This policy relates to both personal data that we have collected ourselves or acquired for our use, as well as data which has been provided to us by our clients and which we use to provide a service.
- When Nicotine Pouches Malta determines the purpose and means of processing of personal data collected, they are considered the Data Controllers.
- When Personal data is collected and processed by Nicotine Pouches Malta on behalf of their clients who determine the purpose and means of processing Nicotine Pouches Malta acts as a data processor.
This policy has been updated for the General Data Protection Regulation (GDPR). We are committed to protecting your privacy and the security of your personal data. We will not give or sell your information to any other company. We will only use such information to provide you with our services and keep you updated.
How do we collect your personal data?
We may collect your personal data when you:
- Visit our website;
- Contact us by phone or email;
- Engage with us on social media
- Sign any of our service/product contracts
- Fill out any form of information (eg. Contact Us Form)
What type of personal data do we need?
Our Personal Data Protection Policy governs the use and storage of your data. You can a copy of our Personal Data Protection Policy by contacting our Data Protection Officer, in writing, at email@example.com
Nicotine Pouches Malta is a data processor of the personal data our clients (our client and data controller) provide us with and of which our clients determine the purpose and means of processing.
We collect the following types of personal data from you to offer you a service therefore acting as data processors on your behalf:
- Your name
- Your surname
- Your address
- Your telephone number
- Your mobile number
- Your email address
- Information related to the browser or device you use to access our website
We use reasonable efforts to safeguard the confidentiality of any and/or all Personal Data that we may process relating to our clients and regularly review and enhance our 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 and organisational measures to protect the Personal Data that We process on behalf of our clients. All our members, staff and sub data processors (including specific subcontractors), who may have access to and are associated with the processing of Personal Data, are further obliged (under contract) to respect the confidentiality of data subject’s Personal Data as well as other obligations as imposed by the Data Protection Laws.
Why we need your personal data?
We need your personal data:
- to establish and fulfil a contract with you, for example, if you enter into an agreement to provide or receive services. We require this information to enter into a contract with you and are unable to do so without it;
- to maintain an effective communication channel with you throughout the execution of a service/job, to manage our relationship with you as our customer and to improve our services and enhance your experience with us in the future;
- to respond, with your express consent, to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our products or services;
- to personalise (i) our communications to you; provide you with (ii) updates on any services/products we are providing you with (iii) updates on any jobs where your services may be required; and (iv) products or services for you, in accordance with our legitimate interests;
- to protect Nicotine Pouches Malta’s legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
- to receive payment for any products/services provided
Where applicable and allowed, you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic communications at any time by following the instructions in the relevant communication.
What we do with it?
Your personal data is processed in our offices in Qormi located in the Malta. Hosting and storage of your data takes place on our servers located in Amsterdam, Netherlands.
We may also share your personal data with the below third parties;
- Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us;
- Our professional advisors such as our auditors, consultants and external legal and financial advisors
No other third-party providers have access to your data, unless specifically required by law.
How long we keep it?
As data processors on behalf of our clients:
Under Maltese law, we are required to keep your documents according to your (our client) Data Retention Policy. After this period, your personal data will be irreversibly destroyed. Any personal data held by us for marketing, service update notifications and requests for services or products required by Nicotine Pouches Malta, will be kept by us until such time that you notify us that you no longer wish to receive this information. We will not retain your data for longer than you (our client) stipulate.
We will keep your information for the length of any contractual relationship you have with us and after that for a period of 10 years due to fiscal laws that impinge on Nicotine Pouches Malta. In cases of legal issues, these are retained until the relevant court case is resolved.
As data controllers:
Under Maltese law, we are required to keep your documents according to our Data Retention Policy. After this period, your personal data will be irreversibly destroyed. Any personal data held by us for marketing, service update notifications and requests for services or products required by Nicotine Pouches Malta, will be kept by us until such time that you notify us that you no longer wish to receive this information.
We will not retain your data for longer than is necessary to fulfill the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
What are cookies and how do we use them?
There are generally two categories of cookies used on our Sites:
- Functional: These cookies are required for basic site functionality and are therefore always enabled. These include cookies that allow you to be remembered as you explore our Sites within a single session or, if you request, from session to session.
- Third party: Third party cookies offer the possibility to connect you to your social networks and share content from our Sites through social media. Advertising cookies (of third parties) collect information to help better tailor advertising to your interests, both within and beyond our site. In some cases, these cookies involve the processing of your personal data. Refusing these cookies may result in seeing advertising that is not as relevant to you or you not being able to link effectively with Facebook, Instagram, or other social networks and/or not allowing you to share content on social media.
You can always change your preference by updating the browser settings to restrict, block or delete cookies from Nicotine Pouches Malta or send us an email on firstname.lastname@example.org
For a comprehensive and up-to-date summary of every third-party accessing your web browser, we recommend installing a web browser plugin built for this purpose. You can also choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings on each browser and device that you use. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to many features that make our Sites more efficient and some of our services will not function properly.
What are your rights?
You have the right to request:
- access to your personal data;
- an electronic copy of your personal data (portability);
- correction of your personal data if it is incomplete or inaccurate; or
- deletion or restriction of your personal data in certain circumstances provided by applicable law.
Where we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
If you still feel that your personal data has not been handled appropriately according to the law, you can contact the Information & Data Protection Office (IDPC) located in Sliema and file a complaint with them.
Office of the Information and Data Protection Commissioner
Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, Malta