Terms of Use

1. Terms and abbreviations used in the Privacy Policy

1.1. Processing – is any action or set of operations performed with or without automated means on Personal Data or on sets of Personal Data, such as collection, registration, organization, structuring, storage, adaptation or modification, recovery, viewing, use, disclosure by dispatching, distributing or otherwise making available, coordination, combination, restriction, erasure or destruction.

1.2. Data Processor – is a natural or legal person, public authority, agency or another body that processes Personal Data on behalf of the Data Controller.

1.3. Data Controller – Company that processes Personal Data of the Data Subject in accordance with the specified purposes and means of Personal Data Processing.

1.4. Data Subject – ETM potential, current, former client – natural person, employment candidate, visitor, websites visitor and user, participant of events organized by ETM, employee of legal entities, official, contact person, authorized person, beneficial owner and any other identified or identifiable natural person, whose Personal Data is Processed by ETM.

1.5. ETM – Company, registered with Malta Business Register, reg. No. C84077, legal address: 4, Cresta Court, Triq Abate Rigord, Ta’ Xbiex, Malta.

1.6. Personal Data – any information relating to an identified or identifiable natural person (Data Subject).

1.7. General Data Protection Regulation – Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the Processing of Personal Data and on the free movement of such data and repealing Directive 95/46/EC.

2. General provisions

2.1. The purpose of this “Privacy Policy” (hereinafter – Privacy Policy) is to provide a Data Subject with information on purpose, legal basis, scope, terms of processing, protection measures performed by ETM, as well as on the Data Subject’s rights in relation to Personal Data processing. Additional information on processing of Personal Data may be included in agreements, confidentiality notices and other documents.

2.2. ETM takes care of the privacy of Data Subjects and protection of Personal Data, observing the Data Subjects’ right to the lawfulness of Personal Data Processing in accordance with the General Data Protection Regulation and applicable national and other regulatory enactments in the field of privacy and Personal Data Processing.

2.3. ETM has implemented appropriate technical and organizational measures to protect Personal Data from unauthorized access, unlawful disclosure, accidental loss, alteration, destruction or any other unlawful processing.

2.4. Personal Data is obtained directly from the Data Subject and from services used by Data Subject, as well as from external sources (e.g. public registers or databases) or other persons (e.g. legal entity represented by the Data Subject, or whose employee, official, beneficial owner he/she is). ETM may record telephone conversations, video and/or audio, save e-mail communication or otherwise document the Data Subject’s interaction and communication with ETM.

3. Information about Data Controller

3.1. ETM may be a Data Controller, Data Processor or Joint Controller when processing Personal Data of the Data Subject.

4. Purposes of Personal Data Processing

4.1. ETM processes Personal Data mainly for the following purposes:

Compliance with legal requirements;
Conclusion and execution of contracts;
Placing orders, delivery of goods, fulfillment of product warranty obligations;
Preparation of invoices, settlements;
Identification of client / Data Subject;
To ensure communication;
To ensure the course of ETM personnel selection process;
For implementation of rights of ETM;
For ETM marketing activities;
For video surveillance in premises, warehouses and territories;
For prevention and detection of criminal offenses;
For obtaining and preservation of evidence in civil disputes;
For reviewing applications / complaints and other documents;
For other purposes in legally justified cases.

4.2. In any of the cases referred to in Clause 4.1 of the Privacy Policy, ETM Processes Personal Data to the extent permitted by the specific purpose of Personal Data Processing and in accordance with the procedures required and permitted by applicable laws and regulations.

5. Legal basis for Personal Data processing

5.1. ETM processes Personal Data on the basis of the following legal grounds:

For conclusion and execution of an agreement;
In order to fulfill legal obligation;
In order to implement or defend legitimate interests;
Consent;
Public interests.

6. Categories of personal data and their types

6.1. The amount and categories of Personal Data to be processed depend on the purpose of the Processing, which may differ in different situations. ETM mainly processes the following categories and types of Personal Data:

Identification data, such as personal identification code, date of birth, data of identity documents, incl. photo;
Contact information, such as address, phone number, email address;
Financial data, for example, information on execution of customer payments in connection with the goods sold by ETM;
Account details, such as bank account number;
Reliability and research data, such as data on counterparty payment discipline, data enabling ETM to conduct customer research activities related to prevention of money laundering and terrorist financing and to verify compliance with international sanctions, including the purpose of cooperation and whether a business partner, its representative, real beneficiary is a politically significant person;
Data obtained and/or created in the course of performing duties provided for in regulatory enactments, for example, data that ETM is obliged to provide to such institutions as tax authorities, courts, law enforcement authorities;
Communication and device data, such as data contained in messages, e-mails, videos, photographs and/or audio recordings, as well as other types of communication and interaction data collected when the Data Subject visits ETM premises and organized events or contacted a Data Subject, and data related to the Data Subject’s ETM website;
Professional data, such as data on education or professional career;
Special category Personal Data, such as data on suitability of a job vacancy candidate for the position to be held.

7. Personal Data Protection Measures

7.1. For the protection of Personal Data, ETM uses various technical and organizational security measures to protect Personal Data from unauthorized disclosure, access, loss, erasure, destruction (e.g. data encryption, anti-burglary equipment, firewalls, security passwords, etc.).

7.2. Personal Data is available to a limited number of employees of ETM and involved Data Processors, who need it for performance of the respective official functions/tasks, and who have binding confidentiality requirements.

8. Transfer / Disclosure of Personal Data

8.1. ETM may transfer Personal Data to persons to whom ETM has the right to disclose them or has an obligation in accordance with regulatory enactments or concluded agreements, or if the Data Subject’s consent has been obtained.

8.2. ETM may transfer Personal Data mainly to the following recipients:

Institutions and officials, such as supervisory authorities, tax authorities, law enforcement authorities, sworn bailiffs, sworn notaries, courts, out-of-court dispute resolution institutions;
Credit and financial institutions, insurance service providers, third parties involved in the execution of transactions, settlements and reporting;
Financial and legal consultants, auditors;
Providers of information systems and databases;
Debt collection service providers, assignees, insolvency administrators;
Other persons and suppliers related to the provision of services to ETM, incl. video surveillance, IT, telecommunications, archiving, postal service providers, etc.

8.3. ETM does not regularly or systematically transfer Personal Data to third countries. However, Personal Data may be processed by Data Processors located in third countries. In this case, ETM ensures the procedures provided for in regulatory enactments to ensure an adequate level of protection.

9. Duration of storage of Personal Data

9.1. ETM does not store Personal Data for longer than it is necessary for the respective purpose of Personal Data Processing, or longer than specified in the binding regulatory enactments.

10. Profiling and automated decision making

10.1. ETM does not perform profiling and automated decision-making in relation to the Data Subject.

11. Cookies

11.1. ETM uses cookies on their website. The cookies used and information about them are available in the Cookie Policy section.

12. Video surveillance

12.1. If ETM performs video surveillance, information signs are placed at the entrances indicating the purpose of video surveillance.

13. Rights of the Data Subject

13.1. In accordance with the General Data Protection Regulation, the Data Subject has the following rights:

To receive confirmation whether ETM processes their Personal Data and access to it;
To request correction of inaccurate Personal Data;
To request deletion of Personal Data;
To restrict Processing of Personal Data;
To object to the Processing of Personal Data;
To data portability;
To withdraw consent at any time.

14. Contact information

In case of any questions or for additional information regarding the processing of Personal Data by ETM, please contact us at: info@etm.mt.

15. Privacy Policy Availability and Amendments

15.1. ETM is entitled to unilaterally make changes and additions to the Privacy Policy at any time by publishing the current version on the ETM website.