Systemato: Website Privacy Policy
CONTENTS
1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
8. Data retention
7. Your legal rights
9. Google Analytics
10. Conclusion
Introduction
Welcome to Systemato’s privacy notice (the “Notice”).
Systemato is the trading name for our operations which are directed by Mark Debono having registered address at Norfolk Pine Court, Flat 2, Triq N.Cottoner, Lija LJA 1610 (“Systemato”; “we”; “us”; or “our”). Systemato respects your privacy and is committed to protecting your personal data.
The purpose of this Notice is to set out the basis on which your personal data is processed by us and to inform you about how we will handle and look after your personal data when you visit our website <https://systemato.com/ > (the “Website” or the “Site”) (regardless of where you visit from), and to tell you about (i) our obligations in regard to processing your personal data responsibly, (ii) your data protection rights as a data subject and (iii) how the law protects you.
We process your data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 440 of the Laws of Malta) (the “Act”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR” or the “Regulation”), following its application on 25th May 2018.
This Notice is provided in a layered format so you can scroll through to the specific areas set out below.
1. Important information and who we are;
2. The data we collect about you;
3. How is your personal data collected;
4. How we use your personal data;
5. Disclosures of your personal data;
6. No international transfers;
7. Data security;
8. Data retention;
9. Your legal rights;
11. Google Analytics.
1. Important information and who we are
Purpose of this privacy notice
This Notice aims to give you information on how Systemato, as defined above, collects and processes your personal through your access and use of the Website, including any data you may provide via the Site, such as when using the contact us form or when you use any of our services.
The Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Notice, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Notice supplements the other notices and is not intended to override them. Moreover, certain processing activities will require your express consent in order to be carried out, as specifically indicated below in this Notice.
Our website also uses Cookies. Please refer to our Cookie Policy to learn more about how we use Cookies to improve your experience on our website.
Contact details
Our full details are:
Full name of legal entity: Mark Debono, trading as Systemato
Name of data protection contact point: Mark Debono
Email address: info@systemato.com
Postal address: Norfolk Pine Court, Flat 2, Triq N.Cottoner, Lija, Malta
Telephone number: 00356 99834999
You have the right to lodge a complaint at any time to the competent supervisory authority in your jurisdiction on data protection matters. In the case of Malta, this is the Information and Data Protection Commissioner (“IDPC”) (https://idpc.org.mt/en/Pages/Home.aspx). We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version of the Notice was lasted updated on 17th May 2018.
The data protection laws across the EU, including Malta, will change on 25th May, 2018, due to the GDPR. Although this Notice sets out most of your rights under the GDPR, we may not yet be able to respond to some of your requests until May, 2018 (for example, a request to have your personal data transmitted to another controller), as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
The Website may include links to third-party websites, plug-ins and applications. 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 notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Kindly note that information relating to a legal person (for example, a company or legal entity) does not amount to personal data in terms of applicable data protection and privacy law. In that regard, the definition of personal is strictly limited to information which relates to a natural person.
On this basis, the collection and use of information such as a company name, its company number, registered office and VAT number (i.e. “Company Information”), does not amount to the processing of personal data and, in turn, does not give rise to data controller obligations and data subject rights. Where collected, we will naturally still treat and handle such Company Information in an appropriately confidential and secure manner. This is particularly relevant to those of our customers which are businesses (i.e. where the relationship with Systemato constitutes a business-to-business (B2B) relationship).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes your first name, last name, username or similar identifier, title, date of birth and gender. This will form part of any account that you may register on the Website.
• Contact Data includes your billing address, delivery address, email address and telephone numbers.
• Financial Data includes your bank account and payment card details.
• Transaction Data includes details about payments to and from you, and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use the Website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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 Data to calculate the percentage of users accessing a specific feature of the Site. 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.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a product or service that you have requested). In this case, we may have to cancel that product or service, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by making an inquiry or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply, or place an order for and/or purchase any of our products or services;
• request marketing to be sent to you;
• use the contact form on our Website; or
• give us some feedback.
• Automated technologies or interactions. As you interact with the Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
(a) analytics providers;
(b) advertising networks; and
(c) search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at info@systemato.com.
Purposes for which we will use your personal data
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.
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 on info@systemato.com 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.
