This Privacy Policy (“Policy”) outlines the manner in which we handle the information and personal data which you have provided to us and which enables us to effectively manage your relationship with us. Any references in this Policy to the “Company”, “Frankie”, “us”, “we” or “our” relate to the Data Controller, namely, Sloane Limited, holding company registration number C 7727 and having its registered address at Zachary House, Marsa Industrial Estate, Marsa.
This Policy is intended to give you (the “Data Subject”) a better understanding of the data we collect, the reason why we collect such data, the manner in which we process this data, the entities with whom we share the said personal data, your rights in relation to the collection, processing and sharing of such data and any other pertinent matter relating to privacy and security.
All processing of Personal Data performed by the Company as envisaged in this Policy shall be carried out in line with:
- The Maltese Data Protection Act (hereafter referred to as the “DPA” - Chapter 586 of the Laws of Malta) as well as any other subsidiary legislation issued under the DPA as may be amended from time to time; and
- 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 the “Regulation” or “GDPR”).
The DPA and the GDPR shall hereafter be collectively referred to as the “Data Protection Laws”.
The Company determines the means and purposes of the processing of Personal Data and therefore acts as the “Data Controller” in terms of the applicable Data Protection Laws.
SECTION 1 – WHAT DO WE DO WITH YOUR INFORMATION?
Here at Frankie we take your privacy seriously and we are bound to only process Personal Data if such processing is based on a genuine and legitimate reason to do so, on the basis of one of the legal grounds established in the GDPR.
The following table outlines the categories of Personal Data which we process, the purpose for which we process such data as well as the corresponding legal basis used for such processing. It is pertinent to note that the same categories of personal data may be processed for different purposes and therefore on the basis of various legal grounds simultaneously, depending on the purpose of the Processing.
CATEGORIES OF PERSONAL DATA | PURPOSE OF THE PROCESSING | LEGAL BASIS USED FOR PROCESSING |
Contact data (E.g.: Name, Surname, email address)
| To administer your account
To provide any information you have requested from us.
| Legitimate Interest (if you do not provide us with a means of contacting you we will be unable to respond to your enquiry, and so the processing is necessary for us to meet that interest)
|
Contact data (E.g.: Name, Surname, home address, email address, proof of opt-in consent (where required), proof of objections to marketing, website data and online identifiers (such as IP address, and other information generated by your browser))
| To provide you with our offers, new products or updates that you have opted in to receive or that we are otherwise authorised to send you.
To personalise your customer experience. | Your consent
OR
Our Legitimate interests (for marketing purposes, where We do not require your consent & to improve Our services) |
SECTION 2 – CONSENT
In those cases where we process on the basis of your consent (which we will never presume but which we shall have obtained in a clear and manifest manner from you), you have the right to withdraw your consent at any time.
How do I withdraw my consent?
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection or use of your information, at any time, by clicking here and filling the form. By doing so, all information we hold about you on our website will be deleted.
You can also stop receiving marketing messages from us at any time, by:
- clicking on the ‘unsubscribe’ link in any email; or
- contacting us on: info@frankie.com.mt
If you would like to review the data we have collected, you can request access to such data by clicking here and filling the form.
SECTION 3 – DISCLOSURE
We may disclose your personal information if we are required by law to do so or if it is necessary for purposes such as: to protect and defend our rights and property or to protect against abuse, misuse or unauthorised use of our website.
SECTION 4 – THIRD-PARTY SERVICES
Our service providers will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
Any such processing will be done in accordance with the Data Protection laws (for example, all our processors are contractually bound by the requirements in the said Data Protection Laws, including a strict obligation to keep any information they receive confidential and to ensure that their employees/personnel are also bound by similar obligations). The said service providers (our processors) are also bound by a number of other obligations (in particular, those established in Article 28 of the GDPR).
Your Personal Data will never be shared with third parties for their marketing purposes.
Links that we provide to third-party websites are clearly marked and we are not in any way whatsoever responsible for (nor can we be deemed to endorse in any way) the content of such websites (including any applicable privacy policies or data processing operations of any kind). We suggest that you read the privacy policies of any such third-party websites.
SECTION 5
SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
YOUR RIGHTS
As a Data Subject you have certain rights at law. The core Data Subject rights within the GDPR are set out below:
- Right to access
- Right to rectification
- Right to be forgotten
- Right to object
- Right to withdraw your consent
- Right to restriction of processing
- Right to data portability
- Right to lodge a complaint with a supervisory authority
Right to access and to rectification
You have a right to request access to and/or correction of your Personal Data processed by us. Please note that the right to be forgotten may be limited depending on our business interests and legal obligations. Any such request must be made in writing to Frankie at the address indicated on the homepage of our website or via email to dpo@amsm.com.mt. In order to authenticate such requests so as to avoid unauthorised disclosure, we may need to verify your identity.
Right to be forgotten
Frankie acknowledges that you have a right to be forgotten. Therefore, no Personal Data that is processed while providing you with our services, or through our website will be kept longer than necessary for the purposes for which it is processed. Personal Data will only be kept for a period corresponding with our obligations of retention under relevant laws.
Should you wish all or any category of your Personal Data to be deleted, you may request this in writing at dpo@amsm.com.mt.
Right to object, withdraw your consent and restriction of processing
You may object to / withdraw consent from marketing communications at any time as specified in Section 2 above. Please contact us in relation to other types of requests in relation to restriction of processing.
Right to data portability
The right to data portability is to allow secure handover between data controllers (e.g. mobile phone providers). We do not consider this right to be relevant to Our data subjects.
Right to lodge a complaint with a supervisory authority
Malta’s supervisory authority is the Office of the Information & Data Protection Commissioner (“IDPC”), located at Floor 2, Airways House, Triq Il – Kbira, Tas-Sliema SLM 1549 Malta. Complaints can be lodged on their website.
COOKIES
Here is a list of cookies that we use. We’ve listed them here so you can choose if you want to opt-out of cookies or not.
Site analytics cookies – these cookies allow us to measure and analyse how our customers use the site, to improve both its functionality and your shopping experience.
Targeting or advertising cookies – these cookies are used to deliver ads relevant to you. They also limit the number of times that you see an ad and help us measure the effectiveness of our marketing campaigns.
By using our site, you agree to us placing these sorts of cookies on your device and accessing them when you visit the site in the future. If you want to delete any cookies that are already on your computer, the “help” section in your browser should provide instructions on how to locate the file or directory that stores cookies. Please note that by deleting or disabling future cookies, your user experience may be affected and you might not be able to take advantage of certain functions of our site.
SECTION 6 – AGE OF CONSENT
By using this site, you represent that you are at least the age of majority in your state, county, province, region or country of residence, or that you are the age of majority in your state, county, province, region or country of residence and you have given us your consent to allow any of your minor dependents to use this site.
SECTION 7 – CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this privacy policy at any time, therefore we invite you to review it frequently. Changes and clarifications will take effect immediately upon their posting on the website.
In case our company is acquired or merged with another company, your information may be transferred to the new owner/s and such new owner/s may under the terms of this Policy, be permitted to use your Personal Data for the same purposes.
QUESTIONS AND CONTACT INFORMATION
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at dpo@amsm.com.mt.
Version 2019.01 | Last Update: May 2021
