Sandstone Malta Ltd, as your data controller, is committed to safeguarding your privacy.

This policy, last updated on 8th January 2023, is our overarching Privacy Notice and will give information about what, how and why we collect and process the data, how we store the data, how long we keep it for and who we share it with.

Our website may, from time to time, contain links to and from third parties’ websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

What personal information we may collect from you

We may collect and process the following data about you:

• Information that you provide by filling in forms on our website or as required, for providing our services to you.
• Details of your visits to our website including, but not limited to, traffic data, location data or communication data, for our own statistics.
• We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Cookies

To ensure that content from our website is presented in the most effective manner for you and for your computer, our website uses cookies to distinguish you from other users of our website.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently and allow improving the websites.

• Analytics Cookies: To help us enhance your experience and the efficiency of our website, we use cookies, small text files saved to your computer, to obtain insight into how our website is used. This allows us to optimise our website to display what you would find helpful and interesting. All data we obtain is anonymous and will not contain any sensitive information about you, but will include information about how you have interacted with the website, such as where you have clicked, scrolled and moved your mouse, words typed into our search bar, pages visited on the site, when and where you entered and exited from, and information about the platform and browser used. We also use cookies to find out how our online advertisements are interacted with. The companies on our panel may also use cookies and have their own cookie policy for their website.
• The Google Analytics tracking cookie also allows us to access aggregates demographic and audience data from online behavioural advertising services. This information is only available to us at a group level, with no personal or identifiable information contained within it. It is used only for us to evaluate the effectiveness of the website and see how different groups of users use and respond to the site, and in no way allow us to track people individually. You may opt out of this tracking by disabling cookies within your browser.
• Commercial Cookies: Our website uses retargeting to advertise to our visitors on third party websites. We use commercial cookies to show personalised advertisements based on past visitors’ interaction with the website. Third-party vendors, including Google & Facebook, use cookies to serve ads based on someone’s past visits to our website. Of course, any data collected will be used in accordance with our own privacy policy and Google & Facebook’s privacy policies.

You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

We use Perfect Audience for Facebook retargeting.

How and why we process your personal data

We will only process your personal data consistently with data protection laws and for the following purposes and lawful reasons:

• When we have your consent to process your personal information for a specific purpose
• When we need to process your personal information to enter into or administer a contractual agreement we have with you
• When we need to process your personal data in order to protect anyone’s vital interest
• When we need to process your personal information to comply with our legal obligations
• When processing of your personal information is necessary for the performance of a task carried out in the public interest
• When we need to pursue your legitimate interest such as safeguarding your assets, belongings and possessions
• When we need to pursue our legitimate interest such as providing information for audits

Uses made of the information

Our use of the information is subject to your instructions, the Data Protection legislation and our duty of confidentiality.

Your personal data may be shared with, but not limited to our employees and representatives, our third-party business partners and sub-contractors and/ or any other party which may be engaged or otherwise used by us for any purpose in connection with the performance of our services to you.

We may also disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets
• If Sandstone Malta Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms or to protect the rights, property, or safety of us, our customers, or others.

How we store your personal data

The data that we collect from you will be stored electronically. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via internet or email communications; any transmission is at your own risk, unless you notify us in writing that internet or e-mail is not an acceptable means of communication.

How long we keep your data for

The data will be kept for no longer than is necessary for the purposes for which it is being processed.

Your rights

You have the following rights:

• The right to be informed about the collection and use of your personal data
• The right to access your personal data (commonly referred to as subject access)
• The right to have inaccurate personal data rectified, or completed if it is incomplete
• The right to have personal data erased when you object to the processing of your data under legitimate interests’ basis and there is no overriding legitimate interest to continue this processing
• The right to restrict processing in certain circumstances (e.g. if you want us to establish the data’s accuracy)
• The right to object to the processing of your personal data in certain circumstances (e.g. for direct marketing)
• The right not to be subject to automated decision-making including profiling
• The right to ask us, in appropriate circumstances, to transfer your personal information to another organisation indicated by you

You can exercise any of your rights by contacting us at office@sandstonemalta.com. If you are unhappy about how we handle your personal data you can complain to the Office of the Information and Data Protection Commissioner (IDPC). Further information about the services offered by IDPC and the conditions for using such services can be found at idpc.org.mt

Changes to our privacy policy

Our Privacy Policy is reviewed regularly and updated where necessary.

Any further change will be communicated to all individuals about whom information is held by way of an e-mail. Continuing the use of our services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.