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Privacy

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Last updated: 21 May 2018

1. INTRODUCTION

By:

  • Visiting Hudson Holdings LTD (“Hudson”) official website (“the Website”) at https://hudson.com.mt;
  • Applying for a job through the Careers section;
  • Sending us a request through the Contact Us form;

you provide us with your personal data.

Personal data, due its sensitive nature, shall be processed within the terms of Law.

The aim of this policy is to inform you about:

  • The Controller and Processor of your personal data;
  • The purposes and legal basis for the collection of such data;
  • The recipients of your such data;
  • The retention period of such data;
  • Your rights in relation to personal data.

We have tried to keep this policy as simple and plain as possible. However, if  any part is  unclear to you, contact us at privacy@hudson.com.mt and we will respond to your query  in due time and clarify any doubt you may have.

2. DATA CONTROLLER AND PROCESSOR

The Data Controller (“the Controller”), i.e. the entity who determines the purposes and means of data processing, is Hudson Holdings LTD, company incorporated in Malta with offices at Hudson House, Burmarrad Road, Burmarrad, SPB9061, Malta. The Controller is reachable at: privacy@hudson.com.mt or +356 2147 2790.

The Controller is also the owner and registrant of the Website.

The Data Processor (“the Processor”), i.e. the entity who processes the data on the behalf of the Controller, is Ipoint LTD, company incorporated in Malta with offices at 4, Sylvienne’s Crt,Triq Ic – Cirasa, San Gwann. The Processor is reachable at info@ipoint.com.mt or +356 21 384 308;

The relationship between the Controller and the Processor has been formalized concluding a Data Sharing Agreement, pursuant to art. 28 GDPR.

3. INFORMATION WE COLLECT

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

  • (i) Your IP Address;
  • (ii) Cookies (please refer to our Cookie Policy for more information);
  • (iii) Browser information (including language settings) and device used;
  • (iv) Your location (as per your IP address);
  • (v) Your screen resolution;
  • (vi) Average time you spend on each webpage part of the Website;
  • (vii) You age and gender (if you visit the Website while logged into you Google account).

The Website visitor data is anonymised.

3.2 When you apply for a job through the Careers section of the Website, we collect the following information about you (“job applicant data”):

  • (i) Your name and surname;
  • (ii) The name of your company (if provided);
  • (iii) Your contact number;
  • (iv) Your email address;
  • (v) Your CV;
  • (vi) The items of personal data that you may include in the free-text box.

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

  • (i) Your name;
  • (ii) The name of your company (if provided);
  • (iii) Your contact number;
  • (iv) Your email address;
  • (v) The items of personal data that you may include in the free-text box.

4. PURPOSES AND LEGAL BASIS FOR COLLECTING DATA

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

Categories of personal data Purpose(s) Legal basis
Website visitor data –  Improve the content and functionality of our website;

–  Better understand the categories of visitors to our Website,

–  Improve our products and services.

Legitimate interest
Purpose – is there a legitimate interest behind the processing?

YES, Hudson has a legitimate interest to understand the category of visitors to the Website and the visitors/users have interest in having the best possible experience by visiting the Website.

Necessity – is the processing necessary for that purpose?

YES, Hudson could not achieve the same purposes without collecting such data.

Balancing – is the legitimate interest overridden by the individual’s interests, rights or freedoms?

NO, individual’s interests, rights or freedoms are not overridden by collecting personal data of the subject.

Job applicant data Recruitment and selection of candidates Legitimate interest
Purpose – is there a legitimate interest behind the processing?

YES, Hudson has legitimate interest to collect personal data to find suitable candidates for the vacant positions advertised on the Website, and the applicants/jobseekers have interest in their applications being considered and examined by Hudson.

Necessity – is the processing necessary for that purpose?

YES, Hudson need some items of personal data of the applicants in the recruitment process. The same purpose, being recruitment and selection of suitable candidates, cannot be achieved without the collection of personal data of the applicant.

Balancing – is the legitimate interest overridden by the individual’s interests, rights or freedoms?

NO, individual’s interests, rights or freedoms are not overridden by collecting personal data of the subject

Information enquirer data Respond to information requests Legitimate interest
Purpose – is there a legitimate interest behind the processing?

YES, we have a legitimate interest to create and maintain professional relationship with any member of the public enquiring information from us.

Necessity – is the processing necessary for that purpose?

YES, personal data is necessary to respond to the enquirer

Balancing is the legitimate interest overridden by the individual’s interests, rights or freedoms?

NO, individual’s interests, rights or freedoms are not overridden by collecting personal data of the subject.

5. RECIPIENTS OF PERSONAL DATA

5.1  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 Processor.

5.3  Your personal data is never transferred outside of the European Economic Area (EEA) or to international organizations.

5.4  We do not sell, trade or otherwise transfer any personal information to third parties.

5.5  We will release your data if we are obliged to do so to comply with any law, regulation or court order.

6. 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 period for each category of data are identified below.

Categories of personal data Retention period
Website visitor data Data is retained for 25 months from the date of collection.
Job applicant data Data is retained for 3 months from the date of the application, which is the maximum duration of the recruitment process.

An email acknowledging receipt of the application is send to the applicant with a link to this Policy.

Once the recruitment process is over, we may ask you if you would like us to retain your application for further three months. We will do so only if you positively opt-in.

Information enquirer data Data is retained only for the time necessary to process a response to the enquiry.

Once this is completed, the enquirer data is deleted.

7. YOUR RIGHTS

7.1 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 month 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:

  • (i)  Your requests are manifestly unfounded or excessive, in particular because of their repetitive character. In this case we will charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested. In this case, we may also refuse to act on the request after having explained our position;
  • (ii) 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:

7.2  Access

You may obtain confirmation from us as to whether or not your personal data is being processed including:

  • (i)  the purposes of the processing;
  • (ii)  the categories of personal data concerned;
  • (iii)  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;
  • (iv)  where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • (v)  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;
  • (vi)  the right to lodge a complaint with the supervisory authority;
  • (vii)  the existence of automated decision-making, including profiling.

7.3  Rectification

In case your date 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:

  • (i)  the data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
  • (ii)  You have withdrawn consent to process your data and there is no other legal basis legitimating its processing;
  • (iii) You have objected to processing your data and there is no other legal basis legitimating its processing;
  • (iv) Your personal data has been unlawfully processed;
  • (v)  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.

7.5 Restriction

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

  • (i)  You contest the accuracy of your personal data, for a period enabling us to verify the accuracy of such data;
  • (ii)  The processing of your data is unlawful, and you oppose the erasure of your personal data and request the restriction of their use instead;
  • (iii)  We no longer need the personal data for the purposes of the processing;
  • (iv)  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;
  • (v)  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.

7.6 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 competent supervisory authority if you consider that your personal data has been processed unlawfully.

7.7 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.

8. APPLICABLE 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”).

9. 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.

Last updated: 20 September 2018

  1. INTRODUCTION

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.

The aim of this policy is to inform you in simple terms about the identity of the controller of your data, what information we collect, how long we keep it and about your rights in relation to data protection.

We have tried to keep this policy as simple and plain as possible. However, if any part is unclear to you, contact us at privacy@hudson.com.mt and we will respond to your query in due time and clarify any doubt you may have.

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

  1. DATA CONTROLLER

The Data Controller (“the Controller”), i.e. the entity who determines the purposes and means of data processing, is Hudson Holdings Ltd, company incorporated in Malta with offices at Hudson House, Burmarrad Road, Burmarrad, SPB9060, Malta. The Controller is reachable at: privacy@hudson.com.mt or +356 2147 2790.

  1. INFORMATION WE COLLECT

3.1 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”):

i) Name and Last Name;

ii) Date of birth;

iii) Email address;

iv) Mobile number.

  1. PURPOSES AND LEGAL BASIS

Personal data is collected for specific, explicitly stated and legitimate purposes and it is processed according to the legal basis identified below.

Categories of personal data Purpose(s) Legal basis
i) Name and Last Name Management of the competition – identification of members.

Keep you informed and send you marketing communications about our latest promotions and offers.

Consent
ii) Date of birth Verify your age as legal requirement to enter the competition Consent
iii) Email address Management of the competition – Establish contact with members (if needed)

Keep you informed and send you marketing communications about our latest promotions and offers.

Consent
iv) Mobile number Management of the competition – Establish contact with members (if needed)

Keep you informed and send you marketing communications about our latest promotions and offers.

Consent
  1. RECIPIENTS OF PERSONAL DATA

5.1  Your personal data may be shared between the undertakings forming part of the Hudson Group.

5.2  Your personal data is never transferred outside of EEA or to international organizations.

5.3 We do not sell, trade or otherwise transfer any personal information to third parties.

5.4 We will release your data if we are obliged to do so to comply with any law, regulation or court order.

  1. DATA RETENTION AND STORAGE

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

  1. YOUR RIGHTS

7.1 As a competitor, 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.

You are guaranteed a response within 30 days month 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:

  • (i)  Your requests are manifestly unfounded or excessive, in particular because of their repetitive character. In this case we will charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested. In this case, we may also refuse to act on the request after having explained our position;
  • (ii) 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:

7.2 Access

You may obtain confirmation from us as to whether or not your personal data is being processed including:

  • (i)  the purposes of the processing;
  • (ii) the categories of personal data concerned;
  • (iii) 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;
  • (iv) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • (v) 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;
  • (vi) the right to lodge a complaint with the supervisory authority;
  • (vii) the existence of automated decision-making, including profiling.

7.3 Rectification

In case your date 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:

  • (i) the data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
  • (ii) You have withdrawn consent to process your data and there is no other legal basis legitimating its processing;
  • (iii) You have objected to processing your data and there is no other legal basis legitimating its processing;
  • (iv) Your personal data has been unlawfully processed;
  • (v) 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 state.

7.5 Restriction

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

  • (i) You contest the accuracy of your personal data, for a period enabling us to verify the accuracy of such data;
  • (ii) The processing of your data is unlawful, and you oppose the erasure of your personal data and request the restriction of their use instead;
  • (iii) We no longer need the personal data for the purposes of the processing;
  • (iv) 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;
  • (v) 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 EU 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.

7.6 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.

7.7 Withdrawal of consent

You have the right to withdraw consent at any time by contact us using the details given above.

The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

7.8 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 competent supervisory authority if you consider that your personal data has been processed unlawfully.

  1. APPLICABLE 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”).

  1. 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.