Privacy Policy

We are committed to protecting and respecting your privacy.

Last Updated: February 8, 2022

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

This Privacy Policy is issued on behalf of the affiliated entities, so when we refer to "We," "Us," or "Our" in this Privacy Policy, we mean the relevant organization responsible for processing your data. We will provide information on which organization processes personal data when a customer uses any of our services. In cases where a customer's personal data is provided, stored, and processed by us in countries where additional local data protection laws apply, our customers may refer to the relevant jurisdiction below for additional information on the relevant local data protection laws regarding the privacy policy notice.

In this Privacy Policy, the terms "You," "Your," and "User" refer to the identified or identifiable individual who is a User of the Site and/or a client (or potential client) – the recipient of any of Our Services. Full information, including contact details, can be found below.

This Policy describes how [Your Company] processes information and personal data that you have provided to us, allowing 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 disclose any information about any person visiting our Website to any third parties, except as expressly provided in this Privacy Policy.

• Identification of the types of personal data we collect about customers and how we use Your personal information.
• Identification of the legal basis on which we process any personal data.
• Informing you of how we process your personal data.
• Explaining our commitment to the provisions on data protection regarding the lawful and responsible processing of our customers' personal data.
• Informing you of your data protection rights.

2. Legal Aspects of Personal Data Processing

All processing of Personal Data carried out by us is conducted in accordance with this Privacy Policy and:

• The Data Protection Act of Malta (hereinafter referred to as the "DPA" - Chapter 586 of the laws of Malta), as well as any other subsidiary legislation issued in accordance with the DPA, which may be amended and updated from time to time;
• The 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").

We comply with local data protection laws in the jurisdictions in which we operate.

This Privacy Policy should be read in conjunction with our Cookie Policy and any other privacy notices that We may provide on occasion when We collect or process personal data about you for a full understanding of how and why We use your data.

3. Data Controller

ADMIN Mallta Limited (company registration number C 806082), Malta, acts as the data controller and is responsible for this website.

We control the personal data collected or received and processed in the course of providing our services and/or operating the website. Our affiliated legal entities may act as data controllers, either jointly or separately.

4. Personal Data Obtained from Our Users

Personal data or personal information is any information about an individual by which that individual can be identified. Personal data does not include information where the identity has been removed (anonymous data). Our website is structured so that our users can visit our site on the Internet without identifying themselves and without disclosing any personal information. However, if you choose to provide us with personal information, we ensure the protection of this information and use it only as described below.

We collect and process the following personal data about you:

• Identification data, including name, maiden name, surname after marriage, position, identity document number, gender, nationality, employment status, organization, occupation, email address, and phone number.

If you use our services or apply for a job vacancy, additional information may be required from you. If you are a user of our services, we may also require additional information from you before entering into commercial relationships with you.

We may also request information from you that may be necessary to establish your identity and serve as proof of your identity, such as copies of your passport or national identity card. If you are a job applicant, you will need to provide a copy of your current resume.

If we need to obtain certain personal data in accordance with legal requirements or the terms of the contract entered into with you, and you cannot provide this data upon request, this may result in the impossibility of providing the service as agreed or the inability to enter into a contract with you, but we will inform you of this in advance. As a result of the inability to provide certain data, it may be necessary to terminate contractual relations with you.

Contact Information

Contact information includes billing address, mailing address, email address, and phone numbers for communication.

Compliance Data (AML and KYC)

Compliance data (AML and KYC) include the following information and documentation related to the checks conducted regarding Our clients or their representatives, shareholders, founders, beneficiaries, directors, if the client is a legal entity: copy of identity document, "KYC" integrity check report (databases), and any other documentation that may be required from time to time by the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta) ("PMLA"), Anti-Money Laundering and Countering the Financing of Terrorism Regulations ("PMLFTR"), Financial Intelligence Analysis Unit ("FIAU"), and/or at the request of any other competent authority or relevant legislation.

Auxiliary Data

• Client's current position, plans, interests, goals, or tasks;
• Services requested and provided to the client.

Financial Data

Financial data includes client bank account details, as well as information about any payment methods used by the client to pay Our invoices, and, if required in specific circumstances, the client's financial position and creditworthiness.

Transaction Data

Transaction data includes detailed information about invoices issued to the client (including payment date and methods), payments to and from the client, and any unpaid invoices owed to the client.

Technical Data

Technical data includes Internet Protocol (IP) address, login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other information about your experience with the website, such as page response time, download errors, duration of visits to specific pages, information about interactions with the page (e.g., scrolling, clicks, and mouse hover), and methods used to navigate away from pages.

Location Information: We may receive information about your location and may determine your location based on your IP address, as well as, when accessing the website through a mobile device, using data we collect from that device. This includes information about wireless networks or cell 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 to provide you with a good browsing experience on our website and allows us to improve our site. For detailed information about the cookies we use and the purposes for which we use them, see our cookie policy.

Marketing and Communication Data

Marketing and communication data – your preferences in receiving advertising materials from us and our third parties or related entities, as well as preferences regarding communication methods. This may include information about whether you have subscribed to any of our newsletters or unsubscribed, attended any of our events, or accepted any of our invitations.

We also collect, use, and process any other personal information you voluntarily provide or disclose to us where appropriate and necessary for the provision of services you have requested from us.

5. How Your Personal Data is Collected

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

• Filling out a request form on the website,
• Correspondence with us by mail, negotiations by phone, email, or otherwise when applying for our services,
• Subscribing to our services or publications,
• Requesting a quote for sending to you,
• Reviews about our services,
• Initiating negotiations or entering into a contract.
• Every time you visit our website, we automatically collect technical data.
• We may also receive personal data of 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 public sources, background check databases, and/or data service providers, obtained as a result of checks, in the EU and beyond, so that we can ensure that you are an appropriate client or supplier for us.

6. How We Use Your Personal Data

We use personal data:

• To facilitate the provision of requested services under the contract we have or are entering 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,
• When it is necessary to comply with legal or regulatory obligations,
• To address any issues you report and provide support-related services,
• To manage our relationship with you as a supplier,
• For the administration of our website and internal operations, including troubleshooting, as well as ensuring the security of our site,
• To improve the operation of our website to provide the most effective content presentation for you,
• So that all information on the website is presented in a user-friendly format.

7. Legal Basis for Data Processing

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

We may also process your personal data based on any legitimate interests or to fulfill any legal obligations. These interests and obligations may include pursuing or defending legal claims, complying with a court, tribunal, or regulatory authority order, as well as disclosing information to the government or regulatory authority.

Generally, we do not require separate legally certified consent to process your personal data. However, if your consent is required, we will provide you with a personal data processing request form.

8. Marketing

Upon your request, you will receive promotional messages by providing us with your data through this website and your consent to receive such information. If we have entered into business relations (namely, signed a contract) with you, we may inform you about our activities, offers, or other information that, in our opinion, may be useful to you in accordance with our legitimate interests.

We do not disclose your personal data to third parties for marketing purposes without your consent.

You have the right to withdraw consent or unsubscribe from receiving marketing information at any time by clicking the unsubscribe button. Once you withdraw your consent or if objections arise to any of the points listed here, we will cease sending you any marketing messages. If you decide not to give consent or prefer to unsubscribe, we may still be able to provide our services to the extent possible without the information required to provide the full range of services. This may affect the efficiency with which we provide the services you request.

9. Disclosure of Your Personal Data

We reserve the right to disclose your personal data to any of our international offices or companies within our group, which may act as joint data controllers or data processors for our company. These offices or companies become responsible controllers of your data when providing our services, and/or they provide administration, monitoring, and reporting services. All our companies respect and protect the security of your personal data in accordance with applicable laws (including GDPR) and apply all measures to protect data.

We may need to transfer personal data to government agencies and authorities in the country where you plan to obtain residency or citizenship. We provide such information only to the extent necessary to provide services under our contract with you.

We may need to provide your data to local agents or other counterparties (for data processing) to provide the services you request. These local agents and providers store and process your data based on strict confidentiality and compliance with relevant security measures and guarantees.

We may also disclose or transfer your data to other third parties acting as data controllers, such as legal, tax, real estate, immigration, or other consultants and agents, (international) banks for payment details, or third parties providing other or additional services or products to you, such as real estate agencies, owners, or developers with whom you may wish to interact on separate terms. These third parties will process your data according to their own regulations, and in this case, their data protection rules and processes apply.

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

10. Data Transfer to Third Countries

When we transfer your personal data to 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 GDPR.

All IMIN Malta Limited divisions act as data processing representatives in the EU for other divisions located outside the EEA. You can ask any questions and resolve any issues that may arise for you regarding us.

11. Access by Third Parties to Your Personal Data

With the aim of providing services, we closely collaborate with third parties. These third parties include cloud storage providers, providers of analytical services, and information suppliers for search engines. We work with third-party providers only if they comply with applicable laws in the jurisdictions where we operate and adhere to GPL to ensure a high level of security and protection of your personal data.

12. Data Security

We take all necessary security measures against unlawful or unauthorized processing of personal data, as well as against accidental loss or damage to personal data. Additionally, we grant access to your personal data only to those employees, agents, service providers, and other professional third parties who need to know this information. They operate your personal data strictly in accordance with our instructions and maintain confidentiality. All our employees and agents have undergone appropriate data protection training.

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

All personal data is stored on a secure server that utilizes firewall and other advanced technologies to protect against interference or unauthorized access. Usernames and passwords are provided to individuals authorized to access personal data, our employees, who are required to maintain confidentiality and are not authorized to disclose any personal data.

No method of data transmission is 100% secure, and therefore, absolute security cannot be guaranteed.

13. Data Retention

We retain your data only for as long as strictly necessary for the purposes for which it was collected (i.e., to provide you with our services or to satisfy any legal requirements, accounting requirements, or reporting obligations).

We store your personal data only for as long as necessary to achieve the purposes for which it was collected (providing services and continuing our professional relationship with you), and thereafter for compliance with any legal requirements or requirements related to accounting, taxation, anti-money laundering, reporting obligations, or obligations imposed on us. We may need to retain your personal data to be able to bring, exercise, or defend against potential future lawsuits involving you.

In general, the retention period of your personal data by us should not exceed six (6) years from the termination of our cooperation. This retention period allows us to use your personal data for potential reporting obligations for AML purposes to FIAU (legal obligation) and/or for asserting, filing, or defending against potential lawsuits involving you.

14. Data Minimization

Whenever possible, we anonymize the data we store about you when there is no longer a need to identify you based on this data.

15. Your Rights as a Data Subject

You have the following rights in accordance with GDPR:

1. Right to Information Access: You have the right to request information about whether your personal data is being processed by us, as well as information on how and why it is being processed.
2. Right to Object: You may contact us at any time to request that we do not use your personal data.
3. Right to Rectification: You have the right to make changes and correct any inaccuracies in your personal data used by us.
4. Right to Data Deletion: You have the right to request the deletion of your personal data provided 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 in certain cases.
6. Right to Data Portability: We will provide you or a selected third party with your personal data in a structured, widely used, electronic format.
7. Right to Withdraw Consent: If you have given your consent for the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that particular operation at any time.

16. Legislation Governing Disputes

The Privacy Policy and any disputes arising out of its application are governed by Maltese law. By accepting this, you agree that the courts of Malta have exclusive jurisdiction over any claims, disputes, or disagreements relating to the Commitment Letter and any matters arising from it. Each party unconditionally waives any right it may have to object to the filing of a lawsuit in these courts, to claim that the lawsuit was filed in an inconvenient forum, or to claim that these courts do not have proper jurisdiction.

17. Changes to this Privacy Policy

Any changes we may make to this Privacy Policy in the future will be posted on this page and, if necessary, emailed to you.

18. How to Contact Us

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