In this notice, ‘we’ and ‘us’ shall refer to CodeBlack Ltd, and ‘our’ shall be construed accordingly.
‘You’ refers to you and any attorney duly appointed by means of a power of attorney or mandate, or any trustee, executor, curator or other legitimate representative acting on your behalf, and ‘your’ shall be construed accordingly.
This policy lays down the basis for which any of your personal data is collected and processed by us.
‘Personal Data’ is data that identifies an individual, described by the General Data Protection Regulation (GDPR) [Regulation (EU) 2016/679] as “any information relating to an identified or identifiable natural person”, and it includes but is not limited to
- Name and surname
- Identification number, linked to an official identification document, such as an identity card of passport
- Copies of such documents
- Details regarding parentage, enabling your better identification
- Email address
- Postal address
- Residential address
- Contact numbers
- Date of birth
- Photographic and videographic recordings
- VAT Number
- Credit card details necessary for the processing of payments
We collect and process Personal Data that
- May be given to us directly by yourself;
- May be collected automatically through our website;
- May be collected from other publicly available sources.
USE AND PROCESSING OF YOUR PERSONAL DATA
We will process information regarding your business interactions with us, your account and transactions, including quotations requested, requests for information, orders made, services purchased, and payments effected. This information shall be processed for the purposes of
- supplying the services in question and for keeping proper account and records of the said transactions, and reasons ancillary thereto;
- entering into and the execution of a contract between you and tenderfinder/codeblack;
- for the proper administration of our business and our website where applicable;
- for internal assessment and analysis, including but not limited to, product analysis, risk management and to protect any of our legitimate interest or the public interest;
- for direct marketing and for research purposes;
- to safeguard our legal rights, including but not limited to, for protecting and enforcing our interests, recovering any amounts owed to us by you or your co-debtors.
We also reserve the right to employ CCTV systems on our premises and use other means in order to record images to prevent and detect crime, including, but not limited to, the recording and preservation of screenshots and similar records. We also reserve the right to carry out any checks before entering into any agreement and at any time thereafter, which include searches to confirm your identity.
The Personal Data shall be processed in any lawful manner, both electronically as well as manually, when such processing is necessary for the performance and / or execution of any contract entered into between you and us, when such processing is necessary for compliance with a legal obligation to which we are or may become subject, and when such processing is necessary for the purposes of the legitimate interests pursued by us.
Such Personal Data shall only be disclosed or shared if one of the following applies:
- With your consent;
- For external processing, on a ‘need to know’ basis to/with other entities and/or sub-contractors and/or other persons if pertinent to performance and/or enforcement of any contract between you and us (such as in the case where it is necessary for us to outsource certain functions in order to be able to execute any contract entered into between you and us),
- For legal reasons, where we have a well founded belief that such disclosure is necessary for meeting any legal requirement binding upon us, meeting an enforceable request from the government or any other lawful authority, enforce applicable terms of service, detect and prevent crime, and to protect against harm the rights and property belonging to us or to the public as required or permitted by law which disclosure or sharing shall be done in line with local Data Protection legislation.
We also reserve the right to share data publicly as long as this is not personally identifiable.
Financial transactions related to online and/or electronic payments shall be handled by our services providers, and information will be shared with such service providers to the extent necessary for the purposes of processing such payments, effecting any refunds that may be due, and in dealing with any complaints and or queries related to such payments and refunds.
RETENTION AND DELETION OF PERSONAL DATA
Personal Data processed by us for any purpose shall not be retained for longer than is necessary for such purpose, which term may be extended from time to time.
We will retain account and transaction information for legal, contractual and internal financial accounting purposes for no longer than it is required in order to maintain your relationship with us, or for any other legal or regulatory requirements.
In some cases it may not be possible for us to determine in advance for how long your Personal Data will be retained. We may also retain your Personal Data where this is necessary in order for us to be able to comply with any legal requirement applicable in our regard and in order to protect our interest or even yours.
DATA SUBJECTS RIGHTS
As a Data Subject as understood under locally applicable Data Protection Legislation, you are entitled to a number of rights including:
- The right of access – You have the right to request a copy of the Personal Data we hold about you and be informed of how we process it and the recipients of the same. Provided that third parties’ rights and freedoms are not affected, you will be supplied with a copy of your Personal Data, for which a reasonable fee may be requested.
- The right to rectification – You have a right to request a correction of any incomplete or inaccurate data related to you, taking into account the purposes of the processing.
- The right to erasure – You may, in some circumstances, request that we delete or remove your Personal Data where there is no reason for us to continue to store and/or process the same. Such circumstances include situations where the Personal Data is no longer necessary, where you withdraw your consent to processing based on your consent, where the processing is only for direct marketing purposes. There are exclusions to this right, including but not limited to, that such Data is necessary for the establishment, exercise and defence of legal claims, for the compliance with any legal obligation, or for exercising the right of freedom of expression and information.
- The right of restriction of processing – You have the right to request a suspension of the processing of your Personal Data in certain cases, such as, if you are contesting its accuracy or the very reasons for its being processed. In such a case we will only be able to process your Personal Data where we have your consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person or reasons of important public interest.
- The right of data portability – You have a right, in certain circumstances, to ask us to provide your Personal Datain a structured, commonly used and machine-readable format and have the right to transmit those Data to another controller without hindrance from us where such processing is based on your consent or on the performance of a contract with you and such processing is carried out by automated means.
- The right to object to certain processing – You have a right to object to the processing of your Personal Data by us in those cases where we only process your Personal Data when this is (a) necessary for the performance of a task carried out in the public interests or in the exercise of official authority vested in us, or (b) when such processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. On such objection processing shall cease, unless we provide compelling and legitimate grounds requiring the continuation of the data processing which outweigh the objections that may have been raised by you.
- The right to lodge a complaint with any supervisory authority – You also have the right to lodge complaints with the appropriate Data Protection Supervisory Authority. The competent authority in Malta is the Office of the Information and Data Protection Commissioner. We kindly ask that you please attempt to resolve any issued you may have with us first, even though, as stated herein, you have the right to contact the competent authority at time.
Additionally you may also choose not to provide us with any personal data and still continue to browse our website, however, we will not be able to process and provide customer support to queries, or process forms. Also, this would make you unable to subscribe to the service provided by us.
You can also turn off cookies in your browser by changing its settings, however we only collect anonymous data for the purpose of analytics. This data helps us better understand our market, so if this does not bother you, then you may allow cookies.
We will inform you, before collecting your data, if we intend to use if for marketing and if third parties are involved. You can opt out from marketing by contact us via an email to the address indicated hereunder.
Thanks for taking the time to read our privacy notice. We have designed it to help you understand what we do with your personal data by being transparent and clear. Hopefully we have shown you how important your privacy is to us and that you can trust us with your personal data.
You may contact us using the following details:
EMAIL [email protected]
Cookies are small files which are stored on a user’s computer or mobile device, or similar, when you visit a website. They are designed to hold a reasonable amount of data specific to a particular client and website, and can be accessed either by the web server or the client computer. This allows the server to deliver a page tailored to a particular user, or the page itself can contain some script which is aware of the data in the cookie and so is able to carry information from one visit to the website (or related site) to the next.First party cookies are cookies set by the website you’re visiting. Only that website can read them. In addition, a website might potentially use external services, which also set their own cookies, known as third-party cookies.
What cookies do we use?
We can classify cookies into two separate categories, being those what are necessary for the functionality of the website, and those which we collect to analyse your activity to improve how the website works. The table below – which will be updated from time to time – gives you a brief explanation of what types of cookies we may collect, what the source of the cookies is, why we use the cookie, how long we retain the cookie, and whether the cookie is necessary for the website’s functionality or not:
|Name of cookie
|Expiry / Retention period of cookie
|Purpose of the cookie
|Is if necessary for the website’s functionality?
|How can you block the cookie
|The purpose is advertisement. The cookie contains encrypted Facebook ID and browser ID.
You can manage and delete cookies as you may wish.You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited.Be aware, however, that you may also lose some saved information (e.g. saved login details, site preferences). More detailed control over site-specific cookies can be exercised through the privacy and cookies settings in the browser on your device. Many browsers may also be set in such a manner as to prevent any cookies being placed in your device, however, this may require manual adjustment of your preferences when visiting a website or page, and certain functionalities may not work properly or at all.
Apart from the information you provide us with when using our website, other information may be passively collected from you (without you actively furnishing such information) when you navigate through the website. We use various technologies and navigational data collection methods to gather such passive information for various reasons, for example to track how many visitors access our website, the date and time of their visit, the length of their stay and which pages they view. The passive information also aids us to determine which web browsers our visitors use and the address from which they accessed our website – for instance if they connect to our website through clicking on one of our banner ads. This technology does not identify you personally.
Such passively collected information may be used and combined to improve our services to website visitors, customise the website based on your preferences, compile and analyse statistics and trends of our visitors and their use of the sites operated by us and our related entities or subsidiaries. Together with our related entities and subsidiaries we will use this information and share it with third parties to improve the content, functionality and administration of our websites, to better understand our customers and markets, and to improve our products and services.
Such passive information shall not be combined with personally identifiable information collected elsewhere by our website or respective sites operated by our related entities or subsidiaries.