Privacy

We are committed to protecting and respecting your personal data privacy.

Last updated: February 8, 2022.

This privacy policy (hereinafter referred to as "Privacy Policy") applies to the website or any connected websites or related domains (hereinafter referred to as "Website" or "Site"), the services provided by (the owner and operator of the website), and all associated software applications ("Applications"), where your personal data is processed (whether through the website, one of our applications, or otherwise).

This privacy policy is issued on behalf of subsidiaries, therefore in this policy when the pronouns "we", "us" or "our" are referred to, we refer to the relevant organization responsible for processing your data. We will inform you which organization processes the personal data when a customer uses one of our services. In certain cases, where a customer's personal data is provided, stored, and processed by us in countries that additionally apply local data protection laws, our customers may refer to the respective jurisdiction for further information on the respective local data protection laws in connection with the privacy notices.

In the privacy policy, the words "you", "your" and "user" refer to an identified or identifiable person who is a user of the website and/or a customer (or potential customer) of the website. The term "user" refers to an identifiable person who is a user of the website and/or a customer (or potential customer) of the website. Customer) - a recipient of our services. All details, including contact information, can be found below.

This policy describes how [Your Company] processes the information and personal data you have provided to us. Data that you have provided to us that allows us to effectively manage your relationship with us.

1. Purpose of this Privacy Policy

We respect and value the privacy of our customers. We do not sell, transfer, or otherwise provide to third parties information about individuals who visit our website, except in cases where this is expressly provided for in this privacy policy.

• The type of personal data we collect about our customers and how we use your personal information.
• A statement of the basis on which we process personal data.
• To inform you how we process your personal data,
• Clarification of the data protection obligation to act lawfully and responsibly in handling the personal data of our customers.
• Information about your data protection rights

2. Legal aspects of processing personal data

All processing of personal data carried out by us is done in accordance with this privacy policy and:

• Malta Data Protection Act (hereinafter referred to as "DPA" - Chapter 586 of the Maltese laws), as well as all other Maltese data protection laws (hereinafter referred to as "GDPR" - Chapter 586 of the Maltese laws) and all other regulations issued under the GDPR, in their applicable version and amendments;
• Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016. "On the protection of natural persons in relation to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC" (General Data Protection Regulation - hereinafter referred to as "Regulation" or "GDPR").

We comply with local data protection laws in the countries where we operate.

This privacy policy should be read in conjunction with our policy on the following topics Cookies and all other privacy notices that we provide in certain instances where we collect or process personal data about you, so that you fully understand how and why we use your data.

3. Data Controller

ADMIN Mallta Limited (Company Registration Number C 86082), Malta, is a data controller and is responsible for this website.

We control the personal data that we collect or receive and process in the course of providing our services and/or operating our website. Our affiliated legal entities may become data controllers, either jointly or as separate data controllers.

4. Personal data we receive from our users

Personal data or personal information is any information about an individual that can be identified. Information that does not relate to a person (anonymous data) is not considered personal data. Our website is designed so that our users can access our website without identifying themselves or disclosing personal data. However, if you choose to provide personal information, we will protect that information and only use it in the manner described below.

We collect and process the following personal data about you:

• Identification details including name, birth name, surname after marriage, job title, ID number, gender, nationality, employment status, organization, profession, email address, and phone number.

If you use our services or apply for a job, you may be asked to provide additional information. If you use our services, we may require further information before we enter into a business relationship with you.

We may also request information from you that is necessary to establish your identity. We may also ask you for information that is necessary to verify your identity, such as copies of your passport or ID card. If you apply for a position, you will need to provide a copy of your current resume.

If we require certain personal data due to legal requirements or in the context of a contract with you and you are unable to provide us with this data upon request, we may not be able to provide the service as agreed, or we may not be able to enter into a contract with you. However, we will inform you in advance. If we cannot provide certain data, we may have to terminate our contractual relationship with you.

Contact details

Contact details include billing address, postal address, email address, and phone numbers for communication.

Compliance data (AML and KYC)

Compliance data (AML and KYC) includes the following information and documents related to ongoing checks regarding our customers or their representatives, shareholders, founders, beneficiaries, directors, if the customer is a legal entity: a copy of the ID, the "KYC" due diligence report, and any other documentation required from time to time by the Prevention of Money Laundering Act (Chapter 373 of the Maltese laws) ("PMLA"), the regulations for the prevention of money laundering and terrorist financing, and/or as required by other competent authorities or relevant legislation.

Supporting data

• The current situation of the customer, their plans, interests, goals, or objectives;
• Requested and provided services for the customer.

Financial data

Financial data includes the customer's bank details as well as information about any payment methods the customer uses to settle our invoices, and, if necessary under certain circumstances, the financial situation and creditworthiness of the customer.

Transaction data

Transaction data includes details of invoices issued to the customer (including payment date and payment methods), payments to and from the customer, and outstanding invoices to the customer.

Technical data

Technical data includes your IP address (Internet Protocol), your login details, browser type and version, time zone setting and location, types and versions of browser plugins, operating system and platform, as well as other information about your experiences with the website, such as page response times, loading errors, the duration of your visit to certain pages, information about your interaction with the page (e.g., scrolling, clicking, and hovering) and the methods by which you navigate to the pages.

Location information: We may obtain information about your location and may be able to determine your location based on your IP address and, if you access the website via a mobile device, based on the data we collect from that device. This includes information about wireless networks or cell towers near your mobile device at the time of access.

Our website uses cookies to distinguish you from other users of our website. This helps us provide you with a quality surfing experience on our website and allows us to improve our website. For more information about the cookies we use and the purposes for which we use them, please read our cookie policy.

Marketing and communication data

Marketing and communication data - your preferences for receiving promotional material from us and our third parties or affiliates, as well as your preferences regarding the manner of your communication. This may include information about whether you have subscribed to or unsubscribed from one of our newsletters, whether you have attended one of our events, or accepted one of our invitations.

We also collect, use, and process any other personal data that you voluntarily provide or communicate to us when it is appropriate and necessary to provide the services you requested.

5. How your personal data is collected

Personal data may be provided by you in the following cases:

• Filling out the inquiry form on the website,
• Correspondence with us by post, phone, email, or otherwise in the context of submitting an application for our services,
• Subscribing to our services or publications,
• Requesting a quote to be sent to you,
• Testimonials about our services,
• Entering into negotiations or concluding a contract.
• If you visit our website, we automatically collect technical data.
• We may also obtain personal data about our visitors from various third parties and publicly available sources (Google Analytics advertising features including Google AdWords, Facebook Pixel, Google Tag Manager, LinkedIn, and other specialized paid media partnerships).
• Identification, contact, and reference data from publicly available sources, verification databases, and/or providers of verification data in the EU and outside the EU, so that we can ensure that you are a suitable customer or supplier for us.

6. How we use your personal data

We use personal data:

• To facilitate the format for providing the requested services under the contract we enter into or have entered into with you,
• When our legitimate interests (or those of third parties) require it and when your interests and rights do not override these interests,
• Compliance with legal or regulatory requirements,
• Resolving issues you report and providing support services,
• To manage our relationship with you as a supplier,
• To manage our website and internal operations, including troubleshooting, and to ensure the security of our website,
• To improve the performance of our website and to make the content as effective as possible for you,
• Ensuring that all information on the website is presented in a user-friendly manner.

7. Legal basis for data processing

We process your personal data only to the extent necessary for us to provide our services, and/or for the purposes mentioned in this privacy policy.

We may also process your personal data on the basis of legitimate interests or to fulfill legal obligations. These interests and obligations may include the exercise of or defense of legal claims or compliance with a court, tribunal, or authority order, and the disclosure of information to a government or regulatory authority.

For the processing of your personal data, we generally do not require separate, legally secured consent. However, if your consent is required, we will provide you with a form to request the processing of personal data.

8. Marketing

At your request, you will receive promotional communications by providing us with your data through this website and your consent to receive such information. If we have entered into a business relationship with you (i.e., have concluded a contract) with you, we may inform you about our activities, offers, or other information that we believe may be useful to you in accordance with our legitimate interests.

We do not share your personal data with third parties for marketing purposes without your consent.

You have the right to withdraw your consent or unsubscribe from receiving promotional information at any time by clicking on the "Unsubscribe" button. Once you withdraw your consent or if you disagree with any of the following points, we will no longer send you any further marketing communications. If you choose not to give consent or cancel your subscription, we may provide our services to the extent possible without the information required for the provision of all services. This may impact the efficiency with which we provide the services you requested.

9. Disclosure of your personal data

We reserve the right to disclose your personal data to one of our international branches or companies within our company that act as joint controllers or data controllers for our company. These offices or companies will be responsible for controlling your data in the provision of our services, and/or they will take over the management, control, and reporting. All our companies respect and protect the security of your personal data in accordance with applicable legislation (including GDPR) and implement all measures to protect your data.

We may need to disclose personal data to government agencies and authorities in the country where you apply for your residence or citizenship. We will only disclose such information to the extent necessary for the provision of services in accordance with our contract with you.

It may be necessary for us to disclose your data to local representatives or other contractors (to process the data) to provide the services you requested. These local representatives and suppliers store and process your data on a strictly confidential basis and with appropriate security measures and safeguards.

We may also disclose your data to other third parties that act as data controllers, such as legal, tax, real estate, immigration, or other advisors and representatives, (international) banks for payment information, or to third parties that provide other or additional services or products for you, such as real estate agents, owners, or developers, with whom you may wish to interact under separate terms. These third parties process your data under their own privacy policies and procedures.

We may also disclose or share your data when we are required to do so to comply with legal requirements, a court order, or at the request of a court, tribunal, or authority. We may also disclose your data to enforce our terms of use or to protect our rights, property, or the safety of our partners or other users of our website. This includes sharing information with other companies and organizations for the purposes of preventing money laundering or due diligence, compliance with laws against bribery or corruption, and/or to protect against fraud.

10. Transfer of data to third countries

If we transfer your personal data to third parties, this may involve transferring your data outside the EEA. We transfer your personal data in accordance with standard contractual clauses to ensure that your personal data is protected and securely transferred in accordance with applicable law, including GDPR.

All business units of IMIN Malta Limited act as EU data processors for other business units based outside the EEA.

11. Access of third parties to your personal data

We work closely with third parties in providing services. These third-party providers include cloud storage providers, analytics providers, and search engine information providers. We only work with third parties when they comply with applicable laws in the respective countries where we operate and follow GDPR to ensure a high level of security and protection for your personal information.

12. Data security

We take all necessary security measures against the unlawful or unauthorized processing of personal data and against accidental loss or damage to personal data. Furthermore, we provide access to your personal data only to those employees, representatives, service providers, and other professional third parties who need to know this information. These will treat your personal data strictly in accordance with our instructions and maintain confidentiality. All our employees and representatives have been adequately trained in data protection.

The transfer of information between our website and your device is protected by security certificates (Transport Layer Security (TLS) certificates). When the website is accessed with compatible browsers, this technology protects personal data by using both server authentication and data encryption to ensure the security of personal data during transmission.

All personal data is stored on a secure server that has a firewall and other advanced technology to protect against manipulation or unauthorized access. Usernames and passwords are issued to individuals who are authorized to access personal data, our employees, who are bound to confidentiality and are not authorized to disclose personal data.

No method of data transmission is 100 percent secure, and it is therefore impossible to guarantee absolute security.

13. Data retention

We retain your data only as long as necessary for the purposes for which it was collected (i.e., to provide you with our services or to fulfill legal, accounting, or reporting requirements).

We will retain your personal data only as long as necessary to fulfill the purposes for which it was collected (to provide services and continue our business relationship with you), and beyond that for the purposes of fulfilling legal or accounting requirements, taxation, anti-money laundering, for the purposes of required reporting or for the purposes of obligations imposed on us. We may need to retain your personal data to be able to initiate, exercise, or defend possible future legal actions against you or to involve you in other ways.

In general, we will not retain your personal data for longer than six (6) years from the date of termination of the contractual relationship. This retention period allows us to use your personal data for the following purposes: reporting obligations for AML/CFT purposes to the FIAU (legal obligation) and/or for approvals, submissions, or to defend against possible legal actions affecting you.

14. Data minimization

Where possible, we anonymize the data we have stored about you when it is no longer necessary to identify you based on that data.

15. Your rights as a data subject

You are entitled to exercise the following rights under the LOA:

1. Right of access to information: You have the right to request information about whether your personal data is being processed by us, and information about how and why it is being processed.
2. Right to object: You can contact us at any time to request that we stop using your personal data.
3. Right to rectification: You have the right to rectify and correct inaccuracies in your personal data used by us.
4. Right to erasure: You have the right to request the deletion of your personal data that has been transmitted to us when it is no longer needed.
5. Right to restrict processing of personal data: You have the right to restrict our right to use your personal data under certain circumstances.
6. Right to data portability: We will provide you or a third party of your choice with your personal data in a structured, commonly used, electronic format.
7. Right to withdraw consent: If you have given your consent for the collection, processing, and sharing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific transaction at any time.

16. Legislation on contentious issues

The privacy policy and all disputes regarding its application are subject to the laws of Malta. You hereby agree that the courts of Malta have exclusive jurisdiction over all claims, disputes, or controversies in connection with the obligation statement and all matters arising therefrom. Each party irrevocably waives its right to assert that the claim was filed in an inconvenient location or that these courts are not competent.

17. Changes to this Privacy Policy

Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, sent to you by email.

18. How to contact us

If you have any questions or comments about this privacy policy, please contact us today using the contact information (see section 3, "Data Controller").