1. Personal Information
The aim of this policy is to inform you about:
2. Data Controller
The Data Controller (“the Controller”), i.e. the entity who determines the purposes and means of data processing, is SG Solutions which operates iCentre, incorporated in Malta with offices at SG Solutions Ltd, Dun Karm street, B’Kara Bypass, B’Kara, Malta.
The Controller is reachable at: [email protected] or +356 21442123 (Attn: Tony Saliba).
The Controller is also the owner and registrant of the Website.
3. Information to Collect
3.1 When you visit the Website, we might collect the following information about you in the case where you;
Visit our website
Create an account to buy from our online shop
Send us a message through the Contact Us form
Join our newsletter
Apply for the iCentre Loyalty Card
Pre-order or register interest for new products
4. Purpose and legal basis for collecting and processing data
4.1 Personal Data, as described in Clause 3 above is only collected for specific, explicitly stated and legitimate purposes and is processed according to the legal basis identified below.
4.1.1 Website visitor data is used to improve the content and functionality of our website, to better understand the categories of visitors and improve our products and services.
4.1.2 Account for online shop data is used to process your order. Your shopping history also helps us to improve our services, content and advertising.
4.1.3 Information enquirer data is used to respond to information requests.
4.1.4 Newsletter subscription data is used to keep you updated on our latest product announcements, updates, competitions and upcoming events.
4.1.4 The Loyalty card data is used to issue the loyalty card and manage the collection and redemption of the points.
4.1.5 The pre-order and register your interest data will be used to notify you about the availability of stock for new products.
4.2 Your Personal Data may be shared with third party data processors solely for the purposes set out in clause 4.1 above, and clause 5 below, or to otherwise fulfill SG Solutions’ requirements and obligations at law. Accordingly, your Personal Data may be processed by our service providers including but not limited to our accountants and auditors. Where your Personal Data is processed by any third party, we will confirm with such third party at your Personal Data will be retained in conformity with the law.
4.3 You may withdraw your consent to our retention of any Personal Data, subject to our legal requirements to hold such Personal Data at law. Similarly you have the right to request SG Solutions to provide you with the Personal Data we hold and to require SG Solutions to amend the Personal Data we hold. In this respect, you may communicate with SG Solutions at any time by sending an email on [email protected]
4.4 SG Solutions Ltd ensures that the information collected from the iCentre website is obtained through a secure connection. Thus we will take sufficient technical and organizational measures to protect all Personal Data.
5. Recipients of Personal Data
5.1 Your Personal Data may be shared between the undertakings forming part of the same group of companies as SG Solutions Ltd.
5.2 Your Personal Data may be also shared between the Controller and third party data processors as described in clause 4.2 above and this clause 5.
5.3 In addition, iCentre will share relevant information with third parties who provide services such as leasing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies will be obliged to protect this information.
5.6 You should be aware that SG Solutions may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all Personal Data we collect to the relevant third party.
5.7 Our website, products, applications and services may contain links to third-party websites, products and services. Our products and services may also use or offer products or services from third parties − for example, a third-party iPhone app. SG Solutions is not responsible for such third parties and bears no responsibility for any personal data such third parties may collect on you. Information collected by third parties, which may include such things as location data or contact details, is governed by the third party’s privacy practices and not those of SG Solutions. We encourage you to learn about the privacy practices of those third parties and to be aware that such third parties may retain or transfer any personal data they have collected on you outside of the European Economic Area (EEA).
6. Data Retention
We will retain your personal information for as long as required for the purposes for which your data was collected and processed or required by laws and regulations. This means that we will keep your data in line with our retention policies which take into account our business, administrative, legal and other regulatory retention requirements.
7. Your Rights
7.1 As a website visitor and user, you have extensive rights when it comes to the processing of your Personal Data.
Your rights, listed below, may be enforced by contacting the Controller by email, by post or by phone using the contact details provided above. SG Solutions will provide you with a response without undue delay.
You should note that if your request is particularly complex or we need to process an extraordinary number of simultaneous requests, our reply may take longer but will be nonetheless seek to respond without undue delay. In such circumstances, our reply will also include details explaining the reason for the delay in our response.
We will provide the information in digital format or if preferred in hard copy format.
Such requests will not incur any fee, except when:
Should we have reasonable doubts concerning your identity when making the request above, we may require additional information, necessary to confirm your identity.
You have the right to request a copy of the information that we hold about you. You may obtain confirmation from us as to whether or not your Personal Data is being processed including:
In case your Personal Data is inaccurate, incomplete or out-of-date, you have the right to rectify it.
7.4 Deletion(“the right to be forgotten”)
You have the right to have your Personal Data erased in case:
Where certain conditions apply, you have the right to request a restriction on the processing of your Personal Data.
You have the right to have the Personal Data we hold about you transferred to another organisation.
7.7 Right to object
You have the right to object to;
In addition to the above, and without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the local authority i.e. the Information and Data Protection Commission (IDPC).
In the event that SG Solutions refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain to the local supervisory authority. In the event that you wish to make a complaint about how your personal data is being processed by SG Solutions, or how your complaint has been handled, you have the right to lodge a complaint directly with SG Solutions. Alternatively you may raise a complaint directly with the supervisory authority.
The contact details of the supervisory authority are as follows:
Supervisory authority contact details
Information and Data Protection Commissioner
Level 2, Airways House
High Street, Sliema
+356 2328 7100
9. Applicability Law
The law applicable to the processing activities, and to this policy, shall be:
• Until 25 May 2018, the Data Protection Act, Chapter 440 of the Laws of Malta and other subsidiary legislation
• After 25 May 2018, Regulation EU 2016/679 (“GDPR”).