Our Site is designed in such a manner that it makes it possible for users to visit and use our Website without disclosing or revealing any personal information about themselves. However, you may choose to provide us with personal information when you contact us via the ‘Contact Us’ page on our Website. Should this occur, we oblige ourselves to process any such personal data that you may provide in full accordance with all applicable data privacy laws, and in such a manner that is necessary for us to be able to respond and administer any request that you may make.
From time to time, we may further process your personal data to provide you with information about developments taking place in our business industries, and which we feel may be of interest to you. However, this will be subject to you giving us prior consent for such personal data processing. Please inform us by sending an email to firstname.lastname@example.org if you do not wish to receive such information from us.
Furthermore, we are entitled to request from you, at any point in time, information and/or other documentation that we, in our sole discretion, deem fit and necessary in order to comply with any applicable law or regulation in connection with the holding and using of Grow tokens (GROW).
b. Providing personal data to third parties
We do not pass on your personal data, collected from you as a visitor to our Website, to any third party unless you provide us with your consent to do so. Such disclosure to third parties would be required to provide to you our services, such as running campaigns and competitions which may be conducted with the assistance of third parties. Your refusal to provide such third parties with your personal information may disqualify you from participating in the campaigns or competition concerned. Furthermore, your personal information will be shared with third parties, without the need of obtaining your consent, in the instances indicated below.
You will be aware however that personal data sent via the internet may be transmitted across international borders, even where the sender and the receiver of such information are located in the same country. Consequently, data relating to you may be transmitted via a country having a lower level of data protection than that existing in your country of residence.
- For the purpose of preventing, detecting or suppressing fraud or any other criminal activity;
- Where it is a matter of national or public security;
- In the interest of national budgetary, monetary or taxation matters that can arise;
- To protect and defend our rights and property or that of users of our Website;
- To protect against abuse, misuse or unauthorized use of our Website;
- To protect the personal safety or property of users of our Website (e.g. if you provide false or deceptive information about yourself or attempt to pose as someone else, we shall disclose any information we may have about you in our possession so as to assist any type of investigation into your actions);
- For any purpose that may be necessary for the performance of any agreement you may have entered into with us; or
- As may be allowed or required by or under any law
c. Retention of personal data
No personal data that we process will be kept longer than necessary for the purposes for which it is collected. In particular, we shall retain your personal information for the longer of the following periods: (i) the end of the relevant campaign, competition, survey or other activity being the purpose for which you have provided your personal data; (ii) any retention period that is required by law (including but not limited to any prevention of money laundering and funding of terrorism legislation that may be applicable); or (iii) the end of the period in which litigation or investigations might arise in respect of your use of our services.
- Administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
- Physical security measures, such as staff security passes to access our premises;
- Technological security measures, including firewalls, encryption and anti-virus software.
- Where data is processed by a third-party as outlined in this Privacy Notice, we ensure that such third parties provide sufficient guarantees to implement appropriate technical and organizational measures in such a manner that any processing by them satisfies the legal requirements in terms of applicable data protection laws, including the protection of your rights. Moreover, we also ensure that processing by third parties is governed by an agreement between us and third party which includes the necessary contractual clauses to ensure protection of your personal data.
Although we use appropriate security measures once we have received your personal data, we remind you that by its very nature the internet may not always be a secure medium and data sent via the internet can potentially be subject to unauthorised acts by third parties. We cannot guarantee the privacy or confidentiality of any information passing over our Website, nor shall we accept any responsibility or liability whatsoever for the security of your personal data while in transit through the internet.
e. Third party websites
No third party is permitted to link any other website to our website without obtaining our prior consent in writing.
g. What are your rights?
Provided you fall within the legal definition of a ‘data subject’ in terms of Chapter 586 of the Laws of Malta and EU Regulation 2016/679, you have the following rights in relation to your personal data:
- Obtain confirmation that we are processing your personal data and request access to such personal data we hold about you;
- Ask that we update the personal data we hold about you or correct such personal data that you think is incorrect or incomplete;
- Ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data;
- Withdraw consent to our processing of your personal data (to the extent such processing is based on consent);
- Receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format;
- Object to our processing of your personal data.
Any request to exercise any of your above rights must be made in writing to us at the following mailing address email@example.com and must be signed by yourself as the data subject to whom the particular personal data relates to.
We shall provide you with access to your personal data, including a copy thereof, at no charge. However, if your requests in exercising your above rights be manifestly unfounded or excessive, in particular repetitive in nature, we reserve the right to charge you an administrative charge (determined at our sole discretion) of which you shall be informed beforehand.
h. Right to enter a complaint
You are reminded that the law grants you a right to lodge a complaint with your local or national data protection authority, provided you are based in an EEA territory. In Malta, this is the Office of the Information and Data Protection Commission, which may be accessed by clicking this link (http://www.idpc.org.mt/).
Latest Update: 26th March 2021