Website Privacy Policy

Effective date: May 2018

Belair Operations Ltd having its registered office situated at 245, Msida Road, Gżira GZR1400 Malta (hereinafter referred to as the ‘Company’) is committed to respect your right to have your data protected, under the General Data Protection Regulation (the ‘GDPR’) and the Data Protection Act Chapter 586 of the Laws of Malta (the ‘Act’).

1. Defining "Personal Data"

The term Personal Data refers to all information about you from which you may be personally identified, such as your name, surname, address, telephone number, etc.

2. How Personal Data is collected

The Company collects Personal Data from:
– email and social media communication;
– information submitted in client forms;
– online request of information forms;
– information submitted when signing up for the newsletter.

3. How Consent is obtained

When signing up to the Company`s, website or newsletters, or filling client forms, or any other document whatsoever, it is presumed that you are doing this voluntarily, and therefore freely giving your consent to the Company to collect, review and process any Personal Data found therein.

It is furthermore presumed that information divulged is correct. The Company reserves the right to erase the information or to even refuse to extend its services to the individual, should it find out that information given was incorrect, even more so if the Company finds out that a person declared that he was more than sixteen years old and it results that this was not the case.
Consent, once given, may be withdrawn at any time, by emailing the Company Data Protection Officer as provided under clause 10 below.

4. How Personal Data is used

Your Personal Data is only used for the purpose for which it was collected, that is, as part of our business and the services which the Company endeavours to offer you. However, the Company may find itself in a situation where your Personal Data will have to be processed to fulfil a legal or regulatory obligation.

Although the Company likes to keep in touch with our customers and potential customers, for example by sending them news or even a newsletter, the Company, will only do this if you specifically sign up to receive such news.

5. How Personal Data is stored

As a general rule, the Company, does not keep physical files. However, in the event that such files are so required the information therein will be limited to the Personal Data which is so required to process the information. All physical files are under lock and key and shall not be left stored unsecured. Such physical files will only be accessed by limited selected individuals.

Any database will be held under lock and key and shall not be left stored on an unsecure device, however the Company or any employees, may store third-party storage platforms, such as a cloud system.

Any information transferred or shared with third parties or supplies will only be limited to any obligation legally imposed on the Company, nevertheless any third-parties or supplies shall be fully compliant with the GDPR and the Act.

6. Who Personal Data may be shared with

As a general rule, the Company, does not share your Personal Data with anybody. Having said that, the Company, does not exclude that employees, other officials and related service providers are given access to what Personal Data they will inevitably require in order to carry out their duties.

The Company, also uses services or otherwise of third parties during the course of its work. As a result, your information may be shared with Notaries, Lawyers, Financial Intelligence Analysis Unit, Diligex & any other Legal or Lawfully authorised entities.

The Company’s website may even include links to other websites belonging to third parties. You will be notified when you are exiting the Company`s, website; it is not excluded that by choosing to enter a third-party website, an amount of transferring of your Personal Data may occur.

7. Retention of Personal Data

The Company aim to collect no more Personal Data than that which is required to carry out its duties and to provide customers with satisfactory services. The data is kept for no longer than necessary.

8. Your rights

Your rights under the GDPR include:
– the right to inquire about what Personal Data about you is held, and the right to receive a reply to such an inquiry;
– the right to have any inaccuracies in the Personal Data which is held, corrected;
– the right to request that your Personal Data be deleted, whether partially or completely, on the basis that in your view it is no longer required by the Company;
– the right to complain primarily with the Company, as a first step, and if still dissatisfied after the Company has reacted to your complaint, to the Data Protection Commissioner;
– the right to request the Company, to stop processing any of your Personal Data, if you oppose such processing;
– the right to request that you longer receive news from the Company if you had signed up to the newsletter;
– the right to have your testimonial removed from the Company`s, website, if you had given your consent to such a testimonial;
– the right to be informed, within seventy-two (72) hours, if a data breach should occur, and also to be informed about what remedial steps were taken further to that breach.

9. Data Security

The Company undertakes to keep your Personal Data secure and shall commit to take appropriate technical and organisational measures to protect your Personal Data against unauthorised or unlawful processing.

9. Use of Cookies, Profiling & Links

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

10. Personal Data Officer

The Company Data Protection Officer is Trevor Galea. He may be contacted by email at dpo@belair.com.mt. You may contact him at any time, with any queries, difficulties, or possibly even with a complaint.

11. Updates

This privacy policy was brought into effect on 25th May 2018. From time to time the Company may update this Privacy Policy, for example as result of a change in applicable law or processing activities. Any such changes will be communicated to you prior to the commencement of the relevant processing activity.