Elia Borg Bonaci Ltd takes Data protection very seriously and invests in resources to ensure that personal data is protected through processes that are by design targeted at keeping personal data safe. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR). By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, Elia Borg Bonaci Ltd has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed.
The Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Elia Borg Bonaci Ltd ,68, Villambrosa Street, Hamrun.
HMR 1129. Malta.
What data do we collect and why do we store and process your Personal Data?
Elia Borg Bonaci Ltd collects a series of general data and information when a data subject either becomes a member by coming physically to our premises or through other communication channels. This data and information is stored securely either on a centralised server or on one of the club’s computers. Generally, when a data subject visits our premises we collect the following: Name & Surname, Address, Telephone and Mobile numbers and email addresses.
When using our website we may collect the above personal details as well. Our web hosting provider also collects data through their server logs such as (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (referrer), (4) the date and time of access to the Internet site, (5) an Internet protocol address (IP address), (6) the Internet service provider of the accessing system, and (7) any other similar data and information that may be used in the event of attacks on our information technology systems.
The data collected is never used by Elia Borg Bonaci Ltd to draw any conclusions about the data subject. Rather, this information is needed to help us deliver the level of service that we feel our members deserve. We use this data to be able to contact our members and also to offer them new services and offers from time to time. Subscription to these offers and services will require separate consent from our members. Offers may be sent to data subjects through various channels such as: Email Marketing and printed material by post.
Elia Borg Bonaci Ltd analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files, if any, is stored separately from all personal data provided by a data subject.
Where we are obliged to process your personal data in fulfilment of a legal requirement to which we are subject, or in pursuance of performing an obligation under a contract which we have with you, and you fail to provide us with that data, we may not be able to perform the Services as agreed upon.
Who collects personal data?
Data is collected by
- By our representatives through physical contact;
- Through our website and social media pages;
- Through emails opened and actioned by our representatives;
- Through phone calls;
- Through postal mail;
We usually retain the personal data of our members for the period during which they are considered as members. As part of the services we offer, we include periodic services as part of a structured course or programme. In this case Elia Borg Bonaci Ltd will retain the data throughout the period of the programme. As a policy, Elia Borg Bonaci Ltd retains all personal data for two years from the date of the last contact. After this period, the data subject is no longer considered a client and their data is erased unless asked to do otherwise by the data subject.
In the case of marketing communications we ask for specific permission from the data subject to retain their email address and/or phone number indefinitely. The data subject is reminded continuously in every mail shot that they may opt out whenever they like of these communications.
Who we share your data with
Elia Borg Bonaci Ltd may use third party partners to help in processing data for marketing or other purposes such as ICT, logistics and Accounting and Audit firms. We are assured that our partners handle personal data under the strictest controls. We also purposely share only the data that is required for the processing task rather than all the personal data about a data subject.
Transferring of data outside of the European Union, particularly to countries which might not have appropriate data protection safeguards in place, will be based on your consent.
Subscription to our newsletter
On our website, users are given the opportunity to subscribe to our newsletter. Elia Borg Bonaci Ltd uses this newsletter to inform its customers and business partners about its offers. The newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter and (3) if the data subject is a client and gives Elia Borg Bonaci Ltd consent (Opts in). A confirmation e-mail will be sent to the e-mail address when a user subscribes. A double opt-in procedure is employed. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter.
CCTV Cameras at our premises
Wherever we have CCTV cameras installed, their purpose is solely for security and not to monitor the movement of members or club representatives. Their purpose is simply to ensure the security of the clubs’ assets as well as the personal physical security of our members while they are at our premises. Data collected through these systems will only be divulged to third parties such as law enforcement agencies in the event of a security incident. Data on these systems is stored in a rotating manner and it is overwritten roughly every 30 days.
The processing of your data will be processed in accordance with the provision of the GDPR. Elia Borg Bonaci Ltd takes appropriate precautions to preserve your rights and prevent any corruption, loss, damage or destruction of your personal data. The club has appropriate security arrangements, including, where appropriate, limited physical access, administrative, procedural, and information ICT measures to prevent unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal or destruction of personal data. In case our systems are compromised and suffer a data breach where the personal data of our members is exposed, Elia Borg Bonaci Ltd will promptly inform the data subject and the Office of the Data Protection Commissioner.
Elia Borg Bonaci Ltd ’s representatives may access personal data strictly on a “need to use” basis for the performance of their duties. Club representatives are aware of the confidential nature of personal data and how they should handle it in strictest confidence.
How to contact us
You can contact us as follows:
Elia Borg Bonaci Ltd ,
68, Villambrosa Street, Hamrun.
HMR 1129. Malta.
Phone Number: +(356) 2124 6920, +(356) 2122 7085
Fax Number: +(356) 2125 5908
Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is erased in accordance with legal requirements.
You rights as a data subject
As a data subject GDPR provides you with extensive rights as follows:
- Right of confirmation
- Right of access
- Right to rectification
- Right to erasure (Right to be forgotten)
- Right of restriction of processing
- Right to data portability
- Right to object
- Automated individual decision-making, including profiling
- Right to withdraw data protection consent
- Data protection for applications and the application procedures
For more detailed information about your rights under GDPR, please click here
Last revision 21th May 2018