Last updated [22/11/2023]
1.2. This website is not intended for children and we do not knowingly collect data relating to children.
1.4. We are not responsible for the content or the privacy policies of websites to which we may link.
1.5. Allied Newspapers Limited (C-308) is the controller and responsible for your personal data.
2. What information do we gather/track about you?
2.1 We may collect or obtain such data because you give it to us (for example in a form on our Website or if you contact us), or because it is publicly available.
2.2 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2.3 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
2.4 Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
2.5 Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].
2.6 Usage Data includes [information about how you use our website, products and services].
2.7 Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
2.9 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. From where do we collect information?
3.1 In the course of using this Website, we will collect or obtain personal data about you.
3.2 We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise.
4. What do we do with the information we gather/track?
4.1 We will only process your personal data to the extent allowed by law. As part of this, we may process your personal data in the course of correspondence relating to our services and to the use of the Website.
5. Use of personal information collected via our Website
5.1 In addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our Website:
E-mail: Using the email addresses provided, we periodically send promotional email to our subscribers about services we offer and our advertisers.
We use e-mail links located in our contact us page to allow you to contact us directly with any questions or comments you may have. We will use your e-mail address to respond directly to these questions or comments.
6. Information Security
6.1 To prevent unauthorised access, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate physical, electronic, and managerial procedures to protect the information we collect online.
7. Requirements for processing:
7.1 Allied Newspapers Limited will ensure that:
- personal data is processed fairly and lawfully;
- personal data is always processed in accordance with good practice;
- personal data is only collected for specific, explicitly stated and legitimate purposes;
- personal data is not processed for any purpose that is incompatible with the purpose for which the information is collected. [The processing of personal data for historical, statistical or scientific purposes shall not be regarded as incompatible with the purposes for which the information was collected];
- personal data that is processed is adequate and relevant to the purposes of the processing;
- no more personal data is processed than what is necessary for the purposes of the processing;
- personal data that is processed is correct and up to date;
- all reasonable measures are taken to complete, correct, block or erase incomplete or incorrect data;
- personal data is not kept for a period longer than is necessary;
- personal data is not lost.
7.2 We will only process personal data if the consent of the data subject is given unless the law requires otherwise. [And explicit consent must be given in order for us to process sensitive personal data.]
7.3 As a safeguard to your personal data, we do not sell any personal data without the explicit written permission of the data subject [being the person to whom the data relates.]
7.4 Disclaimer: Allied Newspapers Limited shall not be held liable for any data errors in transmission not occasioned by itself, or for any unauthorised acts of third parties.
8. With whom do we share the information we gather/track?
8.1 We may disclose personal information if we are required and permitted to do so by law, in accordance with the Mata Data Protection Act (Chapter 586 of the Laws of Malta) and the GDPR.
8.2 We may also share your personal information within Allied Newspapers Limited and these organisations:
- Competent authorities (including authorities regulating us);
- Market researchers;
- Companies you ask us to share your data with;
- Third parties that provide services to Allied Newspapers Limited in order to for us to be able to provide you with our Website, in which case we have ensured by an agreement in writing that such third parties provide an adequate level of protection.
9. Aggregated/anonymised information
9.1 We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
9.2 We may also share your personal information if the make-up of Allied Newspapers Limited changes in the future:
- We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
- During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
- If the change to our Group happens, then other parties may use your data in the same way as set out in this notice
10. What if you choose not to give personal information?
10.1 We may need to collect personal information by law, or under the terms of a contract, we have with you.
10.2 If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your subscription. It could mean that we cancel a product or service you have with us.
10.3 Any data collection that is optional would be made clear at the point of collection.
11. The measures taken to protect your personal information
11.1 We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:
- education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
- administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
- technological security measures, including firewalls, encryption and anti-virus software;
- physical security measures, such as staff security passes to access our premises.
11.2 Although we use appropriate security measures once we have received your personal data, the transmission of data over the Internet (including by e-mail) is never completely secure. We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.
12. How long we keep your information for?
12.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
12.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
13. Your rights
13.1 You have various rights in relation to your personal data. In particular, you have a right to:
- obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
- ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
- ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data;
- withdraw consent to our processing of your personal data (to the extent such processing is based on consent);
- receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
- object to our processing of your personal data.
13.2 To exercise any of your rights, or if you have any other questions about our use of your personal data, please e-mail our Data Protection Officer on [email protected] or write to us at the address below:
Allied Newspapers Ltd
Times Of Malta, Triq l-Intornjatur,
Zone 1, Central Business District, Birkirkara CBD1050 – MALTA
You may also use these contact details if you wish to make a complaint to us relating to your privacy.
14. Right to complain
14.1 If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Office of the Information and Data Protection Commissioner in Malta or the relative data protection authority in your country. Find out on the IDPC website how to send a compliant.
15. Changes to this privacy statement
15.1 We may modify or amend this privacy statement from time to time.
15.2 To let you know when we make changes to this privacy statement, we will amend the revision date at the top of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.
16.1 When you visit any website including our Website, a cookie may be sent to you. A cookie is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing our Website. Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you and can customise what you see on the screen according to your registered preferences.
16. 2 While browsing our Website cookies may be used in the following scenarios:
- For statistical purposes to track how many users we have and how often they visit our Website. We collect information listing which of our pages are most frequently visited, and by which types of users and from which countries.
- We use other organisations to collect anonymous user information.
- Advertisers may also use statistical cookies to track who has seen an advert and clicked on it.
16.3 You can turn cookies off but if you do so, you may not be able to use all services on our Website and you might see more pop-ups and other advertising. This is because we won’t be able to limit what you see by using cookies. However, you will still be able to see our editorial content.