Last updated: 06/11/2024
I. Introduction
This Privacy Notice explains how our company (collectively “we” “us” or “our”) will collect, compile and disclose information about those who use of or contact us via the Website or other communication channels. We put great efforts in making sure that we secure your personally identifiable information and use it properly. This Privacy Notice explains generally how we receive Personal Information about you, and what we do with that Personal Information once we have it.
Please read this Privacy Notice (“Privacy Notice”, “Notice”) in full before using the Website. If you do not agree to this Notice, please do not provide us with your data.
II. Scope of application
This Privacy Notice applies to data processing activities carried out as part of:
● Site management https://znaki-agency.com/ (“Website”). ● Requests sent through the feedback forms posted on the Website. ● Sending our newsletter. ● Recruitment of employees. ● Interaction with clients, service providers and partners.
III. What do we mean by “Personal Data” and “Processing of your Personal Data”?
For us, “Personal data” or “Personal information” means information relating to persons who:
● can be identified, or who are identifiable, directly from the information in question; or ● who can be indirectly identified from that information in combination with other information.
“Processing” covers “any operation” performed on personal data “such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
IV. Who we are, and what is our role with respect to your Personal Data?
In this Privacy Notice, any reference to “https://znaki-agency.com/”, “we”, “us” and “our” means: Znaki LTD, limited liability company incorporated under laws of Malta.
Registration number: C109417. Address: 152/9, TRIQ IN-NAXXAR, SAN GWANN, SGN 9030, Malta.Email: .moc.ycnega-ikanz%40ofni
If you have any questions about this Privacy Notice, please contact us via the above-mentioned contact details.
With respect to personal data collected when you access and use the Website or communication channels via Social Media (as Twitter, LinkedIn or Facebook), we may act as a data controller, joint data controller, or a data processor depending on applicable circumstances as described below.
Data controller means an entity or individual that determines the purposes and means of processing personal data. In other words, the data controller is responsible for deciding why and how personal data is collected, stored, used, and disclosed. The Data controller is also obligated to ensure that the processing of personal data complies with the principles and requirements of the applicable legislation, including obtaining the necessary consent from data subjects and protecting their rights in relation to their personal data.
Joint data controller refers to two or more entities or organizations that jointly determine the purposes and means of processing personal data. In this scenario, they share the responsibility for complying with data protection laws and ensuring the protection of individuals' rights whose personal data is being processed. According to the applicable data protection legislation, which includes the General Data Protection Regulation, also known as the GDPR (“Applicable Legislation”), we may be regarded as joint controllers, for example, in the following case: with respect to your Social Media Data (what is this data outlined below) — when you contact us via Social Media, we are deemed a data controller with respect to (i) the data you provide us with and (ii) the statistical data provided by the respective Social Media. However, with respect to any other processing of your data, the respective Social Media acts as an independent data controller.
Data processor mean an entity or organization that processes personal data on behalf of a Data controller. The Data processor's role is to process Personal data according to the instructions provided by the Data controller. They may include various tasks such as collecting, storing, organizing, analyzing, and deleting Personal data.
V. What are Our principles?
We are committed to maintaining the highest standards of data protection and privacy when processing your Personal data. Our data processing practices are guided by the following principles:
Principles
Description
Principles
Principles
Description
Description
Lawfulness, Fairness, and Transparency
We process your Personal data lawfully, with a clear and legitimate purpose. We ensure that you are informed about the processing activities through this Privacy Notice and any other relevant communications.
Principles
Lawfulness, Fairness, and Transparency
Description
We process your Personal data lawfully, with a clear and legitimate purpose. We ensure that you are informed about the processing activities through this Privacy Notice and any other relevant communications.
Purpose Limitation
Your Personal data is collected for specified, explicit, and legitimate purposes and will not be further processed in a manner incompatible with those purposes. We do not use your data for purposes that are unrelated to the original intent of collection without obtaining your consent, unless required or permitted by law.
Principles
Purpose Limitation
Description
Your Personal data is collected for specified, explicit, and legitimate purposes and will not be further processed in a manner incompatible with those purposes. We do not use your data for purposes that are unrelated to the original intent of collection without obtaining your consent, unless required or permitted by law.
Data Minimization
We only collect and process Personal data that is adequate, relevant, and limited to what is necessary for the purposes for which it is being processed. We do not retain your data longer than required to fulfill the specified purposes, unless retention is necessary for legal or regulatory compliance.
Principles
Data Minimization
Description
We only collect and process Personal data that is adequate, relevant, and limited to what is necessary for the purposes for which it is being processed. We do not retain your data longer than required to fulfill the specified purposes, unless retention is necessary for legal or regulatory compliance.
Accuracy
We strive to keep your Personal data accurate, complete, and up-to-date. You have the right to request the correction of any inaccurate or incomplete information.
Principles
Accuracy
Description
We strive to keep your Personal data accurate, complete, and up-to-date. You have the right to request the correction of any inaccurate or incomplete information.
Integrity and Confidentiality
We implement appropriate technical and organizational measures to ensure the security and confidentiality of your Personal data, protecting it from unauthorized access, disclosure, alteration, or destruction.
Principles
Integrity and Confidentiality
Description
We implement appropriate technical and organizational measures to ensure the security and confidentiality of your Personal data, protecting it from unauthorized access, disclosure, alteration, or destruction.
Accountability
We take responsibility for our data processing practices and comply with applicable data protection laws and regulations. We maintain records of our processing activities and conduct periodic assessments to ensure compliance.
Principles
Accountability
Description
We take responsibility for our data processing practices and comply with applicable data protection laws and regulations. We maintain records of our processing activities and conduct periodic assessments to ensure compliance.
Lawful Bases for Processing
We process your personal data based on one or more lawful bases, such as your consent, the performance of a contract, compliance with legal obligations, legitimate interests, or other lawful grounds provided by the Applicable legislation.
Principles
Lawful Bases for Processing
Description
We process your personal data based on one or more lawful bases, such as your consent, the performance of a contract, compliance with legal obligations, legitimate interests, or other lawful grounds provided by the Applicable legislation.
Data Subject Rights
We respect your rights as a data subject and provide mechanisms for you to exercise those rights.
Principles
Data Subject Rights
Description
We respect your rights as a data subject and provide mechanisms for you to exercise those rights.
International Data Transfers Security
If we transfer your Personal data to countries outside the European Economic Area (EEA), we will ensure that adequate safeguards are in place to protect your data, as required by applicable data protection laws.
Principles
International Data Transfers Security
Description
If we transfer your Personal data to countries outside the European Economic Area (EEA), we will ensure that adequate safeguards are in place to protect your data, as required by applicable data protection laws.
Category of Data
Examples
Description or Comments
Category of Data
Category of Data
Examples
Examples
Description or Comments
Description or Comments
Analytical and Statistical Data
● internet protocol (IP) address● the type of device used● the browser used● the device operating system● information regarding your use of the Website, for instance, when you clicked a certain button or made some input.
When you access and use the Website, certain data may be collected automatically via Google Analytics. More information regarding Google Analytics is available here.
After collecting the personal data, Google creates reports about the use of the Platform, which contain the aggregated information where we do not see any data pertaining to a particular person. In other words, we cannot identify you from the other users.
Besides, we gather the information by means of placing cookies. Cookies are a feature of the software that allows web servers to recognise the device used to access the Website. A cookie is a small text file that the Website saves on your device when you visit thereof. They allow the Website to remember your actions and preferences over a period of time.
Category of Data
Analytical and Statistical Data
Examples
● internet protocol (IP) address● the type of device used● the browser used● the device operating system● information regarding your use of the Website, for instance, when you clicked a certain button or made some input.
Description or Comments
When you access and use the Website, certain data may be collected automatically via Google Analytics. More information regarding Google Analytics is available here.
After collecting the personal data, Google creates reports about the use of the Platform, which contain the aggregated information where we do not see any data pertaining to a particular person. In other words, we cannot identify you from the other users.
Besides, we gather the information by means of placing cookies. Cookies are a feature of the software that allows web servers to recognise the device used to access the Website. A cookie is a small text file that the Website saves on your device when you visit thereof. They allow the Website to remember your actions and preferences over a period of time.
Contact Data
● name/nickname● email address● phone number● any other data requested by us or data that you choose to provide us with
This data are collected through contact form on the website.
You decide at your own discretion what data to provide to us.
Category of Data
Contact Data
Examples
● name/nickname● email address● phone number● any other data requested by us or data that you choose to provide us with
Description or Comments
This data are collected through contact form on the website.
You decide at your own discretion what data to provide to us.
Subscription Data
email address
If you contact us via contact form on the website, we may use indicated email for our marketing and newsletter purposes.
Category of Data
Subscription Data
Examples
email address
Description or Comments
If you contact us via contact form on the website, we may use indicated email for our marketing and newsletter purposes.
Social Media Data
● nicknames, names, and/or photos
messages, comments, and other communications● information provided to us by the respective Social Media as outlined below● other data that you choose to provide us with
You may contact us via Social Media as Twitter, LinkedIn or Facebook.
In general, Social Media makes available the respective statistical information to us in an anonymized form. It is impossible for us to make any conclusions about individual users and access to individual user profiles relying solely on such information.
Certain categories of personal data and processing details vary depending on the Social Media, therefore, please refer to the Privacy policies of the respective Social Media as listed below.
- Twitter- LinkedIn- Facebook
Category of Data
Social Media Data
Examples
● nicknames, names, and/or photos
messages, comments, and other communications● information provided to us by the respective Social Media as outlined below● other data that you choose to provide us with
Description or Comments
You may contact us via Social Media as Twitter, LinkedIn or Facebook.
In general, Social Media makes available the respective statistical information to us in an anonymized form. It is impossible for us to make any conclusions about individual users and access to individual user profiles relying solely on such information.
Certain categories of personal data and processing details vary depending on the Social Media, therefore, please refer to the Privacy policies of the respective Social Media as listed below.
- Twitter- LinkedIn- Facebook
Contract Data
● full name● contact details
position in company● passport data● other data that required by applicable legislation for establishment of contractual relationship or agreement between us
If you want us to enter into a contract to provide you with services, you will need to provide some Personal data about yourself. If you are acting independently, this includes, at least, your full name, passport details, and channels of communication. If you are acting on behalf of a company, you will also need to indicate your position in such a company (as example, managing director etc.).
Please note that the email as ten.ynapmoc%40ofni is not personal data.
Category of Data
Contract Data
Examples
● full name● contact details
position in company● passport data● other data that required by applicable legislation for establishment of contractual relationship or agreement between us
Description or Comments
If you want us to enter into a contract to provide you with services, you will need to provide some Personal data about yourself. If you are acting independently, this includes, at least, your full name, passport details, and channels of communication. If you are acting on behalf of a company, you will also need to indicate your position in such a company (as example, managing director etc.).
Please note that the email as ten.ynapmoc%40ofni is not personal data.
Recruitment Data
● full name● email address● phone number● professional experience● previous position● other information that you provide when applying and/or resume and/or during interviews: photos, skills, educational level, languages spoken, expected salary level, home address, hobby, etc.● in case of employment (Passport Data, TIN)
We need this information in order to understand whether you meet the requirements of our vacancy.
In the case of employment, the provision of certain information is required by law. We use such data only to the extent and for the purposes necessary to fulfill our legal obligations.
Category of Data
Recruitment Data
Examples
● full name● email address● phone number● professional experience● previous position● other information that you provide when applying and/or resume and/or during interviews: photos, skills, educational level, languages spoken, expected salary level, home address, hobby, etc.● in case of employment (Passport Data, TIN)
Description or Comments
We need this information in order to understand whether you meet the requirements of our vacancy.
In the case of employment, the provision of certain information is required by law. We use such data only to the extent and for the purposes necessary to fulfill our legal obligations.
Feedback Data
● name● position● photo
If you are satisfied with the services, or for other reasons decide to tell others your impression of us, you can send us feedback and we will publish it on our Website.
Category of Data
Feedback Data
Examples
● name● position● photo
Description or Comments
If you are satisfied with the services, or for other reasons decide to tell others your impression of us, you can send us feedback and we will publish it on our Website.
Category of Data
Description
Lawful Basis for Processing
Category of Data
Category of Data
Description
Description
Lawful Basis for Processing
Lawful Basis for Processing
Analytical and Statistical Data
To provide a better user experience by improving functionality, usability, user flow and interface of the Website.
Our legitimate interest to improve the Website functionality and user experience, detect fraud and respond to requests from authorities.
Category of Data
Analytical and Statistical Data
Description
To provide a better user experience by improving functionality, usability, user flow and interface of the Website.
Lawful Basis for Processing
Our legitimate interest to improve the Website functionality and user experience, detect fraud and respond to requests from authorities.
Contact Data
To respond to your inquiry.
Our legitimate interest to respond to your inquiry.
Category of Data
Contact Data
Description
To respond to your inquiry.
Lawful Basis for Processing
Our legitimate interest to respond to your inquiry.
Subscription Data
To provide you with marketing and newsletter emails concerning our services, compliance guidance, as well as general updates.
Your consent. You may revoke your consent and unsubscribe from receiving marketing and newsletter emails from us at any time by (i) contacting us; or (ii) clicking the unsubscribe button available at the bottom of each marketing and newsletter email.
In such a case, we will delete your email address from the respective marketing database.
Category of Data
Subscription Data
Description
To provide you with marketing and newsletter emails concerning our services, compliance guidance, as well as general updates.
Lawful Basis for Processing
Your consent. You may revoke your consent and unsubscribe from receiving marketing and newsletter emails from us at any time by (i) contacting us; or (ii) clicking the unsubscribe button available at the bottom of each marketing and newsletter email.
In such a case, we will delete your email address from the respective marketing database.
Social Media Data
To communicate with the visitors, participants, or subscribersTo handle requests from visitors via the communication channels.To obtain statistical information about the reach of the communication channels.To conduct customer surveys, marketing campaigns, market analyses, or other promotions and events.
Our legitimate interest to achieve the purposes outlined herein.
To take steps at your request prior to entering into a contract and further to perform such a contract, if and to the extent you wish to enter into a contractual relationship with us.
Category of Data
Social Media Data
Description
To communicate with the visitors, participants, or subscribersTo handle requests from visitors via the communication channels.To obtain statistical information about the reach of the communication channels.To conduct customer surveys, marketing campaigns, market analyses, or other promotions and events.
Lawful Basis for Processing
Our legitimate interest to achieve the purposes outlined herein.
To take steps at your request prior to entering into a contract and further to perform such a contract, if and to the extent you wish to enter into a contractual relationship with us.
Contract Data
-
To perform a contract with you.
Category of Data
Contract Data
Description
-
Lawful Basis for Processing
To perform a contract with you.
Recruitment Data
To hire new employees for our open positions.
Our legitimate interest. In case of Employment – Legal obligation.
Category of Data
Recruitment Data
Description
To hire new employees for our open positions.
Lawful Basis for Processing
Our legitimate interest. In case of Employment – Legal obligation.
Feedback Data
To provide Website users with the experience and impressions of others from cooperation with us.
Our legitimate interest to achieve the purposes outlined herein.
Category of Data
Feedback Data
Description
To provide Website users with the experience and impressions of others from cooperation with us.
Lawful Basis for Processing
Our legitimate interest to achieve the purposes outlined herein.
Category of Data
Period of retention
Explanation
Category of Data
Category of Data
Period of retention
Period of retention
Explanation
Explanation
Analytical and Statistical Data
Up to two (2) years. You may find specific timelines here.
Specific timelines are set by Google in its settings.
Category of Data
Analytical and Statistical Data
Period of retention
Up to two (2) years. You may find specific timelines here.
Explanation
Specific timelines are set by Google in its settings.
Contact Data
2 years after the last communication, unless otherwise provided by the relevant legislation
Category of Data
Contact Data
Period of retention
2 years after the last communication, unless otherwise provided by the relevant legislation
Explanation
Subscription Data
As long as you remain a subscriber.
We process such data only until you opt out from receiving our marketing and newsletter emails.
Category of Data
Subscription Data
Period of retention
As long as you remain a subscriber.
Explanation
We process such data only until you opt out from receiving our marketing and newsletter emails.
Social Media Data
No retention period for statistical and analytical information.
The personal data you provided us with is stored as long as it is not deleted by you or respective Social Media.
Information on our communication will be deleted by us after 2 years from the last communication.
We do not establish any retention period for statistical and analytical information, because such information does not allow us to identify any particular individual.
We may not be able to erase the personal data you provided us within the communication channels, therefore, such data is processed until either you or respective Social Media deletes it.
Category of Data
Social Media Data
Period of retention
No retention period for statistical and analytical information.
The personal data you provided us with is stored as long as it is not deleted by you or respective Social Media.
Information on our communication will be deleted by us after 2 years from the last communication.
Explanation
We do not establish any retention period for statistical and analytical information, because such information does not allow us to identify any particular individual.
We may not be able to erase the personal data you provided us within the communication channels, therefore, such data is processed until either you or respective Social Media deletes it.
Contract Data
In case of contractual relationship between you and us, 2 years after its termination.
This term is related to our fulfillment of our obligations under the law, such as accounting, auditing, taxation, etc.
Category of Data
Contract Data
Period of retention
In case of contractual relationship between you and us, 2 years after its termination.
Explanation
This term is related to our fulfillment of our obligations under the law, such as accounting, auditing, taxation, etc.
Recruitment Data
In case of employment: for the period of work with us and after dismissal within 1 year. In case of refusal: within 6 months after it, if you do not object to processing.
-
Category of Data
Recruitment Data
Period of retention
In case of employment: for the period of work with us and after dismissal within 1 year. In case of refusal: within 6 months after it, if you do not object to processing.
Explanation
-
Feedback Data
As long as your feedback remains on our Website.
We process such data only until you opt out by informing us via contact details stipulated in the "Contact Us" section.
Category of Data
Feedback Data
Period of retention
As long as your feedback remains on our Website.
Explanation
We process such data only until you opt out by informing us via contact details stipulated in the "Contact Us" section.
Rights
Time
Rights
Rights
Time
Time
Right of access
You have the right to request access to the personal data we hold about you. Upon receipt of such a request, we will provide you with information about the purposes of the processing, the categories of personal data being processed, any recipients of the data, and the data retention period.
Rights
Right of access
Time
You have the right to request access to the personal data we hold about you. Upon receipt of such a request, we will provide you with information about the purposes of the processing, the categories of personal data being processed, any recipients of the data, and the data retention period.
Right to rectification
If you believe that the personal data we have about you is inaccurate or incomplete, you have the right to request that we rectify or update it promptly.
Rights
Right to rectification
Time
If you believe that the personal data we have about you is inaccurate or incomplete, you have the right to request that we rectify or update it promptly.
Right to erasure (Right to be Forgotten)
You can request the deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or if you withdraw your consent, and there are no legitimate grounds for continuing the processing.
Rights
Right to erasure (Right to be Forgotten)
Time
You can request the deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or if you withdraw your consent, and there are no legitimate grounds for continuing the processing.
Right to restrict processing
You have the right to request the restriction of processing your personal data under specific circumstances, for example, if you contest the accuracy of the data or if the processing is unlawful, and you oppose erasure.
Rights
Right to restrict processing
Time
You have the right to request the restriction of processing your personal data under specific circumstances, for example, if you contest the accuracy of the data or if the processing is unlawful, and you oppose erasure.
Right to data portability
You may request to receive a copy of the personal data you have provided to us in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another data controller, where technically feasible.
Rights
Right to data portability
Time
You may request to receive a copy of the personal data you have provided to us in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another data controller, where technically feasible.
Right to object
You have the right to object to the processing of your personal data based on our legitimate interests. We will cease processing your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms.
Rights
Right to object
Time
You have the right to object to the processing of your personal data based on our legitimate interests. We will cease processing your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms.
Right to withdraw consent
If you have provided consent for the processing of your personal data, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Rights
Right to withdraw consent
Time
If you have provided consent for the processing of your personal data, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Right to file a complaint
If you believe that your rights under the Applicable legislation have been violated or that we have not properly addressed your concerns regarding the processing of your personal data, you have the right to file a complaint with the relevant supervisory authority.
The supervisory authority is the data protection authority in your country or region responsible for overseeing compliance with data protection laws. You can find the contact details of your supervisory authority on their official website or through other relevant sources.
The supervisory authority in Malta:
Office of the Information and Data Protection Commissioner
Website: https://idpc.org.mt/
Address: Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, Malta
Phones: +356 2328 7100
E-mail: tm.gro.cpdi%40ofni.cpdi
Rights
Right to file a complaint
Time
If you believe that your rights under the Applicable legislation have been violated or that we have not properly addressed your concerns regarding the processing of your personal data, you have the right to file a complaint with the relevant supervisory authority.
The supervisory authority is the data protection authority in your country or region responsible for overseeing compliance with data protection laws. You can find the contact details of your supervisory authority on their official website or through other relevant sources.
The supervisory authority in Malta:
Office of the Information and Data Protection Commissioner
Website: https://idpc.org.mt/
Address: Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, Malta
Phones: +356 2328 7100
E-mail: tm.gro.cpdi%40ofni.cpdi