Protecting Your Privacy
We, the team at Bortex Group, strongly value privacy and are committed to protect your personal data (i.e. information that identifies you).
One of your rights under EU law – the GDPR – is that you must be informed when your personal data is processed by any organisation. You also have the right to know the details and purpose of that processing.
This privacy policy describes our practices relating to the personal data of visitors of ‘the website’ and the use of our online facilities. For the data collected through and the maintenance of our website, the data controller is Bortex Group Holdings with its address at St. Therese, Hughes Hallet Street, Sliema.
We assure you that we will only use and disclose any personal data collected from you in accordance with the manner set out in this policy.
Information we collect
Most of the personal information which we may collect about you through this website is given to us only if you choose to give it to us. Such personal information may be requested from you when you fill in a field, e.g. to fill in our contact form with your questions and comments on the Bortex Group Holdings Website. If you send us emails, then the personal data we process will depend on what you send us in the email.
- The information we collect from you normally includes the following:
Information about your device (phone or laptop) with which how used our website; - If you reach out through us through our contact form, we will also collect your name and email address;
The next sections will outline how and why we use this information.
Some other information is given to us because you accessed this website (e.g. logs, recorded through cookies). This is explained in the Cookies section below.
How & Why we use your information
We use your information in a number of different ways — what we do with it then depends on the information and the purpose for which we collected.
The tables below set this out in detail, showing what we do, and why we do it.
1. Your name and contact details
How we use your:
Name, Surname, and Contact Details
Why?
Fraud prevention and detection
To prevent and detect fraud against either you or us – unfortunate, but absolutely essential
Knowing what you, and other customers, like
To ensure we are giving you what you want, and to stay ahead of the competition
2. Your contact history with us
What you’ve said to us — for example, over email or contact forms.
How we use your contact history
Why?
Provide customer service and support
This is how we ensure that we have answered any queries you may have
Train our staff
For our team to remain up to scratch so that you get the best possible service
3. Information about your device (phone or laptop) with which how used our website
Information you give us when you browse our site or use our app, including your IP address and device type and, if you choose to share it with us, your location data, as well as how you use our website and app.
How we use information about your phone or laptop, and how you use our website and app
Why?
Improve our website
To give you the best possible user experience
Protect our website
To prevent and detect fraud against either you or us — and to meet our legal obligations about looking after your data
- You don’t have to give us any of this personal information but if you don’t, you may not be able to use our site or all of the services we offer on the site, and you are unlikely to receive an optimal customer experience.
- We also anonymise and aggregate personal information (so that it does not identify you) and use it for purposes including testing our IT systems, research, data analysis and improving our site. We also share this anonymised information with third parties – but don’t worry, they cannot identify you.
The Legal Basis for Processing
For all of the uses of your personal data (as described above), we ensure that there is a legal basis under applicable data protection laws for us to use such personal data.
This includes, for example, where it is necessary for us to use the information to perform a contract with you or take steps at your request prior to entering into a contract with you. We also use consent as a legal basis in order to process your query when you contact us, provide customer-care and support services to you.
It also includes circumstances (such as we have described below) where we have a legitimate interest to use your data, provided that proper care is taken in relation to your rights and interests:
- to carry out research and analysis of your data as this helps us understand our clients better, who they are and how they interact with us.
- to improve and ensure the security of the website (for example, for statistical, testing and analytical purposes, troubleshooting).
Retention Periods
- We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data.
- We may also keep hold of some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
- As a guide: – we will keep personal data until such time as you ask us to stop communications with you, unless we need to keep the data for longer;– we may keep certain categories of personal data for longer in order to meet any legal or regulatory requirements, or to resolve a legal dispute.
We may keep different types of personal data for different lengths of time if required by law (for instance, we may need to keep certain personal data relating to purchases for about 10 years in order to comply with tax/VAT reporting requirements).
Children Under 16
If you are aged 16 or under, please get your parent/guardian’s permission before you provide any personal information to us.
We will need to process personal data relating to parents or guardians in that case – and we may also need to request for verification documentation to ensure that consent is given or authorised by the holder of parental responsibility.
We do not, and will not, sell any of your personal data to any third party – including your name, email address or any other information you provide to us. It is not our business to do so – and we want to earn your trust and confidence.
However, we share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out below:
- Companies in the group to which Bortex Group belongs, as sometimes different entities within our group are responsible for different activities (especially licensed ones). This includes Bortex Group – related entities and members of the Group (any of our subsidiaries). Related entities and subsidiaries use the information collected to help us improve the content and functionality of our websites; to better understand our customers and markets; and to improve our services. Members of the group vary from time to time.
- Professional service providers, such as marketing agencies, advertising partners and website hosts who service us in turn to operate our business.
- Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud.
- In most circumstances we will not disclose personal data without consent. However there may be occasions where we might have to – e.g. with a court order, to comply with legal requirements and satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our subsidiaries and related entities.
- When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended.
- We may also provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you. Anonymous information means it is anonymous and you will not be identified through this data.
- If we ever have to share data with entities that are outside of the EEA, we will be sure to do so in a manner that complies with the requirements established by the GDPR.
- What are cookies? A cookie is a small text file (typically numbers and letters) that is downloaded onto ‘terminal equipment’ (e.g. your computer or smartphone) when you (or someone else) access a website using that device. Cookies are then sent back to originating website on each subsequent visit – and they are useful because they allow a website to recognize a user’s device and store some information about your preferences or past actions. Some cookies are needed for the sole purpose of carrying out the transmission of a communication over an electronic communications network – others may be necessary for the provision of a service over the internet, in which case they have to be used. Other cookies may be desirable to improve your experience, in which case we will ask you for your consent to use them. Should you wish to amend your cookie preferences, you may click on the banner at the bottom of this page. What cookies do we use? The cookies we use are the following:
- Type of cookie
- Why we use them
- Who serves them
- Analytics cookies
- These are used to understand, improve, and research users visiting the website and their needs to improve our website’s user experience. For example, we may use cookies to understand what pages a user browses before submitting using the contact form. We do not share information about this analysis with any third parties.
- Google Analytics cookies: _ga, _gat, _gid
We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.
HotJar Cookies: _hjFirstSeen, _hjid
If you’d like to opt out of tracking by Hotjar, visit the Do Not Track page. - Necessary cookies
- These are used as an extra layer of security.
- Cloudflare cookies: _cfduid Cloudflare is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis.
- How do you change your cookie settings? Should you wish to amend your cookie preferences, you may click on the banner at the bottom of this page. Other Passive Information which we collect Apart from the information you provide us with when using our Website, other information is passively collected from you (without you actively furnishing such information) when you navigate through the website. We use various technologies and navigational data collection methods to gather such passive information for various reasons, for example to track how many visitors access our website, the date and time of their visit, the length of their stay and which pages they view. The passive information also aids us to determine which web browsers our visitors use and the address from which they accessed our website – for instance if they connect to our Website through clicking on one of our banner ads. This technology does not identify you personally. We assure you that, unless you have consented, such passive information shall not be combined with personally identifiable information collected elsewhere by our website or respective sites operated by our related entities or subsidiaries.
Your Rights
You enjoy several rights relating to your personal information:
- The right to be informed about how your personal information is being used;
We need to be clear with you about how we process your personal data. We do this through this Privacy Policy, which we will keep as up to date as possible.
- The right to request that we delete your data, or stop processing it or collecting it;
You can ask us to delete your personal data; however, this is not an absolute right. In spite of a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation (for instance, we are required by personal data for VAT reporting purposes); and (ii) in relation to the exercise or defence of any legal claims. When you ask us to delete your personal data, we assume that you do not want to hear from us again. Other than as described above, we will always comply with your request and do so promptly. We would carry out our best efforts to notify any third parties with whom we have shared your personal data about your request so that they could also comply.
- The right to object to certain processing based on legitimate interest;
You have a right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling using automated means.
- The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;
- The right to withdraw consent for other consent-based processing at any time;
- The right to request that we transfer or port elements of your data either to you or another service provider;
You have the right to move, copy or transfer your personal data from one organisation to another. If you do wish to transfer your personal data we would be happy to help. If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation. When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.
Security of your Personal Data
Security of your personal data is very important to us.
Where it’s appropriate, our website uses HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.
We do our best to keep the information you disclose to us secure. Security measures which have implemented to secure information transmitted over our website or stored on our systems include the following:
- Use of secure servers;
- Use of firewalls;
- Use of encryption;
- Physical access controls at data centres;
- Information access controls;
- Use of back-up systems;
Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.
Changes to how we protect your privacy
Our website is continually under review – new functions and features are periodically added and improved to interface, thus changes to our privacy policy may be required from time to time.
We therefore encourage you to check our privacy policy on a frequent basis.
