Privacy Policy
General
We, the team at SmartCity, take your privacy seriously and are committed to protecting your personal data.
For the purpose of protecting your rights in terms of European Union law, specifically the General Data Protection Regulation (Regulation (EU) 2016/679 – the “GDPR”) as implemented into Maltese law pursuant to the Data Protection Act (Chapter 586 of the laws of Malta), you must be informed when your personal data is processed by an organisation and to know the details and purpose of that processing. In line with the foregoing, this Privacy Notice provides information on our practices regarding collection, use, disclosure and transfer of your personal data that SmartCity (Malta) Limited (a company registered in Malta with registration number C41194 and having its registered office situated at SmartCity Malta, Ricasoli, limits of Kalkara, SCM 1001) and its affiliates (the “Company”, “We” or “Us”) may, from time to time, collect and process via its website ([https://www.smartcitymalta.com.mt/] – the “Website”) in a clear and transparent way.
If you have any questions about how we protect your privacy, you can contact us on info@smartcitymalta.com.mt
Data Controller
We are controllers of personal data in terms of the GDPR and the Act and we assure that your personal data will be processed in accordance with the applicable data privacy laws and this Privacy Notice.
Personal Data Collected
Upon accessing the Website, we collect and process your personal data which is requested from you via the Website and may include but is not limited to:
• Personal details: including without limitation your name, email address and mobile number; and
• Information collected via cookies and similar technologies when you use the Website. (in this respect, we kindly refer you to the section on Cookies below for further information).
Please be aware that you may refuse to provide us with any personal data however, such may hinder your use of this certain features of the Website.
Use of Personal Data
The personal data which we collect, process and store via this Website in accordance with applicable law is used in a number of different ways depending on the nature of the personal data collected and the purpose for which this has taken place, which includes without limitation:
• responding to your request for information;
• the maintenance and improvement of our Website;
• to collect statistical website usage data;
• to notify you about changes to our Website, including to this Policy;
• where you have consented to receive our e-newsletters, from time to time to provide the same to you.
Legal Basis
We ensure a valid legal basis under the applicable data protection laws for all of the uses of your personal data as collected via this Website, which include one or more of the following legal grounds:
(i) performance of a contract with you;
(ii) compliance with a legal obligation;
(iii) consent, where applicable; and
(iv) our legitimate interests, provided that proper care is taken in relation to your rights and interests, which legitimate interests include but are not limited to:
a. to ensure that you are aware of any changes made to the Website and/or the terms of this Privacy Notice;
b. to ensure that we maintain our Website and improve the same;
c. to carry out research and analysis in respect of your personal data to better understand the use of the Website and its visitors; and
d. to improve the security of the Website.
Data Retention
Your personal data that we collect via the Website shall not be retained for longer than is necessary having regard to the purpose and intention for which said personal data was collected. It may also be the case that your personal data is retained where such retention becomes necessary:
(a) to ensure compliance with our legal and statutory requirements;
(b) to resolve disputes;
(c) to prevent fraud and abuse;
(d) to enforce our terms and conditions.
Data Security
Whilst we have the technical and organisational measures in place to protect your personal data, the transmission of information via the Internet or email is not completely secure. Although we endeavour to do our best to protect your personal data, we cannot guarantee the security of your personal data while you are transmitting it to us via our Website and any such transmission is therefore at your own risk.
The above notwithstanding, we have in place (i) appropriate security measures to prevent your personal data from being accidentally lost, used, altered or accessed in an unauthorised way, and (ii) procedures to adequately address any suspected personal data breach, which security measures and remedial procedures are regularly reviewed and where required, improved upon. In this respect, you will be promptly notified together with any applicable regulator of any such breach where we are legally obliged to do so.
It may be the case that we are required to disclose your personal data to the relevant authorities where this becomes necessary, including without limitation (i) in connection with investigations of fraudulent activities and/or to prevent fraud and (ii) to ensure compliance with the applicable law.
Sharing Your Personal Data
We may share your personal data with third parties as appropriate, including with Our designated marketing agency to assist us in delivering promotional communications, analysing customer engagement, and improving our marketing strategies. Any processing of your personal data by our marketing agency is carried out in accordance with applicable data protection laws, including the GDPR.If We ever have to share data with entities that are outside of the EEA, this will be done so in a manner that complies with the requirements established by the GDPR.
Cookies
Our Website uses cookies to gather information about your computer or other device from which you are accessing the same. For more information on cookies used, please refer to the Website’s Cookie Notice.
Your Rights
We have set out below your rights as a data subject which are exercisable in accordance with applicable law.
Right of Access
As a user of the Website, you have the right to request access to all the personal data processed by the Company.
Right to Withdraw Consent
As a user of the Website, you are entitled to withdraw your consent given to the Company for the processing of your data and opt out at any time.
Right to Rectification
As a user of the Website, you are entitled to request that we rectify without undue delay any inaccurate personal data which we hold and/or process.
Right to Erasure (‘the right to be forgotten’)
As a user of the Website, you have the right to request that we delete all your personal data held by us where there is no legal basis for us to retain the same.
Right to Restriction of Processing
As a user of the Website, you are entitled to restrict the manner in which we process your personal data without deleting the same.
Right to object
As a user of the Website, you have the right to object to the processing of your personal data when such is based on legitimate interest or when your data is processed for public interest.
Right to lodge a Complaint
As a user of the Website, you are entitled to lodge a complaint arising in connection with this Policy (i) via email on info@smartcitymalta.com.mt and/or (ii) to the Information and Data Protection Commissioner in Malta as the data protection supervisory authority at the below address:
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
Links to Third Party Websites
We may post links to other websites which are operated by third party companies, and your activities on those websites will be governed by the policies, practices and laws applicable in respect thereof. We encourage you to review the privacy practices of these third party websites and qualify that we are not responsible for the privacy practices of those websites.
Changes to this Privacy Policy
We may update and/or replace this Policy from time to time and not that is your responsibility to frequently access the page on our Website detailing the same to remain updated with any changes that may be implemented by us from time to time.
Law and Jurisdiction
This Policy shall be governed by Maltese law, and any dispute arising from, or related to, such Policy shall be subject to the jurisdiction of the courts of Malta.
Further details
To contact us for more information about the Website, please email us at info@smartcitymalta.com.mt