Privacy Policy

We are committed to protecting and respecting your personal information privacy.

Last updated: February 8, 2022.

This Privacy Policy (hereinafter referred to as the "Privacy Policy") applies to the website or any subsidiary website or relevant domains (hereinafter referred to as the "website" or "site"), services provided by the owner and operator of the Site, and any relevant applications ("Applications") in which your personal data is processed (through the Site, any of Our applications, or otherwise).

This Privacy Policy is issued on behalf of affiliates, so when the pronouns "We", "Us", or "Our" are mentioned in this Privacy Policy, we mean the relevant organization responsible for processing your data. We will provide information about which organization operates personal data when a client uses any of our services. In certain cases, when a client's personal data is provided, stored, and processed by us in countries where additional local data protection laws apply, our clients may refer to the relevant jurisdiction below for further information about the relevant local data protection laws regarding the privacy policy notification.

In this Privacy Policy, the words "You", "Your", and "User" refer to an identified or identifiable natural person 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 read below.

This Policy describes the ways in which [Your Company] processes the information and personal data you have provided to us, allowing us to effectively manage your relationships with us.

1. Purpose of this Privacy Policy

We respect and value the privacy of our clients. We do not sell, transfer, or otherwise provide any information about any person visiting our Website to third parties, except as expressly provided in this Privacy Policy.

• Identification of the type of personal data we collect about clients and how we use your personal information.
• Identification of the basis on which we process any personal data.
• Informing you about how we process your personal data,
• Clarifying the obligation under data protection provisions regarding the lawful and responsible processing of our clients' personal data.
• Informing you of your data protection rights

2. Legal issues regarding the processing of personal data

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 "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 changed from time to time;
• Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, "On the protection of natural persons regarding 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 "Regulation" or "GDPR").

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

This Privacy Policy should be considered in conjunction with our Cookie Policy and any other privacy notices that we may provide in certain cases when we collect or process personal data about you for full awareness of how and why we use your data.

3. Data Controller

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

We control the personal data that we collect or receive and process in the course of providing our services and/or operating the website. Our affiliated legal entities may become data controllers, both jointly and as separate data controllers.

4. Personal data collected from our Users

Personal data or personal information is any information about a natural person by which that person can be identified. Personal data does not include information where there is no mention of identity (anonymous data). Our website is structured in such a way that our users can access our site online without identifying themselves and without disclosing any personal information. However, if you choose to provide us with personal information, we ensure the protection of that information and use it only in the ways described below.

We collect and process the following personal data about you:

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

If you use our services or apply for a job, you may be required to provide additional information. If you are a user of our services, we may also require additional information before we enter into a commercial relationship with you.

We may also request information that may be required 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 under the terms of the contract concluded with you, and you cannot provide this data upon request, this may result in the inability to provide the service as agreed or the inability to conclude 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.

b) Contact details

Contact details include payment address, postal address, email address, and phone numbers for contact.

c) Compliance data (AML and KYC)

Compliance data (AML and KYC) includes 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: a copy of the identification document, a KYC due diligence report (databases), and any other documentation that may be required from time to time under the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta) ("PMLA"), the Prevention of Money Laundering and Terrorist Financing Regulations ("PMLFTR"), the Financial Intelligence Analysis Unit ("FIAU"), and/or at the request of any other competent authority or relevant legislation.

d) Auxiliary data

• Current client status, plans, interests, goals, or objectives;
• Services requested and provided to the client.

e) Financial data

Financial data includes the client's 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.

f) Transaction data

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

g) Technical data

Technical data includes Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, types and versions of browser plug-ins, operating system and platform, as well as other information about your experience with the Website, such as page response times, loading 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 to pages.

Location information: we may obtain information about your location and may determine your location by your IP address, as well as, when accessing the website via a mobile device, using data that 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 provide a quality viewing format of 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.

h) Marketing and communication data

Marketing and communication data – your preferences for receiving promotional materials from us and our third parties or related parties, 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 that you voluntarily provide or disclose to us in cases where this is appropriate and necessary for providing the 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, phone negotiations, email, or otherwise in the course of applying for our services,
• Subscribing to our services or publications,
• Requesting a quote to be sent to you,
• Feedback on our services,
• Starting negotiations or concluding a contract.
• Whenever you visit our website, we automatically collect technical data.
• We may also obtain personal data from our visitors from various third parties and public sources (advertising features of Google Analytics, including Google AdWords, Facebook Pixel, Google Tag Manager, LinkedIn, and other special paid media partnerships).
• Identification, contact, and reference data from public sources, databases of checks, and/or data service providers obtained as a result of checks, in the EU and beyond, so that we can ensure that you are a suitable client or supplier for us.

6. How we use your personal data

We use personal data:

• To simplify the format of providing requested services under the contract we enter into or have entered into with you,
• When required by our legitimate interests (or the interests of third parties) and when your interests and rights do not have a prevailing effect over those interests,
• As necessary to comply with legal or regulatory obligations,
• To address any issues you report and to provide support-related services,
• To manage our relationships with you as a supplier,
• To administer our website and internal operations, including troubleshooting, as well as to ensure the security of our site,
• To improve the operation of our website to ensure the most effective presentation of content for you,
• To ensure that all information on the site is presented in a user-friendly manner.

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 specified 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 the enforcement or defense of legal claims or compliance with any court, tribunal, or governmental authority order, as well as disclosure of information to the government or regulatory authority.

As a rule, we do not require separate legally binding consent to process your personal data. However, if your consent is required, we will provide you with a request form for handling personal data.

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 a business relationship (namely, signed a contract) with you, we may inform you about our activities, offers, or other information that we believe will be useful to you in accordance with our legitimate interests.

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

You have the right to withdraw consent or unsubscribe from receiving promotional information at any time by clicking the unsubscribe button. Once you withdraw your consent or in case of objections to any of the points listed here, we will stop sending you any marketing messages. If you decide not to give consent or prefer to unsubscribe, we may provide our services to the extent possible without the information required to provide the full range of services. This may affect the effectiveness with which we provide the services you requested.

9. Disclosure of your personal data

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

We may be required to provide your data to local agents or other contractors (for data processing) for the purpose of providing the services you requested. These local agents and suppliers store and process your data on the basis of strict confidentiality and with appropriate security measures and guarantees.

We may also transfer your data to other third parties who perform data controller functions, 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 under their own regulations, and in this case, their rules and data protection processes apply.

We may also disclose or transfer your data if we are required to do so to comply with any legal obligation, court order, or by order of a 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 safety of our partners or other users of our website. This includes sharing information with other companies and organizations for the purposes of combating money laundering or due diligence, compliance with anti-bribery or corruption laws, and/or fraud protection.

10. Data transfer to third countries

When we transfer your personal data to third parties, this may include 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 divisions of IMIN Malta Limited act as a data processing representative in the EU for other divisions located outside the EEA. You may ask any questions and resolve issues that may arise regarding us.

11. Third-party access to your personal data

In order to provide services, we work closely with third parties. Such third parties include cloud storage providers, analytics service providers, and information providers for search engines. We work with third-party suppliers only if they comply with applicable laws in the jurisdictions in which we operate and follow GDPR 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. In addition, we provide 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 secured by transport layer security (TLS) certificates. When accessing the website using compatible browsers, this technology protects personal information using both server authentication and data encryption to ensure the security of personal information during transmission.

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

No method of data transmission is 100% secure, and therefore it is impossible to guarantee absolute security.

13. Data retention

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

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

In general, the retention period for your personal data 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 under AML/CFT to FIAU (legal obligation) and/or for asserting, filing, or defending against potential legal claims involving you.

14. Data minimization

Where possible, we anonymize the data we hold about you when there is no longer a need to identify you by that data.

15. Your rights as a data subject

You have the right to exercise the following rights under GDPR:

1. Right of access to information: You have the right to request information about whether your personal data is being processed by us, as well as information about how and why it is being processed.
2. Right to object: You may contact us at any time to ask us not to 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 erasure: You have the right to request the deletion of your personal data provided to us when it is no longer required.
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 third party of your choice with your personal data in a structured, commonly 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 specific operation at any time.

16. Legislation governing disputes

The Privacy Policy and all disputes arising in connection with its application are governed by the laws of Malta. You hereby agree that the courts of Malta have exclusive jurisdiction over any claims, disputes, or disagreements arising from the Letter of Commitment and any issues arising from it. Each party unconditionally waives any right it may have to object to the filing of a claim in these courts, to assert that the claim was filed in an inconvenient forum, or to assert 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, sent to you by email.

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").