Erremme Business Advisors Ltd is committed to protect your personal information when you are using our services. This Privacy Notice relates to our specific use of any personal information you provide to us through www.erremme.com.mt (“the Website”).
- What information will we collect?
We collect certain information that personally identifies you (“personal information”) when you when you send a query through the www.erremme.com.mt/contact/ web page.
Depending on the circumstances for collection, personal information that we collect is usually any or all of the following: your name, email addresses, phone numbers and content that you wrote in your query. We may also collect other personal information from you when needed to provide data, service or other information that you requested. We will not normally collect any sensitive personal data and in any event will request your explicit consent if we do so.
- Why do we collect this information?
We will use your personal information for a number of purposes including the following:
- For “service administration purposes”, which means that we may contact you for reasons related to the service you have signed up for (e.g. to notify you that a particular service has been suspended for maintenance);
- To contact you about a submission you have made to the Website, including any content you provide;
- To analyse and improve the services offered on the Website and the firm.
- How long will information be held for?
Erremme Business Advisors Ltd has a requirement to maintain certain data for a long period such as the requirements emanating from the Income Tax Management Act. In relation to our services, we will hold your personal information on our systems for 10 years from the end of service rendered to a client.
By submitting personal information to us and using our services, you consent to our use of your personal information in the manner set out in this Privacy Notice.
If you have any questions, comments or suggestions about our use of your personal data please contact our Data Protection Officer, Ms. Tracy Borg on email@example.com or 21661273.
You may request details of personal information which we hold about you. A small fee may be payable to collect and pass on this information. If you would like details of the information held on you please contact Ms. Tracy Borg on firstname.lastname@example.org or 21661273.
- Our guiding privacy principles
Erremme Business Advisors Ltd is committed to upholding your privacy as a prospective, existing or past client. The personal data about you that we collect, process or use (‘Data’) is held securely and treated in accordance with this Policy. Whenever you give us Data, you are consenting to its collection and use as explained at the time of collection and in this Policy, including our use of ‘cookies’ (see section 14).
We operate an integrated communications programme which means we use your Data to communicate with you through several different channels, including direct mail and email (see section 13). Our aim is to keep you up-to-date with all the latest services and updates however if you feel you no longer wish to receive direct mail or email communications from us, you are able to ‘opt out’ of them individually at any time (see section 13).
- What personal data do we collect?
If you visit Erremme Business Advisors Ltd website, your Internet Protocol (‘IP’) address and other information relating to your visit will be tracked by a method called URL Rewriting the link (URL) to any page on the site has a unique session ID appended to it (see section 13 for more details).
You will be required to submit the following personal data through the website if you send a query through the Www.erremme.com.mt/contact/ web page:
- Name and Surname
- Email address
- Phone Number
- Query Content(if applicable)
- Disclosure of information
The firm’s use of your Data for any of the purposes disclosed in this Policy, or any other purposes disclosed in any separate communication, may involve the firm sharing it with third party suppliers such as contractors, agents or professional advisers appointed by the firm to assist us in providing services.
In no other case, unless obliged to do so by law, will the firm sell, rent, lease or otherwise share your Data with third parties, unless you have provided your specific, positive and unambiguous consent.
- What we use your data for
Data about you provided to the firm will be used for the purposes described at the time of collection. It may also be used for the other purposes described in this Policy. For instance, Data may be used by the firm to record the Website usage patterns and your use of the firm`s other services and facilities, thus helping us to administer these effectively and provide the highest possible level of service. It also helps us better understand your needs and interests.
We will always require you to supply an email address when you apply for any service for email confirmation and administration purposes. However, when capturing your email address we may also offer you the chance to ‘opt in’ to receive other email communications. If you do not ask to be sent these communications, you will only receive email for administration purposes.
Apart from the data that you have provided us with, we may maintain data for security reasons such as CCTV footage as well as logins of entry and exit from the firm. At the discretion of management, this may be given to third parties in connection with requests being made for valid security reasons. The firm needs to make sure that all members before subscription to a service or to any event which will be held on the firm`s premises shall be made aware that CCTV cameras are available around the premises. Subsequent to being aware of CCTV records and they still enter the property, they are accepting image footage to be recorded by the firm. The firm shall also have clear notices with regards to CCTV cameras before one reaches the premises gates or entry doors.
- Promotional communications
Unless you have previously opted out of receiving such communications (see ‘Opting out’ – section 12), your Data will be used by the firm for marketing, advertising and promotions (’Promotions’). These Promotions may advertise firm’s services and special offers related to the firm’s operations.
Other Promotional communications may also invite you to participate in surveys or events sponsored by third parties. These third parties will have been specially selected by the firm and third party Promotions will not result in your Data coming into the third party’s possession unless you give separate consent to this occurring. In that event please check notices supplied by that third party for information as to how they will make use of your Data.
Promotional communications may be made by post, facsimile, or email. In the case of email communications these will only be sent to you if you have opted into the firm’s use of email to communicate with you on these matters. Should you wish to opt out of email communications please refer to clause 12.
- Opting out
You may at any time opt out of any future firm`s communication, digital or non-digital, Promotional or non-Promotional. If you wish to opt out of receiving postal communications please contact the firm`s DPO(refer to point5; General).
If you wish to opt out from digital communications, please follow the instructions made available from the unsubscribe tab of the same communication sent to you or send an email to our DPO (refer to point 5; General).
A cookie is a small piece of data that is sent from our web server to your browser when you visit the Website. It is stored on your hard drive. There are several types of cookie that are used to keep track of information needed by a site user as they travel from page to page within a website. We use a method called URLRewriting where the link (URL) to any page on the site has a unique session identifier (session ID) appended to it. This allows the Website to track a user’s behaviour during each visit to the website (session) without the need to write a temporary cookie to their PC’s hard drive.
Other types of cookie can be used to track internet activity after the user has left a website. These are normally facilitated by organisations external to the website being visited and are generally known as ‘third party’ cookies. These usually have a long lifetime with several months being quite common. They are “harvested” and “refreshed” whenever the user visits a page where the same or a similar cookie is being used. We currently have a third party cookie written from the Website as follows:
We currently use Google Analytics to measure and analyse visitor information related to our web site. For that purpose, your IP address, Internet traffic data and data on your browser type and PC are collected. We will not use any of this data to identify you personally, it is used only to monitor and improve the Website.
Internet browsers normally accept cookies by default, but it is possible to set a browser to reject cookies. If this is done it is important not to exclude the benign and useful cookies. Choose an option that rejects all third party and long-lived cookies.
This will ensure you are able to prevent information about your visit to our website being collected, if you wish. The ICO guidance can be accessed here: ICO new cookie guidance. Further information on cookies can be accessed here: allaboutcookies.org.
- Supplementary information
We may supplement your personal data with other Data about you we have received from third parties, provided that they have obtained and shared that Data with us in a manner that is compliant with all relevant laws and codes. For instance a third party may be used to verify your payment details. We may also combine Data about your subscribed services habits with similar Data about you to create a personalised user profile. We can then use this to send you communications which are more likely to be of interest to you.
- Maintaining the information we hold about you
The firm aims to keep the Data it holds about you accurate and up to date. If at any time you want to verify, update or amend any Data we hold about you or if you become aware of possible errors or inaccuracies in that Data, please contact our DPO(Refer to Section 5 General)
If you wish to opt out of further use of your Data for any purpose, please refer to Section 12 on ‘Opting Out.’
- Links to third party sites
The Website may contain links to other sites, provided as a convenience to you. You are under no obligation to use these sites, but if you choose to do so, please be aware that these sites have separate content, privacy and data collection policies. Please refer to these before interacting with the site. The firm cannot accept responsibility for any use of your Data by these sites.
The firm places great importance on the security of all Data associated with our members, customers, registered users of the Website and other contacts. We have security measures in place to protect against loss, misuse or alteration of Data under our control.
Unfortunately no transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, we cannot warrant the absolute security of any Data you transmit to us online or to any other persons providing products or services online through the Website.