Legal Basis of Data Processing
As a user of our websites or as our customer, we shall process your data in line with the contents of this Privacy Notice.
In accordance with the applicable law we collect, process, use and store your data for one or more of the following reasons:
- Your personal data is needed to fulfil a legal obligation;
- Your personal data is needed to fulfil our contractual obligations with you;
- Your personal data is processed in line with your consent;
- The Company has a legitimate interest to process your personal data.
If we are processing your data on the basis that you have provided us with your consent, you may withdraw your consent at any time by sending an email to email@example.com or a letter to the registered office address of the Company being ATL Business Centre, 89, Suite 3, Cannon Road, St. Venera SVR 9035, Malta.
In no circumstance will your personal data be used by the Company for promotional or marketing purposes.
Collection and Use of Data
1. The following is a list of the personal data you are required to provide us with when you make a request or claim through our contact pages, by filling in our online request form and which personal data we process:
– Your first and last names
– Your email address
– Your phone number
– The date and time when you called our services
– Bank account number (IBAN) or Paypal email address for reimbursement
The processing of data in this case is based on your consent, the fulfilment of our contractual obligations with you and in pursuance of compliance with legal obligations to which we are subject. The data provided to us will be used solely for the purpose of providing you with the requested service and for the proper administration of the services being offered.
2. When you call one of one of our SVA numbers indicated on our websites, the following personal data is processed by us:
– Your telephone number
– The phone number you are making research on or that will be contacted by the service
The calls made to the SVA numbers displayed on our websites may be recorded and the number from which your call originates is also stored by us for quality assurance and regulatory purposes. Live calls and call recordings may be used for internal and external audits and investigations, including by competent authorities. Such data may be necessary for crime prevention, detection, reporting, investigation or prosecution, to resolve any complaints which may arise, and to comply either with our legal obligations or in line with our internal policies. The processing of data in this case is based on your consent, the fulfilment of our contractual obligations with you and in pursuance of compliance with legal obligations to which we are subject. The data provided to us will be used solely for the purpose of providing you with the requested service.
3. In providing the universal directory publishing, the Company obtains personal data of the subscribers on the directory services of Free, SFR, Orange and Bouygues Telecom and SVA directory, which is listed hereunder, from the electronic communications operator to which the individual is subscribed to:
- name and surname of the subscriber;
- address of the subscriber;
- phone number(s) of the correspondent individual;
- occupation of the correspondent
The processing of the above data which is obtained from third parties is undertaken by the Company on the basis that the said third party has obtained the necessary consent to provide us with the personal data of the subscribers and to share the same with our customers. The processing done by the Company is strictly limited to the said purpose.
4. The following list is the personal data which you are requested to provide us with when you give feedback and leave comments on our websites, and which personal data is processed by us:
– Email address
– IP Address
The processing of data in this case is based on your consent. The purpose of collecting this data is in pursuance of processing your request and comments.
5. Other data is processed and retained by us to understand our customers’ preferences and quality of our services and to provide the proper administration and better usage of our websites. Our websites uses the technology of ‘cookies’ which provides for your IP Address, the IP Address of the site which might have referred you to us, whether the viewing was successful, download or purchases made, date and time of access to our websites, the operating system you are using, the version and make of the browser and additional metrics which may be available. You can opt-out of this technology by changing your web browser preferences. The data provided by our customers or website users will only be used in accordance with the purposes for which such data was given to us. Data of customers and users of our websites may also be used for internal purposes such as auditing, internal management, research and development and administrative purposes. Data may also be used to protect our legitimate interests and the proper and good conduct of our business. We will also share your data if requested by local or foreign public authorities in accordance with a legal obligation for the exercise of their official mission, such as tax and customs authorities, financial investigation units, independent administrative authorities, or financial market authorities. Data will also be shared in compliance with litigious processes in any tribunal, court of law or investigative or judicial body or composition.
Sharing of Data
Data of our customers
Your personal data is shared with the following recipients:
- Governmental or quasi-governmental authorities, entities, bodies, institutions, boards or other official compositions and any other competent authority, courts of law, tribunals, administrative bodies or arbitral boards, in any Member State of the European Union;
- Lawyers, accountants, auditors and other professional advisors of the Company;
- The Company’s representatives, employees, agents, suppliers, contractors and sub-contractors, and business partners as required strictly to carry out the purposes of this privacy notice;
- any other third party related to the re-organisation of the Company or part thereof, in furtherance of change in the controlling interest or composition of the Company, including any mergers, acquisitions or disposals.
Data on the universal directory
The personal data of the subscribers on the directory services of Free, SFR, Orange and Bouygues Telecom and SVA directory, which is provided and published on our universal directory, is shared with our customers in pursuance of the provision of our services and the contractual relationship with our customers. The sharing of such information is based on the consent granted by the said subscribers to their operator who in turn share the data of their subscribers with us. Our processing of such information is based on the instructions of the operator and to such end we are not the controllers of this data.
Transfer of Data to Third Countries
The Company may transfer the personal data of its website users or customers to any party which is located in a third country outside of the European Union which does not have data protection safeguards in place which are equivalent to those applicable in the EU. You recognise the possible risks which may be posed by such transfers in the absence of an adequacy decision under the Regulation and appropriate safeguards. Where feasible, the Company will ensure that the information transferred is subject to appropriate safeguards.
Retention of Data
Personal data of our users and customers is kept for as long as is needed in fulfilment of the purposes for which it was collected. Depending on the type of data and the legal basis for which such data is processed, the data shall be retained accordingly.
The Company endeavours to secure the confidentiality of personal data of its users and customers which it retains. In this regard, the Company has the necessary technical procedures in place to ensure that the personal data of its customers and website users are protected from unauthorised access or changes, improper use or disclosure, unlawful destruction or accidental losses or damages.
As our customer or user of our websites, in relation to whom we process personal data, you have the following rights:
1. The right to obtain from the Company confirmation as to whether or not personal data concerning you is being processed, and where that is the case, access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the right to request, from the Company rectification or erasure of processing of personal data concerning you or the object of such processing;
- the right to lodge a complaint with a supervisory authority;
- if the personal data is not collected from yourself, information on the source providing such data;
- if personal data is to be transferred to a third country or to an international organisation, you shall have the right to be informed of the appropriate safeguards related to the transfer;
- You are entitled to request the Company to provide you with a copy of the data undergoing processing, for any further copies provided, the Company may charge a reasonable fee based on administrative costs. Where the information is requested in electronic means, the information will be provided in electronic format.
2. You have the right to obtain from the Company without undue delay the rectification of inaccurate personal data concerning you. You shall also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
3. You have the right to obtain from the Company the erasure of your personal data without undue delay, being within a period of thirty (30) days, where the following grounds apply:
- the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
- if the processing is based in your consent, where you withdraw your consent and there is no further legal ground on which to process data;
- where the personal data has been unlawfully processed;
- where the personal data has been erased for compliance with a legal obligation in Union or Malta. Provided that the above, shall not be applicable to the extent that the processing is necessary for the Company’s compliance with a legal obligation.
4. You have the right to obtain from the Company restriction of processing where one of the following applies:
- if the accuracy of the personal data is contested by yourself, for a period enabling the Company to verify the accuracy of the personal data;
- if the processing is unlawful and you oppose to the erasure of the personal data and request the restriction of their use instead;
- if the Company no longer needs the personal data for the purposes of the processing, but it is required by yourself for the establishment, exercise or defence of legal claims.
5. The Company shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with the paragraphs mentioned above, to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate efforts. Additionally, the Company will inform you about those recipients if you request it.
6. Where processing is based on the performance of a contract, and where the processing is carried out by automated means, you shall also have the right to data portability namely, the right to receive personal data concerning you, which you have provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance.
7. the Company will inform you in case any of your rights are breached.