Privacy Policy

Is-Suq Tal-Belt Valletta Food Market | Website Privacy Policy

Privacy Policy

  • Last updated: August 2nd, 2023

    Introduction

    Arkadia Marketing Limited (C11113) trading as Is-Suq Tal-Belt Valletta Food Market values your privacy and is committed to protecting the privacy and security of personal data in accordance with the General Data Protection Regulation EU 2016/679 (“GDPR” or “Regulation”), the Data Protection Act, Chapter 586 of the Laws of Malta, and subsidiary legislation as may be amended from time to time.

    Purpose of this Privacy Policy

    This privacy policy (referred to as the "Policy") aims to give you information on how your personal data is collected and processed when you visit our website https://issuqtalbelt.com/ (referred to as the "Website" or the "Site") as well as when you reach out to us through any of the forms available on the Site and when we send you our promotions or communications through newsletters about our products, offers or events subject to your consent.

    It is important that you carefully review this Privacy Policy in conjunction with any additional privacy policies or privacy notices that we may provide during specific occasions when we are collecting or processing your personal data. This will ensure that you are fully aware of how and why we are using your data. It is important to note that this Privacy Policy serves as a complement to the other policies or notices and is not intended to supersede or replace them.

    Please note that this Policy applies only to the use of information collected through our website or during communications with us. It does not apply to the privacy policies of third-party websites linked to our site or to communications with other third parties.

    Controller Details

    The Controller of the personal data collected through the Website is Arkadia Marketing Limited, a company registered in Malta bearing company registration number C1113 and having its registered address at Mizzi Organisation, Corporate Office, Testaferrata Street, Ta' Xbiex, 1407, Malta (the "Controller”).

    The Controller is the owner of Is-Suq tal-Belt Valletta Food Market and is part of the Mizzi Organisation Group (which means those companies having Mizzi Organisation Limited as their ultimate parent company). The Mizzi Group has established an Intra Group Data Transfer Agreement which governs any transfer of personal data within the companies.

    The Company has appointed a Data Protection Officer (“DPO”) who is responsible for overseeing matters in relation to data protection including this Policy. If you have any queries relating to this Policy, including any requests to exercise your rights, please contact the DPO using the details given below.

     

    Contact Details

    Full name of legal entity: Arkadia Marketing Limited
    Company registration number: C11113
    Postal address: Mizzi Organisation Corporate Office, Testaferrata Street, Ta' Xbiex, XBX 1407, Malta
    Data Protection Officer (DPO): dpo@issuqtalbelt.com


    The Data We May Collect About You

    Personal data means any information about an individual from which that person can be identified, directly or indirectly. It does not include data where the identity has been removed (anonymous data). We may collect your data directly from you or automatically when you access our Website.

    When collecting and utilizing your personal data, we guarantee that the processing is conducted on a lawful basis as per Article 6 of the GDPR. The table below presents transparent information regarding the processing of your personal data in relation to our website:


    Activity

    Personal Data

    Purposes and lawful basis for processing

     

    When you visit this Website

    Usage Data such as cookies, IP address, pages of visited on our Site, the time and date of your visit, time spent on those pages, unique device identifiers etc.

    Device and Browser Specifications such as browser type, browser versions, the type of mobile device you use, mobile device unique ID, mobile operating system, unique device identifiers etc.

    We collect and use your data to better understand our users’ needs, to continuously improve our website and to enable users to access the Website, for purposes of (network) security, to measure and improve the effectiveness of this Website, to help diagnose problems with our server, to administer this Website and to see where website traffic is coming from.

    Legal basis: art. 6 (1) (f) of GDPR, the process is necessary to fulfil our legitimate interests.

    When you request our services through the Contact Us Form or when you contact us via our social media pages

    Identity Data such first name and last name

    Contact Information such as phone number and email address

    Third Party Data such as personal data included within your message which pertains to other individuals.

    We collect and use your data to provide you with the information requested and to provide you with our services.

    Legal basis: art. 6 (1) (b) of GDPR the process is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

    Legal basis: art. 6 (1) (f) of GDPR Processing is necessary for our legitimate interests of conducting our business and reply to queries, complaints or concerns raised within the form.

    When you place a booking request for events, conferences, private catering or team building activities.

    Identity Data such as first and last name of organiser, name and surname of persons attending the event (guest list).

    Contact Information such as email address and mobile number.

    Health data such as dietary requirements and physical disabilities.

    We collect and use your data to respond and action your booking request.

    Legal basis: art. 6 (1) (b) of GDPR the process is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

    Legal basis: art. 6 (1) (f) of GDPR Processing is necessary for our legitimate interests of conducting our business.

    Art. 9(2)(a) of the GDPR where the data subject has given explicit consent to the processing of their personal data in relation to dietary requirements.

    To send you marketing communication through newsletters regarding any promotions, offers, events or competitions.

    Identity data such as first name and last name

    Contact information such as phone number and email address.

    Data related to our communications such as date and time accessed, type and content of the communications, your subscription status.

    We collect and use your data with the purpose of providing you with promotional materials (including news and special offers) concerning our services as well as products.

    Legal basis: art. 6 (1) (a) of GDPR. We process data for the purpose of marketing activities with your consent

    To send you any prizes which you may win as part of a competition that we have organised

    Identity data such as first name and last name

    Contact information such as phone number and email address, postal address.

    If you participate in a competition, we may collect your postal address to send the reward, if you are a winner of the competition via post.

    Legal basis: art. 6 (1) (b) of GDPR the process is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

     

    In relation to the legal basis of our legitimate interest under art. 6 (1) (f) GDPR, in addition to the purposes listed above, we might process Your data also for the purposes of the establishment, exercise or defence of a claim or a legal action, to ensure network and information security and to report criminal acts.  Where we process your personal data in reliance on article 6(1)(f) GDPR, we ensure that our legitimate interest does not override your interests or fundamental rights and freedoms which require protection of personal data.

    Furthermore, we might process your data in order to comply with legal obligations which we might be subject to.

    You have the right to withdraw the consent to marketing at any time by unsubscribing from our mailing list or by contacting our DPO at dpo@issuqtalbelt.com

    Cookies

    When you visit our Website, we use cookies which allows us to automatically collect information about you as well as your device for different purposes, in order to enhance your navigation on our services, improve our services’ performance and customise your experience on our services. We also use this information to collect statistics about the usage of our services. For further information on what cookies are, which cookies we use, how and why we use cookies, and how you can control cookies, please read our Cookie Policy.

    If you fail to provide personal data

    The provision of personal data is not a statutory or a contractual requirement. However, if you do not provide the requested personal data, we may not be able to provide you with the requested services.

    Minors

    The Site is not intended for individuals under the age of 13. We do not intentionally collect personal information from children. If you are the parent or guardian and believe your child has provided us with personal information, please contact Us at the address below to request deletion.

    Sharing of your personal data

    The personal information will be disclosed to third parties only to the extent required for the specific purpose(s), as stipulated in this Policy. We may have to share your personal data with the following categories of recipients:

    • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and auditing services.
    • Any service providers that may have access to your personal data in rendering us with their support services, for example, marketing service providers and IT support.
    • We may disclose personal data processed to other companies within the Mizzi Group in accordance with Intra Group Data Transfer Agreement.
    • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
    • Administrative, regulatory or judiciary authorities or agencies and other third parties to comply with any legal, enforcement or regulatory obligation and/or in the cases of an express and justified request or in case of an alleged violation of legal or regulatory provisions.

    International Transfers

    Unless otherwise required, we keep your information within the European Economic Area (“EEA”). However, in the event that we are required to transfer your personal data to a recipient and/or third party situated in a jurisdiction outside of the EU that has not received an adequacy decision issued by the European Commission (Art. 45 GDPR), the transmission of data shall be subject to appropriate safeguards within the meaning of Article 46(1) GDPR which might include the Standard Contractual Clauses (SCCs). You can obtain a copy of the Standard Contractual Clauses (SCCs) by contacting us at dpo@issuqtalbelt.com.

    Data Security

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

    Data Retention

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Where your personal data is no longer required by us, we will either securely delete or anonymise the personal data in question. If you wish to know more about our retention periods, you can contact us at dpo@issuqtalbelt.com.

    Your Rights

    Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.

    • Right to be informed about the processing of your personal data through this Policy.
    • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
    • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    • Request the transfer of your personal data to you or to a third party. We will provide you, or a third party of your choice, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
    • Right to be informed of the source where the personal data we hold about you was not provided to us directly by you, you may also have the right to be informed of the source from which your personal data originates.

     

    Please note that your rights in relation to your Personal Data are not absolute and we may not be able to entertain such a request if we are prevented from doing so in terms of an applicable law.

     

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

    If you have any questions or wish to exercise your rights, you can directly contact our Data Protection Officer (DPO) via dpo@issuqtalbelt.com.

    Automated Decision-Making

    We do not engage in automated decision-making activities. Should we endeavour to make any decision based on fully automated basis we shall notify you and seek your explicit consent.

    You have the right to object to processing based solely on automated decision-making (which includes profiling) when that decision-making has a legal effect on you or otherwise significantly affects you.

    What We May Need From You

    We may need to request specific information from you to help us confirming your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you for further information in relation to your request to speed up our response.

    Time Limit to Respond

    We try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    Fees

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive in nature. Alternatively, we could refuse to comply with your request in these circumstances.

    Right to complaint

    You have the right to make a complaint at any time to the Information and Data Protection Commissioner Office (IDPC), the Maltese supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so kindly contact us in the first instance at dpo@issuqtalbelt.com. The IDPC’s contact details are as follows:

    Address: Level 2, Airways House, High Street, Sliema SLM 1549, Malta

    Email: idpc.info@idpc.org.mt

    Website: https://idpc.org.mt/file-a-complaint/

    Further processing

    Where we need to further process your personal data for a purpose other than that for which your personal data have been collected, we will provide you, with any relevant information prior to the commencement of the further processing.

    Changes to the Privacy Policy

    We may update this Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.