PRIVACY POLICY FOR INTERCONNECT MALTA

This Privacy Notice provides information on the processing of personal data by InterConnect Malta Limited in connection with the performance of its objectives and the exercise of its functions.

Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession.

Who are we?

InterConnect Malta Limited is the controller of personal data in terms of 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 Data Protection Regulations – the ‘GDPR’) and Data Protection Act (CAP. 586 of the Laws of Malta – the ‘DPA’).

InterConnect Malta Limited (‘InterConnect/We’) ensures that personal data is processed in accordance with the GDPR, the DPA and any other relevant national and European Union (‘EU’) law. We ensure inter alia the confidentiality and security of such personal data.

This Privacy Notice outlines the types of information that are collected and recorded by InterConnect Malta and how we use such information. We will make every effort to ensure that our activities keep within the spirit of this Policy. If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

What informaton does InterConnect gather about you and how is it being used?

InterConnect Malta collects, uses, shares or otherwise processes personal information that you provide to us when you use our website or when you conduct activities with us in the performance of our functions, supply us with products or services, or otherwise communicate with us, such as for the submission of a query or to lodge a complaint. We also process data which relates to you, that we may otherwise obtain or generate, through other publicly available sources, such as the electoral register.

The personal information that InterConnect Malta collects about you when you communicate with us for any of the aforementioned purposes may include:

  • Your name and surname;
  • Email address and address;
  • Phone number;
  • Your identity card number;
  • Financial and other commercial information as may be required in terms of public procurement regulations;

As a website user, the personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

Use of your personal information

InterConnect Malta will process any personal data provided by you (other than as a website user) as outlined above for all or any of the following purposes:

  • To keep and manage an up-to date database of its suppliers, tenderers and other third parties we have dealings with;
  • Communicate with you to follow up on your queries, to inform you of any important matters which may require your attention, to provide you with information as may be required;
  • To send important notices, such as changes to our policies;
  • For internal purposes such as auditing, internal management and administration, research and statistics;
  • To ensure we have up-to-date contact information for you;
  • To prevent, detect and/or prosecute any illegal and/or criminal activity which we are bound to report and to meet any other specific legal or contractual obligations;
  • To establish, exercise or defend any legal action;
  • To protect and promote the our legitimate interests and the proper performance of our objectives;

As a website user, we use the information we collect in various ways, including to:

  • Provide, operate, and maintain our website
  • Improve, personalize, and expand our website
  • Understand and analyze how you use our website
  • Develop new features, and functionality
  • Communicate with you to provide you with updates and other information relating to the website
  • Send you emails
  • Find and prevent fraud

Log Files for Website Users

InterConnect Malta follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this as a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.

Cookies and Web Beacons for Website Users

Like any other website, InterConnect Malta uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information. For more general information on cookies, please read “What Are Cookies”.
InterConnect Malta also be required to processes your personal data for the purpose of:

  • Compliance with applicable laws, rules, regulations, guidance and codes;
  • Compliance with demands or requests made by local and foreign regulators, governments, courts and law enforcement authorities, and complying with a court process, or in connection with any litigation;

On what basis does InterConnect use your personal information?

  • For the performance of a contract: InterConnect process your personal data as necessary in order to execute an agreement entered into with you.
  • With your consent: InterConnect will process your personal information when you have given your consent to the processing of your personal data for any other purpose. You have various rights where we process your information on the basis of your consent. You may withdraw your consent for any such processing at any time.
  • To promote a legitimate interest: InterConnect may have a legitimate interest to process your personal data in circumstances which are not directly related to the exercise of its functions, such as for security purposes.
  • To comply with a legal obligation: There may be instances where InterConnect is legally obliged to process your personal information.

Recipients and sharing of your personal information

Your personal information will be received and processed by InterConnect’s representatives and employees, depending on the nature of the personal information:

We may also share your personal information with any of the following:

  • Other entities as necessary in order to process any request made by you or to give effect to any contractual obligations entered into with you;
  • Any service providers who may have access to the personal data held by InterConnect, strictly as required in order to provide us with the required service.
  • Our professional advisors and auditors strictly as required for consultation purposes or for compliance with our legal obligations;
  • Regulators, governments and law enforcement authorities as and when this is required under applicable laws and regulations;
  • Courts, tribunals, arbitrators or other competent bodies who may have authority to request such personal information;

Transfers outside the European Union

InterConnect does not intend to transfer personal data outside of the European Union. In the event that this is necessary, the countries to which your personal information would be transferred may not offer an equivalent level of protection for personal information to the laws of Malta. Where appropriate, we will take steps to ensure your information is transferred subject to appropriate safeguards, such as by entering into data transfer agreements. Where we have put data transfer agreements or similar safeguards in place, we may be able to make a copy of this available to you if you contact us via one of the methods set out under the header “Contact Us” below.

How long will InterConnect keep your personal information?

We have a data retention policy that sets out how long we keep your information. This policy is based on the type of information, the purpose of collection, and the system within our digital platforms in which the information is held. As a general rule, we keep your personal information for as long as we need to in order to carry out those purposes for which your data has been collected.

Security

InterConnect uses reasonable efforts to safeguard the integrity, availability and confidentiality of all personal data that it processes relating to you and regularly reviews and enhances its technical, physical and managerial procedures so as to ensure that your personal data is protected from:

  • Unauthorised access;
  • Improper use or disclosure;
  • Unauthorised modification;
  • Unlawful destruction or accidental loss.

To this end we have implemented security policies, rules and technical measures to protect the personal data that InterConnect has under its control. All our employees and data processors, who have access to and are associated with the processing of personal data, are further obliged to respect our data subjects’ confidentiality.

Third Party Privacy Policies

InterConnect Malta’s Privacy Policy does not apply to other websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party websites for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

GDPR Data Protection Rights

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

The right to complain to a competent supervisory authority, or to a court of law, if your data protection rights are violated or you have suffered as a result of unlawful processing of your personal information.

If you would like access to the information that we hold about you, if any of the information that we hold about you is inaccurate or out of date, or if you wish to withdraw your consent to the processing of your data or to restrict or object to us processing it, please let us know by getting in touch via one of the methods set out under the header “Contact Us“ below.

If you object to our processing of your personal information, we will respect such requests in accordance with our legal obligations. Your objection may mean that we may not be able to perform the actions necessary to achieve the purposes set out above.

InterConnect may be required or entitled to retain your information to comply with legal and regulatory obligations and to protect and exercise our legal rights and legitimate interests.

In addition to those rights outlined above you also have an unconditional right to object at any time to the processing of your personal information for direct marketing purposes by contacting us via one of the methods set out under the header “Contact Us” below.

Contact Us

The Data Protection Officer may be contacted on:

Address

 

The Data Protection Officer

InterConnect Malta

12, Triq Spiru Mizzi

Birkirkara BKR 1762

Malta

Telephone

 

(+356) 22208600

 

Email

 

 

info@icm.mt

Changes to this Policy

Should we update, amend or make any changes to this document, those changes will be prominently posted here.

Version 1.01 Date: 25th August 2022