Privacy Policy

Definitions

We/Us/Our/Malta SIR means Malta Sotheby’s International Realty

You/Your/Yourself means the User of the website

This is our Privacy Policy

It sets out how we deal with Your personal data. Malta Sotheby’s International Realty respects Your privacy whether You are just beginning Your real estate search or have previously visited Our Website. Malta Sotheby’s International Realty seeks to protect Your personal data. This Privacy Policy gives You specific information about how we may collect data, with whom we may share it, the use of the data, the amount of information Malta Sotheby’s International Realty holds on You and how it uses it. By registering for or using Our Website, You signify Your acceptance of this Privacy Policy. Should you not be in agreement with Our Privacy Policy, kindly refrain from using Our Services. We reserve the right to modify this Policy at any time. Your use of the Website after any modification indicates to Us that You agree to the changes.

Information on Yourself shall be collected through our website located at www.maltasothebysrealty.com. Kindly be aware that any terms that are not provided within the said Policy shall be found in our Disclaimer and Terms of Use. Unless otherwise provided in the said Policy, this Policy only makes reference to the use and disclosure of information collected through Our Services. For certain services, We may collect and transfer Personal Data to a service provider, who may collect and use Your Personal Data for other purposes which are not within Our services.

Kindly be informed that we will treat your personal data in strict confidence and in accordance with the requirements of the provisions of the Data Protection Act, 2001 and also in line with the General Data Protection Regulation (GDPR) which shall be effective as from 25^th May 2018.

When Personal Data pertaining to Yourself is collected, the said information is being collected on behalf of ourselves, our parent company, subsidiaries and other entities under common control with Malta Sotheby’s International Realty.

Kindly be aware that this Policy does not apply to information collected by third parties, such as when visiting third parties Websites. Kindly review the Privacy Policies of third party Websites before You disclose Your Personal Data to them since We disclaim any responsibility whatsoever for their actions with regards to Your Personal Data.

What kind of data is collected and for which purpose it is being collected and processed

In general, as a user of our Website, You may visit the site without telling us who You are or revealing any information about Yourself. We use IP addresses to analyse trends, administer the site and to gather broad demographic information for aggregate use. IP addresses are not linked to personal information, only to usage. You may however choose to provide us with personal information if you complete and submit any of the forms that may be available sporadically on our website.  We shall store the data that You provide us and further process it as may be necessary in order to provide You with the particular service you might have requested from us as well as responding to any queries who might have posed.

Cookies

Our Website also uses a technology called “cookies.” “Cookies” are small files saved to the user’s computer / device that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to consent to the use of cookies on their computer / device. This complies with legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

Cookies enable us to collect information about how our Website and services are being used and to manage them more efficiently. These cookies are created for each session when You visit our website, the cookie will only track general usage patterns and technical information about Your computer type and will not be used to identify You individually.

Cookies are also used for targeting / advertising. Such cookies are used to share some information with third parties who we advertise with, so we understand and monitor how You reach Our website. We can also use cookies to identify the parts of the website You are interested in. We then use this information to show You adverts and pages we think may also be of interest to You.

The information so gathered through cookies may include:

• the date and time when You access our Website;
• the Website pages that You view and any download that You may make through such pages;
• whether or not such viewing or download is successful;
• the Internet address of the Website or the domain name of the computer from which You access our Website;
• the operating system of the machine running Your Web browser; and the type and version of Your Web browser.

Kindly note that You may reject the use of cookies that are used by our Website by modifying  Your Web browser preferences. Nevertheless, kindly note that if You reject all cookies, then You might be unable to use some of the services available on our Website. Moreover, kindly note that You may set Your browser in a certain way in order to be notified when You receive a cookie so that You have the option to choose whether to accept the cookie or not. In this regard, You should note that if You do so, this may materially distort the quality of service and data You receive. Thus, You would be doing this at Your own risk.

If the product You are using has digital certificates/certificate signatures then Your name and related details may be displayed as part of any certificate issued to You. It will be seen by those to whom Your certificate or signature is presented or who rely on it. Your details may also need to be entered into a related status directory of certificates issued.

This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website. You can read Google’s privacy policy here for further information.

Other cookies may be stored to your computer / device by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.

Personal data and its usage

Personal data means any information relating to an identified or identifiable natural person which shall be known as the data subject. Kindly note that We will process any personal and/or sensitive data supplied to Us by Yourself, whether orally or in writing, for all or any of the following purposes:

• as necessary to provide You with the information You would have requested from Us, including information about Our services;
• manage the Services and assess usage;
• enhance or personalise Your experience using Our Services;
• process or maintain Your subscription to a newsletter or mailing list;
• study the use and popularity of various areas of Our Services and to improve Our Services;
• in other ways described in this Privacy Policy or to which You have otherwise consented or requested or to any agreement entered with Malta Sotheby’s International Realty;
• in order to prevent, detect and/or prosecute fraud and any other criminal activity which We are bound to report and to meet any other specific legal or contractual obligations including but not limited to protecting and defending Our rights and property and that of Our clients or users of Our website;
• in order to establish, exercise or defend any legal action;
• for internal risk assessment purposes, internal management, research and statistics, systems administration and the development and improvement of Our properties, Our products and/or services;
• for the protection and promotion of Our legitimate interests and the proper conduct of Our business; and/or
• as may be allowed or required by or under any law.

Moreover, relevant data may be disclosed or shared with Our employees and with Our associates if pertinent to any of the purposes listed above. Kindly note that data shall not be disclosed to unauthorised personnel.

When You complete and forward to Us an online form which includes the information of another person, You confirm that You are giving Your explicit consent, in terms of the Data Protection Act, 2001, on behalf of Yourself and all the other persons specified in this form, in order for us to process the said personal information as outlined above and You would confirm that You have brought this Privacy Policy to the attention of these other persons and have obtained their respective consents.

You may subscribe to Our Portfolio whereby You shall be required to provide us with Your name, Surname, Mailing Address, Country, Post Code, Phone Number and Email address or any other information as updated from time to time. Subscribing to Our Portfolio entitles You to receive valuable email newsletters, occasional announcements and other information Malta Sotheby’s International Realty shall send from time to time.

Transfer of personal data

We do not pass on Your details collected from You as a visitor to any third party unless you give us your consent to do so, or in the instances indicated below.

You will be aware however that data sent via the Internet may be transmitted across international borders even where sender and receiver of information are located in the same country. Consequently, data relating to You may be transmitted via a country having a lower level of data protection than that existing in Your country of residence.

Without prejudice to anything contained in this Privacy Policy, we reserve the right to disclose personal data relating to You to any third party if such disclosures are necessary inter alia for the following purposes:

• for the purpose of preventing, detecting or suppressing fraud;
• to protect and defend Our rights and property or that of users of Our Website;
• to protect against abuse, misuse or unauthorised use of Our Website;
• to protect the personal safety or property of users of Our Website (e.g. if You provide false or deceptive information about Yourself or attempt to pose as someone else, we shall disclose any information we may have about You in our possession so as to assist any type of investigation into Your actions);
• for any purpose that may be necessary for the performance of any agreement You may have entered into with us; or as may be allowed or required by or under any law;
• for any purpose that may be necessary for the management, maintenance, upkeep of Our Website.

Kindly note that We do not share Your personal information with any third parties for marketing purposes.

Kindly be aware that in the event that We go through a business transition, such as a merger or an acquisition or else a liquidation, Personal Data We would be in receipt of, shall be disclosed subject to confidentiality restrictions during the due diligence process. Should a transfer occur, kindly note that the Personal Data transferred to the acquiring company shall still be subject to this Privacy Policy.

We use a Customer Relationship Management (“CRM”) which specifically manages Our interaction with current and potential customers. Through the said CRM, We are able to upload and save clients details as well as keep a record of the exchange of emails along with any attachments included in the correspondence.

The data extracted and used for Our CRM is uploaded on a third party server.

The use of the CRM enables Us to improve Our business relationship with clients. This is based on Our legitimate interest to oversee our relationship with clients and to ultimately develop business growth.

Retention of personal data and rights of the data subject

No personal data that we process will be kept longer than necessary for the purposes for which it is processed. You have the right to request a copy of the personal data that Malta Sotheby’s International Realty holds about You and to have any inaccuracies corrected. Further, you may, where applicable, also have the right to have certain personal data rectified, blocked or erased. Please address any such requests in writing to the Data Protection Officer, Malta Sotheby’s International Realty, 200 Tower Road, Sliema SLM 1602, Malta or at info@maltasothebysrealty.com. Kindly note that such request must be signed by Yourself as the data subject to whom the particular data relates.

Privacy compliance

Our Privacy Policy is compliant with the Maltese Data Protection Act, and the GDPR and we reserve the right to update this Privacy Policy at any time. Kindly be informed that it is in Your sole interest to read Our Privacy Policy every time You access Our website in order to be aware of any amendments made to the Policy. The date when this Policy was last updated is indicated at the end of this Policy.

Security

We use reasonable efforts to safeguard the 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; and
• unlawful destruction or accidental loss.

In this respect, kindly be informed that We have implemented security policies, rules as well as 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 visitors’ personal data. Nevertheless, kindly be aware that by its very nature, the Internet is not a secure medium and data sent via this medium can potentially be subject to unauthorised acts by third parties. Indeed, We cannot guarantee the privacy or confidentiality of any information passing over Our Website. We shall accept no responsibility or liability whatsoever for the security of Your data while in transit through the Internet.

Links to third-party websites

At times, Our Website may contain links that direct You to either local or international third-party Websites. This could only be done if We have the third party’s consent. Kindly be aware that We do not endorse any information or services that are portrayed in the said Websites. To this end, We are not responsible for the content, use, services and/or privacy policies of these Websites. Kindly note that once You enter such Websites, You become subject to the Privacy Policy of that Website and not to Ours. Furthermore, no third party shall link any Website to Our Website without Our prior written consent.

E-mail communications

Kindly be aware that Malta Sotheby’s International Realty may intercept some mail and e-mails addressed to individuals within Malta Sotheby’s International Realty.  Security of Malta Sotheby’s International Realty and of its personnel is the reason this might occur. Indeed, We might intercept mail in order to detect and prevent any crime, to identify the correct recipients or to make sure mail is dealt with whilst staff is away from the office. In the case of e-mails, We may reject, delay or remove content from e-mails which have a nature, content or attachments which may disrupt Our systems or because they may pose security issues such as viruses. We may also filter out e-mails which contain certain content on the basis that content is offensive or the e-mail is unwanted or considered spam. In certain circumstances, this may, unfortunately, result in “innocent” e-mails being affected but we do try and reduce such occurrences.

Most e-mail messages sent from Malta Sotheby’s International Realty have been automatically scanned for viruses and as such should be free from any virus; malicious code; script or other executable attachment. However, the accuracy of scanning products is not guaranteed. The recipient(s) should therefore carry out any checks that they deem to be appropriate in this respect. We cannot be held responsible for the loss of or damage to data or other damages, resulting from such actions out of Our control, howsoever incurred. All e-mail messages from Malta Sotheby’s International Realty are sent in good faith. We cannot be held responsible for any modification that happens by any virus, or other third party after they have been sent. All messages are intended for the recipient only. If You are not the intended recipient specifically identified as the addressee on the email then You should delete the message and all its attachments and You are prohibited from using, reading, disclosing to any person or otherwise acting on the information contained in it and/or its contents in any way and should also notify Us as soon as possible of this fact.

Although Malta Sotheby’s International Realty takes all the necessary steps to ensure your safety and that of your data, We may not be held liable for any loss of data which may be transmitted from your end through email spoofing or similar malicious techniques utilised by third parties.

Security and staff awareness

Malta Sotheby’s International Realty has developed strict policies governing information technology. These cover areas such as access control, authentication, audit, monitoring, alarms, data storage and back up and transmission standards. Malta Sotheby’s International Realty staff is subject to a code of conduct which requires them to adhere to privacy principles.

Limitation of liability

Kindly be aware that when You provide Us with Your Personal Data, You expressly release and hold harmless Malta Sotheby’s International Realty and its directors, employees or agents from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of Your collected Personal Data. In addition, even though We take reasonable steps to prevent third-party companies from making unauthorised use of Your Personal Data, We cannot be held liable for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of Your collected Personal Data by those third parties.

Contact us

Kindly forward any queries You have with respect the said Privacy Policy at:

Attn: Dr Franklin Cachia
The Data Protection Officer
Malta Sotheby’s International Realty
200, Tower Road, Sliema, SLM 1602, Malta EU
Email: franklin.cachia@maltasothebysrealty.com

Each Office is Independently Owned and Operated
Last updated on 11th October 2019