2. Personal Information – Collection & Processing
We may collect, store and use the following types of personal information:
Personal details including your name, surname, address, identification details, date of birth, citizenship, nationality, CV, email address and contact number.
Copy of your communication with us, such as emails and messages through the website, in line with our legal obligations or due to a legitimate interest.
We may hold CCTV recordings of you should you visit our offices. These are kept for the purpose of preventing crime and protecting our staff and clients.
We shall process your personal information if the scope therefor falls within at least one of the following categories:
Contractual obligation or necessity;
Vital interest of the data subject;
When processing the data is in the best interest of the public; and
It is the nature of our business to process your data mostly due to a legitimate interest.
3. Non-personally identifiable information and traffic analysis
CEEK strives to make its website as user friendly as possible and easy to find on the internet. CEEK collects data on how you use the site, which does not identify you personally. When you access the website, our servers keep an activity log unique to you that collects certain administrative and traffic information including: source IP address, time of access, date of access, web page(s) visited, and type of browser used.
We shall need your consent in the following circumstances:
When sending you direct marketing material or promotions regarding our services;
When sharing your personal information outside the Company, and outside the scope of Section 2;
When processing your personal information without having any legal basis in terms of the General Data Protection Regulation (“GDPR”).
You can withdraw your consent at any time, unless there is another legal basis that allows us to process your data as per the below section.
6. Non-Marketing Material
From time to time we may send you non-marketing material such as general information about matters that may concern you. Such material is usually sent by email. This is performed after ensuring that our legitimate interest to send you such non-marketing material would not affect your privacy in a negative manner. We shall always provide you with an option to unsubscribe from such informative material. Should you unsubscribe, we shall not send you further non-marketing material. The same would apply if you have requested or shall request that no material whatsoever is sent to you.
Whilst we perceive it a legitimate interest that we use your personal information to source employment for you, including by the disclosure to third parties, if you do not consent to disclosure of your data to our clients when there is a vacancy that suits your profile, pursuant to your selection at registration, we shall contact you to authorise disclosure on a case-by-case basis. Should you wish to change your selection, please contact us on +356 2703 0133.
IN addition to disclosure based on your consent, we may disclose your personal information:
To the extent that we are required to do so by law;
In connection with any ongoing or prospective legal proceedings;
In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information;
To any of our employees, officers, insurers, professional advisers, bankers, agents, suppliers, IT service providers or subcontractors insofar as reasonably necessary for the purposes set out in this notice (also known as Processors and sub-processors);
To any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this notice. If the Company is merged, acquired, or sold, or in the event of a transfer of some, or all, of our assets or equity, we may disclose or transfer Personal Information and usage data in connection with such transaction;
In all other circumstances where you would have given your consent.
We will not, without your express consent, supply your personal information to any third party for the purpose of their, or any other third party's direct marketing.
8. Storage & Protection
Your data may be stored in one or more of the following locations:
Physical files in our office;
A server located at our registered office;
A back-up server located in Malta; and
On Cloud which is located within the European Union.
We take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of personal information and other information transmitted to us.
You acknowledge that the transmission of information over the internet is inherently insecure and while we strive to protect information transmitted on or through the website, we cannot, and do not, guarantee the security of any information you transmit on, or through, the website, and you do so at your own risk.
We shall take the necessary steps to protect such information.
9. Your Rights
If you would like a copy of the personal information we hold about you, you should request it by emailing firstname.lastname@example.org
To ensure the security of your personal information, we may ask you for valid proof of identity and once we’ve received it we will provide our response within a reasonable timeframe.
You can obtain information regarding the processing of your personal information and access to the personal information which we hold about you by contacting us on +356 2703 0133.
For any information that cannot be updated through your account on the website, you may request rectification by sending an e-mail to email@example.com
You have the right to request that we erase your personal information if it is inaccurate or incomplete. There may be circumstances where you ask us to erase your personal information, but we are legally obliged to retain it.
You may object to the processing of your personal information however there might be circumstances where you object to, or ask us to restrict our processing of your personal information but we would be legally entitled to refuse that request.
You may instruct us at any time not to process your personal information for marketing purposes.
Personal data will be retained for as long as it is necessary for the purposes of processing such data. Thus, the Company will keep data for as long as it is obliged to by law, or need to keep a record of, a relationship with a client.
Following the lapse of the applicable retention period we shall destroy your data in a safe and reliable manner. Physical files shall be destroyed by means of shredding and data stored in digital format shall be permanently deleted, including any backups held on servers and/or cloud. Correspondence records shall also be deleted. Should the Company dispose or replace any hardware on which data is stored, we shall ensure disposal is done in a professional manner and in a way that data cannot be retrieved from it in the future.
We value your comments and we are committed to ensure that all your data is safeguarded and in line with regulation and our internal policies. Should you feel the need to complain about, or raise your objections, to how we are handling your personal data, then you may contact us using either/all of the following:
By post to DPO, Ceek, 88B, Triq Salvu Psaila, B’Kara BKR 9073 Malta
By telephone on +356 2703 0133
By sending an email on firstname.lastname@example.org
We will do our utmost to ensure that complaints are handled and settled internally in an efficient and professional manner.
You may also contact the Office of the Data Commissioner as follows:
You may file a complaint with the Maltese Data Protection Commissioner through the following link: https://idpc.org.mt/en/pages/contact/complaints.aspx
Alternatively, you may contact the office of the Maltese Data Commissioner by phone on +356 23287100 or by post addressed to The Commissioner, Level 2, Airways House, High Street, Sliema, SLM 1549
12. Approval of the Policy
You have the right to cease using the website at any time, however we may still be legally required to retain some of your personal information.