As a website user, you can tour through most of our websites without giving any information that personally identifies you, reveals personal information or allows us to contact you. We will require certain information about you should you wish to submit an enquiry or message through our website.
ClikkiClikki Limited collects, uses, shares or otherwise processes personal information that you provide to us when you subscribe to our services.
This statement explains the data we collect from you and its use.
1. What information do we gather about you and how is it being used?
1.1. Website users
Every computer connected to the Internet is provided with a domain name (e.g. google.com) and an IP Address (e.g. 126.96.36.199). When a visitor requests a page from within this site, our servers automatically identify and log the HTTP request that is made to our Web Server. Our website also uses a technology called “cookies”. A cookie is an element of data that a website can send to your browser, which may then be stored on your system. Cookies are created for each session when you visit our website. None of the information collected by means of cookies is associated with you as an individual. We do not use cookie technology to capture individual e-mail addresses or any personally identifying information about you.
In fact, very little information is automatically gathered and logged.
1.2 What personal information do we collect for our registered account holders?
Registering for an account: The personal information that we collect about you when you register for an account includes:
- your name;
- your city and province;
- your email address.
In order to have access to other features of our website, you will be required to validate your account by submitting a copy of your identity card or passport, and by updating your customer profile, at which stage we will collect the following personal information:
- Firstname and Lastname
- Phone number
- Taxpayer ID
- Identity document (Validity period of the document, Issued by)
- Marital Status
Booking a Visit: You may also book a visit to a property through our website in which case your personal information will be processed and shared with our agents who will be meeting with you on-site.
Communicating with You: We also process your personal information in order to communicate with you in the event that you are the winner of an auction, in order to provide you with further details regarding the transfer of the property.
Registering Your Property: It is also possible for property owners to register their property through our website, in which case we will request details of your property including the address, specifications of the property including property type, commercial area, plan and levels, number of rooms and bathrooms, plan and levels, appliances, a general description, and you will be requested to provide photos of the exterior and interior, and plans and you will also be requested to submit your name, telephone number and email address.
Email marketing: With your permission, we may send you emails about our company, our services and other updates including special offers and promotions, and to inform you of new auctions you may be interested in signing up for.
Winners: With your permission, we will publish videos and/or photos of the property acquisition and interviews with successful bidders, which videos and/or photos may be published on our website and shared on social media.
2. Use of your personal information
We will process any personal data supplied to us for all or any of the following purposes:
- to validate your account in order to allow you to make use of our website’s features including to register for auctions and participate in such auctions, to book a visit, to register your property, and to purchase Blue Bricks;
- communicate with you and provide you with information about your purchases, participation in our auctions, and to provide you with further details in the event that you are the winner of an auction;
- to communicate with you and provide you with information about our properties and services, including direct marketing communications;
- answer your queries and solicit your feedback;
- process payments as agreed with you;
- send important notices, such as changes to our terms and conditions and policies;
- send you technical notices, updates, security alerts and support and administrative messages;
- for internal purposes such as auditing, risk assessment purposes, internal management, research and statistics, systems administration and the development and improvement of our services;
- to monitor and analyse trends, usage and activities in connection with our services to understand which parts of our digital platforms and services are of the most interest and to improve the design and content of our platforms;
- to ensure we have up-to-date contact information for you;
- to prevent, detect and/or prosecute any illegal and/or criminal activity which we are bound to report and to meet any other specific legal or contractual obligations;
- to establish, exercise or defend any legal action;
- to protect and promote our legitimate interests and the proper conduct of our business;
We may also be required to processes your personal data for the purpose of:
- compliance with applicable laws, rules, regulations, guidance and codes;
- compliance with demands or requests made by local and foreign regulators, governments, courts and law enforcement authorities, and complying with a court process, or in connection with any litigation;
3. On what basis do we use your personal information?
- Necessary Processing: We process your personal data as necessary in order to provide you with the service you require, such as when you make an enquiry, when you make a purchase, when you register for an auction.
- With your consent: We will only process your personal information for any other purpose, including direct marketing, when you have given your consent to the processing of your personal data for such other purpose. You have various rights where we are processing your information on the basis of your consent. For example, if you no longer wish to be on one of our mailing lists, you can choose to opt out at any time by following the “unsubscribe” instructions at the bottom of our promotional emails. If you have an online account with us, you can also opt out by updating your preferences.
- For legitimate business purposes: There may be instances where we are required to process your personal information in order to safeguard our legitimate business interests. For example, we may need to process your personal data if you violate our Terms and Conditions. Where we use your personal information for this purpose, rest assured that we will take measures to protect your personal information.
- To comply with a legal obligation: There may be instances where we are legally obliged to process your personal information.
4. Recipients of personal information
Your personal information will be received by Clikki Clikki’s representatives and employees.
We may also share your personal information with any of the following:
- other companies forming part of the same group of companies, affiliate companies and companies having the same shareholding as Clikki Clikki Limited or in which Clikki Clikki Limited has a controlling interest, for legitimate business purposes;
- trusted businesses or persons to whom we may outsource certain functions from time to time, in order to provide the required services;
- our agents, suppliers and business partners strictly as required in order to carry out the purposes outlined in this privacy notice;
- our professional advisors and auditors strictly as required for consultation purposes or for compliance with our legal obligations;
- regulators, governments and law enforcement authorities as and when this is required under applicable laws and regulations;
- courts, tribunals, arbitrators or other competent bodies who may have authority to request such personal information;
- other third parties in connection with our selling, merging, buying or reorganising all or any part of our business, or carrying out any similar change of our business (including any potential or actual purchaser of that business or that purchaser’s advisors).
5. Transfers outside the European Union
We may transfer your personal information outside of Malta. The countries to which your personal information is transferred may not offer an equivalent level of protection for personal information to the laws of Malta. Where appropriate, we will take steps to ensure your information is transferred subject to appropriate safeguards, such as by entering into data transfer agreements. Where we have put data transfer agreements or similar safeguards in place, we may be able to make a copy of this available to you if you contact us via one of the methods set out under the header “Contact Us” below.
6. How long will we keep your personal information?
We have a data retention policy that sets out how long we keep your information. This policy is based on the type of information, the purpose of collection, and the system within our digital platforms in which the information is held. As a general rule, we keep your personal information for as long as we need to in order to carry out those purposes for which your data has been collected.
Records relating to financial transactions are kept for a period of ten (10) years from the date of the final contract of sale.
Records of other transactions are kept of a period of five (5) years, with the exception of cases relating to any legal claims which may require an extension of such period.
We use reasonable efforts to safeguard the integrity, availability and confidentiality of all personal data that we process relating to you and regularly review and enhance our technical, physical and managerial procedures so as to ensure that your personal data is protected from:
- unauthorised access;
- improper use or disclosure;
- unauthorised modification;
- unlawful destruction or accidental loss.
To this end, we have implemented security policies, rules and technical measures to protect the personal data that we have under our control. All our employees and data processors, who have access to and are associated with the processing of personal data, are further obliged to respect the confidentiality of our clients’ and visitors’ personal data.
Online identity theft and account hacking, including the practice currently known as “phishing” are of great concern. You should always suspect when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your personal information or your credit card information in a non-secure or unsolicited communication (e-mail, phone or otherwise).
8. Sensitive Data
We do not request or require special categories of information concerning religion, health, sexual orientation, trade union membership, or political affiliation and ask you to refrain from providing any such personal data in your communication with us.
9. Third Party Links
If you choose a direct payment gateway to complete your purchase, then a third party processor stores your credit card data. Your data will be encrypted and your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
9.2 Third Party Services
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us and in accordance with the law.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
We recommend that you read their privacy policies, so you can understand the manner in which your personal information will be handled by these providers.
We make every effort to use only third party providers of good repute and to ensure that they take all necessary measures to protect your data to the best of their abilities, in accordance with best industry practices and according to law.
10. Your Rights
You have the right to:
- Withdraw your consent when your personal data is processed on the basis of your consent. The withdrawal of your consent shall not affect the lawfulness of processing before the withdrawal of your consent.
- Ask ClikkiClikki Limited about the processing of your personal information, including to be provided with a copy of your personal information held by ClikkiClikki Limited;
- to request the correction and/or deletion of your personal information, or restrict or object to the processing of your personal information;
- to request to obtain and reuse your personal information for your own purposes across different services; and
- to complain to a competent supervisory authority, or to a court of law, if your data protection rights are violated or you have suffered as a result of unlawful processing of your personal information.
If you would like access to the information that we hold about you, if any of the information that we hold about you is inaccurate or out of date, or if you wish to withdraw your consent to the processing of your data or to restrict or object to us processing it, please let us know by getting in touch via one of the methods set out under the header “Contact Us“ below.
If you object to our processing of your personal information, we will respect such requests in accordance with our legal obligations. Your objection may mean that we may not be able to perform the actions necessary to achieve the purposes set out above.
ClikkiClikki Limited may be required or entitled to retain your information to comply with legal and regulatory obligations and to protect and exercise our legal rights and legitimate interests.
In addition to those rights outlined above you also have an unconditional right to object at any time to the processing of your personal information for direct marketing purposes by contacting us via one of the methods set out under the header “Contact Us” below.
ClikkiClikki Ltd is the controller of your personal information. The contact person for data protection related matters is [insert name].
Should you have any questions, comments and requests regarding the processing of your data you may contact us through any of the following methods:
By email: [email protected]
By mail: ClikkiClikki Ltd
Smart City Malta SCM01
Lower Ground Fl, Unit GR03
Kalkara SCM 1001