1.0 Privacy policy

Midas Management Limited (”We”) is committed to protecting the confidentiality and privacy your personal data. The information collected is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General DataProtection Regulation), or “GDPR” in short.

This Privacy Statement (“Privacy Statement”) sets out how we collect, use and process your personal data.

2.0 Definitions

‘Personal Data’ means any information relating to an identified or identifiable natural person, (the “Data Subject”) that is a person who can be identified, directly or indirectly, in particular by reference to data such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

3.0 Data Collected from our customers or the public

3.1 What data is collected and how is it used

We shall only process the Personal Data which is voluntarily provided by you for the purposes of offering you information about our services. With your consent, we can further process your Personal Data for the purpose of providing you additional services, on your request.

3.2 What data is collected? 

The Personal Data we process is collected either through our contact form available on our website or through email or verbal communication by the Data Subject. By submitting your personal information, you are acknowledging that this personal information may be processed in accordance with this Privacy Statement.

3.2.1 Data collected through the website

The information we collect through our Contact Form is:

• Your name and surname
• Your contact number
• Your Email address

Some other information may be collected anonymously because you accessed this website. Such information may include you IP address and cookies. This information is unidentifiable and will not, under any circumstance, be used as a means to identify the DataSubject.

3.2.1.1 What will you do with the Personal Data collected through the website? 

We will use the Personal Data collected through the Contact Form only to contact you and explain our services or reply to any query you might have.

The data we collect through the website will only be processed in accordance with this Privacy Policy.

3.2.2 Data collected through email or verbal communication

The information collected shall be voluntarily given by the Data Subject and may include all data which is necessary for the performance of the services requested. The data requested shall be commensurate to the specific needs for the particular processing.Typically, such data may include your identification number, your telephone or mobile number, you address or any other data which may be specifically required for the proper performance of the service.

3.2.2.1 What will you do with the Personal Data collected through email of verbal communication?

We will process this Personal Data for the whole duration of the services. Your Personal Data may be used to provide you the services requested, to issue our bills and to keep regular communication with you. You Personal Data will only be processed in accordance with this Privacy Policy.

3.3 What about my Sensitive Data?

Special categories of Personal Data require higher levels of protection and we need to have further justification for collecting, storing and using this type of Personal Data (“Sensitive Personal Data”). We may process special categories of Personal Data in limited circumstances, with your explicit written consent and solely for the purposes of providing you with the services you have specifically requested and which require this type of special data.

We will not use Sensitive Personal Data for any other purpose which is not included in this Privacy Policy, unless such use is required or authorised by Law.

You will be asked to provide such sensitive data on a case by case basis.

3.4 Refusal to provide your Personal Data 

Whenever your Personal Data is required for processing, you will always be asked to provide such data. You are free to refuse in providing such data, but if you fail to provide this Personal Data, we may not be able to perform our services to your satisfaction.

3.5 How long do you retain my Personal Data? 

We retain the Personal Data that we collect from you only for as long as required us for to comply with an individual’s request, with legal, tax or legitimate interest purposes. You may also ask us to delete your personal information. Where such deletion is not possible due to legal, fiscal or business requirements, it will be anonymised so that it will not be linked to you or in any way identifiable.

Your information is retained in electronic or paper format or both. When it is no longer required, it will be deleted or destroyed.

3.6 How may we share you Personal Data? 

We will not share the personal data you provide us through the website.

If you choose to engage our services, we may share your Personal Data with our third party suppliers, or the suppliers of the services you request. This is generally required for the performance of services with You in order to provide you with the services your require, for pricing or quotes.

We may also share Your Personal Data with third parties in those cases required or permitted by law. In all cases, the sharing of Your Personal Data is made subject to appropriate confidentiality safeguards.

4.0 What are the legal grounds on which we process your Personal Data? 

We will collect only the Personal Data necessary to fulfil your request. Where additional information is required from you, we will notify you of such requirement.

The GDPR allows us to process your Personal Data as long as we have a legal basis on which to do so. The legal basis we rely upon are:

Providing Information: this is when you contact us through the website with your queries and we contact you back to discuss your query and assist you;

Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;

Booking Services: this is when you engage us to book services on your behalf and in your name. In order to book these services, we will need to provide third party suppliers with your Personal Data;

Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;

Your consent: all personal data in our possession is there because you provided it to us, knowing that we shall process it for the purposes of providing you the required services. We will process your Personal Data in accordance with your consent. If we require to process your data for purposes other than those for which you provided your consent, we will request your additional consent, unless such purposes are required or permitted by law. 

5.0 Data security and integrity

We will take reasonable steps to ensure that your Personal and Sensitive Personal Data is processed in a secure and reliable way and protected from loss, unauthorised use, misuse, alteration, or destruction. Despite our best efforts, however, we cannot guarantee security against all threats. 

6.0 How is your Personal Data processed? 

Your Personal Data shall only be used for the purposes for which it was collected. Your personal information will not be used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law to use your data for such other purposes.

7.0 Transfer of Personal Data outside of Malta:

7.1 Transfers of Data Within the EU/EEA:

Your Personal data may be transferred to another EU/EEA country which is a party to the GDPR. Such transfer shall only be made as is required for us to comply with your requests and to provide you the service you require. 

7.2 Transfers Outside the EU/EEA:

Your Personal data may be transferred to countries that are not part of the EU/EEA. Such transfer shall only be made if there are appropriate safeguards and strictly as required for us to comply with your requests and to provide you the service you require.

8.0 What are my Rights?

You have the following rights the data we process: 

• To ask us regarding the nature of information we hold and to whom it has been disclosed (“Subject Access Request”);
• To ask us to rectify, block, erase, (including the right to be forgotten), or destroy inaccurate data;
• To request us to provide the Data which you provided to us in a structured, commonly used and machine-readable format for onward transmission by you to another entity,

If you wish to exercise any of these rights you may contact our Data Protection Officer on [email protected]  

You also have the right to complain to the Office of the Information and Data Protection Commissioner. 

9.0 Cookies

9.1 What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

Enabling these cookies is not strictly necessary for the website to work but it will provide you with a better browsing experience. You can delete or block these cookies, but if you do that some features of this site may not work as intended.

The cookie-related information is not used to identify you personally and the pattern data is fully under our control. These cookies are not used for any purpose other than those described here.

9.2  How do we use cookies?

Our website makes use of the following types of cookies:

Necessary Cookies, which help make Our website usable by enabling basic functions like page navigation and access to secure areas of the website. Our website cannot function properly without Necessary Cookies.

Statistics Cookies, which help Us understand how You interact with websites by collecting and reporting information anonymously. Statistics Cookies register a unique ID which is used to generate statistical data on how You use Our website.

Marketing Cookies, which are used to track visitors across websites. We use Marketing Cookies in order to display advertisements which are relevant to You.

9.3 How do I control cookies?

You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

10.0 IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

11.0 Changes to this Privacy Policy

We keep our privacy policy under regular review.  If any change in this privacy policy will affect the way we collect or process any personal information, you will be provided with prior notice via email. Your continued use of services or websites after any change to this privacy notice will constitute your acceptance of such change.