Privacy Policy

We are committed to protecting and respecting the privacy of your personal data.

Last updated: February 8, 2022.

This Privacy Policy (hereinafter referred to as "Privacy Policy") applies to the website or any affiliated websites or related domains (hereinafter referred to as "Website" or "Site"), services provided by (the owner and operator of the Website), and all related software applications ("Applications"), where your personal data is processed (whether through the Website, any of our Applications, or otherwise).

This Privacy Policy is issued on behalf of subsidiaries, therefore in this policy when we refer to the pronouns "we", "us" or "our", we are referring to the relevant organization responsible for processing your data. We inform which organization processes personal data when a customer uses any of our services. In certain cases where customer personal data is provided, stored and processed by us in countries that additionally apply local data protection laws, our customers may refer to the respective jurisdiction for further information about the respective local privacy laws in connection with privacy notices.

In the Privacy Policy, the words "you", "your" and "user" refer to an identified or identifiable person who is a user of the Website and/or a customer (or potential customer) of the Website. The term "user" refers to an identifiable person who is a user of the Website and/or a customer (or potential customer). Customer) - a recipient of our services. All details, including contact information, can be found below.

This policy describes how [Your Company] processes the information and personal data you have provided to us and which enable us to effectively manage your relationship with us.

1. Purpose of this Privacy Policy

We respect and value the privacy of our customers. We do not sell, transfer or otherwise make available to third parties information about individuals who visit our website, except as expressly provided in this Privacy Policy.

• The type of personal data we collect about our customers and how we use your personal information.
• An indication of the basis on which we process personal data.
• To inform you about how we process your personal data.
• Clarification of the privacy obligation to act lawfully and responsibly in handling our customers' personal data.
• Information about your privacy rights

2. Legal Aspects of Personal Data Processing

All processing of personal data carried out by us is in accordance with this Privacy Policy, and:

• Maltese Data Protection Act (hereinafter referred to as "DPA" - Chapter 586 of the Laws of Malta), as well as any other regulations issued under the DPA, as amended and modified;
• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 "On the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC" (General Data Protection Regulation - hereinafter referred to as "Regulation" or "GDPR").

We comply with local data protection laws in the countries where we operate.

This Privacy Policy should be read in conjunction with our Cookies Policy and any other privacy notices we provide in specific circumstances where we collect or process personal data about you so that you fully understand how and why we use your data.

3. Data Controller

ADMIN Malta Limited (Company Registration Number C 86082), Malta, is a data controller and is responsible for this website.

We control the personal data we collect or receive and process in the course of providing our services and/or operating the website. Our affiliated legal entities may become data controllers, either jointly or as separate data controllers.

4. Personal Data We Receive from Our Users

Personal data or personal information is any information about a natural person through which this person can be identified. Personal data does not include information that has no relation to a person (anonymous data). Our website is designed so that our users can access our website without identifying themselves or disclosing personal data. However, if you choose to provide personal information, we will protect this information and use it only as described below.

We collect and process the following personal data about you:

• Identification details including name, birth name, surname after marriage, professional title, ID number, gender, nationality, employment status, organization, occupation, email address and phone number.

When you use our services or apply for a job position, you may be asked to provide additional information. When you use our services, we may need additional information before entering into a business relationship with you.

We may also request information from you that is necessary to establish your identity and serve as proof of your identity, such as copies of your passport or ID card. If you are applying for a position, you will need to provide a copy of your current CV.

If we need certain personal data due to legal requirements or under a contract with you and you are unable to provide us with this data upon request, we may not be able to provide the service as agreed, or we may not be able to enter into a contract with you. We will, however, inform you in advance if we cannot provide certain data.

Contact Details

Contact details include billing address, postal address, email address and telephone numbers for communication.

Compliance Data (AML and KYC)

Compliance data (AML and KYC) includes the following information and documents related to ongoing checks regarding our customers or their representatives, shareholders, founders, beneficiaries, directors if the customer is a legal entity: a copy of identification, "KYC" due diligence report (database) and any other documentation required from time to time by the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta) ("PMLA"), the Prevention of Money Laundering and Terrorist Financing Regulations ("PMLFTR"), the Financial Intelligence Analysis Unit ("FIAU") and/or as required by other competent authorities or relevant legislation.

Supporting Data

• The customer's current situation, plans, interests, goals or objectives;
• Services requested and provided to the customer.

Financial Data

Financial data includes the customer's bank details and information about any payment methods used by the customer to settle our invoices, and, if required under certain circumstances, the customer's financial situation and creditworthiness.

Transaction Data

Transaction data includes details of invoices issued to the customer (including payment date and payment methods), payments to and from the customer, and outstanding invoices to the customer.

Technical Data

Technical data includes your IP address, login credentials, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other information about your experience with the website, such as page response times, loading errors, length of visits to certain pages, information about your interaction with the page (such as scrolling, clicks, and mouse-overs) and methods used to navigate away from pages.

Location Information: We may receive information about your location and may be able to determine your location using your IP address and, if you access the website through a mobile device, using data we collect from that device. This includes information about wireless networks or mobile towers near your mobile device at the time of access.

Our website uses cookies to distinguish you from other users of our website. This helps us provide you with a high-quality browsing experience on our website and allows us to improve our website. For more information about the cookies we use and the purposes for which we use them, please read our Cookie Policy.

Marketing and Communications Data

Marketing and communications data - your preferences for receiving marketing material from us and our third parties or affiliated companies, as well as your preferences regarding how you communicate. This may include information about whether you have subscribed to or unsubscribed from one of our newsletters, whether you have attended one of our events or accepted one of our invitations.

We also collect, use and process any other personal data that you voluntarily provide or communicate to us when appropriate and necessary to provide the services you request.

5. How Your Personal Data is Collected

Personal data may be provided by you in the following cases:

• Filling out the inquiry form on the website,
• Corresponding with us by mail, telephone, email or otherwise when submitting an application for our services,
• Subscribe to our services or publications,
• Request to send a calculation to you,
• Testimonials about our services,
• Entering into negotiations or concluding a contract.
• When you visit our website, we automatically collect technical data.
• We may also receive personal data about our visitors from various third parties and public sources (Google Analytics advertising features including Google AdWords, Facebook Pixel, Google Tag Manager, LinkedIn and other specialized paid media partnerships).
• Identification, contact and reference data from publicly available sources, verification databases, and/or verification data providers within and outside the EU to ensure you are a suitable customer or supplier for us.

6. How We Use Your Personal Data

We use personal data:

• To facilitate the format for providing the requested services under the contract we are entering into or have entered into with you,
• When our legitimate interests (or those of third parties) require it and when your interests and rights do not override these interests,
• Compliance with legal or regulatory requirements,
• Resolution of problems you report and provision of support services,
• To manage our relationship with you as a supplier,
• To manage our website and internal operations, including troubleshooting, and to ensure the security of our website,
• To improve the performance of our website and make content as effective as possible for you,
• Ensure that all information on the website is presented in a user-friendly manner.

7. Legal Basis for Data Processing

We process your personal data only to the extent necessary to provide our services, and/or for the purposes stated in this Privacy Policy.

We may also process your personal data based on legitimate interests or to fulfill legal obligations. These interests and obligations may include the exercise or defense of legal claims or compliance with an order of a court, tribunal or authority, and the disclosure of information to a government or regulatory authority.

We usually do not need separate, legally secured consent for processing your personal data. However, if your consent is required, we will provide you with a form to request the processing of personal data.

8. Marketing

At your request, you will receive marketing communications by providing us with your data through this website and consenting to receive such information. If we have entered into a business relationship with you (i.e., entered into a contract), we may inform you about our activities, offers or other information that we believe will be useful to you in accordance with our legitimate interests.

We do not share your personal data with third parties for marketing purposes without your consent.

You have the right to withdraw your consent or opt out of receiving marketing information at any time by clicking the "Unsubscribe" button. Once you withdraw your consent or if you object to any of the listed points, we will not send you any further marketing communications. If you choose not to give consent or cancel your subscription, we can provide our services to the extent possible without the information required for all services. This may affect the efficiency with which we provide the services you want.

9. Disclosure of Your Personal Data

We reserve the right to share your personal data with any of our international offices or companies within our company that act as co-controllers or data controllers for our company. These offices or companies will become responsible controllers of your data in the provision of our services, and/or they take on administration, control and reporting. All our companies respect and protect the security of your personal data in accordance with applicable legislation (including GDPR) and apply all measures to protect your data.

We may need to share personal data with government agencies and authorities in the country where you are applying for residence or citizenship. We will only share such information to the extent necessary for the provision of services in accordance with our contract with you.

We may need to share your data with local representatives or other contractors (to process the data) to provide the services you request. These local representatives and suppliers store and process your data on a strictly confidential basis with appropriate security measures and safeguards.

We may also share your data with other third parties who act as data controllers, such as legal, tax, real estate, immigration or other advisors and representatives, (international) banks for payment information, or with third parties who provide other or additional services or products for you, such as real estate agents, owners or developers with whom you may wish to interact on separate terms. These third parties process your data on their own terms and their own privacy policies and procedures apply.

We may also disclose or share your data if we are required to do so to comply with a legal requirement, court order or at the direction of a court, tribunal or authority. We may also disclose your data to enforce our terms of use or protect our rights, property or the safety of our partners or other users of our website. This includes sharing information with other companies and organizations for the purposes of anti-money laundering or due diligence, compliance with anti-bribery or corruption laws, integrity, and/or protection against fraud.

10. Data Transfer to Third Countries

When we share your personal data with third parties, this may involve transferring your data outside the EEA. We transfer your personal data in accordance with standard contractual clauses to ensure that your personal data is protected and securely transferred in accordance with applicable law, including the GDPR.

All IMIN Malta Limited business units act as EU data processors for other business units located outside the EEA.

11. Third Party Access to Your Personal Data

We work closely with third parties in providing services. These third-party providers include cloud storage providers, analytics providers and search engine information providers. We only work with third-party providers who comply with applicable laws in the countries where we operate and follow the GPL to ensure a high level of security and protection for your personal information.

12. Data Security

We take all necessary security measures against unlawful or unauthorized processing of personal data and against accidental loss or damage to personal data. Furthermore, we provide access to your personal data only to those employees, representatives, service providers and other professional third parties who need to know this information. They will process your personal data strictly in accordance with our instructions and maintain confidentiality. All our employees and representatives have received appropriate privacy training.

The transfer of information between our website and your device is protected by Transport Layer Security (TLS) certificates. When the website is accessed with compatible browsers, this technology protects personal data by using both server authentication and data encryption to ensure the security of personal data during transmission.

All personal data is stored on a secure server that has a firewall and other advanced technology to protect against tampering or unauthorized access. Usernames and passwords are issued to persons authorized to access personal data, our employees who are bound by confidentiality and are not authorized to disclose personal data.

No method of data transmission is 100 percent secure, and it is therefore impossible to guarantee absolute security.

13. Data Storage

We store your data only as long as absolutely necessary for the purposes for which it was collected (i.e., to provide you with our services or to comply with legal, accounting or reporting requirements).

We retain your personal data only as long as necessary to fulfill the purposes for which it was collected (to provide services and continue our business relationship with you), and beyond that for the purposes of fulfilling legal or accounting requirements, taxation, anti-money laundering, for the purposes of required reporting or for the purposes of obligations imposed on us. We may need to retain your personal data to be able to take, exercise or defend possible future legal actions against you or otherwise involve you.

Generally, we do not keep your personal data for longer than six (6) years from the date of termination of our cooperation. This retention period allows us to use your personal data for AML/CFT reporting purposes to the FIAU (legal obligation) and/or for approvals, filing or defense against possible legal actions involving you.

14. Data Minimization

Where possible, we anonymize the data we have stored about you when it is no longer necessary to identify you from this data.

15. Your Rights as a Data Subject

You are entitled to exercise the following rights under the LOA:

1. Right to Access Information: You have the right to request information about whether your personal data is being processed by us, and information about how and why it is being processed.
2. Right to Object: You can contact us at any time to request us to use your personal data.
3. Right to Amendment: You have the right to amend and correct inaccuracies in your personal data used by us.
4. Right to Data Deletion: You have the right to request deletion of your personal data that has been transmitted to us when it is no longer needed.
5. Right to Restrict Processing of Personal Data: You have the right to restrict our right to use your personal data under certain circumstances.
6. Right to Data Transfer: We provide your personal data to you or a third party of your choice in a structured, commonly used, electronic format.
7. Right to Withdraw Consent: If you have given consent for the collection, processing and sharing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific transaction at any time.

16. Legislation on Disputed Issues

The Privacy Policy and any disputes regarding its application are governed by the laws of Malta. You hereby agree that the courts of Malta shall have exclusive jurisdiction over all claims, disputes or controversies relating to the Statement of Commitment and all matters arising therefrom. Each party irrevocably waives its right to object to the filing of a lawsuit before these courts, to claim that the lawsuit was filed in an unfavorable location or that these courts do not have jurisdiction.

17. Changes to this Privacy Policy

Any changes we make to this Privacy Policy in the future will be posted on this page and sent to you by email where appropriate.

18. How You Can Contact Us

If you have any questions or comments about this Privacy Policy, contact us today using the contact information (see Section 3, "Data Controller").