1. Introduction

By:

• Visiting Hudson Holdings Ltd’s (“Hudson”) official website (“the Website”) at <https://hudson.com.mt>; or
• Applying for a job through the Careers section; or
• Sending us a request through the Contact Us form; or
• Signing up to check the balance on your Hudson Coin;

you provide us with your personal data.

“Personal data” means any information relating to an identified or identifiable natural person

Hudson is committed to protecting the privacy and security of your personal information.

This privacy notice describes how Hudson collects and uses personal information about you, in accordance with data protection laws.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

2. Data Controller and processor

The Data Controller refers to Hudson. This means that Hudson is responsible for deciding how it holds and uses personal information about you. Hudson is required under data protection legislation to notify you of the information contained in this privacy notice. Hudson is also the owner and registrant of the Website.

A Data Processor (“Processor/s”), i.e. an entity which processes the personal data on behalf of the Controller. Below is a list of Processors that the Controller engages in connection with the Website:

The relationship between the Controller and its Processors are formalized concluding a Data Processing Agreement.

3. Information Hudson collects

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

1. Your IP Address;
2. Cookies (please refer to our Cookie Policy for more information)
3. Browser information (including language settings) and device used;
4. Your location (as per your IP address);
5. Your screen resolution;
6. The average time you spend on each webpage part of the Website;
7. Your age and gender (if you visit the Website while logged into you Google account).

The Website visitor data is anonymised.

For more information on how we handle your personal data relating to your recruitment process, kindly refer to Section 5 on Recruitment.

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

1. Your name;
2. The name of your company (if provided);

• Your contact number;

1. Your email address;
2. The items of personal data that you may include in the free-text box.

When you sign up to check the balance on your Hudson Coin, we collect the following information (“Hudson Coin information”):

1. Your name; and
2. Your email address.

• Serial Number of the Hudson Coin

4. Competitions

By entering our competitions and promotions, you are asked to fill out a registration and consent form where you agree to provide us with your personal data.

We collect your data to be able to identify and contact you as a member of our competitions and promotions. We also use your data to keep you informed about our promotions and offers.

Section 10 applies to you only if you are a resident of the European Economic Area (“EEA”), together with the Terms and Conditions of each competition, which govern your relationship with Hudson with regards to our competitions and promotions.

4.1. Information collected for Competitions

When you fill out a form to take part to any of our competition or promotion, we collect the following personal information about you (“the Competitor Data”):

1. Name and Last Name;
2. Date of birth;

• Email address;

1. Mobile number.

Personal data is collected based on your consent, for the purpose of participation in the competitions and subsequent selection of the competition’s winner/s and  is processed according to the legal basis identified below.

5.    Recruitment

The Recruitment Data may be used to communicate with applicant, to manage Hudson’s recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If an applicant is hired, the Recruitment Data may be used in connection with employment and corporate management and will be subject to Hudson’s Privacy Policy.

Hudson does not request or require special categories of information concerning religion, health, sexual orientation, trade union membership, genetic data, biometric data (including fingerprint) or political affiliation in connection with recruiting. If the applicant has a disability and would like Hudson to consider he/she may provide that information during the recruiting process. Further information on an applicant’s nationality may be needed in order to confirm whether Hudson would need to apply for a residence permit in their respect. Hudson does not otherwise require applicants to provide race or ethnicity information, and if an applicant provides this information, it will not be viewable in the hiring or selection process.

An Applicant is responsible for the information he/she provides or makes available to Hudson and must ensure it is honest, truthful, accurate and not misleading in any way. Further, if an applicant provides any information concerning any other person, such as individuals they provide as references, they are responsible for providing any notices and obtaining any consents necessary for Hudson to collect and use that information as described in this policy.

Applicants should retain their own copy of any information submitted to us.

6. Purposes and Legal Basis for Collecting Data

Personal data, as listed in Section 3 above is only collected for specific, explicitly stated and legitimate purposes and is processed according to the legal basis identified below

7. Recipients of personal data

Your personal data may be shared between the undertakings forming part of the Hudson Group, as foreseen by Recital 48 of GDPR.

5.2  Your personal data may be also shared between the Controller and the Processors.

Your personal data may be transferred outside of the European Economic Area (EEA) or to international organizations. If we do, you can expect a similar degree of protection in respect of your personal information.

We do not sell, trade or otherwise transfer any personal information to third parties.We also regularly review and, where practicable, improve upon these security measures.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

While we do our utmost to safeguard your personal data, no data transmission over the internet can be totally secure and therefore we cannot guarantee or warrant that no unauthorised access will occur.

8. Data Retention

Personal data is not kept for a period longer than is necessary, having regard to the purposes for which they are processed. We may also need to keep some of your personal data where we are obliged to do so in terms of legal or regulatory requirements, or in order to protect ourselves against legal claims, or to enforce our company terms and conditions.

Retention period for each category of data are identified below.

We keep your data as long as your consent is valid and effective.

Once you decide to opt-out, we delete your data in full. We may need to keep some of your personal data where we are obliged to do so in terms of legal or regulatory requirements, or in order to protect ourselves against legal claims, or to enforce our company terms and conditions.

We do our best to store your data securely and protect it against unauthorised access and leakage.

9.    Your Rights

As a website visitor, job applicant or information enquirer, 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 or the Processor by email, by post or by phone using the contact details provided above.

You are guaranteed a response within 30 days from the date of receipt of your enquiry.

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 provided no later than 2 months from the date of receipt of your enquiry. This 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 you request the information on paper and posted. In that case, we will charge you the postage fees.

Should we have reasonable doubts concerning your identity when making the request above, we may require additional information, necessary to confirm your identity.

Your rights are:

9.1.

In order to process this request, we will require proof of your identity. You may obtain confirmation from us as to whether or not your personal data is being processed including:

1. the purposes of the processing;
2. the categories of personal data concerned;

• the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

1. the existence of the right to request from the Controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
2. the right to lodge a complaint with the supervisory authority;
3. the existence of automated decision-making, including profiling.

9.2. Rectification

In case your date is inaccurate, incomplete or out-of-date, you have the right to rectify it.

9.3. Deletion (“the right to be forgotten”)

You have the right to have your personal data erased in case:

1. the data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
2. You have withdrawn consent to process your data and there is no other legal basis legitimating its processing;

• You have objected to processing your data and there is no other legal basis legitimating its processing;

1. Your personal data has been unlawfully processed;

Your personal data has to be erased in order to ensure compliance with any  legal obligations arising from any legislation enacted within the EU or any member states.

This right is not absolute, and we may be justified in keeping certain personal data, for instance when we are legally obliged to do so or if such data may be necessary for us to defend a legal claim.

9.4. Restriction

You have the right to request a restriction on the processing of your data in case:

1. You contest the accuracy of your personal data, for a period enabling us to verify the accuracy of such data;
2. The processing of your data is unlawful, and you oppose the erasure of your personal data and request the restriction of their use instead;

• We no longer need the personal data for the purposes of the processing;

1. We no longer need your data, but we are required by you to retain the data for the establishment, exercise or defence of legal claims;
2. You have objected to processing (as specified in detail below), pending the verification whether our legitimate grounds override yours.

When you restrict processing, your personal data will, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

In case you have obtained restriction of processing as per above, we will inform you before the restriction of processing is lifted.

9.5. Complaint

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 Information and Data Protection Commissioner in Malta if you consider that your personal data has been processed unlawfully:

Information and Data Protection Commissioner

Level 2, Airways House

High Street

Sliema SLM 1549

Malta

Tel: (+356) 2328 7100

Email: [email protected]

9.6. Data Portability

You enjoy a right to data portability with respect to your Personal Data held by Hudson and Hudson hereby binds itself to provide you with the Personal Data concerning yourself which you have provided to the Hudson, in a structured, commonly used and machine-readable format. In addition, you enjoy the right to transmit that data to another data controller without hindrance from Hudson.

9.7. Right to Object

You have the right to object to the processing of your personal data in cases where the legal basis of such processing is that of legitimate interest. If you choose to do so, Hudson shall no longer process the personal data unless the it can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

9.8. Right to Withdraw Consent

Where we rely on your consent for processing personal data (such as in the case of marketing, or when you sign up to get updates about your Hudson Coin), you have the right to withdraw such consent at any time. Once you withdraw consent, we will stop processing your personal data.

10. Cookies and other tracking mechanisms

Like most online platforms, Hudson uses cookies to collect information. Cookies are small data files of letters and numbers that are stored in your browser or the hard drive of your computer and contain information that is transferred to your computer’s hard drive. We use cookies on our website to improve its functionality and to allow us to constantly improve the website. When you continue to browse this website, you are agreeing to our use of cookies.

We use cookies as follows:

10.1.    How to control cookies

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. We require your consent for non-essential cookies, which is acquired by ticking the pop-up box upon accessing the website.

Most web browsers today allow you to control cookies through the settings and preferences of your browser of choice. It is possible for you to disable cookies or set your browser to alert you when cookies are being sent. The website supports your right to block any unwanted Internet activity, especially from unscrupulous websites. You can delete all cookies that are already on your computer, and you can set your browser to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site, and some services and functionalities may not work.

Keep in mind, however, that blocking all cookies or even some of them will have a negative impact on the usability and rendering of many websites, including our website. If you block cookies, you will not be able to use all the features on the website and might not be able to view it correctly in the way it was originally intended to be displayed.

Furthermore, if you wish to change your cookie preferences with regards to our websites, please click here.

11. Amendments

This Privacy Policy is subject to changes. You are invited to familiarize with its content and visit this URL frequently to familiarize with the changes.

12. Applicable Law

The law applicable to the processing activities, and to this policy, shall be:

• The Data Protection Act, Chapter 586 of the Laws of Malta and any other subsidiary legislation
• Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or GDPR)

13. Amendments

This Privacy Policy is subject to changes. You are invited to familiarize with its content and visit this URL frequently to familiarize with the changes.

14. Hudson Privilege Club

Hudson welcomes loyal customers to join its Privilege Scheme, for which they can redeem discounts and other privileges. A full list of terms and conditions, can be found here.