The Controller is Righthere Company Limited (“Righthere”, “Keepmeposted”, “we”, “our”, or “us”) which is a company incorporated in Malta with registration number C 53432 and with registered offices at 10, Triq it-Trinkatur, Mosta, MST 1812, Malta.

We are committed to protecting and respecting your privacy as a visitor to our website. To better protect such rights, we are providing this Privacy Policy, explaining our information practices and the choices that you can make about the way in which we collect and further process your personal information. Please be informed that by providing us with your personal information, you signify that you consent to us processing such personal data in accordance with this Privacy Policy. We will treat such information in strict confidence in accordance with the requirements of the provisions of the Data Protection Act and any other relevant legislation. For this purpose, we kindly invite you to read the following information so that you will be better guided as to how we will use and protect your personal information.

Definitions

For the sake of clarity, the following terms shall be interpreted in the following manner for the purpose of this Privacy policy:

“Job Seeker” means any person who registers to create an account on our website to receive our mailshot service for a job vacancy by signing up on our website.

“Client” means any person using and purchasing the mailshot service by email where a person includes but is not limited to, direct employers, recruitment agencies, recruitment process outsourcing agencies and advertising agencies.

Furthermore, the terms “You”, “Your”, “Yourself” means the User of the Website.

Information We Collect

When you visit the website, we collect the following information about you (“Website visitor data”):

• Your IP Address;
• Cookies (please refer to the “Cookies” section below);
• The date and time when you accessed the site;
• The details of the requested webpage and/or download; and
• Whether your request was successful or not.

When you visit the website to find a job or to post a vacancy, you may voluntarily choose to provide us with personal information if you complete and submit any of the forms that may from time to time be available on our website. If at any time you would like to change any of the information you sent us or uploaded, you can do so by logging in to your account and changing your details. This will enable us to contact you to provide you with the feedback or service which you have requested. We shall process this personal information in order to provide you with the particular service you request when completing these forms such as informing Job Seekers of any vacancies, providing Clients with business terms and responding to any enquiries that you may make. (“Job Seeker Data”).

When you send us a message through the Contact Us form, we collect the following information (“Information Enquirer Data”):

• Your name;
• Your phone number;
• Your email address; and
• The items of personal data that you may include in the free-text box.

When you visit and browse through our website, you can do so without telling us who you are and/or revealing any other information about yourself.  When you send us your details for a job or for prospective jobs that you may be suited to, we may use social media platforms to search for you.

Marketing material that we send to our Clients

If you, as our Client, have given your consent, as a result of opting-in, we use the information that we collect to send you marketing material. Please inform us by sending an email to [email protected] if you do not wish to receive any such direct marketing material.

We will not send marketing material to Job Seekers, website visitors and enquirers.

Purposes and Legal Basis for Data Collection:

Website Visitor Data
Purpose(s)
– Improve the content and functionality of our website;
– Better understand the categories of visitors to our website;
– Improve our products services.

Legitimate Interest
Is there a legitimate interest behind the processing?
Yes, we have a legitimate interest to understand the category of visitors to our website and the visitors/users have an interest in having the best possible experience by visiting the website.

Job Seeker Data
Purpose(s)
-To create an account for Job Seekers in order to provide the service they have subscribed for, namely sending them mailshots about job vacancies;
-Internal risk assessment purposes, internal management, research and statistics, systems administration and the development and improvement of our products and services;
-The protection and promotion of our legitimate interests and the proper conduct of our business;
-As may be allowed or required by or under any law.

Legitimate Interest
Is there a legitimate interest behind the processing?
Yes, we have a legitimate interest to understand the category of visitors to our website and the visitors/users have an interest in having the best possible experience by visiting the website.

Information Enquirer Data
Purpose(s)
-Respond to information requests

Legitimate Interest
Is there a legitimate interest behind the processing?
Yes, we have a legitimate interest to create and maintain a professional relationship with any member of the public enquiring information from us.

Cookies
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 store it 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.

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.

Should you wish to reject all or certain cookies used by our website, you may modify your web browser preferences to do so. If however, you reject all cookies then you might be unable to use some of the services available on our website. Moreover, you may set your browser to notify you when you receive a cookie, giving you the opportunity to choose whether or not you wish to accept it. Usually, the information on how to change your options regarding cookies can be obtained by referring to your operating systems manual or to the ‘Help’ section of your web browser, or by contacting your Internet Service Provider.

Disclosure of your Personal Data

We may have to grant access to, disclose, or share your personal data with our employees for the purposes set out in the Section on “Purposes and Legal Basis for Data Collection” above.

Data Retention
Personal data is not kept for a period longer than is necessary, having regard to the purposes for which they are processed. Retention Periods for each category are identified below.

Website Visitor Data
Data is retained for 12 months from the date of collection.

Job Seeker Data
Data is retained for 48 months from the date of collection.

Information Enquirer Data
Data is retained for 12 months from the date of collection.

Your Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.       
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
• Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
• Right to complain. The individual also has the right to lodge a complaint with the Information and Data Protection Commissioner in Malta as the data protection supervisory authority:

Information and Data Protection Commissioner
Level 2, Airways House
High Street
Sliema SLM 1549
Malta

Tel: (+356) 23287100

Email: [email protected]

Security

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 visitors’ personal data.

By its very nature, however, the Internet is not a secure medium and data sent via this medium can potentially be subject to unauthorised acts by third parties.  We cannot guarantee the privacy or confidentiality of any information passing over our website.

Moreover, 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.  We shall accept no responsibility or liability whatsoever for the security of your data while in transit through the Internet.

Changes to the Privacy Policy

We reserve the right to update this Privacy Policy at any time.  It is in your own interest to check this page any time you access our website so as to be aware of any amendments which may have been made.

Support

If you have an enquiry or concern about our Privacy Policy, please contact us at:

Righthere Company Limited
Centris Business Gateway, Level M, Triq Il-Palazz L-Ahmar, Mriehel, Malta
Phone Number: (+356) 2142 3737
Email: [email protected]

This version was last updated during the month May, 2018.