Privacy Policy for WH Partners
Last updated on 28/01/2019
Welcome to whpartners.eu (the ‘Website’)
1. Who We Are
1.1. WH Partners takes the privacy of its clients and visitors seriously into account. This purpose behind this agreement (the ‘Privacy Policy’) is to inform you of how WH Partners protects the privacy of your communications and collects, processes, uses and stores your Personal Data through the Website as well as the rights you have with regard to the foregoing collection and processing of your Personal Data.
1.2. By visiting our Website and using our services you acknowledge reading and fully considering the Privacy Policy.
1.3. WH Partners is a controller of Personal Information collected on the Website.
1.4. WH Partners acknowledges that in collecting your personal details it is bound by the Laws of Malta and will process your Personal Data in accordance with the European Union’s General Data Protection Regulation (GDPR). For any further request or query about how we use your personal information, you may address us by using the following email address: [email protected]
1.5. Any notice, demand, request or other communication which you address to WH Partners shall either be sent by certified mail, return receipt requested, or by e-mail. All notices given by e-mail shall be deemed given as of the business day following the day of transmission.
2. Definitions
For the purposes of this Privacy Policy the following definitions shall apply:
2.1. WH Parnters Parties – WH Partners and its respective past, present and future employees, officers, directors, contractors, consultants, attorneys, accountants, financial advisors, equity holders, suppliers, vendors, service providers, parent companies, subsidiaries, affiliates, agents, representatives, predecessors, successors and assigns.
2.2. Consent – any explicit, specific and freely given indication by which the User, after having been fully informed, signifies her agreement to Personal Data relating to her being processed.
2.3. Cookie – short text of software code, which is transmitted from the web server of our WH Partners and stored at your device each time that you enter the Website.
2.4. GDPR – the General Data Protection 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of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced or superseded and in force from time to time and as transposed into member-state legislation.
2.5. Personal Data – any information relating to an identified or identifiable User of the Website.
2.6. Processing – any operation or set of operations which is performed by WH Partners upon the Personal Data of the Users whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
2.7. Services – the online services at the Website.
2.8. User – Any internet user who accesses and browses or registers an Account on the Website.
3. Subject Matter
3.1. This Privacy Policy sets out the terms and conditions which WH Partners follows in order to protect the privacy of our clients and visitors. It describes the conditions under which we make any collection and processing of your Personal Data and ensure their confidentiality.
3.2. WH Partners reserves the right to amend and update this Privacy Policy, whenever it deems it appropriate, and any changes thereof shall come in force and effect from the instance they appear online at the Website. Any substantial modifications to this Privacy Policy will communicated to you.
4. Principles of Data Processing
4.1. We fully respect your fundamental rights and render protection of your privacy a priority of WH Partners. In this context, when processing your Personal Data, we follow the following basic principles:
4.1.1. We submit your Personal Data only to legitimate processing, and we maintain full transparency vis-à-vis the way we handle your Personal Data.
4.1.2. We collect and process your Personal Data only for specified, explicit, and legitimate purposes as outlined in the Privacy Policy, and we do not process it further in a manner incompatible with these purposes.
4.1.3. We process your Personal Data only to the extent that it is appropriate and relevant to the above purposes, while limiting the processing to the measure necessary for these purposes.
4.1.4. We make reasonable efforts with your own assistance to ensure that your processed data is accurate and, where necessary, updated with regard to the purposes of the processing, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.
4.1.5. We keep your Personal Data in a form that allows you to identify yourself only for the time required for the above processing purposes.
4.1.6. We process your Personal Data in a way that guarantees its security by using appropriate technical or organisational measures.
4.1.7. We do not intend to further process your Personal Data for purposes other than the ones for which they are collected.
4.1.8. We inform you that there is no obligation to provide your Personal Data and that there are no possible consequences from the choice not to provide it. Furthermore, we inform you that your Personal Data will not be used for automated decision making, including profiling.
4.2. Without prejudice to what is stated in the Privacy Policy, we do not disclose and transmit your Personal Data to third parties without your consent, unless permitted by law or by a specific contractual agreement with you.
4.3. In general, we comply with all applicable laws and comply with all our statutory obligations, as data controllers of your Personal Data.
5 Types of Personal Data Collected[WHP1]
5.1. At the point of requesting an appointment, making an enquiry, applying for a job opportunity or our trainee program, you shall provide to WH Partners your personal identification information, such as:
· Name and Surname
· E-mail address
5.2. At the point of uploaded documents:
· All Personal Data included in such documents directly provided by you.
5.3. At the point of your access and during the use of the Website.
· IP Address.
· End user device data
· General communication data.
· Browsing data.
· Information on user preferences regarding the Website [WHP2]
5.4. At the point of accepting the receipt of advertisements and any other type of commercial communications placed at or communicated through the Website or through WH Partners’ social media channels:
· All Personal Data directly provided by you.
· Non-personally identifiable information regarding the popularity of such commercial communications.
5.5. Any other personally identifiable information directly provided by you during interaction with our social media channels.
6. Purposes and Legal Bases of Data Processing [WHP3]
6.1. Personal Data necessary for the navigation and use of our Website and the Services is collected and processed by WH Partners pursuant to Article 6(1)(b) of the GDPR (‘Performance of Contract’) for the following purposes:
· Administration and development of the Website and the Services;
· Enhancement of user experience, including the provision of personalized Services and improvement of the Website and the Services;
· Development of new products, utilities and offerings;
· Detection, investigation and prevention of fraudulent transactions and other illegal activities and protection of your rights and rights of WH Partners Parties;
· Collection, processing and performing statistical and other research and analysis of information for enhancement of the Website and the Services;
· Verifying compliance with the Terms of Use of the Website. [WHP4]
6.2. WH Partners may process Personal Data only with your lawful consent for the following purposes:
· For the purposes of commercial communication, marketing and advertising of our services or third-party services via e-mail, internet, mail, social media and / or any other appropriate communication channels.
6.3. You have the right to withdraw your consent at any time in writing to our contact details mentioned in this Policy. Withdrawal of your consent does not affect the lawfulness of the treatment of your data prior to its revocation. Your consent is also revoked in the same manner as provided.
7. Data Recipients
7.1. For the execution of the purposes mentioned in the Privacy Policy, WH Partners may provide access to or transmit your Personal Data to the following processors:
• our internet and data hosting providers for hosting purposes.
• our information technology maintenance and support providers for the smooth operation of Website and our information and communication systems.
• third-party marketing platform with regards to WH Newsletter.
7.2. The processing of your Personal Data by our data processors mentioned above is executed under a contract with us subject to, compelling such data processors to the same level of data protection provided by the Privacy Policy.
7.3. We will not disclose your Personal Data with any third parties outside of the European Union in countries where there is no adequate data protection regime. However, in the event that such a data transfer occurs, we will take all reasonable steps possible to ensure that your data is treated as securely as it is within the European Union and in accordance with this Privacy Policy and the applicable legislation. Additionally, we will update the current Privacy Policy in order to reflect the cross-border data transfer and the relevant safeguards for your privacy.
7.4. In the event that we are required by a court or other administrative authority, pursuant to an investigation relating to unlawful activities such as money laundering and in any other case that we are legally bound to do so, WH Partners may transfer your Personal Data to public authorities to the extent specified by law.
8. Data Security and Confidentiality
8.1. In order to ensure the proper use and integrity of your Personal Data and to prevent their unauthorized or accidental access, processing, deletion, alteration or other use, WH Partners applies appropriate internal policies and takes all appropriate organizational, technical, physical, logical and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.
8.2. The processing of your Personal Data by WH Partners is conducted in a manner that ensures their confidentiality and physical and logical security, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for your rights and freedoms, which are applicable in each circumstance.
8.3. Your Personal Data is processed solely by authorised personnel of WH Partners, bound by strict obligations of confidentiality.
9. Retention of Personal Data
9.1. We keep your Personal Data for as long as necessary for the relevant purposes of their processing, in alignment with the ‘Data Minimisation and Storage Limitation’ principles as defined in Article 5 of the GDPR.
9.2. WH Partners may retain your Personal Data after the expiration of their relevant processing purposes in the following limited cases:
• In case that there is a legal obligation under a relevant statutory provision.
• For research or statistical purposes or for the proper organisation and operation of our business provided that anonymity or pseudonymization of your data takes place.
• In case of any claims against WH Partners, for as long as necessary to defend our rights and legitimate interests before any competent court and any other public authority.
9.3. After the period of retention, your Personal Data is erased from our databases and systems in accordance with our Privacy Policy and provided that their retention is no longer required for the fulfillment of the purposes we have described above.
9.4. For more information about data retention terms in relation to specific Personal Data, please contact us at [email protected].
10. Your Rights
10.1. You have the right:
• To request access to your Personal Data and information related to their processing and obtain a copy thereof.
• To request for the rectification of any inaccuracies or any missing Personal Data of yours.
• To request for the erasure of your Personal Data.
• To request for the restriction of the processing of your Personal Data in cases explicitly provided for by law.
• To request for the portability of your Personal Data to another controller in a structured, commonly used and machine-readable format.
• To object to the processing of your Personal Data in cases explicitly provided for by law.
• To object to a decision taken solely on the basis of automated processing, including profiling, which has impact on you or significantly affects you.
10.2. Any requests relevant to the above Section 10.1 must be addressed in writing to our email address mentioned in Section 1.3 and Section 9.5 the Privacy Policy.
10.3. WH Partners will respond to any of your requests within one (1) month from their receipt. Upon prior notice, this period may be extended by a further two (2) months if necessary, taking into account the complexity of the request and the number of any other pending requests. In case of rejection of your request, we will provide relevant justification.
10.4. If your request does not meet the requirements of applicable law, WH Partners reserves the right either to: (a) impose a reasonable fee, taking into account the administrative costs of providing the information or communicating or executing the requested action, or (b) reject your request.
10.5. In the event of any violation of your Personal Data, which may place your rights and freedoms at a high risk, and provided that it does not fall under one of the exceptions expressly provided for by applicable law, we undertake to inform you without undue delay.
10.6. If there are any doubts as to the identity of the individual submitting the request, we reserve the right to request the provision of additional information necessary to confirm his / her identity.
10.7. If your rights are infringed, we inform you that you have the right to file a complaint with the Office of the Information and Data Protection Commissioner at the following website https://idpc.org.mt/en/Pages/contact/complaints.aspx.
11. Your Obligations
11.1. By using our Website and by providing your Personal Data upon your consent, you acknowledge that you are required to state your actual, accurate and complete information requested by WH Partners. Furthermore, you must inform our WH Partners of any changes to your information so as to ensure it is kept up-to-date and accurate.
11.2. If you are found to be in breach of your obligations or if our WH Partners has reasonable suspicion that the information you provide is false or incomplete or in any way contrary to applicable law or this Privacy Policy, we retain the right to reject your application for registration or to suspend or terminate your account immediately without notice. In this case, you have no right to any compensation due to the rejection of your application, or the suspension or termination of your account.
11.3. By using our Website you confirm that you are over eighteen (18) years old. If you are under the age of eighteen (18) you have the obligation to abstain from any use of our Website and from any transfer of your Personal Data without the consent of the person who exercises your parental responsibility. If you fail to comply with the foregoing obligations, you must immediately notify WH Partners. In any case, using the Site, you acknowledge that WH Partners is not responsible for your violation of the obligations mentioned above to the extent that it is unable, even if it makes reasonable efforts, to verify your age or to receive consent from your guardian.
12. Cookies
12.1. Our Website uses cookies. For more information please review our Cookie Notice below:
WH Partners website uses “cookies” and other technologies to help us understand which parts of our websites are the most popular, where our visitors are going, and how much time they spend there. We use cookies and other technologies to study traffic patterns on our website, to make it even more rewarding as well as to study the effectiveness of our visitor and client communications. And we use cookies to customize your experience and provide greater convenience each time you interact with us. Information such as your preferred language help us provide a more useful online rental experience. And your contact information, and information about your computer helps us register your content and provide you with customer service.
The cookies our website uses are session cookies and are active only for the duration of your visit of the website.
We use our cookies only for basic web application operations which are strictly necessary for the functioning of our website. Furthermore, the cookies implemented on our website do not collect personal data in accordance with the standards set out by the GDPR.
13. Jurisdiction and Applicable Law
13.1. Any dispute between you and WH Partners arising from or in relation to the subject matter of the Privacy Policy shall be governed and construed in accordance with Maltese law, without reference to its conflict of laws principles and shall be subjected to the exclusive jurisdiction of the competent courts of Malta.