Introduction
The Grand Harbour Regeneration Corporation (“We”, “Us”, or “Our”) is strongly committed to protecting personal data. This privacy policy describes why and how We collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to Us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy policy or as otherwise stated at the point of collection.
This Privacy Policy (“the Privacy Policy”) (together with our Terms of Use) applies to your use of the Mobile Application (“App”).
In this Privacy Policy, “You” and “Your” and “User” refer to an identified or identifiable natural person being the User of the App (or prospective recipient) or of any of Our services. Our full details, including contact details, are available below.
“Personal Data” is any information relating to an identified or identifiable living person. We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how We process personal data. To find out more about Our specific processing activities, please go to the relevant sections of this policy.
To ensure that this Privacy Policy can be understood by all users, all efforts have been made to make it simple and as non-technical as possible.
Who has provided you with this App?
The Visit Marsamxett App (“the App”) is being provided by the Grand Harbour Regeneration Corporation who is also the Data Controller. Under the data protection law, the Data Controller is responsible for the processing of the App users’ data. The Data Controller may be contracted at:
Address:
Malta Tourism Authority
Suites 301-306, Building SCM 01
SmartCity Malta
Ricasoli SCM 1001
Kalkara – MALTA
Telephone: (356) 22915000
Email: [email protected]
The Data Protection Officer can be contacted on the following e-mail address: [email protected]
Is using the App voluntary?
Using the App is entirely voluntary but in order to avail of the functions, the App will need to be downloaded accordingly.
The storing of information in the mobile phone of a user will happen with the user’s consent, which is obtained when the user agrees to this Privacy Policy prior to downloading and using the App.
By downloading and using the App or availing of our Services, you agree to be bound, without reservation and with immediate effect, by all the provisions set out in this Privacy Policy. Such acceptance shall also be deemed to extend to all of our other policies which have been incorporated by reference to the Terms of Use. If you do not wish to be bound by this Privacy Policy, please delete the App from the device/s on which it is being used.
Please note that this will not affect the lawfulness of the processing before the withdrawal.
Individuals who decide not to or cannot use the App will not suffer from any disadvantage.
On what legal basis is your data processed?
Individuals have certain rights, under the data protection laws, over their personal data and We are responsible for fulfilling these rights.
The processing of personal data is governed by data protection legislation, including 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, and repealing Directive 95/46/EC (General Data Protection Regulation)(“GDPR”) and Data Protection Act (Cap 586 of the Laws of Malta).
Information We may collect from you
When You use the App (collectively hereinafter referred to as Our “Services”) and make use of our services We may collect and process the following data about You:
Any information that You provide (“Submitted Information”) by filling in forms on the App or websites we operate or may operate from time to time. This includes any information provided at the time of registering to use Our App, posting material, requesting further services or subscribing to any of Our Services. This data includes the following types of information: gender, age and country of origin. In order to assist You better We may request further information if You report a problem with one of Our Services.
If You choose to connect one or more of Your social media accounts with Our Site to enable the sharing of Personal Data via social media platforms, certain categories of Personal Data relating to You from Your social media account(s) will be shared with Us.
We may keep a record of any correspondence with You if You contact Us.
Details of the resources You access and of Your visits to Our Site.
Where We collect Your data from sources other than Yourself, We undertake:
to do so only by legal means;
to do so only with Your consent; and
to declare to You what sources We use, and under what circumstances.
Where We store Your personal data
We undertake to store and, or to transmit Your data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
To ensure that Your data is treated securely and in accordance with this privacy policy We endeavour to take all reasonable necessary steps in protecting Your privacy. We do Our best to protect Your personal data; however, We have no control over the transmission of information over the internet and therefore cannot guarantee the security of data transmitted to Our Services. Any transmission of data is at Your own risk.
The personal information which We may hold, may be hosted on systems managed by third party processors with whom We have a contract of engagement and they are bound by the requirements of the General Data Protection Regulation (“GDPR”). These third-party processors are also bound by a number of other obligations set out under Article 28 of the GDPR. The personal information collected from You to be able to share the information found on Our Services.
Why We process your personal data
The Grand Harbour Regeneration Corporation processes your data to be able to provide you with a seamless user experience when using the App.
We undertake to use Your data for:
Authenticate your access to an account;
notifying You of any changes to Our service;
ensuring that the content of Our Services is presented in the most effective manner for You and Your device;
allowing You to participate in interactive features of Our service, should You choose to do so;
the purposes for which the information was collected, as necessary for the performance of the agreement between us and as necessary for the purposes of the legitimate interests pursued by the Grand Harbour Regeneration Corporation and/or its sub-contractors;
such other purposes as are subsequently agreed between Yourself and Us;
research and statistical reasons, so that We may understand Our Users needs, to develop and improve Our services/activities;
such additional purposes as may be required by law, in which case, We shall take all reasonable measures available to us to communicate with You that the use has occurred, unless this will involve a disproportionate effort or if it is prohibited by law.
Disclosure of your information
We undertake to solely disclose Your personal data for the provision of the requested service/s. Where such services are sub-contracted, We undertake to regulate the relationship with the contractor by means of a contractual agreement in order to bind the third party to process Your data in accordance with Our instructions.
Your personal data may also be disclosed to other third parties, including Government and regulatory authorities, where this is strictly required by law.
Your personal data shall not be disclosed for any other reason apart from those mentioned above, without Your express consent.
We ensure that users, who have access to Your personal data, have restricted access on a need-to-know basis.
Data Retention and Destruction
We undertake:
to retain Your data for no longer than necessary having regard to the purpose of processing, unless this is strictly required by a specific law;
to retain Your data for one year after last log in or until You withdraw consent;
where Your personal data required by Us beyond the retention period specified above, We will pseudonimise Your personal data; and
to destroy Your data when its purpose has expired, and to do so in such a manner that Your data is not subsequently capable of being recovered.
Updates
We reserve the right, at Our complete discretion, to change, modify, add and/or remove portions of this Privacy Policy at any time. If You are an existing recipient with whom We have a contractual relationship You shall be informed by Us of any changes made to this Privacy Policy (as well as other terms and conditions relevant to the App). We shall also archive and store previous versions of the Privacy Policy, which You would be able to review subsequently.
As a User, with which We have no contractual relationship or even a lawful way of tracing, it is in Your interest to regularly check for any updates to this Privacy Policy (which are usually deemed to be effective on the date they are published), in the event that Our attempts to notify You of such updates do not reach You.
Contact
Thank You for taking the time to read Our Privacy Policy.
If You would like to contact Us regarding any matter related to Your personal data You may send an email to: [email protected]
Last amended: 2023