This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of Malta Business Service.

If you see an undefined term in this Privacy Policy (such as “Malta Business Account” or “Malta Business cards), it has the same definition as in our Legal Agreement for User Account, Legal Agreement for Business Account and User Agreement for Malta Business Service or other legal documents regulating Malta Business Service to all of which this Privacy Policy is inseparable part.

When this policy mentions “we,” “us,” or “our,” it refers to the respective company, proving Malta Business Services to the Client, under the above mentioned Legal Agreements, that is responsible for your information under this Privacy Policy (the “Data Controller”).

For the purposes of this documents Malta Business Services consist of products, services, content, features, technologies, or functions, and all related websites, applications and services distributed to you by us or mobile apps, online platform, official social media platforms, or other online properties through which we distribute payment and e-money services.

We give utmost importance to the protection of personal data of our customers. In the following Privacy Policy, we inform the Client about the collection, use and processing of your personal data when you apply, register or use our Malta Business Service and all functionalities, included in the Service, including our website https://www.maltabusinesscards.com (hereinafter: “Website”), E-money account and Cards.

  • For the purposes of providing Malta Business User Account and Business Account under the Legal Agreement for Malta Business with Em@ney p.l.c, the responsible Data Controller is Em@ney plc, registration number C5558 and located in 4/45 Regent House, Bisazza Street SLM 1640, Sliema, Malta. (referred to as Em@ney p.l.c., Malta);

Where one of the abovementioned entities is specified as responsible Data Controller we inform you that the other entities specified above are acting as Data Processors of the Date Controller and vice-versa. The ultimate liability lies with the respective Data Controller and you should address all your questions to the respective Data Controller via the contact details specified below.

The services distributed by Malta Business is designed for both business purposes and personal use and may be used by individuals or entities. In case you are registering for and/or using Malta Business Services on behalf of an entity we will treat you as authorized person and you may be obliged to disclose to us personal data of the legal representatives, the employees, the agents, the beneficial owners or any other third-party related to the entity pursuant to the rules described below. You certify that where you have provided information regarding any third person beside yourself you have received prior consent from that other person to provide their personal information to us.

In case you are using malta Business Service for your payroll needs (in example you are opening accounts on behalf of your employees for wage payment purposes), you certify that where you have provided information regarding any employee beside yourself you have received prior consent to provide their personal information to us and that you have informed the employee for the present Privacy policy, to which the employee has agreed.

Not a Framework Contract: For the avoidance of doubt, this Privacy Policy does not constitute a “framework contract” for the purpose of the EU Payment Services Directive 2 (EU) 2015/2366 or any implementation of that directive in the European Union or EEA (including, without limitation any national laws implementing the EU PSD).

1. WHAT INFORMATION WE COLLECT

You are informed that there are three general categories of information that is collected from you differentiated on grounds as defined by the Regulation 2016/679 and other applicable data protection national laws.

1.1 Information we collect in order to fulfill our legal obligations and in order to provide the Malta Business service as part of our contract with you. We request and collect from you the following personal information when you use it and request information for the services distributed on this website.

This information is necessary for us to comply with our regulatory obligations and for the proper execution of the contract between you and us. Without it, we may not be able to provide you effectively with the Malta business service for which you register and for which you request information.

Registration and use of account information. When you register and request information for the services distributed by Malta Business, we request some personal information such as:

information such as:

  • First name and surname
  • Date of birth
  • Place of birth
  • Email address
  • Nationality
  • Registered address
  • Mobile telephone number
  • Identification document and all data from the identification document
  • Type of identification document
  • Issue date
  • ID number
  • Issuing authority

And other data which we may choose to collect in our enrol forms, which is necessary for your identification and verification.

Information necessary for adequate customer verification

In accordance with our legal obligations with regard to AML FT (anti-money laundering and financing of terrorism) regulations, we are obliged to verify your identity or the identity of the authorized user who is requesting an account opening.

In order to comply with the CRS / FATCA regulations, we are required to request the tax identification number (“TIN”), the country of tax residence and the status of economic activity (active or passive). We may be required to disclose this information to the competent supervisory tax authorities.

Information related to risks and frauds

In order to comply with relevant AML FT regulations, personal data could be used for verification purposes as required by current legislation and included in certified databases for anti-terrorism checks.

We may receive information about your activities inside and outside of Em@ney through partnerships, or through your interactions with our partners and / or networks.

Source of income, estimated annual turnover on the account, details of the business In order to comply with relevant anti-money laundering and counter-terrorism obligations, we collect personal data relating to sources of income and other similar financial information that could help us prevent money laundering and / or terrorist financing.

2. HOW WE USE INFORMATION WE COLLECT

We use, store, and process information, including personal information, about you to provide, understand, improve, and develop Malta Business Service, create and maintain a secure environment, pursue our legitimate interests and comply with our legal obligations.

2.1. Provide, Personalize, Measure, and Improve our Advertising and Marketing.

  • Send you promotional messages, marketing, advertising, and other information related to Malta Business service and the products and services of unaffiliated businesses that may be of interest to you based on your preferences and social media advertising through social media platforms such as Facebook, LinkedIn or Google.
  • To provide personalised Malta Business Services offered by us on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature or offer to you on third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as advertising or analytics companies to provide these online services.
  • To provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the Malta Business service and provide you with location-based Service, such as advertising, search results, and other personalised content.
  • To make it easier for you to find and connect with others, we may use your information you have shared with the Service to suggest connections between you and people you may know. For example, we may associate information that we learn about you through your and your contacts’ use of the Services, and information you and others provide to suggest people you may know or may want to transact with through our Services. Social functionality and features designed to simplify your use of the Services with others vary by Service.
  • Personalize, measure, and improve our advertising.
  • Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or its third-party partners.
  • For participation in games, quizzes and completion of questionnaire or a contest entry form for promotional campaigns.
  • Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with Malta Business service, information obtained from third parties) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

We will process your personal information for the purposes listed in this section given our legitimate interests in relation to the products we have already offered you and your consent in undertaking marketing activities to offer you products or services that may be of your interest. You have the right to object or opt-out from processing your personal information for the purposes described above by withdrawing your consent at any time and free of charge.

3. WITH WHOM DO WE SHARE PERSONAL DATA

3.1. With other members of the Em@ney plc corporate family: We may share your Personal Data with members of the Em@ney Plc of companies or within our extended family of companies that are related by common ownership or control, so that we may provide the Services you have requested or authorised or to manage the risk, or to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of Malta Business Services and communications.

We may share personal information with third-party service providers who support us in providing products and / or services with functions at our discretion and on our behalf.

For example, these third-party service providers can:

  • Verify your identity or authenticate identification documents;
  • Check information against public databases;
  • Conduct basic or police checks, fraud prevention and risk assessment;
  • Perform risk monitoring;
  • Run the development, maintenance and debut of the product;
  • Allow supply through third-party software platforms and tools (e.g. through integration with our APIs);
  • Provide customer support;
  • IT support and development services;
  • Run courier services on our behalf;
  • Provide cloud, storage or collocation services;
  • Provide audit and accounting services;
  • Provide legal, compliance or other advisory services;

3.2 Marketing and public relations services

These providers have limited access only to the information necessary to perform the activities for which they were contracted on our behalf and are contractually obliged to protect them and use them only for the purposes for which they were disclosed in compliance with Data Protection and Political Confidentiality.

3.3. With other financial institutions, which have been contracted to enable us to supply effectively

Malta Business to our customers:

These financial institutions may use this information only to enable us to provide you with the wide range of payment services. They can be:

  • Correspondent banks for the purpose of liquidation of money transfers and foreign exchange transactions;
  • National payment schemes for the purpose of managing national payments;
  • International payment schemes for the purpose of processing euro payments (SEPA);
  • Card companies for the purpose of issuing and purchasing cards;
  • Financial institutions

3.4. With the other parties to transactions when you use Malta Business Services, such as other Clients, merchants, and their service providers: We may share information with the other participants to your transactions, including other clients or payers/payees you are sending or receiving funds from, and merchants or their service providers when you use the Services to pay for goods or services. The information includes:

  • Personal Data necessary to facilitate the transaction;
  • Personal Data to help other participant(s) resolve disputes and detect and prevent fraud;

3.5. With other third parties for our legitimate interest or as permitted or required by law: We may share information about you with other parties for our legitimate interest or as permitted or required by law, including:

  • if we need to do so to comply with a law, legal process or regulations;
  • to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to us or our corporate family;
  • if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
  • to protect the vital interests of a person;
  • with credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes;
  • to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
  • to protect our property, Services and legal rights;
  • to facilitate a purchase or sale of all or part of our business;
  • in connection with shipping and related services for purchases made using a Service;
  • in relation to promoting Malta Business Service to end users by third party business introducers;
  • to help assess and manage risk and prevent fraud against us, our clients and fraud involving our websites, mobile apps or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals, and merchants;
  • to banking partners as required by card association rules for inclusion on their list of terminated merchants;
  • to credit reporting and collection agencies;
  • to companies that we plan to merge with or be acquired by; and
  • to support our audit, compliance, and corporate governance functions.

With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorise an account connection with a third-party account or platform.

In addition, we may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why users visit our website and services. This data will not personally identify you or provide information about your use of Malta Business Service. We do not share your Personal Data with third parties for their marketing purposes without your consent.

3.6 Aggregated Data. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

3.7 Monitoring

We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, customer services or training purposes. When visiting our offices, CCTV, access control systems and/or other monitoring systems may be in operation.

3.8 Social Media

We may review and use comments and public opinions made on social network sites (i.e. Facebook Twitter, Google +, LinkedIn, YouTube, etc.) and to better understand our customers and our supply and future development.

3.9 Business Transfers.

If any of the companies that provides Malta Business Services is involved in any merger, acquisition, reorganization, sale of assets, transfer of portfolio, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred to a different legal person and/or becomes subject to a different privacy policy.

4. YOUR RIGHTS

You may exercise any of the rights described in this section before the respective Data Controller pursuant to the Legal Agreements by sending an email from your e-mail registered for Malta Business Service to the respective Company providing the Service to you under the respective Legal Agreement stated below. Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws.

4.1 Managing Your Information.

You have the right to obtain the following:

    • Confirmation of whether, and where, the we are processing your personal data;
    • Information about the purposes of the processing;
    • Information about the categories of data being processed;
    • Information about the categories of recipients with whom the data may be shared;
    • Information about the period for which the data will be stored (or the criteria used to determine that period);
    • Information about the existence of the rights to erasure, to rectification, to restriction of processing and to object to processing;
    • Information about the existence of the right to complain to any Regulator;
    • Where the data was not collected from you, information as to the source of the data; and

information about the existence of, and an explanation of the logic involved in, any automated processing.

  • Additionally, you may request a copy of the personal data being processed.

4.2 Correction of incorrect or incomplete information.

You have the right to ask us to correct any inaccurate or incomplete personal information concerning you (which you can’t correct or update yourself via your direct access to your Online account).

4.3 Data Access and Portability.

You have the right to:

  • receive a copy of your personal data in a structured, commonly used, machine-readable format that supports re-use;
  • transfer your personal data from one controller to another;
  • store your personal data for further personal use on a private device; and
  • have your personal data transmitted directly between controllers without hindrance.

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.

4.4 Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our regulatory obligations. If you no longer want us to use your information to provide Malta Business Service to you, you can request that we erase your personal information and close your Online Account, providing your account is in good standing, not blocked or somehow limited for compliance, risk or regulatory reasons, or due to your outstanding obligation to us, court order, pledge or order by another regulator or other reason which prevent us by law to close your account or terminate the Service. In case the Data Controller is a regulated financial institution, such as credit institution, E-money institution or similar, such Data Controller is obliged under PSD and AML laws to keep your personal information and all transactions history for a period of 5 years after the termination of the relation with you. Please note that if you request the erasure of your personal information:

  • We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing security. For example, if we suspend an Online Account for fraud or safety reasons, we may retain certain information from that online Account to prevent that client from opening a new online Account in the future. We are also obliged to retain personal data which we have collected for the purposes of complying with the relevant anti-money laundering and anti-terrorism financing for a period as defined under the applicable law.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Malta Business may keep some of your information for tax, legal reporting and auditing obligations.
  • Because we maintain the Malta Business to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

4.5 Withdrawing Consent and Restriction of Processing.

Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where
(i) you contest the accuracy of your personal information;
(ii) the processing is unlawful and you oppose the erasure of your personal information;
(iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or
(iv) you have objected to the processing and pending the verification whether our legitimate grounds override your own.

4.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling for marketing purposes) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims. Please note that Data Controllers which are regulated financial institutions, such as credit institutions, E-money institutions or similar are obliged under AML laws to make risk profiling of their customers upon opening of the relationship and constantly during the relationship and this is a legitimate reason. In case you do not wish us to process your personal data for certain specific purposes, which are legitimate purposes to us, you shall have to close your account or we may have to stop providing you some or all of the Services, subject to all conditions for the closing of the account, specified above in this Section.

Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to the contact e-mails below.

4.7  Complaints.

4.7.1. You should in first place try to resolve the matter by sending an e-mail to the respective Data Controller under this Privacy Policy from your registered e-mail for the Service:

  • Where the responsible Data Controller (as outlined in the introduction of the Privacy Policy) is specified to be Em@ney p.l.c., Malta, you may contact us at:
    Data Protection Officer (DPO): Francesco Maresca – dpo@emoneyplc.com
  • Where the responsible Data Controller (as outlined in the introduction of the Privacy Policy) is specified to be Malta Bsuiness, you may contact us at:
    Data Protection Officer (DPO):
    dpo@maltabusinesscards.com Consorzio Euromed International Trade Oversea

In the event that the user is not satisfied with the response or resolution of the respective Data Controller, he/she has the right to complain about the data processing activities we perform in front of the competent data protection supervisory authorities as mentioned below.

If the Data Controller is responsible for the respective processing of the data, he has the right to file a complaint with his principal supervisory authority, the Commissioner for the Protection of Information and Data Protection: Address: Level 2, Airways House High Street Sliema SLM 1549 Malta Tel: +356 23 28 7100 e-mail: idpc.info@idpc.org.mt

COMFORT ECC Domain Validation

We limit access to personally identifiable information only to employees or partner who need to know such information in order to provide products or services to the user.

If you know or have reason to believe that your online account credentials have been lost, stolen or otherwise compromised or in the event of unauthorized or suspected use of your account, please contact Em@ney Plc while we are committed to protecting our systems and services, you are responsible for safeguarding and protecting the privacy of your passwords and online account / profile registration information and verifying that the personal information we process is correct and up-to-date.

8. Can Children Use Our Services?

Malta Business Services are not designed to individuals under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use Malta Business service. If we obtain actual knowledge that we have collected Personal Data from an individual under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under the age of 18.

9. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on Malta Business cards Platform. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of Malta Business cards Platform will be subject to the revised Privacy Policy.

10. CONTACT US

If you have any questions or complaints about this Privacy Policy or our information handling practices, you may email us from your registered e-mail for the Services to the e-mails stated above in Section 4.

 

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