Best Deal Properties Holding p.l.c. (“Best Deal”, “us” or “we”) are committed to protecting and respecting your privacy, which includes any personal information that you may choose to provide us (“Personal Information”).

For all our services, the data controller, that is, the company that’s responsible for your privacy, is Best Deal Properties Holding p.l.c., with its address at 63, J.L. Buildings, Office 5, Luqa Road, Paola PLA 9045, Malta.

This privacy policy, together with Best Deal’s Terms of Use and Cookie Policy, describes our practices relating to the personal data of visitors of www.bestdealholdings.com. We may collect data about you including while you are navigating the pages of this website as well as details on how we use the information you provide to us and your rights in this regard. By using this website, you are subject to the terms of the statement.

We assure you that we will only use and disclose any personal data collected from you in accordance with the manner set out in this policy.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Should you have any questions about how we protect your privacy, get in touch with us on: info@bestdealholdings.com.

What happens when you visit this website?

Every time you connect to the internet or, if you use an always-on connection such as broadband or ADSL, you are automatically assigned a unique identifying number known as an Internet Protocol Address (“IP Address”). This IP Address, which contains information regarding the location of your computer on the internet, your country of origin and the name of your internet service provider (ISP), is automatically logged by this website.

When you visit a website, your web browser automatically downloads a copy of the webpages and pictures that you view to your hard disk. Certain pages of this website may also require that your browser downloads, together with the copy of the web page and pictures, a small text file called a “Cookie”. This is explained in the Cookies Policy.

We collect information from you when you fill out a form or where you are asked to provide details.

If you opt to fill in a form you will be asked to supply your email address and certain personal information such as your full name and surname, company, postal address, town, post code, country, telephone number and fax number. We store this information on Best Deal’s database in order to provide you with the requested service.

What information do we collect?

Most of the personal information which we may collect about you through this website is given to us only if you choose to give it to us.

Such personal information may be requested from you when you fill in a field (e.g., to sign up for our newsletter or fill in any other form with your questions and comments or any other form or application downloaded through or from this website. If you send us emails, then the personal data we process will depend on what you send us in the email.

The information we collect from you normally includes the following:

• Name + Surname;
• Contact Details;
• Email address;
• Information about your device (phone or laptop) with which you accessed our website.

Some other information is given to us because you accessed this website (e.g., logs, recorded through cookies). This is explained in the Cookies Policy.

How and why do we use your personal information?

We use your information in a number of different ways — what we do with it then depends on the information and the purpose for which we collected.

Where contact details are submitted through the website or otherwise provided by you, these are stored in Best Deal’s contacts database primarily in order to be able to administer your request and to provide you with the information required. This can include:

• For the provision of services;
• To help identify you in case we need to interact over the phone, electronic email or any other way;
• To verify your age and accuracy of your registration details, including disclosure of such information to third parties e.g., financial institutions and third-party reference agencies;
• To serve appropriate and tailored marketing material and content via SMS, email, phone, push notification, post or otherwise, in accordance with your marketing preferences;
• To help diagnose system problems and to administer our Website;
• To monitor and improve our services;
• To carry out customer research, testing and analysis;
• To carry out risk management;
• To enable us to comply with any legal or regulatory requirements; and
• For advertising and promotional purposes.

You don’t have to give us any of this personal information – however, if you don’t, you may not be able to use our site or all of the services we offer on the site, and you are unlikely to receive an optimal customer experience.

We also anonymise and aggregate personal information (so that it does not identify you) and use it for purposes including testing our IT systems, research, data analysis, improving our site and app, and developing new products and services. We also share this anonymised information with third parties – but don’t worry, they cannot identify you.

Legal basis for using your Personal Information.

We will only process your information in accordance with the provisions of the Data Protection Act (Chapter 440 of the Laws of Malta), the General Data Protection Regulation ((EU) 2016/679), and any and all national implementing laws, regulations and secondary legislation applicable in Malta relating to the processing of personal data, as introduced, amended or updated from time to time (the “Data Protection Laws”).

Data Protection Laws say that we are allowed to use your personal information only if we have a proper reason to do so. Accordingly, we must have one or more of the following reasons:

• to fulfil a contract that we have with you: its use is necessary in relation to a service or a contract that you have entered into or because you have asked for something to be done so you can enter into a contract with us;
• when it is in our legitimate interest: we may process your information when we have a business or commercial reason to use your information. However, even where it is in our legitimate interest to do so, it must not unfairly prejudice your interests or fundamental rights and freedoms;
• when it is our legal duty: when you apply for a product or service (and throughout your relationship with us) we are required by law to collect and process certain personal information about you;
• when you have consented to the using of your data (including sensitive data) in a specific way;
• where we need to protect your vital interests or those of another person; and
• where it is required in the public interest or for official purposes.

Is your personal information secure?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

To whom and where may personal information be disclosed?

Your Personal Information may, for the purposes described above, be transferred or disclosed to any related or subject to appropriate agreement, to third parties, for the processing of that Personal Information on our behalf. We may, from time to time, retain trusted third parties to process your Personal Information for the purposes listed above and such processing will be governed by a contract in the form required by law.

Where required by law, your Personal Information may also be disclosed to an applicable governmental, regulatory enforcement authority.

Retention and Disposal

We keep your information for as long as is necessary for the purpose for which it was originally obtained. We will take all necessary steps to ensure that the privacy of information is maintained upon disposal.

Your rights

You have several rights in relation to how we use your information:

• The right to be informed – You shall have the right to request us to inform you about the personal data that we process about you, the purpose of the processing, the categories of
  data that are being processed, the recipients of the data and the type of processing. Any such access requests must be made to us in writing and must further be signed by you as the
  data subject.
• If you later wish to raise a complaint on how we handled your personal data, you can contact us to have the matter investigated. In the event that you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can then complain to the Information and Data Protection Commissioner’s office.
• The right to maintain your personal data accurate and up to date – We make every effort to ensure that all the personal data that we process about you is accurate and regularly
  updated. However, should you become aware of any errors or omissions in respect of your personal data you are kindly requested to inform us about such errors in writing. If it
  transpires that the information held is inaccurate, we will make the necessary amendments and inform you that these have been made.
• The right to be forgotten – subject to certain exceptions, you shall also have the right to request erasure of your personal data on inter alia the following grounds:
  • where processing is no longer necessary for its intended purpose;
  • if your personal data has been given to us solely for consultation purposes and you choose not to avail yourself of any of our services;
  • when erasure is necessary for compliance with a legal obligation;
  • when you object to the processing, unless there are overriding legitimate grounds for us to process that information;
  • when the data concerns a child and has been collected solely for marketing purposes and not arising out of a contractual relationship for services required from us; and
  • where any data has been collected solely for marketing purposes.
• Instead of requesting erasure, you can also request a restriction of the processing of data in cases where the personal data is inaccurate, unlawful or pending a decision on a complaint lodged by you. In such case we can only store your personal data, and any further processing is only possible with your consent or in a limited number of situations.
• The right to data portability – Since your personal data is subject to automated processing on the basis of our contractual relationship, you are thus allowed to request a copy of the data concerned in order for you to be able to transmit your processed data to another controller without any hindrance from our part.
• The right to object- You have a right to object to us processing your personal information where the legal basis for our use of your data is our legitimate business interest or the
  performance of a task in the public interest. However, in doing so this may have an impact on the services and products we can/are willing to provide. You also have the right to object to the use of your personal data for direct marketing purposes. If you object to this use, we will stop using your data for direct marketing purposes.
• The right to withdraw your consent- where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always
  make it clear where we need your permission to undertake specific processing activities.

Changes to this Notice

We will update this Notice from time to time by publishing an updated version on our website: www.bestdealholdings.com.

Complaints

You have the right to make a complaint at any time to the Information and Data Protection Commissioner (“IDPC”) as the supervisory authority for data protection issues (https://idpc.org.mt/en/Pages/Home.aspx). We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance.