Privacy & Cookies Policy

This Privacy Notice complies with the EU General Data Protection Legislation. It serves a notice for those visiting and using the website http://www.tadirjanu.com. It notifies the users about personal data that the company holds relating to their experiences in the website for what purposes it is processed and for how long it is expected to be used.

Introduction

Agius Services Limited, hereinafter the ”Company”, “we”, “us” or “our”, respects the privacy of all those visiting its website and is dedicated to protect the personal data it processes. This privacy notice has the aim to inform you how the Company will look after any personal data collected during an individual’s experience on its website. It also highlights the user’s privacy rights and how the law protects each user.

Please refer to the Glossary, at the end of this notice, to understand the meaning of some of the terms used throughout the privacy notice.

This privacy notice was last updated on 23.04.2020 . Historic versions of the privacy notice can be obtained by contacting us on the contact details listed below.

1. Purpose of this privacy notice

This privacy notice aims to give you information on how the Company collects and processes your personal data through your use of this website, including any data you may provide through this same website when you browse through the website and when contacting us through the different methods available from the website, such as the contact form, sending us an email, create an account or applying for a vacancy.

This website is not intended for children and thus we do not knowingly collect data relating to those under the age of 16.

2. About us

Controller

The Company is the controller and responsible for your personal data.

We have appointed a Data Protection Lead (DPL) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPL using the details set out below.

Contact details

Our full details are:

You have the right to make a complaint at any time to any supervisory authority. The supervisory authority in Malta is the Office of the Information and Data Protection Commissioner.

We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us on any of the above contact details in the first instance.

3. Accurate data

It is in your interest and also important that the personal data we hold about you is accurate and current. We thus ask you to keep us informed if your personal data changes during your relationship with us.

4. Third party links

This website includes link to third-party websites such as facebook. Clicking on any of the third-party links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit when you leave this website.

5. The data we collect about you.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymous data (data where the identity has been removed).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name and last name.
• Contact Data includes postal address, email address and telephone numbers.

6. The data we collect about you.

We only use direct interaction to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by corresponding with us by post, phone, email, through the forms available on our website or otherwise. This includes personal data you provide when you are

• applying for a job vacancy with us;
• sending us an email;
• give us some feedback or
• creating an account with us

The information we collect by direct interaction mostly includes:

• name and surname
• contact details: e-mail address / Home address / telephone or mobile number
• date of birth
• city/town of residence
• payment information in case of online shopping
• if applying for a vacancy other information will be requested (please see vacancy section)
• your feedback and replies to surveys and competitions
• purchase history and saved items

7. How the company uses your personal data.

We will use the personal information we collect about you to:

• Where we need to interact with you in reply to your communication.
• To start and conduct a recruitment process. Please note that in this case, following the receipt of your application we will send you our Candidates’ Privacy Notice.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Purpose for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

The personal data we collect through this website is given to us only if you choose to provide us with such information. You may choose not to provide us with this data however you may not be able to use the services offered through our website.

Cookies

A cookie is a small piece of data that is stored on your browser machine or device. Cookies are being used to recognize a user’s device on a website and store some information about your user identity on the website. The cookies are needed for carrying out the transmission of a communication over the network. Other cookies are being used to help you remembering your past actions when using our services over the internet. Although most web browsers automatically accept cookies, one can decline or alert cookies from the browser settings. However, we cannot guarantee fully functional service from our website if you disable cookies.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
• Employees that are involved in the process of delivering your purchase order such as payment service providers and pickers.
• Credit reference agencies, law enforcement and fraud prevention agencies

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. International transfers

The Company does not transfer your personal data outside the European Economic Area (EEA).

10. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

12. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights have been listed below. Further information about each right may be found in the Glossary at the end of this privacy notice.

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

14. Children under the age of 18

If you are 18 years of age or under please refrain from providing us with your personal information unless your parents/guardians’ have consented. In this case we will need to process your parents/guardians’ personal data and we may also need to request for verification documentation that consent was given.

15. Marketing messages

If you have opted to received marketing messages we will send you marketing messages by email or sms (in the manner you have opted) . You may at any time stop us from sending you marketing by sending us an e-mail on [email protected] While we may take some time to update the system in this regard, you might continue to receive marketing messages.

16. Vacancy section

Our website also includes a section ‘Vacancies’ wherein we will update in case of new job vacancies within the Company. Interested candidates may submit their information. Please note that in this case, following the receipt of your application we will send you our Candidates’ Privacy Notice

 

Our website may be continualsy under review. Thus we urge you to check our privacy policy on a frequent basis.

(Version 1 - Last updated 23.04.2020)