Date: 21st May 2020
- Vertex Advisory Ltd (C 94077), a company incorporated in Malta
- Cidaris Ltd (C 44044), a company incorporated in Malta.
Our contact details are the following:
- Address: Aragon House, Dragonara Road, St Julians, STJ 3140
- Contact number: +356 2033 1120
- Email: firstname.lastname@example.org
In line with the principle of data minimization and data economy, we only collect personal data and processes it on the following legal bases:
- when you request our services or you are an employee, a collaborator or a supplier, our legal basis for collecting and processing information is based on and the requirements for the performance of a contract or to take steps to enter into a contract and/or legal regulations, mainly anti-money laundering regulations;
- our legal basis for collecting and processing your personal data when you opt-in to receive news and information for us, or to participate in a conference, workshop is based on your consent; and
- we may collect and process information for legitimate interest, primarily to protect us from legal action or claims from third parties, including you and/or to protect our legal rights and/or those of our employees.
The non-public personal data that we collect and the processing of such information will vary on the basis of the purpose and scope of the particular use or engagement. We herein outline the
We operate the following websites:
You may visit our website/s without submitting any personal data. However, to use certain features of the website (such as the fill-in forms to request information), such information may be required (see the section entitled ‘Request for Information’ below)
Through our website/s you may fill in an online form and request information. The information collected through the request for information function is the following:
- information you provide in the fields of the online form;
You can also contract us and request information through email, phone, or social media. In such cases we will be collecting any information you provide to us or available on the relative media used.
In all cases, we will also collect any correspondence in furtherance of the request.
This information is necessary for us to be able to respond to your request.
General and preliminary information will be provided to you without the requirement of any other additional personal information.
An identification document and other personal information will be requested in order to comply with anti-money laundering rules and to be able to provide you detailed and specific information to your request. If you are not able or unwilling to provide us such information, we will not be able to provide any additional information.
We keep in touch with our clients and try to keep them updated on developments that affect their business or the services we are providing. If you consent to receive news and information from us, we will collect your name contact details and keep a record of the information we have sent you as well as any interactions related to such information sent to you.
If you do not provide the information outlined under this section, we will not be able to provide you with news and information.
When we are providing a service, we collect information as required by statutory obligations, principally information required by anti-money laundering rules and regulations, and information required to be able to provide the services. The information collected varies depending on the service/s being provided.
If you are not able or unwilling to provide us such information, we may not be able to provide the service/s.
On collaborators and suppliers we collect information as required by statutory obligations, principally information required by anti-money laundering rules and regulations and information required for the collaboration or the provision of the service by the supplier to us.
If a collaborator or supplier is unable or unwilling to provide us such information, we will not be able to collaborate or use the services.
In those cases where persons apply for a job with any of the Vertex Alliance entities, the following information will be collected:
- name and contact details;
- your previous experiences and details of your previous jobs;
- education details and transcripts;
- referees’ names and contact details; and
- answers to questions made to you during the recruitment process.
We work with various recruitment agency and such information may be obtained from agencies you would have applied with. Please note that we are not responsible and do not undertake any responsibility or liability in relation to the collection and processing of your personal information by such agencies.
We may request you to allow us to process your personal information to contact you for any other vacancy that may arise. Should you consent, we will contact you whenever a suitable vacancy will arise.
Candidates are free to provide the information they deem fit. Whilst we will still process your application for a job, should the information outlined herein not be provided in whole or in part, your application may be affected.
The information required on acceptance of an employment offer on the other hand is necessary to finalize your employment and onboarding process.
On acceptance of an employment offer of an employee, we may collect the following information:
- identification document;
- police conduct certificate or equivalent;
- banking, tax and other details;
- health Information to ensure you are fit to work and to cater for any special conditions; and
- emergency contact details.
During your employment with us, other information will be collected:
- records of your employment performance;
- answers to questions we make to you during assessments; and
- health information obtained through medical certificates and the employer’s medical doctor.
We may also collect general information about you such as your hobbies and interests with the aim of enhancing your working experience with us.
Except for the general information collected which is optional, the information outlined herein is required and will affect your employment if not provided.
Depending on the information collected, any personal non-public information so collected will be used to:
- provide you with news and information, reply to requests, provide services and follow-up; provide information to your representatives/intermediaries, access and progress job applications; in case of employees progress their employment and access performance; to implement and enhance collaboration or receive services in case of collaborators or suppliers;
- comply with any legal or regulatory requirement including compliance with anti-money laundering rules
- to protect us from legal action and claims; and
- for our internal purposes including the administration of the flow of such information, market research and data analytics, internal record keeping, financial and market research and/or to improve our products and people’s experiences.
We may disclose personal information legally in the following scenarios:
- for the performance of a contract or to take steps to enter into a contract;
- to enforce our contractual terms;
- to protect us and our employees from legal action or claims from third parties, including you;
- in cases or merger or acquisition of our business or parts of it to the new owners;
- to group entities;
- when there is a legal requirement to do so; and
- if we are requested to do so by a governmental or regulatory authority or by a court of competent jurisdiction.
The free exchange of personal data between Member States is a fundamental aspect of the EU’s basic principles. This principle is also reflected in the GDPR, which allows for the transfer between EU/EEA companies subject to the legal bases as provided above under the ‘Legal Bases’ section.
We retain the personal information that we collect from you only for as long as required for statutory, business, tax or legitimate interest purposes. Your information is retained in electronic or paper format or both. When it is no longer required, it will be deleted or destroyed. Should you wish to obtain information on the specific retention period of any personal information we hold on you, please contact us on email@example.com
We do not undertake fully automated individual decision-making, including profiling.
We maintain physical, electronic and procedural safeguards to protect personal non-public data. We attempt to protect your personal data from unauthorized access by third parties by means of precautions such as pseudonymization, data minimization and observing deletion periods. Despite these protective measures, however, we cannot completely rule out unlawful processing by third parties.
Additionally, we use the following system in our collection, processing and storing of data:
- we use industry standard tools in order to monitor and collect information on our website/s users’ needs and to optimize the use of our websites. The information collected does not identify the individual users.
- we use a CRM system and other third party systems online to store and process information, data and details;
- we use reCAPTCHA to detect any improperly use of our websites by automated mechanical processing. Certain personal data, including IP address, is thus transmitted to “Google”;
- when someone visits our website/s we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. This information is processed in such a manner that it does not identify the user. Such information is only collected as per our Cookies Policy;
- we use third party HR systems for the collection, processing and storing of information on prospective employees and employees.
To the best of our capabilities, we ensure that third-party systems we use are GDPR compliant. Please contact us on firstname.lastname@example.org should you require more information on the GDPR compliance of such systems.
Your principal rights under data protection law are:
- right to be informed about the personal non-public data we collect and how we process it – this policy aims at providing you with this information;
- right to access – you have the right to obtain confirmation that your personal non-public data is being processed and have the ability to access it;
- right to modification – you have the right to request the modification of any personal non-public data we hold on you if it is incorrect or incomplete;
- right of portability – you may ask us to forward to you the personal data we hold on you and which is portable at law in a structured, commonly used and machine-readable format or to transmit that data to another data controller, where it is technically feasible to do so
- right to erasure – you have the right to request the removal of your personal data, which shall be deleted, unless there is a legal requirement or reason for us to continue processing or storing it;
- right to restrict processing – you have a right to restrict or withdraw consent to the processing of your personal data. In such cases we are permitted to store your data, but not to process it further unless there is a legal requirement or reason for us to continue processing it;
- right to object to processing for specific reasons at law, being the following:
- processing based on legitimate interests or the performance of a task in the public interest or in the exercise of official authority,
- direct marketing, including profiling to the extent that it is related to such marketing activities,
- processing for scientific or historical research purposes or for the purpose of statistics; and
- right to file a complaint with supervisory authorities if your information has not been processed in compliance with GDPR.