personal data refers to any information relating to an identified or identifiable natural person, whom the latter can be identified, directly or indirectly, in particular by reference to an identifier. This personal information may be processed - such processing refers to any operation which is performed on personal data such as collection, recording, organisation, structuring and storage.
The rights afforded to yourself in connection to your personal data are the following:
- Right of Access – the right to obtain for us confirmation as whether or not personal data concerning you is being processed, and where that is the case, access to the personal data and the additional information as outlined in the regulations.
- Right to Rectification – the right to request for your personal data to be amended or updated where it is inaccurate or incomplete;
- Right to Erasure (“Right to be Forgotten”) – the right to request that we delete your personal data, subject to legal, compliance and regulatory obligations which we may be subject;
- Right to Restrict – the right to request that we stop processing all or some of your personal data;
- Right to Object – the right to object at any time, to object to us processing your personal data on grounds relating to your particular situation and the right to object to your personal data being processed for direct marketing purposes;
- Right to Data Portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
- Right not to be subject to Automated Decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
How does C+M Marketing Limited collect your Personal Data?
Your personal data may be collected or accessed in a number of ways including:
- Directly from yourself (whether directly or verbally) by filling up forms
- Generated by us in correspondence for example, through emails or phone calls
Legal Basis for Processing Personal Information
We have the following lawful basis to process your personal information:
- 1. To Provide You with Our Services: the legal basis for processing your personal information is the execution of the Services, to communicate with you if required in relation to our Services, and to provide you with information on offers and promotions related to our Services.
- 2. Consent: In certain instances, we may ask for your consent or specific matters. When your consent is required for the collection, processing and disclosure of personal information, we will ensure that such consent is freely given. We may also ask you for your consent for us to periodically send you marketing material which we think may be suitable for you, such as promotions and offers. Such marketing communications will only be sent to you if you have consented thereto through an ‘Opt-in’. Where you opted in to receive marketing communications, you may change your preferences by sending us an email on email@example.com
- 3. Legitimate Interests: We may process your personal information on the basis of our legitimate interests including, to provide you with our Service, to provide you with promotions and offers, to communicate with you, to improve our Services and improve our content and for administration purpose.
- 4. We may process your personal data, if required by law. This may include responding to requests by government or other law enforcement authorities.
Personal Data collected:
The company may collect the following information:
- Name & Surname
- Residential Address
- Date of Birth
- Email address
- Mobile Number
- Photographs or videos
- Any information provided by yourself in correspondence when you contact us
- Details of resources you access, and of your visits to our website
- Data sent by your web browser eg. IP address, information about your browser and your operating system
When you send us a CV, we may collect the following additional information:
- Resumes and/or applications
- Letters of offers and letters of acceptance
- Details relating to personal health & employment history;
Disclosure of Personal Data
C+M Marketing Limited discloses and gives access to your personal data to its employees and officers who are assigned to carry out their functions. All reasonable steps will take to ensure that our employees and officers are aware of the importance of data protection and the security of your personal data. Your personal data may also be disclosed to third party service providers, for example contracted IT consultants and mailing list services, which may require such information in order to be able to assist us in handling the relationship which we have with you. When we share your personal information with such third parties, we will make sure that such parties make use of this data in a manner which ensures safety and security to your personal data. We will not sell or rent your personal information to third parties for marketing purposes without your consent.
We may disclose your Personal Data if we are required to comply with any applicable law, a summons, a warrant, a court or regulatory order, or other statutory requirement.
International Transfer of Personal Data
Where we allow contractors or third parties to process your personal information outside the European Economic Area, we will make sure that there are the proper safeguards in place so as to safeguard your personal information. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries.
Retention Period of Personal Data
Your personal data shall be retained for only as long as necessary to provide you with our Services and for any legitimate and essential business purpose, such as maintaining the performance of our Service and complying with legal obligations and resolving disputes.
Securing Your Personal Data
We will use appropriate administrative, technical and physical measures to safeguard your personal data against loss, misuse, theft, modificiation, disclosure or destruction. We will restrict access to your Personal Data under our control to our employees and agents of our Company who possess legitimate business needs for such access.
Changes to this Policy
Please note that this policy may change from time to time. All updates will be published on the Website and, if the changes are significant, the changes will be posted on the Website and on this page thirty days prior to taking effect. Each version of this policy will be identifiable at the top of this document by its effective date and version number. We encourage you to refer to this policy periodically.
Complaints and Concerns
If you have any concerns with regards to our privacy methods and processes, you have the right to contact us in the following manners:
- by email to firstname.lastname@example.org or
- by post to C+M Marketing Limited at 3, Ferdinand Inglott Street, Attard Malta.
In case you are not satisfied with our response, you may contact the Information and Data Protection Commissioner of Level 2, Airways house, High Street Sliema SLM 1549 on their website at https://idpc.org.mt.