Brand Ventures Ltd. understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, (“the Website”), and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
2. Information About us
The Website is owned and operated by Brand Ventures Ltd., a company incorporated under the Laws of Malta and bearing company registration number C-92940
Registered address: 5, Triq Mula, Zebbug. ZBG 2293 Malta
Data Protection Officer (DPO) may be contacted as follows:
Postal address: 5, Triq Mula, Zebbug. ZBG 2293 Malta
3. What Does This Policy Cover?
4. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018, Chapter 586 of the Laws of Malta and subsidiary legislation (collectively, “the Data Protection Legislation”) as an ‘identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier.’
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights:
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Office of the Information and Data Protection Commissioner (idpc.org.mt / (+356) 2328 7100 / firstname.lastname@example.org). However, we would welcome the opportunity to resolve your concerns ourselves, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
We do not collect any ‘special category’, ‘sensitive’ personal data, personal data relating to children or data relating to criminal convictions and/or offences.
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will or may use your personal data, and our lawful bases for doing so:
Furthermore and without prejudice to the aforementioned, with your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation, and you will always have the opportunity to opt-out.
We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We will keep your data for the minimum length of time required to comply with the purposes set out in this policy and relevant legal or regulatory obligations. Your personal data may be kept longer if we cannot delete it for technical reasons. For further information about our data retention periods, please do not hesitate to contact us.
9. How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EU and under the Data Protection Legislation as follows.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
10. Do You Share My Personal Data?
We may share your personal data with other companies in our group in order to respond to queries you send to us.
Furthermore, we may sometimes contract with third parties to supply certain products or services and this may require that your personal data is disclosed to third parties. We may share your personal data with the following:
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the Data Protection Legislation, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via the Website, we receive the data directly from you and confirm that it is only to be used to be able to reply back to you directly. You have the option of declining this option, however we will not be able to reply to your enquiry without your consent. In particular, we do not practice email marketing, hence we do not use any data for direct marketing purposes.
12. Can I Withhold Information?
You may access certain areas of the Website without providing any personal data at all. However, to use all features and functions available on the Website you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request as soon as reasonably practicable but in any case not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Cookies are means a small file placed on your computer or device by the Website when you visit certain parts of the Website and/or when you use certain features of the Website.
By using the Website, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us . Third-party Cookies are used on the Website for web-analytical purposes and to collect and analyse information about site performance and usage. These Cookies are not integral to the functioning of the Website and your use and experience of the Website will not be impaired by refusing consent to them.
We may use some or all of the following types of Cookie:
Strictly Necessary Cookies – A Cookie falls into this category if it is essential to the operation of the Website supporting functions.
Analytics Cookies – It is important for Us to understand how you use the Website, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve the Website and your experience of it.
Functionality Cookies – Functionality Cookies enable Us to provide additional functions to you on the Website such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
Targeting Cookies – It is important for Us to know when and how often you visit the Website, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make the Website and advertising more relevant to your interests. Some information gathered by targeting Cookies may also be shared with third parties.
Persistent Cookies – Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit the Website.
Session Cookies – Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit the Website until you close your browser. Session Cookies are deleted when you close your browser.
All Cookies used by and on the Website are used in accordance with current applicable law.
Before Cookies are placed on your computer or device, you will be shown a prompt/pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
Certain features of the Website depend on Cookies to function and are, as such, considered to be “strictly necessary” in terms of applicable law. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that the Website may not work properly if you do so. we have taken great care to ensure that your privacy is not at risk by allowing them.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings. The links below provide instructions on how to control Cookies in all mainstream browsers:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)
Safari (iOS): https://support.apple.com/en-gb/HT201265
Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of (DPO)
Postal Address: 5, Triq Mula, Zebbug. ZBG 2293 Malta
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.