This notice discloses the privacy practices for Smart Spin Ltd. and smartspin.com, which are in compliance with the Data Protection Act, Chapter 440 of the Laws of Malta, the European Union Directive 2002/58/EC and Regulation (EU) 2016/679 (GDPR).
We have adopted a set of information management guidelines which serve as the basis for our customer relationships. These guidelines have been developed with the recognition that Internet technologies are rapidly evolving, and that underlying business models are still not established. Accordingly, guidelines are subject to change. Any such changes will be posted on this page. Please check the Website regularly for any changes. If the changes represent a material departure from our current practices with respect to the use of personal information, the changes will be posted on this page thirty days prior to taking effect and registered users will be notified via e-mail.
We are not responsible for the content or the privacy statements of websites to which we may link.
This privacy statement explains what information we gather about you, what we use that information for and who we give that information to. It also sets out your rights concerning your information and who you can contact for more information or queries.
This privacy notice is to let you know how we process your personal data. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about direct marketing communications you want us to send you. This notice explains how we do this and informs you about your privacy rights and how the law protects you. We are committed to protecting your privacy and handling your information in an open and transparent manner.
When this policy mentions “we” or “us,” it refers to the controller of your information under this policy. The legal person responsible for your personal data under this privacy statement is Smart Spin Ltd., a company registered in Malta at 22, Floor 1, Room 1, Lewis F. Mizzi Street, IKL1061 Iklin.
This privacy statement sets out how we will collect, handle, store and protect information about you when:
When we refer to “our Website” or “this Website” in this policy we mean www.smartspin.com.
This privacy statement also contains information about when we share your personal data with other third parties (for example, our service providers).
In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.
We use many different kinds of personal information and group them as follows.
| Type of personal information | Description |
|---|---|
| Contact | Where you live and how to contact you. |
| Socio-Demographic | This includes details about your work or profession, nationality, education and where you fit into general social or income groupings. |
| Transactional | Details about payments to and from your accounts with us. |
| Contractual | Details about the products or services we provide to you. |
| Locational | Data we get about where you are, which may come from your mobile phone, or the address where you connect a computer to the Internet. |
| Behavioral | Details about how you use our products and services. |
| Technical | Details on the devices and technology you use. |
| Communications | What we learn about you from letters, e-mails and conversations between us. |
| Usage Data | Other data about how you use our products and services. |
| Consents | Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you. |
We may collect or obtain such data because you give it to us (for example in an application form on our Website), or because it is publicly available.
Other examples of what information we may collect about you include the following:
The General Data Protection Regulation (GDPR) says that we are permitted to use personal information only if we have a proper reason to do so. This includes sharing it outside Smart Spin Ltd. The regulation says we must have one or more of these reasons:
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Here is a list of how we may use your personal information, and which of the reasons we rely on to do so. Here we also tell you what our legitimate interests are.
| What we use your personal information for | Our reasons | Our legitimate interests |
|---|---|---|
|
To manage our relationship with you. To develop new ways to meet our customers’ needs and to grow our business. To develop and carry out marketing activities. To study how our customers use products and services from us and other organisations. To provide advice or guidance about our products and services. |
Your consent. Fulfilling contracts. Our legitimate interests. Our legal duty. |
Keeping our records up to date, working out which of our products and services may interest you and tell you about them.
Developing products and services, and what we charge for them. Defining types of customers for new products or services. Seeking your consent when we need it to contact you. Being efficient about how we fulfil our legal duties. |
|
To develop and manage our brands, products and services. To test new products. To manage how we work with other companies that provide services to our customers and us. |
Fulfilling contracts. Our legitimate interests. Our legal duty. |
Developing products and services, and what we charge for them. Defining types of customers for new products or services. Being efficient about how we fulfil our legal and contractual duties. |
| To deliver our products and services. |
Fulfilling contracts. Our legitimate interests. Our legal duty. |
Being efficient about how we fulfil our legal and contractual duties. Complying with regulations that apply to us. |
|
To obey laws and regulations that apply to us. To respond to complaints and seek to resolve them. |
Fulfilling contracts. Our legitimate interests. Our legal duty. |
Complying with regulations that apply to us. Being efficient about how we fulfil our legal and contractual duties. |
| To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit. |
Our legitimate interests. Our legal duty. |
Complying with regulations that apply to us. Being efficient about how we fulfil our legal and contractual duties. |
| To exercise our rights set out in agreements or contracts. | Fulfilling contracts. |
In the course of providing products and services to you, we will collect or obtain personal data about you. We may also collect personal data from you when you use this Website.
We may collect personal information about you from the following sources:
Payment and transaction data.
Profile and usage data. This includes the profile you create to identify yourself when you connect to our Internet and mobile services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other Internet tracking software.
Social networks, such as when you log in to our Website through your social media accounts.
We will use your personal data to provide you with our products and services. As part of this, we may use your personal data in the course of correspondence relating to the products or services. Such correspondence may be with you, our client, our service providers or competent authorities.
Use of personal information collected via our WebsiteIn addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our Website:
Through Google Analytics we determine how often users visit our site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can prevent Google Analytics from recognising you on return visits to this site by disabling cookies on your browser.
Using the e-mail addresses provided at registration, we periodically send promotional e-mail to our subscribers about services we offer and our advertisers. You can indicate on the registration form that you do not wish to receive e-mail information from us or our advertisers. We may contact you regarding changes to the subscriber agreement as well as to confirm registration.
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.
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. The data controller (i.e. the party who decides for what purpose personal data is to be held or processed) for the data collected online, including but not limited to the personal information provided upon subscription, is Smart Spin Ltd.
Smart Spin Limited will ensure that:
Disclaimer: Smart Spin Ltd. shall not be held liable for any data errors in transmission not occasioned by itself, or for any unauthorised acts of third parties.
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 440 of the Laws of Malta) and the GDPR.
We may also share your personal information within Smart Spin Ltd. and these organisations:
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.
We may also share your personal information if the make-up of Smart Spin Ltd. changes in the future:
Please note that some of the recipients of your personal data referenced above may be based in countries outside of the European Economic Area (EEA) whose laws may not provide the same level of data protection. In the event that we do so, we will ensure that there are adequate safeguards in place by means of a data transfer agreement approved by the Information and Data Protection Commissioner in Malta or based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries.
Read more on the EU data protection site (https://ec.europa.eu/info/law/law-topic/data-protection_en).
We may need to collect personal information by law, or under the terms of a contract, we have with you.
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 certain services. It could mean that we cancel a product or service you have with us.
Any data collection that is optional would be made clear at the point of collection.
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:
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.
We will hold your personal data on our systems for the longest of the following periods:
After you stop being a customer, we may keep your data for periods of time as allowed by law for one of those reasons:
In order to protect our legitimate interests, in which case we make sure that this does not override your fundamental privacy rights at law.
You have various rights in relation to your personal data. In particular, you have a right to:
To exercise any of your rights, or if you have any other questions about our use of your personal data, please e-mail data.privacy@smartspin.com or write to us at the address below:
Smart Spin Ltd
22, Floor 1, Room 1,
Lewis F. Mizzi Street
IKL1061 Iklin
Malta
You may also use these contact details if you wish to make a complaint to us relating to your privacy.
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 (https://idpc.org.mt/en/Pages/contact/complaints.aspx).
We may modify or amend this privacy statement from time to time.
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.
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.
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.
Other companies, such as Google AdSense, may use cookies to suggest and deliver content through our Website which may interest you.
Advertisers may also use statistical cookies to track who has seen an advert and clicked on it.
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.
By using this Website you are agreeing to the use of cookies as described.