PRIVACY POLICY

Information on the processing of personal data

Last updated: 16 March 2022

Who is the data controller

Your data are processed, as Data Controller, by Advice Global ltd, with registered office at CMS House, Third Floor, St. Peter’s Street, San Gwann, SGN, 2310 MALTA , Tax Code and VAT no. 23269314 (hereinafter, “ADviceGlobal“). If you wish to contact ADviceGlobal, please refer to the contact details at the bottom of this page.

Where we collect your personal data

We process the following data:

  • data that you have provided us through one of our sites that refer to this Privacy Policy (“Sites“);
  • data that have been provided to us by a third party (autonomous data controller) to whom you had previously provided, respectively, a specific consent for the communication of your data to third parties as well as for the processing of such data for the own promotional and marketing purposes of those third parties;
  • browsing data that we collect through our Sites (see section “Cookies” below).

What personal data we process

The personal data we process are:

  • name and surname;
  • date of birth;
  • sex;
  • telephone number;
  • address and zip code;
  • email address;
  • IP address and other data useful to circumscribe the consent given;
  • browsing data (see section “Cookies” below).

Why and for what purposes we process your personal data

Depending on the case, ADviceGlobal recurs to a different legal ground for the processing of your personal data. In particular, we may process your personal data:

  • on the basis of your specific consent:
    • to send you marketing and promotional communications (via e-mail, fax, telephone, sms, WhatsApp and any other remote communication technology);
    • to communicate your personal data to third parties;
    • to transfer your personal data outside the European Union in cases where it is not possible to do it on the basis of another legal instruments to do so.
  • On the basis of our contractual or pre-contractual relationship, to fulfil our obligations and provide you with the services that you have subscribed to or provide a feedback to your requests.
  • On the basis of a legal obligation, to act in accordance with the law and ensure that everything is in order (e.g., if it is expressly requested by an authority to do so or if we need to carry out any processing for complying with the law, such as the case of any check that is needed vis-a-vis the opt-out register, if applicable) or to defend our right (e.g., to defend ourselves in the context of a judicial proceeding).
  • On the basis of our legitimate interest or the legitimate interest of a third party, provided that your fundamental interests, rights and freedoms do not prevail (e.g. to carry out the necessary processing for our research and development purposes; to send you communications concerning our activities; to send you other communications that do not require consent).

At any time you have the right to withdraw your consent, without affecting the lawfulness of the processing that we have carried out before the withdrawal. You can withdraw your consent for each of the purposes that underlying a processing that is based on the consent (e.g., you can withdraw your consent to no longer receive marketing communications and / or to prevent us from communicating your data to third parties).

Who processes your personal data?

ADviceGlobal allows its workers, who are strictly linked to confidentiality obligations, to become aware of your personal data and to process them in accordance with the permitted purposes.

Furthermore, in compliance with existing legal obligations, ADviceGlobal uses the services of third party suppliers, duly appointed as data processors. These include, for example, email delivery service providers and data storage service providers. In particular, ADviceGlobal has appointed the following suppliers as data processors:

  • Mapp Digital Italy Srl, with registered office in via Orseolo Pietro 12, Milan (MI), Italy.
  • FreeMedia Internet SL with headquarters in C / Filà Cordòn, 36. Pol. Ind. Cotes Altes Acoy (03804), Alicante, Spain.
  • Gidinet with headquarters in Via Medeghino, 15 – 20141 Milan (MI).
  • OVH SAS au capital de 10 174 560 € – RCS Lille Métropole 424 761 419 – Code APE 2620Z N° TVA: FR 22 424 761 – Siège social: 2 Rue Kellermann – 59100 Roubaix – France
  • AdviceMe SRL with registered office in Circonvallazione Clodia 163/171, 00195, Roma
  • We Love Data sp. Z o. o. with registered office in Krakow, ul. Okaszowska 15/4, 31-713 Krakow
  • TheValueFactory SL with registered office in Avinguda Francese Cambo 21, 5, 09003 Barcelona.
  • Mindbaz with registered office in 125 Avenue de la République, 59110 La Madaleine – France.

With regard to the suppliers that are established outside the territory of the European Union, please read the section “Transfer of data outside the European Union“.

To whom we communicate your personal data

Based on your consent to communicate your personal data to third parties, we may communicate your data to third parties who fall into the following product categories:

  • services and products relating to the communications and technology sector and similar.
  • Finance and banking sector: financial entities, insurance, investment, social security and similar (for example you will receive promotions owned by T Dot UK (privacy)  and RS Data Tech).
  • Free Time: pay TV, editorial, sports, collecting, photography, gaming, transportation, navigation, tourism (hotels, tour operators, travel agencies, airlines, etc.), aerospace, gardening and other hobbies, lottery, competitions, communication and entertainment, art, music and similars.
  • Distribution and commerce: electronics, IT, image and sound, fashion, accessories, clothing, textiles, bazaars, cosmetics and sanitation, chemistry, pharmaceuticals and biotechnology, agro-food, supermarkets, drinks, office supplies, furnishings, and similars.
  • Automotive: products and services related to cars, industrial vehicles, scooters, cycles and motorcycles, trucks, mechanics and metallurgy, and similars.
  • Energy and water: products related to electricity, hydrocarbons, gas, water and utilities, and similars.
  • Education, training, education, universities, and similars.
  • Communication and services: advertising, marketing, event, consulting, advertising, PR agencies, advertising agencies, media centers, telecommunications, market research, mobile marketing agencies, and similars.
  • Ecology and environment.
  • Construction, civil engineering, real estate products and home security products/ services (for example you will receive promotions owned by Verisure UK click here for their privacy link): construction, decorations, home, design, real estate agencies, and similars. 
  • Fairs and events, and similars.
  • IT, internet, e-commerce sites, and similars.

If you gave your consent to communicate your data to third parties and we communicate it to them, note that from the moment they receive your data they will begin to process your data as autonomous data controllers. This means that, in addition to the rights that you can always exercise vis-a-vis ADviceGlobal, you can also exercise your rights directly vis-a-vis them. For more information, please refer to the privacy policy that will be provided to you by them.

How long do we keep your personal data?

ADviceGlobal put a big effort in ensuring that the personal data is processed in compliance with the principles of proportionality and minimization. Therefore, ADviceGlobal will not store your data beyond the time that is necessary in relation to the purposes that are pursued. For example:

  • if we realize that your e-mail address has been deactivated, we usually delete it in a short time, as well as any other data associated with it that we could not use for the purposes for which it was collected.
  • If the processing of your data is based on a contractual relationship with ADviceGlobal, we will delete your data after a certain period of time from the termination of the contractual relationship (depending on the specific case and the applicable limitation periods).
  • If we process your data on the basis of consent and you withdraw your consent, we will delete all your data, even if we may continue to keep some information for a certain period of time on the basis of legitimate interest and in order to be able to prove that we had obtained a valid consent to carry out all the treatments carried out until your withdrawal.

Transfers of personal data outside the European Union

In some limited cases, some processing of personal data may take place outside the territory of the European Union, for example in the USA. In these cases, the company recurs to all the legal instruments necessary to ensure adequate protection for your personal data (e.g. by asking suppliers who have an extra-EU establishment to sign the so-called Standard Contractual Clauses (which is a contract that requires them to respect the same standard of protection for personal data as in the European Union) or, if they are established in the USA, to subscribe to the so-called Privacy Shield.

Cookies

Cookies are small text files stored locally in the temporary memory of your browser, and then on your computer, for variable periods of time. Through cookies you can record semi-permanent information about your preferences and other technical data that allow easier navigation and greater ease of use and effectiveness of the site. For example, cookies can be used to determine if a connection has already been made between your computer and our sites. To your guarantee, only the cookie stored on your computer is identified. In this case it is a cd. technical or session cookies. In addition, we use third-party profiling cookies to enable us to reach you with personalized advertising messages. You can manage your cookie preferences directly within your browser, including the ability to delete cookies installed in the past, even from this site. To proceed in this way, you can find information on how to manage (and delete) cookies with some of the most popular browsers for example at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer. With reference to third-party profiling cookies, we use the tools provided by Facebook, Outbrain, Taboola, Revcontent and Tune. Facebook allows you, via the settings available on this page, to disable the features that make it easier to place ADviceGlobal listings shown on Facebook. Outbrain allows you, through the settings available on this page, to disable the functions that facilitate the positioning of ADviceGlobal listings during your web browsing. Taboola allows you, through the settings available on this page, to disable the functions that facilitate the positioning of ADviceGlobal ads during your web browsing. Revcontent allows you, through the settings available on this page, to disable the functions that facilitate the positioning of ADviceGlobal listings during your web browsing. Tune allows you, through the settings available on this page, to disable the functions that facilitate the positioning of ADviceGlobal listings during your web browsing. For more information on cookies, including how to view those that have been set on the device, how to manage and delete them, visit www.allaboutcookies.org.

Your rights

In your quality of data subject, you are granted with the right of access, rectification, cancellation as well as the right to data portability, the right to limit the processing and the right to object to the processing, where the conditions for their applicability exist. In any case, if the processing is carried out for marketing purposes, or is based on our legitimate interest, you are allowed to object to the processing at any time. To help you know your rights, below we provide a brief illustration of the rights that are granted to you by the law:

  • the right of access allows you to obtain confirmation that a processing of your personal data is in place and, if necessary, to access such data and all related information.
  • The right of rectification allows you to obtain the modification of inaccurate personal data concerning you without undue delay and, taking into account the purposes of the processing, to obtain the integration of incomplete personal data.
  • The right to erasure allows you to obtain the erasure of your data without undue delay (e.g. when your personal data are no longer necessary in relation to the purposes for which they were collected), subject to the exceptions provided for by the legislation applicable (e.g. when the retention of your data is necessary for compliance with legal obligations applicable to the data controller).
  • The right to data portability allows you, under certain circumstances provided for by the applicable legislation, to receive the personal data concerning you that you have provided to the data controller in a structured, commonly used and machine-readable format. You will be able to transmit this data to another data controller, provided that this right can be recognized in the light of the applicable legislation, and without prejudice to the case in which an injury to the rights and freedoms of others may result.
  • The right to limitation of processing allows you, under certain circumstances provided for by the applicable legislation, to obtain the limitation of the processing of your personal data. In such cases, the data controller may continue to process your data only in some cases, for example for the exercise of the right of defence or to protect the rights of another natural or legal person.
  • The right to object to the processing allows you, under certain circumstances provided for by the applicable legislation, to object to the processing of your personal data unless there are prevailing legitimate reasons, rights or freedoms that allow the data controller to continue the processing of your data. In any case, if there are reasons related to your particular situation, you are granted with the right to object to the processing of your personal data which is based on a legitimate interest of ADviceGlobal or of a third party. In such cases ADviceGlobal will cease the processing, unless there is a compelling legitimate reason to proceed with the processing.

At any time you have the right to contact the Data Protection Authority if you believe you have not satisfactorily obtained a response from ADviceGlobal regarding your rights or if you believe there is a violation of your rights.

How to contact us to exercise your rights

You can contact ADviceGlobal to exercise your rights at any time by submitting a request by e-mail to customercare@adviceglobal.com.mt

Data Protection Officer (DPO)

To ensure the maximum protection of data subjects’ rights, and in accordance with EU Regulation 679/2016 (“GDPR“), ADviceGlobal has appointed a Data Protection Officer who can be contacted at the e-mail address dpo@adviceglobal.com.mt