Applicable Laws

[i] The Data Protection Act 2018 (Chapter 586 of the Laws of Malta) as well as the various subsidiary legislation issued under the foregoing Act, namely, The Restriction of the Data Protection (Obligations and Rights) Regulations (S.L. 586.09);

[ii] The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and 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) – the ‘GDPR.

All the above are referred to collectively as the ‘Data Protection Laws’ in this Policy.

What Is Personal Data?

‘Personal Data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

What Information Do We Collect?

[i] First name and last name

[ii] Date of birth

[iii] Phone number

[iv] Email address

[v] Address, State, Province, Zip/Postal Code

[vi] Locational – IP address of the computer or device connected to the internet, location data through the mobile phone used, and GPS data.

[vii] Usage data – this includes data about how and when you use our Site and our services, which are collected as you continue to use our Site.

You also may choose to provide information when you participate in any interactive features including forums or discussions on the Site. Please be aware that the information you post in these forums may be viewed or captured by anyone who visits the Site; therefore, you should avoid posting sensitive personal data that you would not want to be available to the public.

Please note regarding the information provided by you through our support channels. You may choose to submit information regarding a problem you are experiencing with a Service. When you engage with our support team, you may be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots, or information that would help resolve the issue.

How Do We Process Your Information?

The processing of your personal data must comply with all six general data quality principles. We process your Personal data in accordance with the general data quality principles as defined by the Data Protection Laws. In line with the principles include, your personal data are:

[i] processed fairly, lawfully and transparently;

[ii] collected for specific, explicit and legitimate purposes and not processed in a manner incompatible with those purposes;

[iii] adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

[iv] accurate and, where necessary, up to date;

[v] kept in an identifiable form for no longer than necessary; and

[vi] kept secure.

Generally, we do not collect any Personal Data that identifies you as an individual other than that which you choose to provide to us such as the data (including Contact Details) you provide when signing up on our Site, when contacting us with enquiries relating to our services, when subscribing to any service offered by us or via our Site, such as any newsletters as may be issued by us from time to time or when subscribing to any offers we may offer from time to time.

Also, with your consent, we use the information we collect from you and in the following ways:

[vii] To enable us to communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including confirming your subscription, sending reminders on the expiration of your subscription, providing customer support, responding to your comments, questions and requests, and sending you technical notices, updates, security alerts, and administrative messages. We also provide tailored communications based on your activity and interactions with us. We also send you communications as you onboard to a particular Service to help you become more proficient in using that Service. These communications are part of the Services.

[viii] For research and development: We frequently evaluate and improve our services, including developing new features for the Site, analysing and enhancing the user experience on the Site, assessing the effectiveness of our marketing and advertising; and managing our communications). This is because we are always looking for ways to make our Services smarter, faster, secure, relevant and integrated. We use the information and collective learnings (including feedback) about how people use our Services to troubleshoot, identify trends, usage, activity patterns, and areas for integration and to improve our Services and develop new products, features and technologies that benefit our users and the public.

[ix] For safety and security: We use information about you to verify accounts and activity, to detect, prevent, and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent or illegal activity, including violations of our Terms of Use.

[x] To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions.

[xi] With your consent: We use information about you only where you have given us consent to do so for a specific purpose. However, where the processing for a purpose other than that for which your personal data have been collected is not based on your consent or the Data Protection Laws, We shall, in order to ascertain whether processing for another purpose is compatible with the purpose for which the information was initially collected, take into account, the following:

Legal Basis For Processing Personal Data

We are not in the business of selling information about you to advertisers nor the disclosure of your personal data to third parties. However, we work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including appropriate security and confidentiality procedures designed to protect your information.

Any such authorised disclosures will be done in accordance with the Data Protection Laws (for example all such service providers/third-parties are contractually bound, and under strict legal obligations to keep any information they receive confidential and to ensure that their employees/personnel are also bound by similar obligations).

Will Your Information Be Shared With Any Third Party

We are not in the business of selling information about you to advertisers nor the disclosure of your personal data to third parties. However, we work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including appropriate security and confidentiality procedures designed to protect your information.

Any such authorized disclosures will be done in accordance with the Data Protection Laws (for example all such service providers/third-parties are contractually bound, and under strict legal obligations to keep any information they receive confidential and to ensure that their employees/personnel are also bound by similar obligations).

Who Will Your Information Be Shared With?

The third parties who we may disclose to and/or share your Personal Data are, at the date of this Privacy Policy, the following:

[i] Cloud Service Provider for the hosting of data under state-of-the-art security protocols and our exclusive control

[ii] IT Service Providers for the maintenance and support of our IT systems/Site(s) with restricted access and under strict controls.

[iii] Customer Support Software Providers for the provision of customer support software to provide our users with high-level customer support with restricted access and strict controls.

[iv] Marketing and Customer Retention Management Tools for the provision of marketing email communications send-outs under our strict control and management.

[v] Public Authorities for compliance with legal obligations and only after verifications are made into a necessity of disclosure.

[vi] Our independent financial and legal advisors for the provision of legal and financial support to QuitGamble and affiliated entities.

How Do We Keep Your Information Safe?

We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change, or damage. All personal information we collect will be stored on secure servers. All electronic transactions entered into via our website will be protected by Secure Sockets Layer (SSL) encryption technology. You should be able to see the padlock symbol in the address bar of your browser. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server. Any data transmitted during the session will be encrypted or scrambled and then decrypted or unscrambled at the receiving end. This will ascertain that data cannot be read during transmission.

Note that, where you register for an account on our Site, you are solely responsible for maintaining your account’s security as more specifically explained in our Terms of Service.

Do We Collect Information From Minors?

Our Site and services are not intended to be used by any person under the age of eighteen (18) and therefore we will never intentionally collect any Personal Data from such persons.

If we become aware that we have collected personal data from a person under the age of eighteen (18), we will delete any such information.

Do We Use Cookies And Other Tracking Technologies?

“Cookies” are small data files assigned to your browser when you visit our Site. These data files enable recognition of your browser and collect and store information about your use of the Site. In addition to cookies, we use other similar technologies that collect information about your use of our Services, including mobile identifiers and “web beacons” which are small graphic files (sometimes called “clear GIFs” or “web pixels”) embedded in a web page or email typically used to monitor activity and send relevant information back to a home server (which can belong to the host site, a network advertiser or some other third party).

Note that most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our website.

How Long Do We Keep Your Information?

The type of information we collect from you determines how long we keep your information. See below for further details on how long we keep information. Please note that after such time as are described below, we will either delete or anonymise your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

[i] Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, support business operations, and continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, but not to specifically analyse personal characteristics about you.

[ii] Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain to allow your team members or other users to make full use of the Services. For example, we continue to display messages you sent to the users that received them and continue to display the content you provided, but when requested details that can identify you will be removed.

[iii] Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your account. We retain information derived from cookies and other tracking technologies for a reasonable time from the date such information was created.

What Are Your Privacy Rights?

Under the Data Protection Law, you have the following rights in respect of your personal information:

[i] Right to obtain a copy of your personal information together with information about how and on what basis that personal information is processed;

[ii] Right to rectify inaccurate or incomplete personal data, and the right to have incomplete personal data completed;

[iii] Right to the erasure of your personal data without undue delay where:

a) The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) You withdraw consent on which the processing of your data is based, and there is no other legal ground for the processing;
c) Tou object to the processing of your personal data and there are no overriding legitimate grounds for the processing or do you object to the processing for direct marketing purposes;
d) Where you believe your personal data is being unlawfully processed by us;
e) The personal data have to be erased for compliance with a legal obligation to which we are subject;

[iv] Right to restrict processing of your personal information where:

a) The accuracy of the personal information is contested;
b) The processing is unlawful but you object to the erasure of the personal information;
c) We no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defence of a legal claim or
d) You have objected to us processing your personal information based on our legitimate interests and we are considering your objection;

[vi] Right to data portability. You have the right to ask us for a copy of your personal data in a structured, machine-readable format, and the right to ask that we transfer to or share your data with another organization. Note, however, that this right only applies to the information you provided to us, and where you have given us your consent.

Kindly note that we will ask you for additional data to confirm your identity and for security purposes, before disclosing the data requested to you. We will not charge you any fee for choosing to exercise your rights under the applicable laws or in this policy. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

In addition to the above, you have the right to lodge a complaint with the appropriate Data Protection Supervisory Authority, if you are in Malta, this will be:

Office of the Information and Data Protection Commissioner (the “Information and Data Protection Commissioner”)
2, Airways House, Second Floor
High Street
Sliema SLM 1549
Malta
www.idpc.org.mt

We kindly ask that you attempt to resolve any issue you may have with us first to enable us to take steps to resolve the issue.

Do We Make Updates To This Policy?

As we continue to develop our Site and services, we may add new services and features to our Site. In the event that these additions affect our Privacy Policy, this document will be updated appropriately. We will post those changes prominently so that you will always know what information we gather, how we might use that information, and whether or not we would disclose it to anyone. We do, however, recommend that you read this Privacy Policy each time you use our Sites in case you missed our notice of changes to the Privacy Policy. We will not, however, materially change our policies and practices to make them less protective of Personal Information we have previously collected from you without your express consent.

Disclaimer

You will be aware that data sent via the internet may be transmitted across international borders even where the sender and receiver of information are located in the same country. We cannot be held responsible for anything done or omitted to be done by you or any third party in connection with any Personal Data prior to our receiving it including but not limited to any transfers of Personal Data from you to us via a country having a lower level of data protection than that in place in the European Union, and this, by any technological means whatsoever.

Moreover, we shall accept no responsibility or liability whatsoever for the security of Your data while in transit through the internet unless Our responsibility results explicitly from a law having effect in Malta.

How Can You Contact Us About This Policy?

If you have questions or concerns about the way QuitGamble is handling your personal information, kindly inform us immediately. The protection of your data is important to us, thus we are available always to address your concerns and questions. You may contact us directly by email at privacy (at) quitgamble.com or by filling out the Privacy Contact Form. You can be sure of a prompt response from us.

Please note that whilst QuitGamble is not required to designate a data protection officer (DPO) under the GDPR, we have designated responsibility for overseeing compliance of the Standards to our in-house resource person who is vast with the data protection standards and responsibility. You can contact our in-house data protection resource person as follows: [email protected]

Anders Bergman