Staff Travel Ltd of 233, Nazju Ellul Street, Gzira GZR 1629, Malta (“Staff Travel”; “we”; “us”; “our”) respects your privacy and values its importance, and is wholly committed to protecting your personal data. The purpose of this Notice is to set out the basis on which we will process your personal data when:
- you approach and engage us to provide you with our travel services (the “Services”);
- receive the services that you may request from us during the course of this engagement; and/or
- you visit and use our website <http://www.stafftravel.com.mt/ > (the “Website” or the “Site”), regardless of where you visit and use it from.
This includes any data that you may provide for and in relation to our newsletters, updates, events and other marketing and promotional communications.
This Notice informs you about the items of personal data that we may collect about you and how we will handle it, and in turn, also tells you about (i) our obligations to process your personal data responsibly, (ii) your data protection rights as a data subject and (iii) how the law protects you.
We process your data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 586 of the Laws of Malta) (the “Act”), as may be amended or replaced from time to time, and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “Regulation” or the “GDPR”).
1. Important information and who we are
Comptroller
We are responsible for the Website.
We are also the data controller of any personal data which we collect or receive and which we process in connection with (i) the Services and/or (ii) the Website.
Our full details are as follows.
Contact details
Full name of legal entity: Staff Travel Ltd.
Email address: tim@stafftravel.com.mt
Postal address: 233, Nazju Ellul Street, Gzira GZR 1629, Malta.
You have the right to lodge a complaint at any time to a competent supervisory authority on data protection matters, such as in particular the supervisory authority in the place of your habitual residence or your place of work. In the case of Malta, this is the Office of the Information and Data Protection Commissioner (the “IDPC”) (https://idpc.org.mt/en/Pages/Home.aspx). We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
It is imperative that the personal data we hold about you is accurate and current at all times. Please keep us informed if your personal data changes during the course of our engagement and professional relationship with you. We will, likewise, advise you should our privacy notice change.
Third-party links
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notice or policies. We strongly encourage you to read the privacy notice of every website you visit, particularly when leaving our Website.
2. Some key definitions
Set out below are key definitions of certain data protection terms which appear in this Notice.
“Consent Form” refers to separate documents which we might from time to time provide you where we ask for your explicit consent for any processing which is not for purposes set out in this Notice.
“Data subjects” means living individuals (i.e. natural persons) about whom we collect and process personal data.
“Data controller” or “controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed.
“Data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the data controller).
“Personal data” means data relating to a living individual (i.e. natural person) who can be identified from the data (information) we hold or possess. This includes, but is not limited to, your name and surname (including maiden name where applicable), address, date of birth, nationality, gender, civil status, tax status, identity card number & passport number, contact details (including mobile and home phone number and personal email address), photographic image, bank account details, emergency contact information as well as online identifiers. The term “personal information”, where and when used in this Notice, shall be taken have the same meaning as personal data.
“Processing” means any activity that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
“Sensitive personal data”, “sensitive data” or “special categories of personal data” includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. This type of sensitive data can only be processed under strict conditions.
3. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified.
In the course of our engagement, Staff Travel will need to collect, use, and sometimes, disclose various items of personal data about you for various purposes associated with the scope of the Services that we provide, as requested and directed by you or by your organisation.
We have made an attempt to group and categorise below the different kinds of personal data that we may generally need to collect, process, use, share and store. For the reasons explained above, these data categories are strictly indicative and not exhaustive.
- Identity Data includes first name, maiden name, last name, title, identity document number, gender, nationality, employment status, organisation, occupation and (in the context of the Site) username or similar identifier.
- Contact Data includes billing address, mailing address, email address and contact numbers.
- Compliance Data (
- Financial Data includes the bank account details of the client together with details about any payment methods used by the client to settle our invoices and, as may be necessary under the particular circumstances, the financial status and creditworthiness of the client.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices which you use to access and browse the Website.
- Usage Data includes information about how you (whether a client or otherwise) use our Website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties or associated entities and your communication preferences. This may include information whether you have subscribed or unsubscribed from any of our mailing lists, attended any of our events or accepted any of our invitations.
If you fail to provide personal data
Where we need to collect personal data by law, or pursuant to our terms of business and engagement, and you fail to provide that data when requested, we may not be able to assist you or provide you with your requested Services, and may have to decline to enter into a business relationship with you.
4. How is your personal data collected?
We generally use different methods to collect data from and about you including through:
- Direct Interaction. You may give us your personal data by filling in our forms (such as our ‘Contact Form’ accessible at: http://www.stafftravel.com.mt/contact), or by corresponding with us by post, phone, email or otherwise or during face-to-face meetings.
- Automated technologies or interactions. When you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
(a) analytics providers;
(b) advertising networks; and
(c) search information providers.
- Financial and Transaction Data from our banks and credit reference agencies.
- Identity, Contact, Compliance and Assistance Data from publicly available sources such as public court documents, the Malta Registry of Companies, and from electronic data searches, online search tools (which may be subscription or license based), anti-fraud databases and other third party databases, sanctions lists and general searches carried out via online search engines (e.g. Google).
If you attend a meeting at our offices, we may hold images of you captured by our CCTV cameras, also for security purposes.
5. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we are providing you with your requested Services;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with our legal and professional obligations to third parties
Purposes for which we will use your personal data
Your personal data will be processed and stored for the following purposes:
a) The provision of Services, including transmission to third parties for the purpose of such provision of services, inter alia, any bookings required by you.
b) To establish and verify your identity.
c) To fulfill our internal and external compliance requirements.
d) Billing and invoicing purposes, including transmission to Credit and Financial Institutions, our Accountants and Lawyers, for credit checks, collection and payment processing
e) Dealing with queries and complaints in the course of our services, as well as to be able to contact you with any updates to the Services as may be required
f) To carry out market research campaigns and market our services to you
Marketing
You may receive marketing communications from us (which may consist of newsletters, industry updates, mailshots, publications and/or information about our events, seminars and webinars) where you have expressly consented to receive them from us.
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any third parties (including our associated corporate entities) for marketing purposes.
Opting out
You can ask us to stop sending you marketing communications (unsubscribe) at any time by following the opt-out (unsubscribe) links on any marketing communication sent to you
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. This Notice should be read in conjunction with our IP Address and Cookie policy.
7. International transfers
We will transfer your personal data to entities outside the European Economic Area (“EEA”) as may be necessary to: (i) provide you with the requested Services, (ii) fulfil our contractual obligations to you or exercise our contractual obligations against you. Where we do need to transfer your personal data to outside the EEA, we will ensure a similar degree of protection is afforded to that personal data by ensuring at least one of the following safeguards applies or is otherwise implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- In the absence of an adequacy decision, we will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Note however that when you instruct us to transfer or share your personal data, we will perform any processing activity required to fulfil such instructions as your mandataries and not as an autonomous controller. As your mandataries, we will not be required to enter into a contractual mechanism, joint controller agreement or otherwise, with the recipient to whom you have instructed us to share or transfer your personal data.
8. 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 (safeguard its integrity and confidentiality).
In addition, we limit access to your personal data to those employees, agents, contractors and other professional third parties who strictly need to know this information. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. All our employees and agents have received appropriate training on data protection.
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.
9. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it (the provision of the Services and the ongoing performance of our professional relationship with you) and, thereafter, for the purpose of satisfying any legal, accounting, tax, anti-money laundering and regulatory reporting requirements or obligations to which we may be subject and/or to the extent that we may also need to retain your personal data to be able to assert, exercise or defend possible future legal claims against or otherwise involving you.
By and large, our retention of your personal data shall not exceed the period of six (6) years from the the fulfilment of services for which you engage us. In certain cases, we may need to retain your personal data for a period of up to eleven (11) years in order to comply with applicable accounting and tax laws (this will primarily consist of your Transaction and Payment Data).
In some circumstances you can ask us to delete your data. See Request erasure below for further information.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request correction (rectification) of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at tim@stafftravel.com.mt.
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. Alternatively, we may simply refuse to comply with your request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm 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 to ask 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 a period of one month from the date of receiving your request. Occasionally it may take us longer than a month 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.
You have the right to:
(i) 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.
You may send an email to tim@stafftravel.com.mt requesting information as to what personal data we process. You shall receive one copy free of charge via email of the personal data which is undergoing processing. Any further copies of the information processed shall incur a charge of €10.00.
(ii) Right to information when collecting and processing personal data about you from publicly accessible or third party sources. When this take places, we will inform you, within a reasonable and practicable time frame, about the third party or publicly accessible source from which we have collected your personal data.
(iii) Request correction or rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected and/or updated, though we may need to verify the accuracy of the new data you provide to us. As mentioned, it is in your interest to keep us informed of any changes or updates to your personal data which may occur during the course of your relationship with us, since this may otherwise impair our ability to provide you with your requested Services or the quality thereof.
(iv) 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 have successfully exercised your right to object to processing (see below);
- we may have processed your information unlawfully; or
- 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. These may include instances where the retention of your personal data is necessary to:
- comply with a legal or regulatory obligation to which we are subject; or
- establish, exercise or defend a legal claim.
(v) 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 personal information that override your rights and freedoms.
(vi) 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:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- 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
- you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.
(vii) Withdraw your consent at any time where we are relying on consent to process your personal data (which will generally not be the case). This will not however affect the lawfulness of any processing which we carried out before you withdrew your consent. Any processing activities that are not based on your consent will remain unaffected.
Kindly note that none of these data subject rights are absolute, and must generally be weighed against our own legal obligations and legitimate interests. If a decision is taken to override your data subject request, you will be informed of this by our data protection team along with the reasons for our decision.
11. Conclusion
We reserve the right to make changes to this Notice in the future, which will be duly notified to you.