Version 1, last updated: 30th August 2021.
Group Privacy Notice
For the purposes of this Privacy Notice (“Notice”), any reference to the Computime Group shall be construed as meaning Computime Holdings Limited bearing company registration number C74592, Computime Limited, bearing company registration number C4760 and Computime Software Limited, bearing registration number C32444. All three companies have their registered address at 170, Pater House, Psaila Street, Birkirkara BKR 9077, Malta.
The terms “Us”, “We” and “Our” refer to the Computime Group collectively.
Any Personal Data We Process is kept within Our own records in accordance with the relevant data protection and privacy laws to which We are subject including but not limited to the Data Protection Regulation (EU) 2016/679 (the “GDPR”) and the Data Protection Act (Chapter 586 of the Laws of Malta) and the subsidiary legislation issued thereto, as may be amended from time to time (hereinafter collectively referred to as the “Applicable Laws”).
References to “Data Controller”, “Data Subject”, “Personal Data”, and “Process”, “Processed”, “Processing” in this Privacy Notice have the meanings set out in, and will be interpreted in accordance with the Applicable Laws. “You” and “Your” refers to the Data Subject.
1. Data Controller Details
The Data Controller of Your Personal Data is each of the members of the Computime Group. We are committed to respecting Your privacy. If You wish to contact Us about Our privacy practices please feel free to do so by contacting Our Data Protection Officer by post at Pater House, Psaila Street, B’Kara, Malta or by email at email@example.com. You may also wish to contact Us by telephone on 21490700.
2. Personal Data
The term “Personal Data” refers to all personally identifiable information about You and includes all the information You provide to Us or information that is provided to Us by third parties, which can be identified with You personally.
The following are the Personal Data that We collect:
- Name and Surname;
- Work Email Address;
- Work Telephone number;
- Work Address;
- Job title;
- ID card number (in limited instances);
- Any video footage that We collect should You visit Our offices; and
- Any cookies that We may collect should You visit Our website.
We do not collect and/or otherwise Process special categories of Personal Data.
3. Purposes of Processing
The purposes of Processing for which Your Personal Data are intended are:
- Handling customer queries and support incidents by phone and by email;
- Corresponding with customers and prospective customers/leads;
- Taking phones calls in general;
- Onboarding new customers;
- Undertaking Our services pursuant to any terms of services entered into between Us and You (or the entity that You represent);
- Sending You updates with regards to promotional or product events, or for other marketing purposes.
4. Legal Basis
Our legal bases of Processing Your Personal Data are:
a. Taking steps to enter into, and the performance of, a contract with Us;
b. Our, or a third party’s, legitimate interests – in particular Process Your Personal Data for safety and security. When we process Your Personal Data on the basis of Our legitimate interests, we ensure that the legitimate interests pursued by Us are not overridden by Your interests, rights and freedoms;
c. Your explicit consent – in which case, Our Processing shall be limited to the purposes specifically indicated when Your consent was requested; and/or
d. Compliance with legal obligations imposed on Us.
On the basis of Our legitimate interests or compliance with legal obligations, as applicable, We may also process Your Personal Data for the purposes of establishing, exercising or defending legal proceedings.
The recipients of Your Personal Data are:
a. selected individuals within Our company;
b. Our intra-group companies and affiliates;
c. Our agents and third parties that provide services to Us; and
d. Third parties to whom disclosure may be required.
6. Processing Requirement
The Processing of Your Personal Data is not a statutory requirement – it is a requirement in order for Us to contact You and maintain Our professional and business relationship with You. While the provision of Your Personal Data is not a statutory requirement, failure to provide Your Personal Data to Us will prevent Us from carrying out Our services and from communicating with You. In certain instances, the Processing of Your Personal Data may be required as a contractual requirement. Failure to provide Us with such Personal Data will prevent Us from entering into such contractual relationship with You or the entity that You represent.
7. Automated Decision-Making and Profiling
Your Personal Data will not be used for any automated decision-making or profiling.
8. Data Retention Period
We will only retain Your Personal Data for the duration of of Your relationship with Us, or as long as necessary to fulfil the purpose for which We have collected it, 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.
9. 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 (except where such Personal Data is provided to us in hand-written format, in which case such Personal Data will be provided to You, upon Your request, in such hand-written form). 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. 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 Your rights in relation to Your Personal Data are not absolute and we may not be able to entertain such a request if we are prevented from doing so in term of an applicable law.
You may exercise the rights indicated in this section by contacting Us at the details indicated above.
If You have any complaints regarding Our Processing of Your Personal Data, we kindly ask that You please attempt to resolve any issues You may have with us first by contacting Us at the contact details included above. However, please note that You always have a right to lodge a complaint with the Office of the Information and Data Protection Commissioner in Malta (File a complaint – IDPC).
11. Where Your Provide Us with Personal Data Related to Third Party Data Subjects
If you are a non-natural person and You supply to Us Personal Data of third party Data Subjects such as Your employees, affiliates, service providers, underlying clients/customers, directors or any other individuals connected to Your business, You shall be solely responsible to ensure that:
- You immediately bring this Privacy Notice to the attention of such Data Subjects and direct them to it;
- the collection, transfer, provision and any Processing of such Personal Data by You fully complies any applicable laws;
- as Data Controller You remain fully liable towards such Data Subjects and shall adhere to the Applicable Law;
- You collect any information notices, approval, consents or other requirements that may be required from such Data Subject before providing Us with their Personal Data;
- You remain responsible for making sure the information You give us is accurate and up to date, and You must tell us if anything changes as soon as possible.
You hereby fully indemnify Us and shall render Us completely harmless on first written demand against all costs, damages or liability of whatsoever nature resulting from any claims or litigation (instituted or threatened) against Us as a result of Your provision of said Personal Data to Us.
This clause shall supersede and extinguish all previous agreements, promises, assurances, warranties, representations and understandings between Us and the non-natural person, as applicable, whether written or oral, relating to its subject matter.