Privacy Policy

We are committed to protecting and respecting your personal information privacy.

Last updated: February 8, 2022

This Privacy Policy (hereinafter referred to as "Privacy Policy") applies to the website or any subsidiary website or related domains (hereinafter referred to as "website" or "site"), services provided (by the Site owner and operator), and any related software applications ("Applications") in which your personal data is processed (through the Site, any of Our applications or otherwise).

This Privacy Policy is issued on behalf of affiliated entities, therefore, when this Privacy Policy mentions the pronouns "We", "Us" or "Our", we mean the relevant organization responsible for processing your data. We will provide information about which organization operates personal data when a client uses any of our services. In certain cases, when a client's personal data is provided, stored and processed by us in countries where additional local data protection laws apply, our clients may refer to the relevant jurisdiction below for additional information about the relevant local data protection laws regarding the privacy policy notice.

In the Privacy Policy, the words "You", "Your" and "User" refer to an identified or identifiable natural person who is a User of the Site and/or a client (or potential client) - recipient of any of Our Services. Complete information, including contact details, can be read below.

This Policy describes the ways in which [Your Company] processes information and personal data that you have provided to us, and which allows us to effectively manage your relationship with us.

1. Purpose of this Privacy Policy

We respect and value the privacy of our clients. We do not sell, transfer or otherwise provide to third parties any information about any person visiting our Website, except as expressly provided in this Privacy Policy.

• Designation of the type of personal data we collect about clients and how we use Your personal information.
• Designation of the basis on which we process any personal data.
• Bringing to Your attention information about how we process your personal data,
• Explanation of the obligation in accordance with data protection provisions regarding legal and responsible processing of our clients' personal data.
• Informing you about your data protection rights

2. Legal Issues of Personal Data Processing

All Personal Data Processing carried out by us is conducted in accordance with this Privacy Policy, and:

• The Malta Data Protection Act (hereinafter referred to as "DPA" - Chapter 586 of the Laws of Malta), as well as any other subsidiary legislation issued under the DPA, which may be amended and changed from time to time;
• 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 - hereinafter referred to as "Regulation" or "GDPR").

We comply with local data protection laws in jurisdictions where we operate.

This Privacy Policy should be considered in conjunction with our Cookie Policy and any other privacy notices that We may provide in certain cases when we collect or process personal data about you for the purpose of full awareness of how and why we use your data.

3. Data Controller

ADMIN Malta Limited (company registration number C 806082), Malta, is the data processing controller and is responsible for this website.

We control personal data that we collect or receive and process in the course of providing our services and/or operating the website. Our affiliated legal entities may become data controllers, both jointly and as separate data controllers.

4. Personal Data Received from our Users

Personal data or personal information is any information about a natural person by which that person can be identified. Personal data does not include information where there is no mention of identity (anonymous data). Our website is structured so that our users can access our site on the Internet without identifying themselves and without disclosing any personal information. However, if you choose to provide us with personal information, We ensure the protection of this information and use it only in the ways described below.

We collect and process the following personal data about you:

• Identification data, including name, maiden name, married name, title, ID number, gender, nationality, employment status, organization, occupation, email address and phone number.

If you use our services or apply for a position, additional information may be required. If you are a user of our services, we may also need additional information before we enter into a commercial relationship with you.

We may also request information that may be required to establish your identity and serve as proof of your identity, such as copies of your passport or national ID. If you are a job applicant, you will need to provide a copy of your current resume.

If we need to obtain certain personal data in accordance with legal requirements or in accordance with the terms of a contract concluded with you, and you cannot provide this data upon request, this makes it impossible to provide the service in accordance with the agreement or impossible to conclude a contract with you, but we will inform you about this in advance. As a result of the inability to provide certain data, it may be necessary to terminate the contractual relationship with you.

b) Contact Details

Contact details include payment address, mailing address, email address and phone numbers for communication.

c) Compliance Data (AML and KYC)

Compliance data (AML and KYC) includes the following information and documentation relating to checks carried out in respect of Our clients or their representatives, shareholders, founders, beneficiaries, directors, if the client is a legal entity: copy of identity document, "KYC" due diligence report (databases) and any other documentation that may be required from time to time by the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta) ("PMLA"), Prevention of Money Laundering and Funding of Terrorism Regulations ("PMLFTR"), Financial Intelligence Analysis Unit ("FIAU") and/or at the request of any other competent authority or relevant legislation.

d) Supporting Data

• Current position of the client, plans, interests, goals or objectives;
• Services requested and provided to the client.

e) Financial Data

Financial data includes the client's bank account details and information about any payment methods used by the client to pay Our invoices, and, if required in specific circumstances, the client's financial position and creditworthiness.

f) Transaction Data

Transaction data includes detailed information about invoices issued to the client (including payment date and payment methods), payments to and from the client, and any unpaid invoices due to the client.

g) Technical Data

Technical data includes Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other information about Your experience with the Website, such as page response time, loading errors, duration of visits to certain pages, page interaction information (such as scrolling, clicks and mouse hovering) and methods used to navigate away from pages.

Location information: we may receive information about your location and can determine your location by your IP address, and when accessing the website through a mobile device, using data that we collect from that device. This includes information about wireless networks or cell towers near your mobile device at the time of access.

Our website uses cookies to distinguish you from other users of our website. This helps us provide quality viewing format of our website, and allows us to improve our site. For detailed information about the cookies we use and the purposes for which we use them, see our cookie policy.

h) Marketing and Communication Data

Marketing and communication data - your preferences in receiving promotional materials from us and our third parties or related persons, as well as preferences regarding communication methods. This may be information about whether you have subscribed to any of our newsletters or unsubscribed, whether you have attended any of our events or accepted any of our invitations.

We also collect, use and process any other personal information that you voluntarily provide or disclose to us in cases where this is appropriate and necessary for providing services that you have requested from us.

5. How Your Personal Data is Collected

Personal data may be provided by you in the following cases:

• Filling out a request form on the site,
• Correspondence with us by mail, telephone conversations, email or otherwise during the application for our services,
• Subscription to our services or publications,
• Request for a quote to be sent to you,
• Feedback about our services,
• Starting negotiations or concluding a contract.
• Whenever you visit our website, we automatically collect technical data.
• We may also receive personal data of our visitors from various third parties and public sources (Google Analytics advertising features, including Google AdWords, Facebook Pixel, Google Tag Manager, LinkedIn and other special paid media partnerships).
• Identification, contact and reference data from public sources, verification databases, and/or data service providers obtained as a result of checks, in the EU and beyond, so that we can ensure that you are a suitable client or supplier for us.

6. How We Use Your Personal Data

We use personal data:

• To simplify the format of providing requested services under a contract that we enter into or have entered into with you,
• When required by our legitimate interests (or interests of third parties) and when your interests and rights do not have precedence over these interests,
• When necessary to comply with legal or regulatory obligations,
• To resolve any issues you report and to provide support-related services,
• To manage our relationship with you as a supplier,
• To administer our website and internal operations, including troubleshooting, and to ensure the security of our site,
• To improve our website performance to ensure the most effective presentation of content for you,
• To ensure that all information on the site is presented in a user-friendly format.

7. Legal Basis for Data Processing

We process your personal data only to the extent necessary for us to provide our services, and/or for the purposes specified in this Privacy Policy.

We may also process your personal data based on any legitimate interests or to fulfill any legal obligations. These interests and obligations may include exercising or defending legal claims or complying with any court, tribunal or authority order, as well as disclosure to government or regulatory body.

Generally, we do not require separate legally certified consent to process your personal data. However, if your consent is required, we will provide you with a form requesting permission to handle personal data.

8. Marketing

At your request, you will receive promotional messages by providing us with your data through this website, and your consent to receive such information. If we have entered into a business relationship (namely, signed a contract) with you, we may inform you about our activities, offers or other information that, in our opinion, will be useful to you in accordance with our legitimate interests.

We do not transfer your personal data to third parties for marketing purposes without your consent.

You have the right to withdraw consent or unsubscribe from receiving promotional information at any time by clicking the unsubscribe button. Once you withdraw your consent or in case of objections to any of the items listed here, we will stop sending you any marketing messages. If you decide not to give consent or prefer to unsubscribe, We will be able to provide our services to the extent possible without the information that is required to implement the full range of services. This may affect the efficiency with which we provide the services you request.

9. Disclosure of Your Personal Data

We reserve the right to disclose your personal data to any of our international offices or companies that are part of our composition, which may act as joint data controllers or data operators for our company. These offices or companies become responsible controllers of your data when providing our services, and/or they provide administration, control and reporting services. All our companies respect and protect the security of your personal data in accordance with applicable law (including GDPR) and apply all measures to protect data.

We may need to transfer personal data to government institutions and authorities in the country where you plan to obtain residence or citizenship. We provide such information only to the extent necessary to provide services in accordance with our contract with you.

We may be required to provide your data to local agents or other contractors (for data processing) for the purpose of providing the services you request. These local agents and suppliers store and process your data on the basis of strict confidentiality and with appropriate security measures and guarantees.

We may also transfer your data to other third parties who perform functions of data controllers, such as legal, tax, real estate, immigration or other consultants and agents, (international) banks for payment details or third parties providing other or additional services or products to you, for example, real estate agencies, owners or developers with whom you may want to interact on separate terms. These third parties will process your data according to their own regulations, and in this case their rules and data protection processes apply.

We may also disclose or transfer your data if we are obliged to do so to fulfill any legal requirement, court decision or by order of a court, tribunal or authority. We may also disclose your data to ensure compliance with our terms of use or to protect our rights, property or safety of our partners or other users of our website. This includes exchanging information with other companies and organizations for the purposes of combating money laundering or due diligence checks, compliance with anti-bribery or corruption laws and/or protection against fraud.

10. Data Transfer to Third Countries

When we transfer your personal data to third parties, this may include transferring your data outside the EEA. We transfer your personal data in accordance with standard contractual provisions in order to guarantee that your personal data is protected and securely transferred in accordance with applicable law, including DPA.

All IMIN Malta Limited units act as data processing representatives in the EU for other units located outside the EEA. You can ask any questions and resolve issues that you may have regarding us.

11. Third Party Access to Your Personal Data

In order to provide services, we work closely with third parties. Such third parties include cloud storage providers, analytics service providers and search engine information providers. We work with third-party providers only if they comply with applicable laws in the jurisdictions in which we operate, and which follow GPL to ensure a high level of security and protection of your personal data.

12. Data Security

We take all necessary security measures against illegal or unauthorized processing of personal data, as well as against accidental loss or damage to personal data. In addition, we provide access to your personal data only to those employees, agents, service providers and other professional third parties who need to know this information. They operate your personal data strictly in accordance with our instructions and maintain confidentiality. All our employees and agents have received appropriate data protection training.

Information transfer between our website and your device is protected by Transport Layer Security (TLS) certificates. When accessing the website using compatible browsers, this technology protects personal information using both server authentication and data encryption to ensure the security of personal information during its transmission.

All personal data is stored on a secure server using a firewall and other advanced technologies to protect against interference or unauthorized access. Usernames and passwords are issued to persons who have the right to access personal data, Our employees who are obliged to maintain confidentiality and are not allowed to disclose any personal data.

No data transmission method is 100% secure, and accordingly, it is impossible to guarantee absolute security.

13. Data Storage

We store your data only as long as it is strictly necessary for the purposes for which they were collected (that is, to provide you with our services or satisfy any legal requirements, accounting or reporting requirements).

We store your personal data only as long as necessary to achieve the purposes for which they were collected (providing services and continuing our professional relationship with you), and further to satisfy any legal requirements or requirements related to accounting, taxation, anti-money laundering purposes, for required reporting, or for obligations imposed on us. We may need to retain your personal data to be able to present, exercise or defend against possible future lawsuits against you or otherwise involving you.

In general, our retention period of your personal data should not exceed six (6) years from the termination of our cooperation. This retention period allows us to use your personal data for potential AML/CFT reporting obligations to FIAU (legal obligation) and/or for approval, filing or defense against possible lawsuits involving you.

14. Data Minimization

Where possible, we anonymize the data we store about you when there is no longer a need to identify you from this data.

15. Your Rights as a Data Subject

You have the right to exercise the following rights under the DPA:

1. Right to Access Information: You have the right to request information about whether your personal data is processed by us, as well as information about how and why it is processed.
2. Right to Object: You can contact us at any time to ask us not to use your personal data.
3. Right to Make Changes: You have the right to make changes and correct any inaccuracies in your personal data used by us.
4. Right to Data Deletion: You have the right to request deletion of your personal data transferred to Us when they are no longer required.
5. Right to Restrict Personal Data Processing: You have the right to restrict our right to use your personal data in certain cases.
6. Right to Receive Data: We will provide you or your chosen third party with your personal data in a structured, widely used, electronic format.
7. Right to Withdraw Consent: If you have given your consent to collect, process and transfer your personal information for a specific purpose, you have the right to withdraw your consent for this specific operation at any time.

16. Legislation Governing Disputes

The Privacy Policy and all disagreements in connection with its application are governed by the laws of Malta. You hereby agree that the courts of Malta have exclusive jurisdiction over any claims, disputes or disagreements concerning the Letter of Commitment and any matters arising from it. Each party unconditionally waives any right it may have to object to filing a lawsuit in these courts, to claim that the lawsuit was filed in an inconvenient place for hearing the case, or to claim that these courts do not have proper jurisdiction.

17. Changes to this Privacy Policy

Any changes that we may make to this Privacy Policy in the future will be posted on this page and, if necessary, sent to you by email.

18. How to Contact Us

If you have any questions or comments regarding this Privacy Policy, contact us today using the contact information (see Section 3 "Data Controller").