Privacy Policy - Client Contact Person

Welcome to Broadwing Limited’s client contact privacy notice (the “Notice”).

Broadwing Limited (C84543) (“BL”, “we”, “us” or “our”) having its registered office at Vault 14, Level 2, Valletta Waterfront, Floriana, FRN 1914 (Phone No.: +356 2017 3007, Email: admin@broadwing.jobs), Malta – EU and its affiliates and subsidiaries, respect privacy and are committed to protecting personal data when acting as controller in respect of Your personal data. We have obtained Your personal data in the process of doing business with the entity whom You represent, ‘the Client’, and will process the personal data as necessary in particular, We may communicate with You and send the relevant notifications to You on behalf of the Client as designated contact person in the agreement between Us and the Client.

This Notice is provided in a layered format so you can click through to the specific areas set out below.

  1. What personal data does the Company collect, purpose and Legal Basis?
  2. Third Parties Receiving Data
  3. Location of Data & Transfers to Third Countries
  4. Data Retention Period
  5. Your Rights
  6. Breach
  7. Transitory Provisions
  8. Version History

1. What personal data does the Company collect, purpose and Legal Basis?

We will process the following personal data on Your behalf as provided by the Client (a) Name and surname, (b) Email, (c) Telephone No., (d) Mobile No.;  (e) CCTV footage. This personal data is processed in order to perform our contract and provide the services to the Client. Furthermore, when visiting Our premises, you are advised that said premises are monitored by CCTV and access control systems for security purposes and that recordings from such systems may be used as evidence in case of any investigation. This is carried out in order to protect your vital interests as well as in furtherance of our legitimate interest to protect our premises.

2. Third Parties Receiving Data

We will process the following personal data on Your behalf as provided by the Client (a) Name and surname, (b) Email, (c) Telephone No., (d) Mobile No.;  (e) CCTV footage. This personal data is processed in order to perform our contract and provide the services to the Client. Furthermore, when visiting Our premises, you are advised that said premises are monitored by CCTV and access control systems for security purposes and that recordings from such systems may be used as evidence in case of any investigation. This is carried out in order to protect your vital interests as well as in furtherance of our legitimate interest to protect our premises.

3. Location of Data & Transfers to Third Countries

We may transfer your personal data outside the EEA in any of the following circumstances:

  1. the transfer is necessary for the performance of a contract between you and BL or for the implementation of pre-contractual measures taken at your request;
  2. the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and another natural or legal person;
  3. the transfer is necessary for important reasons of public interest; or
  4. the transfer is necessary for the establishment, exercise or defence of legal claims.

In certain cases we may transfer your personal data to our third party suppliers, such as IT and system support providers which may be located outside of the EEA. In such cases we have agreements in place to regulate the processing of personal data and ensure that your personal data is handled responsibly and in line with applicable data protection laws.

In particular we may transfer your personal data to the RocketGroup LLC which operates MailChimp which is a marketing service. This service provider is subscribed to the EU-U.S Privacy Shield and any transfers of personal data are carried out on the basis of this adequacy decision.

4. Data Retention Period

Any personal data concerning Your contact details is retained for as long as you remain the Client’s contact person. In the event that You cease to be the Client’s contact person while the agreement with the Client is still in force, Your details will be archived and replaced with those of the new contact person. The agreement between Us and the Client will be retained throughout the duration of the agreement and for a period of five (5) years thereafter so as to enable the Company to establish or defend any legal claim. Thereafter, certain documents, such as the agreement, invoices and receipts may be kept for up to ten (10) years from termination of the Services Agreement (or from date of invoice/receipt) in order for the Us to comply with our book-keeping, tax and VAT record keeping obligations. All CCTV footage is deleted after 7 days unless there is an over-riding interest to keep such personal data, such as in cases where there is a legal claim or an ongoing investigation.

5. Your Rights

You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at admin@broadwings.jobs at any time. You have the following rights:

5.1 Access to your information

You may, at any time submit a request to know what information is held in your regard, if any. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the European Economic Area (“EEA”).

5.2 Rectification

We will use our best endeavours to update and maintain the data as accurate as possible within a reasonable time. You may, at any time, submit a request to have any inaccuracies corrected. We assume no responsibility or liability for the accuracy or correctness of any data provided if changes are not communicated to us.

5.3 Right to be forgotten

Where processing is based on consent and in other specific circumstances You may request to have any or all of your details erased. You can ask us for further information on these specific circumstances by contacting us using the details below. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details below.

5.4 Restriction of processing

You may, at any time, submit a request to restrict the processing of your data. You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details below. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are using the contact details below.

5.5 Right to data portability

You may request to receive your personal information in a structure commonly used and machine readable format and have it transferred to another controller. This right only applies where we use your personal information on the basis of your consent or performance of a contract and where our use of your information is carried out by automated means.

5.6 Right to object and automated individual decision-making

Where processing is based on the performance of a task in the public interest or based on our legitimate interests, You may object to the processing, however, this is subject to any of our overriding interests including in particular compliance with legal requirement on our part. In such case we will aim for a result that is mutually satisfactory such as taking your personal information off the live environment and archiving it for the necessary period to enable us to comply with our legal requirements.

5.7 Right to object to direct marketing

You may object to the processing of your personal data for the purpose of direct marketing. In the event of such an objection, We will no longer be able to provide the Entity with updates regarding our products and services. You may, provide an alternative email address to which direct marketing should be sent.

 

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.  If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make.

6. Breach

You are advised that should you feel that We have breached our commitments in terms of this Privacy Statement you may file a complaint with Us on admin@broadwings.jobs or directly with the Malta Information and Data Protection Commissioner.

7. Transitory Provisions

This Privacy Statement is being issued on the date below stated following a review of the relevant processes in compliance with the GDPR and shall apply to the processing of Your personal data as from the date of issue.

8. Version History

  • Current: V1 – 25/05/2018

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