Purpose

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us when you are using our website, including any data that you may provide through this website when you contact us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Controller

For the purpose of the applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 and the Data Protection Act, Chapter 586 of the Laws of Malta and subsidiary legislation thereto, as may be amended from time to time, the data controller responsible for your personal data is United Group Limited of Level 4, Pinto Business Centre, Triq il-Mithna, Qormi QRM 3104, Malta (hereinafter referred to as the “company” “we”, “us” or “our” in this Policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Notice. If you have any questions about this Notice, including concerns about your personal data or our data collection practices, please contact the data protection officer (DPO) by sending an email at [email protected] or by calling on number 2338 8000 and ask for the Data Protection Officer.

References to “data controller”, “data subject”, “personal data”, “process”, “processed”, “processing” and “Data Protection Officer” in this Privacy Notice have the meanings set out in, and will be interpreted in accordance with applicable laws, including but not limited to the Applicable Law.

Information we may collect from you

The terms “personal data” or “personal information” mean any information about an individual for which that person can be identified.

We may collect and process the following data about you that you voluntarily give us when you use our website. We recognize the importance of the protection of any personal data processed. It takes active measures to protect the information provided to us. Strict security and confidentiality procedures covering the storage and disclosure of information to maintain confidentiality, to prevent unauthorized access to information and to comply with the Applicable Law is maintained at all times.

Information you give us:

You may give us information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, address, e-mail address and phone number.

Information we collect about you:

With regard to each of your visits to our site, in addition to the information you provide when you use our website, we may automatically collect information about your visit, products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Uses made of the information

We use information held about you in the following ways:

1. Contact Us form: When you fill the “Contact Us” form on our website, you provide us with personal information such as your name, email address, phone number and your message to us. We have a legitimate interest to process any personal data submitted in the form as this information is necessary to process and address your complaint/feedback in the way you expect us to and to respond to your message;
2. Cookies: For more information on the use of cookies on our Website, please refer to our Cookie Policy on [www.unitedgroup.com.mt];
3. Data Analytics: If you read or download information from our site, we automatically collect and store the following information:

• The requested web page or download;
• Whether the request was successful or not;
• The date and time when you accessed the site;
• The Internet address of the web site or the domain name of the computer from which you accessed the site;
• 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, usability and composition. This statistical analysis allows us to better understand our users’ needs and to generally make your internet experience more enjoyable and to provide a value-added service to you as a visitor. In order to do so, we make use of third-party services such as Google Analytics.

Google Analytics is a web analytics service that analyses how you use our website based on cookies (see cookie policy above). Google will use this information for the purpose of evaluating your use of our website. Further information about Google’s privacy policy may be obtained from this link.

Be assured that neither Google nor we will ever use this information to identify individual users or to match it with further data on an individual user.

If you do not wish that your user behaviour is analysed, you can opt-out of the services respectively via the following links – Google Analytics Opt-Out.

Information we collect about you:

We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• as part of our efforts to keep our site safe and secure;

Legal Bases of Processing

We process your personal data on the basis of the following legal bases:

1. Our legitimate interests – We have a legitimate interest to process any personal data submitted in the form as this information is necessary to process and address your complaint/feedback in the way you expect us to and to respond to your message.
2. Your explicit opt-in consent – for instance for cookie use, in which case, Our processing shall be limited to the purposes specifically indicated when your consent was requested; and

Where you have provided us with consent you may withdraw your consent by sending an e mail to Data Protection Officer on [email protected] or by calling on number 2338 8000 and ask for the Data Protection Officer.

Disclosure of your information:

We may share your personal information with any member of our group, which means our subsidiaries, our associate companies and their subsidiaries on a need-to-know basis. We may disclose your personal data to whoever the “Contact Us” complaint is about, including other businesses in our group. If you don’t want information identifying you to be disclosed to such third parties, we will try to respect that; however, it may not be possible to handle a complaint or your feedback on an anonymous basis.

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.  If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, and other agreements and security features to try to prevent unauthorised access.

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.

For any personal data that you provide on the Contact Us form, we generally, we do not store personal data longer than necessary for the purpose that you provided it for. We reserve the right to retain data containing complaints or feedback for 10 years from its closing. Personal data will only be retained longer if 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.

Your rights

For as long as We retain your personal data, you have certain rights in relation to your personal data including:

• 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;
• 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);
• Right to Erasure – in certain circumstances you may request that We delete the personal data that we hold about you;
• 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;
• 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;
• Right to Rectification – you have the right to update or correct any inaccurate personal data which We hold about you;
• 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;
• 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
• 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 in this Notice.

Changes to our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail prior to the change becoming effective. Please check back frequently to see any updates or changes to our privacy policy.

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.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to unitedgroup.com.mt. You also have a right to lodge a complaint with the Office of the Information and data Protection Commissioner in Malta (www.idpc.gov.mt). 310