1 What is personal information?
1.2 Personal information is any information that can be used to identify you, including but not limited to your name, birth date, address, email address and telephone number.
1.3 Other categories of Personal Information may include but are not limited to:
- Personal details:contact information (including mobile telephone numbers), passport information, visa information, gender, national identification information, disability information, information on your driving license, photographs, images• Payment information: payment card number and other card information
Details that may make you identifiable: physical, physiological, genetic, mental, economic, cultural or social identity, IP address, geolocation, identification data, online identifiers.
2 Information collected
2.2 Active information collection: We actively collect information from our customers. Examples where we actively collect your information include when you communicate directly with us via e-mail, by filling in online forms on our Website or instore.
2.4 Passive information collection: In some circumstances we may process information on the basis of (i) your related interactions with us (for example, the web page from which you navigated to the Website), or (ii) Personal Information that we have received or obtained from a third party (for example, publicly available information sources). In these circumstances, your Personal Information may be said to have been passively collected (that is, gathered without you actively providing the information).
2.5 An example of where your Personal Information may be passively collected is when you use the Website. Each time you use the Website, we will automatically collect the following information:
- details of your use of the Website including your user name, city, country, page views, searches, downloads (file names)
• technical information, including your device model, operating system of the machine running your web browser, type and version of your web browser, IP address, date and time when you accessed the Website
• web page download information
• general Website usage information
2.6 Like many retail outlets, we value your safety and security. We may therefore record or capture images of our customers in public areas of our outlets. We may also process your Personal Information by using CCTV principally for the purposes of protecting you, our customers and our staff.
3 Purposes and use of information
3.2 We may collect, process and otherwise use your Personal Information for purposes that are required by applicable law, regulation or other contracts or to allow us to fulfill our business needs and legal obligations. These purposes include:
- to administer, improve and develop the Website
• for administration and completion of bookings, reservations and registrations
• to manage our relationship with you and (if relevant), including providing information regarding our products and services
- to administer membership, rewards programmes, promotional offers and related offers
• to personalise your user experience (e.g. by tailoring the content delivered to you on our Website)
• for legal disputes, regulatory investigations and compliance purposes
• to assist us in providing the services you request at any of our properties and to ensure we meet your needs whilst availing of and benefitting from our services and/or to allow us to contact you in relation to matters in connection to such services that might arise from to time.
3.3 When Personal Information is processed for a purpose other than the purposes indicated hereabove, we shall, in order to ascertain whether processing for another purpose is compatible with the purpose for which the Personal Information is initially collected, take into account, inter alia:
- Any link between the purposes for which the Personal Information has been collected and the purposes of the intended further processing;
- The context in which the Personal Information has been collected;
- The nature of the Personal Information;
- The possible consequences of the intended further processing;
- The existence of appropriate safeguards, which may include encryption or pseudonymisation.
- We shall provide you, prior to the further processing for purposes other than the ones agreed to in Clause 3.2 above, with information on that other purpose and any other relevant information beforehand.
- We may rely on third party service providers to help deliver our goods and services to you, including when you visit our Website or any of our outlets.
- Quality of personal data
Personal data shall be accurate and where necessary kept up to date. We shall take any reasonable steps to ensure that personal data that is inaccurate is rectified without delay;
5.1 The Website creates “cookies” when you visit it.
5.2 A cookie is a small piece of data that a website can send to your browser for storage (i.e. so it can later be read back from that browser). The purpose of cookies includes providing more tailored communications from websites.
5.3 Cookies may collect information (including Personal Information), such as user preferences, general usage information, membership information and unique identifiers. Cookies may in some circumstances also remain on your device after you leave the Website.
5.4 Your browser will return the cookie information only to the domain from where the cookie originated, i.e., the Website, and no other website can request this information. When you return to the Website, the cookie is sent back to the web server, along with your new request.
5.5 Your browser may provide settings where you can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or reject the cookie altogether.
6 Disclosure of information
6.2 We may disclose your Personal Information:
(a) to the affiliates of Camilleri group of companies including but not limited to related parties, holding companies and subsidiaries, managers, directors, employees, other members of the staff, external advisors, lawyers, accountants, consultants who are duly bound by confidentiality rules.
(b) where we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request.
7.1 We will take appropriate measures to keep your information confidential and secure in accordance with our internal procedures covering the storage, access and disclosure of information.
7.2 Please note that messages you send to us by e-mail or via any internet connection may not be secure. If you choose to send any confidential information or Personal Information to us by such means you do so at your own risk with the knowledge that a third party may intercept this information. We are not responsible for the security or integrity of such information. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8 Retention of Information
We intend to keep your Personal Information accurate and when necessary up-to-date. We will retain your data for no longer than required. From time to time we may delete or anonymise your personal information if you have not availed of our services
8 Your rights
8.1 If any of the Personal Information that you have provided to us changes, please contact us at firstname.lastname@example.org and let us know the correct details.
8.2 Under applicable law, you have the right to:
- request a copy of the personal information about you that we hold
• request correction or deletion of Personal Information about you that is inaccurate
• withdraw any applicable consent for processing and transfer
• object to our using your personal information for marketing purposes
• object to profiling and automated decision making
In some circumstances, you may also have a “data portability” right to require us to transfer your personal data to you or to a new service provider.
8.3 We will ask your consent if we intend to use your data for marketing purposes or if we intend to disclose your information to any third party for marketing purposes.
8.4 To exercise any of these rights at any time, please contact us at email@example.com
9 Right to erasure of Personal Information
9.1 You have the right to be forgotten and your Personal Information be erased when:
- Personal Information is no longer necessary in relation to the purpose;
- you decide to withdraw your consent and
there is no other legal ground for processing;
- Personal Information has been unlawfully processed;
- Personal Information has to be erased for compliance with a legal obligation.
9.1 We will not be able to erase your Personal Information if processing of such Personal Information is necessary:
- For exercising the right of freedom of expression and information
- For compliance with legal obligations or for the performance of a task carried out in the public interest;
- For archiving purposes in the area of public, scientific or historical research purposes or statistical purposes in so far as the objectives of processing are rendered impossible or seriously impaired.
10 Withdrawal of consent
You can withdraw your consent at any time by sending an email to firstname.lastname@example.org or by simply unsubscribing from our website. Your data will be deleted with undue delay and you will not be contacted any longer.
You can also raise complaints or concerns about our use or other processing of your Personal Information with the body regulating data protection in your country. In Malta, this is the Information and Data Protection Commissioner (details are available at https://idpc.org.mt/en/Pages/contact/complaints.aspx.).
13 Contact us
Last updated: 20.05.2018