This Privacy Notice complies with the EU General Data Protection Legislation and the Maltese Data Protection Act . It serves a notice for those using Ta’Dirjanu App (hereinafter referred to as the “App”). It notifies the users about personal data that the company holds relating to their experiences on the App, for what purposes it is processed and for how long it is expected to be used.
Agius Services Limited (hereinafter referred to as the ”Company”, “we”, “us” or “our”), respects the privacy of all those using the App 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 thisApp. 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 02/27/2023 . Historic versions (if any) of the privacy notice can be obtained by contacting us on the contact details listed below.
This privacy notice aims to give you information on how the Company collects and processes your personal data through your use of this Appincluding any data you may provide through this same App including when creating an account and logging in, when you browse through the services offered on theApp, when you show your interest in particular products, promotions and offers, when contacting us through the different methods available from App such as bysending us an email and when using the App in one of our stores when checking out. This App is not intended for children and thus we do not knowingly collect data relating to those under the age of 16.
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.
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.
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.
This App includes links to third-party websites and apps such as Facebook. Clicking on any of the third-party app or 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 apps and we are not responsible for their privacy statements. We encourage you to read the privacy notice of every website and app you visit when you leave this App to understand what information will be prcessed about you by the operator.
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:
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.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To send you a message such as service messages |
(a) Identity
(b) Contact
|
Performance of a contract with you |
| To manage our relationship with you |
(a) Identity
(b) Contact
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
|
| To send you information about new products, promotions and services |
(a) Identity
(b) Contact
|
(a) Performance of a contract with you. We send this information only if you have opted to receive such information and you can always opt out by sending us an e-mail.
|
| The date of birth information is to detect if you under the age of 18 years |
(a) Identity
(b) Contact
|
Necessary to comply with a legal obligation |
| The payment information is process payment |
(a) Identity
(b) Contact
|
Performance of a contract with you |
| Contact history is to provide customer service and support and training to our staff |
(a) Identity
(b) Contact
(c) Your feedback
|
(a) Performance of a contract
(b) Legitimate interest
|
| Use of the app such as purchase history, viewed items, store visits to determine shopping interest and behaviour |
(a) Identity
(b) Contact
|
(a) Performance of a contract |
| Replies from competitions and promotions |
(a) Identity
(b) Contact
|
Performance of a contract |
| Registration, login and account management |
(a) Identity
(b) Contact
|
Performance of a contract |
| Processing customer service requests |
(a) Identity
(b) Contact
|
Performance of a contract |
The personal data we collect through this App 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.
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.
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.
We may have to share your personal data with the parties set out below for the purposes set out in the table providedabove.
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.
The Company does not transfer your personal data outside the European Economic Area (EEA).
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.
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.
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.
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.
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.
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.
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.
If you have opted to receive 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 messages by sending us an e-mail on info@tadirjanu.com . While we may take some time to update the system in this regard, you might continue to receive marketing messages.
Our App may be continuously under review. Thus we urge you to check our privacy policy on a frequent basis and prior to making use of the App. (Version 1 - Last updated 02/27/2023)