Date: 25th May 2018
Afilexion Alliance appreciates your visit to www.afilexion.com (the “Website”) and is committed to ensuring that your privacy is protected.
The data controller of this Website is Afilexion Alliance Company Limited, a limited liability company established under the Laws of Malta, having its registered address at 66, Old Bakery Street, Valletta, Malta (“AFILEXION”/ “we” / “us” / “our”).
AFILEXION recognises its obligations as data controller and is committed to comply with all applicable laws, including the Data Protection Act (Cap 586 of the Laws of Malta) and the General Data Protection Regulation (2016/679).
The terms “you” and “your” means you, the visitor of this Website.
1. What is personal data?
“Personal data” refers to all information which can render you personally identifiable, such as your name, surname and address and includes all information and documentation that can arise or be produced which can identify you personally.
2. How do we collect and process your personal data?
Please do note that the Website does not collect any data which can render you personally identifiable. The Website does however contain AFILEXION’s email, telephone number and address, together with the email of our team, and should you choose to contact us (or our team), please do note any personal data contained within your message shall be used to respond to your message or to otherwise act upon your request.
Kindly note that the Website processes certain technical data which however does not render you personally identifiable. The Website processes such data through cookies, namely small text files containing information which are sent to and stored on your computer, smartphone, tablet or other device (hereinafter “Device”) when you access a website. Cookies communicate with the originating website on each subsequent visit or with another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device as well as remembering your actions and preferences, thus helping you to browse a website more efficiently and helping improve your experience while using a website. Our Website exclusively makes use of the so called “session-cookies”, namely cookies which are deleted automatically from your Device when you close the relevant session. We do not make use of any other cookies.
4. Third Party Websites
Please do note that our Website may contain links to third party websites for your perusal. Should you access such third party websites, please note that you will be subject to the third party privacy policies and practices of such third parties, and we accept no liability in such regard.
5. What personal data do we process?
Kindly do note that any personal data you include in any message which you may choose to send to us or any member of our team shall be processed by us, exclusively to act upon your request and respond to your message.
6. Legal Basis for Processing
Our legal basis for processing your personal data shall be exclusively your explicit consent when contacting us and we shall limit our processing exclusively to the purposes specifically indicated by you. The provision of your personal data is not a statutory or contractual requirement. You are not obliged to provide us any personal data and it is your choice whether to provide us with your personal data.
7. Recipients of your Personal Data
We do not sell or transfer your personal data to third parties. Your personal data will only be shared with our employees who require access to such personal data on a strict need to know basis. Furthermore, note that our IT suppliers may also process your personal data for technical purposes. All processing will happen in Malta or in the EU.
8. Automated Decision Making and Profiling
Your personal data will not be processed for the purposes of any decisions taken solely on the basis of profiling methods or algorithmic/automated decision-making without human intervention.
Your personal data shall be retained exclusively for the period in which it is necessary to fulfil the purpose of collection, or till you withdraw your consent, whichever is the earlier. We will thereafter immediately and irrevocably destroy your personal data.
10. Your Rights
You enjoy various rights in relation to your personal data.
i. Right of Access – the right to ascertain whether we hold personal data about you and to receive a copy of such personal data;
ii. Right to Complain – if you have any complaints regarding our processing of your personal data note that you may contact us at the contact details provided below. You also have a right to lodge a complaint with the Information and Data Protection Commissioner in Malta. The Information and Data Protection Commissioner may be contacted at www.idpc.gov.mt;
iii. Right to Erasure – you have a right to request that we delete your data in certain circumstances;
iv. Right to Object – you have a right to object to our processing of your personal data and request that we stop such processing where we rely on our or a third party’s legitimate interest/s;
v. Right to Data Portability– you have a right to request that we port certain personal data in a structured, commonly used and machine-readable format. If technically feasible, you may also request that such data is transmitted by us directly to a third-party controller of your choice;
vi. Right to Rectification – you have the right to update, correct and rectify any inaccurate personal data we process about you;
vii. Right to Restriction – you have a right to request that we restrict your personal data in certain circumstances; and
viii. Right to Withdraw Consent– as we process data on the basis of your consent, you have a right to withdraw consent by contacting us at our contact details below. Withdrawal of your consent does not affect the legality of any processing prior to your withdrawal.
Note that if we process personal data which have not been provided to us directly by you, you may also have a right to be informed of the source from which your personal data originates.
11. Data Security
We take the protection of your personal data very seriously and are committed to take the appropriate technical and organisation measures to protect your data against unauthorised or unlawful processing. We might store your data in physical paper files as well as electronically on our technology systems.
12. Contact Details
Please do not hesitate to contact us regarding our processing practices at the contact details below:
· Address: 66, Old Bakery Street, Valletta, Malta
· Telephone: (+356) 2142713
· Email: firstname.lastname@example.org
Our Data Protection Officer may also be contacted by email at email@example.com.