Introduction
The purpose behind this policy (“Privacy Policy”) is to inform you of how EasyGas (Malta) Ltd (“EasyGas”) collects, processes, uses, and stores your Personal Data as well as the rights which you have in this regard.
“Personal Data” in this case means any information which relates to an identified or identifiable individual.
An individual is ‘identified’ or ‘identifiable’ if one can distinguish him/her from other individuals.
By using our services, you acknowledge that you have read and fully considered the Privacy Policy.
For the purposes of the General Data Protection Regulation (the ‘GDPR’), EasyGas is the Data Controller of the Personal Data collected.
A ‘Data Controller’ is that person (in this case EasyGas) who determines the purposes and means of the processing of Personal Data.
‘Processing’ means any operation which is performed on Personal Data such as collection, storage, use, and erasure.
For any further request or query about how we use Your Personal Data, you may contact us by using the following email address: info@easygas.com.mt
Information We Collect
The data which we may collect about you includes:
- Your name and surname
- Your email address
- Your IP address
- Any personal data that you may provide to us through our website
- Any personal data that you may provide to us through your communication with us (such as through meetings, calls, emails, etc.)
- Any personal data that is necessary for the performance of a contract and/or order and for compliance with our legal obligations
Legal Basis of Processing
Under the applicable data protection laws, namely the GDPR, we may process your Personal Data if you have given us your consent or if such processing is necessary:
- To comply with a legal obligation
- For the performance of a contract and/or order
- For our legitimate interests
Sharing of Personal Data
EasyGas will not share any of your Personal Data with third parties without your consent unless we are obliged to do so in terms of our legal or regulatory obligations or where such sharing of information is required for us to be able to provide you with a service which you have engaged us to provide.
Transfer of Data to Third Countries
EasyGas shall not transfer any of your Personal Data to third countries (those countries located outside the EU/EEA).
Data Security
In order to protect the Personal Data which you provide to us, EasyGas, amongst other measures:
- Maintains physical, electronic, and procedural safeguards to protect information which is transmitted to us
- Ensures that your Personal Data is processed solely by authorised personnel
- Ensures that whoever has access to your Personal Data as duly authorised is obliged to respect the Confidentiality of such Personal Data as well as other obligations as imposed by the applicable data protection laws
Despite making use of such measures, it is acknowledged that data transmission over the internet and/or a storage system can never be totally secure. Therefore, any information transmitted to us is done at your own risk.
Your Rights
As a Data Subject, you have the following rights:
Right to be Informed
According to the GDPR, you have a right to know the following information:
- Why the Controller is using your data
- What type/types of data the Controller is using
- For how long such data will be kept
- If the data is going to be transferred to third parties, and if so, the names or categories of recipients, and the reasons for the transfer
- Information as to whether the Controller is going to transfer the data to third countries, including the country involved and what will be done with the data
- Your data protection rights
- Where the data is collected from
- If the Controller is using the data in profiling (this is a type of automated processing where your personal data is used to analyse or predict things such as your performance at work, economic situation, health, personal preferences, and interests)
- How to contact the Controller
- Your right to lodge a complaint with the IDPC
All of the above information has been provided to you in this Privacy Policy. Moreover, if at any time we process any Personal Data which has not been provided to us directly by you, you also have a right to be informed of the source from which your personal data originates.
Right of Access
This is a right to ascertain whether we hold Personal Data about you and to receive a copy of such Personal Data.
Right to Rectification
This is a right to update and/or correct any Personal Data we process about you which may be inaccurate/incorrect. If you wish to check the information which we hold about you, you can contact us at any time via email on: info@easygas.com.mt.
Right to Erasure (‘Right to be forgotten’)
This is a right to request that we delete your Personal Data which is held and processed by EasyGas. This right is not absolute. There may be circumstances where we may have a valid reason to keep certain Personal Data (for example when we are legally obliged to do so).
Right to Object
This is a right to object to the processing of your Personal Data in certain circumstances. These circumstances include when such processing is carried out for the purpose of our legitimate interests.
Right to Data Portability
This is a right to move, copy, or transfer your Personal Data from one data controller to another. You also have a right to request from us a copy of your Personal Data in a structured, commonly used, and machine-readable format, which we may provide to you or another organisation at your request.
Right in relation to the decisions taken solely by automated means
This is a right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or significantly affects you. Profiling is a type of automated processing where your Personal Data is used to analyse or predict things such as your performance at work, economic situation, health, personal preferences, and interests. It should be noted that EasyGas does not use any of your Personal Data provided for the purpose of any decisions taken solely on the basis of automated decision making, including profiling.
Right to Lodge a Complaint
If at any time you have any complaints with regards to our processing of your Personal Data, please contact us on info@easygas.com.mt. Moreover, you also have a right to lodge a complaint with the Information and Data Protection Commissioner in Malta (IDPC). A complaint can be lodged either through their website directly: IDPC, or by sending an email to the following address: idpc.info@idpc.org.mt.
Retention of your Personal Data
EasyGas shall retain your Personal Data exclusively for the period in which it is necessary to fulfil the purpose of its collection, or until you withdraw your consent, where applicable. There may also be circumstances wherein we are required to retain some of your Personal Data, as the case may be, for a longer period. These include:
- In case that there is a legal obligation to do so under a relevant statutory provision
- In case of any claims against EasyGas, for as long as necessary to defend our rights and legitimate interests before any competent court and any other public authority
Once we are no longer required to retain your Personal Data, EasyGas will then immediately and irrevocably proceed to destroy such Personal Data.
Changes to the Privacy Policy
EasyGas may change or amend any part of this Privacy Policy from time to time as it may deem fit. Before enforcing any changes made, EasyGas shall first communicate such changes in this Privacy Policy. It is your sole responsibility to make sure that you go through the Privacy Policy as updated and if you continue to use the services or our website, you are consenting to the updated Privacy Policy.
Law and Jurisdiction
This Privacy Policy shall be governed by Maltese Law and any dispute arising from, or in relation to, such Privacy Policy shall be subject to the Exclusive Jurisdiction of the Courts of Malta.
