Privacy and Cookie Policy

Last Updated: May 2020

General

 

The EU General Data Protection Regulation (GDPR), which came into force on 25 May 2018, provides new rights to individuals and requires organisations to provide information about their processing in a clear and transparent way. We have published Privacy Policy to take into account new requirements and to explain how Francis Busuttil & Sons (Marketing) Limited (“the Company”, “we” or “us”) collects, stores and use personal data.

Any personal data provided by you voluntarily through our website https://www.fbsmarketing.com/ will be processed in accordance with the Data Protection Act (Chapter 586 of the Laws of Malta), the GDPR and any other relevant data protection legislation, as may be amended from time to time.

 

Data Controller

For the purposes of the GDPR, the Company is the Data Controller.

If you have any questions about how we process your personal data, please email our data protection representative on gdpr@fbsmarketing.com. Our postal address is Busuttil Buildings, St Venera Square, Santa Venera SVR 1681.

 

Information We Collect

The data that we may collect about you usually includes:

  • Your name

  • Your email address

  • Curriculum Vitae

  • Address

  • Telephone Number

  • Any other data which you give us when communicating with us

 

Basis of Processing

We will process personal data on the basis of:

  • Necessity for the performance of a contract which you have asked us to enter into, or in order to take steps prior to entering into a contract (for example, to be able to enter into an employment contract);

  • Our legitimate interests (for example, to ensure we are providing you with the best possible customer service when you send any complaints or suggestions for improvement,).

 

Sharing your Information

Any data collected may be shared with employees in order for the data to be processed for the purpose for which it was collected (for example, a complaint will be forwarded to an employee within the relevant department or a job application will be forwarded to Human Resources).

We will not share any of your personal data with third parties without your permission, except where this is strictly required for us to provide you with a service you have engaged us to provide or where we are obliged to do so in terms of our legal or regulatory obligations.  

We may share your personal data with the following categories of entities as necessary:

  • Wix (cloud service provider) 

If we ever have to share your personal data with an entity outside the EU, we will do so in accordance with the requirements of the GDPR and any other applicable law. 

 

Data Security

We take the security of your personal data very seriously and have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed, so as to safeguard its integrity and confidentiality.

The security measures we have implemented to ensure safe transmission and storage of personal data include:

  • Use of secure servers;

  • Use of firewalls;

  • Use of encryption;

  • Physical access controls at data centers;

  • Information access controls;

  • Use of back-up system

  • End point protection system

We also regularly review and, where practicable, improve upon these security measures.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

While we do our utmost to safeguard your personal data, no data transmission over the internet can be totally secure and therefore we cannot guarantee or warrant that no unauthorized access will occur.

 

Cookies

As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the sites functionality.

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.

You can find more information about the individual cookies below:

First Party Cookies - Strictly Necessary: 

First Party Cookies - Functionality

Third Party Cookies - Functionality

Your Rights

Right of Access

You have the right to access all the personal data held and processed by the Company. To exercise this right, you can contact us at the email or postal address at the top of this page.

In order to process this request, we will require proof of your identity. We will do our best to process the request as soon as possible, and in no event not longer than sixty days from hearing from you. 

 

Right to Rectification

You have the right to request modification of all the personal data held and processed by the Company. If you think we may hold details about you that are inaccurate or out of date, please contact us at the email or postal address at the top of this page.

Right to Erasure (‘right to be forgotten’)

You have the right to request that we delete the personal data held and processed by the Company by contacting us at the email or postal address at the top of this page.

This right is not absolute, and we may be justified in keeping certain personal data, for instance when we are legally obliged to do so or if such data may be necessary for us to defend a legal claim. 

 

Right to Object

You have the right to object to the processing of your personal data, including where such processing takes place for the Company’s legitimate interests, and you may request to withdraw from all future activities and the removal of all personal data held and processed by us by contacting us at the email or postal address at the top of this page.

 

Right to Data Portability

You have the right to move, copy or transfer your personal data from one organisation to another, and you have the right to request from us a copy of your personal data in a structured, commonly used and machine-readable format, which we may provide to you or another organisation at your request. If you would like us to assist you with this please contact us at the email or postal address at the top of this page.

 

Right to Lodge a Complaint

All Data Protection enquiries/complaints should be sent to gdpr@fbsmarketing.com

You also have the right to lodge a complaint with the Information and Data Protection Commissioner in Malta as the data protection supervisory authority:

Information and Data Protection Commissioner

Level 2, Airways House
High Street
Sliema SLM 1549
Malta
Tel: (+356) 2328 7100
Email: idpc.info@idpc.org.mt

 

Marketing

If you are a customer, from time to time, we may wish to contact you about products and/or services which you have purchased or shown interest in.

You have the right to ask us to stop sending you marketing material at any time.

You can stop receiving marketing messages from us at any time through any of the following methods:

  • By contacting us at the postal or email addresses at the top of this page

This will not affect any processing that took place prior to the withdrawal of consent. Please note that, it may take a few days for all our systems to be updated, so you might get messages from us while we process your request.

Please also be aware that if you ask us to stop sending you marketing material, we will still continue to contact you in relation to the service we have been engaged by you to provide (for example, to send you a quote, bill, order update, etc), if this is necessary for us to provide the service.

 

Retention

We will not store personal data for longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected that data. We may also need to keep some of your personal data where we are obliged to do so in terms of legal or regulatory requirements, or in order to protect ourselves against legal claims, or to enforce our company terms and conditions.

As a general rule we will retain your personal data as long as you remain a client of ours, or until you ask us to stop communicating with you, unless we have a valid reason to keep the information for a longer time.

For more information about our retention policy, please contact us at the postal or email addresses at the top of this page.

 

Links to Third Party Websites

We may post links to other web sites which are operated by companies that are outside of our control, and your activities at those sites will be governed by the policies, practices and laws of those third party operators. We encourage you to review the privacy practices of these third parties as we are not responsible for the privacy practices of those sites.

 

Changes to this Privacy Policy

We may update this Policy from time to time and we will replace this policy with an updated version. It is your responsibility to access the ‘Privacy Policy’ page frequently so that you will be aware of any changes that may be implemented by us from time to time.

 

Law and Jurisdiction

This Policy shall be governed by Maltese Law. Any dispute arising from, or related to, such Policy shall be subject to the non-exclusive jurisdiction of the courts of Malta.

© 2020 Francis Busuttil & Sons Marketing Ltd | Privacy Policy

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