CYBERPASS LIMITED

PRIVACY & COOKIE NOTICE

1. ABOUT US

1.1 INTRODUCTION

This privacy and cookie policy (‘the Privacy Policy’) sets out the ways in which CyberPass Limited (registered in Malta, Europe with Registration Number C27416) (hereafter ‘CyberPass’, ‘We’ ‘Us’ or ‘our’) as the data controller may use your personal data and what your choices are in relation to our data practices. Within the context of this policy, CyberPass means CyberPass limited and/or any of its affiliates, subsidiaries or associated entities. For information concerning Cyberpass please visit www.cyberpass.com.mt.

The privacy and security of your personal information is important to us. We want to assure You that your information will be properly managed and protected whilst in our disposal. Any consents and authorisations that were provided by you in relation to your information shall continue to apply in full force and effect, to the extent that it is necessary and permissible by applicable law.

The term “You” or “Your” means you and/or any person authorised by you to act as your representative. The Policy relates to our use of any personal information we collect about You.

Kindly review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please stop using the website.

1.2 OUR CONTACT DETAILS

You can contact us:

  • By post, using the following postal address: Soteria Buildings, Dawret Hal-Ghaxaq, Malta

  • By email: info@cyberpass.com.mt

2. ABOUT YOUR DATA

2.1 DATA WE PROCESS

The personal data we collect/process in Your regard may be any of the following:

Data Category Type of Data What it’s used for Our legal Basis

Tracking Data:

Data about Your use of the Website IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation paths, and information about the timing, frequency, activity log and pattern of Your use. For functionality, for security purposes, to analyse the use of the Website and to personalise and optimize content available to You on the Website.

Legitimate interest

Communications Data:

Data provided to us when You complete a ‘Contact Us’ Form Name and surname, contact number, email address, IP address, and other information You may enter into the form. To reply to Your queries. Legitimate Interest

Subscription Data Information that You provide to us for the purpose of subscribing to our newsletter. Email address and IP address To send You information about our products, services, offers, discounts and news. Consent: NOTE that you have the right to withdraw Your consent, at any time by clicking on the ‘unsubscribe’ link found in any marketing communications. You may also send an email to info@cyberpass.com.mt.

Account Data we may have access to all data collected in your account when using the Cybertrack system as described in any relevant data processing agreement entered into between ourselves and You. Location and all other data emanating from the use of the Cybertrack system. To enable you to make use of the tracking software or devices that You have contracted from us. Contract

2.2 COOKIES & OTHER TRACKING MECHANISMS

A cookie is a small file of letters and numbers that are stored on your browser or the hard drive of your computer and contain information that is transferred to your computer’s hard drive. We use cookies on the Website to improve its functionality, and to allow Us to better the site. When You continue to browse the Website, You are agreeing to our use of cookies.

Please note that You can block cookies at any time by activating the setting on Your browser that allows You to refuse the setting of all or some cookies. Keep in mind, however, that blocking all cookies, or even some of them, will have a negative impact on the usability and possibly the rendering of many websites, including ours. If You block cookies, You will not be able to use all the features on the Website and might not be able to view it correctly or in the way it was originally intended to be displayed. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them visit: www.allaboutcookies.org.

2.3 RETENTION OF DATA

We retain Your personal data no longer than strictly necessary i) to realize the purpose for which your personal data was originally collected ii) as required by a specific law to which we may be subject and iii) to manage any legal claims in relation to which such data may be required in evidence. Transactional records may be kept for up to 10 years from the performance of a contract for accounting and VAT record purposes. Should You need to know the complete list of the retention periods we adhere to with respect to the indicated categories of personal data, please contact us on info@cyberpass.com.mt.

2.4 WHO HAS ACCESS TO YOUR DATA

CyberPass is a Malta-domiciled organisation whose primary offices are in Malta. The Website insert is hosted in the European Union. The majority of the service providers who are able to access the Website or any of the personal information collected from or relating thereto are located within the EEA, and where personal data may be shared, we have data processing agreements in place with these parties. These include customer relationship management, online review service provider, email service provider, web developers, affiliates, payment gateway, SEO agents, product suppliers, delivery and logistics, providers of professional advice (accounting and legal). Personal data that we hold is at all times on a strict ‘need to know’ basis.

If we need to send data outside the EEA, we will ensure that we have appropriate legal and security relationships with these parties and have taken steps to ensure that they are complying with the General Data Protection Regulation, including, as necessary, execution of contracts based on the European Union’s Standard Contractual Clauses for cross-border data transfers.

2.5 AUTOMATED DECISION-MAKING

Other than ‘profiling’ activities carried out in order to display advertisements that will be relevant to You as explained in Paragraph 2.2 above, we do not engage in any automated decision-making.

2.6 PERSONAL DATA RELATING TO CHILDREN

The Website should only be accessible by individuals over the age of 16. It is a parent’s or legal guardian’s responsibility to ensure that persons do not use Our Website.

2.7 MARKETING

We may use your personal information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email, we may use that information to send you special offers or information. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications, but we will continue to contact you regarding other administrative matters and to respond to your requests. We may also use your personal information to analyze and improve our marketing campaigns.

3. ABOUT YOUR RIGHTS

At any point in time during Our processing of Your data, You have the following rights. All requests in this regard may be made by sending an email to info@cyberpass.com.mt. We will also forward Your request to the relevant 3rd Parties mentioned above as required.

• Right of access – You can request a copy of the information that We hold about You.

• Right of rectification – You can ask Us to correct data that We hold about You if it’s inaccurate or incomplete.

• Right to be forgotten – in some situations, You may ask Us to delete certain data We hold about You and We will always comply to the extent allowed or required by any applicable law.

• Right to restriction of processing – in some situations, You may ask Us to restrict the processing of Your data.

• Right of portability – You may ask Us to transfer certain data We hold about You to another organization.

• Right to object – You have the right to object to certain types of processing such as direct marketing.

• Right to object to automated processing, including profiling – You also have the right to object to the legal effects of automated processing or profiling.

•Right to complain about how your Personal Data is being processed by Us (or third parties), or about how Your complaint has been handled, - You can lodge a complaint directly with the Office of the Information and Data Protection Commissioner (https://idpc.org.mt/) and with Us on info@cyberpass.com.mt.

•Right to Withdraw – you have the right to withdraw Your consent, where given, at any time. This applies in particular to receiving marketing communications, where You are able to opt-out of receiving further notifications by clicking on the ‘unsubscribe’ link found in all such communications. You may also send an email to info@cyberpass.com.mt.

4. SECURITY

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any personal information to CyberPass via the Internet.

5. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time for example, to keep it up to date or to comply with legal requirements. You should regularly check this Privacy Policy for updates. If there will be any significant changes made to the use of your personal information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website.

6. QUESTIONS

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at: info@cyberpass.com.mt.

The version of this Privacy & Cookies Policy is currently Version 1 and was last updated in November 2022. It is valid and applies to You until a new version uploaded on the Website and is accepted by You.