Proact Advisory has developed this privacy notice because We want you to feel confident about the privacy and security of your personal information. Please read it carefully so you are aware of how and why We are using such information and what your rights are under the data protection legislation.
1. APPLICABILITY OF PRIVACY NOTICE
This privacy notice has been drafted in accordance with the provisions of the General Data Protection Regulation – Regulation (EU) 2016/679 (the “GDPR”) and applies in all instances when Proact Advisory acts as a controller of personal data relating users of Our website.
For the purposes of this privacy notice, the terms “Us”, “We” and “Our” refer to Proact Advisory (hereinafter referred to as “Proact”). The terms “you” and “your” refer to the data subject, being the person in relation to whom We have all personally identifiable information.
We can make changes to this privacy notice from time to time. We will identify the changes We have made on this page. In circumstances where a change will materially change the way in which We collect or use your personal information or data, We will send a notice of this change to you and you shall have a right to object to any such update and/or amendment or withdraw your consent.
3. PERSONAL DATA
The terms “personal data” or “personal information” mean any information about an individual for which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect and process personal data that you voluntarily give Us when you use Our website. For example, you may use this Website to contact Us with questions and comments. When you fill out the contact Us form on Our website, you provide Us with personal information such as your name and email address.
In addition to the information you provide when you use Our website, We may use technology to collect aggregated data such as statistical data. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, We may aggregate your usage of Our website to calculate the percentage of users accessing a specific website feature. However, if We combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, We treat the combined data as personal data which will be used in accordance with this notice.
4. HOW WE USE YOUR DATA
When you fill the contact Us form on this website, We use the personal information submitted in the form only to respond to your message or act on your request. This personal information will not be kept longer than necessary and will be deleted once the feedback requirement is met.
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.
Only minimal personal data is collected when you fill the contact Us form on this website, namely your name and email address. Without provision of such personal data, We will not be in a position to respond to your message or act on your request.
You may withdraw your consent to the processing of your personal data at any time. Such withdrawal does not affect the legality of any processing based on your consent prior withdrawal.
5. THIRD PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. It is important to note that clicking on those 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 policies.
6. DATA SHARING
As a general rule, any information gathered through the use of Our website is used solely by Us and, save as otherwise permitted herein and/or required by law, will not be transferred to third parties.
We may, however, have to share your personal data with the parties set out below:
- selected individuals within Our company;
- Our intra-group companies and affiliates; and
- Our agents and third parties that provide services to Us.
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.
7. DATA SECURITY AND DATA RETENTION
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on Our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained by sending an e-mail to email@example.com
This personal information will not be kept for longer than necessary and will be deleted once the feedback requirement is met unless We are required to keep that information due to a statutory obligation imposed on Us and/or due to accepted standards (including where processing may be necessary for the establishment, exercise or defence of legal claims)
8. DOWNLOAD INFORMATION AND DATA ANALYTICS
If you read or download information from Our site, We automatically collect and store the following information:
i) The requested web page or download;
ii) Whether the request was successful or not;
iii) The date and time when you accessed the site;
iv) The Internet address of the web site or the domain name of the computer from which you accessed the site;
v) The operating system of the machine running your web browser and the type and version of your web browser.
We use the information that We gather in order to evaluate the website’s usage, content, navigability and composition. This statistical analysis allows Us to improve Our website, to generally make your internet experience more enjoyable and to provide a value-added service. We may engage third party processors to conduct such data analytics on Our behalf, and if We do, We will ensure that such processors handle personal data in line with the applicable law and according to Our instructions.
Download information and data analytics information which constitute personal data will only be retained for as long as is necessary unless We are required to keep that information due to a statutory obligation imposed on Us and/or due to accepted standards (including where processing may be necessary for the establishment, exercise or defence of legal claims).
Marketing will be carried out primarily through the circulation of e-mails. Other means of communication may also be used, however Proact shall always seek your prior consent.
You may withdraw consent to the processing of personal data for Marketing purposes at any time by sending us an e-mail on: firstname.lastname@example.org. Alternatively, you may unsubscribe to such communications by clicking the “Unsubscribe” link contained in the footer of any Marketing email you will receive from the Company. However, withdrawal of consent for Marketing communication does not affect the lawfulness of the processing of personal data based on such consent prior to its withdrawal.
11. YOUR RIGHTS
For as long as We retain your personal data, you have certain rights in relation to your personal data including:
i. Right of Access – you have the right to ascertain the personal data We hold about you and to receive a copy of such personal data;
ii. Right to Complain – you have the right to lodge a complaint regarding the processing of your personal data with the supervisory authority for data protection matters. In Malta this is the Information and Data Protection Commissioner (contact details provided below);
iii. Right to Erasure – in certain circumstances you may request that We delete the personal data that We hold about you;
iv. Right to Object – you have a right to object and request that We cease the processing of your personal data where We rely on Our, or a third party’s legitimate interest for processing your personal data;
v. Right to Portability – you may request that We provide you with certain personal data which you have provided to Us in a structured, commonly used and machine-readable format. Where technically feasible, you may also request that We transmit such personal data to a third party controller indicated by you;
vi. Right to Rectification – you have the right to update or correct any inaccurate personal data which We hold about you;
vii. Right to Restriction – you have the right to request that We stop using your personal data in certain circumstances, including if you believe that We are unlawfully processing your personal data or the personal data that We hold about you is inaccurate;
viii. Right to withdraw your consent – where Our processing is based on your consent, you have the right to withdraw your consent. Withdrawal of your consent shall not affect the lawfulness of the processing based on your consent prior to the withdrawal of your consent; and
ix. Right to be informed of the source – where the personal data We hold about you was not provided to Us directly by you, you may also have the right to be informed of the source from which your personal data originates.
Please note that in terms of the applicable laws, your rights in relation to your personal data are not absolute.
You may exercise the rights indicated in this section by contacting Us or Our Data Protection Officer at the details indicated below.
Given that the legal basis for Our processing of your personal information is consent, you have the right to withdraw that consent at any time by sending an e-mail to email@example.com. Withdrawal will not affect the lawfulness of processing before the withdrawal.
If you consider that Our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In Malta the supervisory authority is the Information and Data Protection Commissioner; link: https://idpc.org.mt/en/Pages/contact/complaints.aspx
12. DATA PROTECTION OFFICER
Our Data Protection Officer is Alan Alden, (Tel: +356 2759 5000 ext 601; Email: firstname.lastname@example.org).
13. THE CONTROLLER’S DETAILS
We, Proact Advisory, are incorporated in Malta with company registration number C 4760 and Our registered office is at 170, Pater House, Psaila Street, Birkirkara, BKR 9077, Malta.
You may contact Us by:
i) post to the postal address above;
ii) using Our website contact forms;
iii) telephone on +356 21490700;
iv) e-mail on email@example.com