AML – Atlantis Management Ltd. (hereinafter referred to as “AML” or “we”) respects the right to privacy of users of this website and of its clients. AML will always seek to protect your Personal Data. This Policy describes how we gather and use such information, the amount of information AML holds on you and how it uses it.
The following definitions shall have the same meaning as those contained in the General Data Protection Regulation (EU) 2016/679 (“GDPR”): “Data Subject”, “Data Controller, “Data Processor”, “Personal Data”, “Process” or “Processing”
Collection of Information
We may collect Personal Data from you as the Data Subject, when you provide your Personal Data through our website, when you enter into services agreements with us or sign letters of engagement, through your professional/legal relationship with us, while you are in contact with our staff or at any other stage in the course of business.
Through Our Website
We may collect, store and use the following kinds of Personal Data:
a) We may collect information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and number of page views. We may use this information in the administration of this website, to improve the website’s usability, and for marketing purposes.
b) Information that you provide to us for the purpose of registering with us and/or subscribing to our website services and/or email notifications. In such instances, we will store the information that you provide us with and process it further as may be necessary for us to respond to and process any request that you may make. Nevertheless, you may visit our website without having to subscribe or provide login details.
You are requested to inform us by sending an e-mail to email@example.com if you do not wish to receive any such email notifications from us or opt out via the “Unsubscribe” link that would be included in any marketing email.
We may send a cookie which may be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of this website, to improve the website’s usability and for marketing purposes. We may also use that information to recognise your computer when you visit our website, and to personalise your experience on our website.
Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.) This may, however, have a negative impact upon the usability of many websites, including this one.
Through Our Professional Services
Before providing our professional services, we view and subsequently retain Personal Data such as your name, address, email address, date of birth, gender, identification documents and information in relation to your occupation. We may also process data received through your e-mails to us, accounting, payment data etc. This is important data required for ‘Know-your-Customer’ processes, as imposed by anti-money laundering regulations, applicable in Malta.
In view of the strict legal obligations imposed upon us, we would not be able to provide you with our professional services if you do not supply us with the Personal Data required under the applicable laws.
Use of Personal Data
Personal data submitted on this website and gathered through our professional services will be used to deliver the professional services requested from us and honour the services agreements or letters of engagement which regulate our relationship.
Other processing activities include:
a) Professional communications with you;
b) Improving your browsing experience by personalising the website;
c) Sending information to you which we think may be of interest to you by post or by email or similar technology;
d) Sending you marketing communications material relating to our business (or the businesses of carefully-selected third parties – provided that you have given your consent) by post or, where you have specifically agreed to this, by email or similar technology (You can inform us by sending an e-mail to firstname.lastname@example.org if you do not wish to receive any such email notifications from us or opt out via the “Unsubscribe” link contained in any marketing email).
e) Providing other companies with statistical information about our users, but this information will not be used to identify any individual user.
We will NEVER provide your Personal Data to any third party for the purpose of direct marketing without your express prior consent.
The legal basis for the processing of your Personal Data may vary, depending on the nature of the personal data, but this would normally include the following:
- Your explicit consent, which you may withdraw at any time by sending us an email or unsubscribing from marketing communications;
- When the processing is necessary for the performance of a contract such as a services agreement or letter of engagement;
- When the processing is necessary for our legitimate business interests, in the provision of the services you have engaged us to carry out;
- When the processing is necessary to promote safety and security as described in the ‘Security of Personal Data’ section below;
- When the processing is necessary to comply with any applicable legal obligation.
Providing Personal Data to Third Parties
Please be aware that data sent through the internet may potentially, for reasons beyond our control that are solely of a technical nature, be transmitted across international borders even where the sender and the receiver of information are located in the same country. Consequently, Personal Data relating to you may in such cases be transmitted via a country having a lower level of data protection than that existing in your country of residence.
Personal Data, once obtained from you, may be transmitted to third parties in those situations where any one of the exceptional instances indicated below arises.
- for the purpose of preventing, detecting or suppressing fraud or any other criminal offence;
- where it is necessary as a matter of national or public security;
- in the interest of national budgetary, monetary or taxation matters that can arise or the collection of national statistics;
- to protect and defend our rights and property or that of users of our website;
- to protect against abuse, misuse or unauthorised use of our website;
- to protect the personal safety or property of users of our website (e.g. if you provide false or deceptive information about yourself or attempt to pose as someone else, we shall disclose any information we may have about you in our possession so as to assist any type of investigation into your actions);
- for any purpose that may be necessary for the performance of any agreement you may have entered into with us; or
- as may be allowed or required by or under any law.
It is also important to highlight the fact that there may be instances where we may transfer your Personal Data to other service providers, acting as Data Processors, who process data for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. Data Processors who are engaged to assist us in attaining the purposes of processing listed in the ‘Use of Personal Data’ section may include service providers which supply us with services globally, including for customer support, information technology (including backup and email services), payments, sales, data analysis, research, and surveys.
Retention of Personal Data and the Right to be Forgotten
We keep your Personal Data for as long as necessary for our legitimate business interests, for legal reasons and to prevent harm, including as described in the ‘Use of Personal Data’ and ‘Providing Personal Data to Third Parties’ sections of this policy.
AML acknowledges that you have a right to be forgotten. Therefore, no Personal Data that is processed while providing you with our services, or through our website will be kept longer than necessary for the purposes for which it is processed. Personal Data will only be kept for a period corresponding with our obligations of retention under relevant laws.
Should you wish all or any category of your Personal Data to be deleted, you may request this in writing at email@example.com.
Security of Personal Data
AML engages all reasonable efforts for the purpose of safeguarding the confidentiality of all Personal Data that it processes and regularly reviews and enhances its 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 dedicated to the protection of the Personal Data processed by us and that data that we have under our control. All our employees and third-party 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’ and clients’ 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 that are outside our control. There can be no absolute guarantee in relation to the privacy or confidentiality of any information passing through our website. We shall accept no responsibility or liability whatsoever for the security of your data while in transit through the internet.
Third Party Websites
Copyright of any brand logos featured on this website may belong to third parties and their use here does not imply any ownership of these rights. The design and layout of this website is original and any similarity with other websites published online is purely coincidental.
How we Communicate with you
We use your contact information when necessary, to provide you with our professional services. We may also use your contact information to keep you updated through our newsletters and other updates. You can limit or restrict the receipt of these communications via the “Unsubscribe” link in any marketing email or by requesting the same in writing at firstname.lastname@example.org when such communication or marketing is sent via traditional mail.
E-Mail Communications Policy
AML may intercept some mail and e-mail addressed to individuals within AML. The reasons it may do this are related to security of AML, its staff and others, for detection and prevention of crime and to identify correct recipients or to make sure mail is dealt with during staff absence. In the case of e-mails, we may reject, delay or remove content from e-mails whose nature, content or attachments which may disrupt our systems or because they may pose security issues, possibly through viruses. We may also filter out e-mails which contain certain content on the basis that content is offensive or the e-mail is unwanted or constitutes spam. In certain circumstances this may unfortunately result in harmless and legitimate e-mails being affected but we do try and reduce such occurrences.
All e-mail messages sent from AML are routinely scanned for viruses and as such should be free from any virus, malicious code, script or other executable attachment. The accuracy of scanning products is not guaranteed. The recipient(s) should therefore carry out any checks that they deem to be appropriate in this respect. AML cannot be held responsible for loss of or damage to data or other damage resulting from such actions that are out of its control, howsoever incurred.
All e-mail messages from AML are sent in good faith. We cannot be held responsible for any modification that happens through any virus, or the intervention of a third party after they have been sent. All messages are intended for the recipient only. If you are not the intended recipient specifically identified as the addressee on it then you should delete the message and all its attachments and are prohibited from using, reading, disclosing to any person or otherwise acting on the information contained in it and/or its contents in any way and should also notify us as soon as possible of this fact.
Security and Staff Awareness Measures
AML has developed strict policies governing information technology. These cover areas such as access control, authentication, audit, monitoring, data storage and back up and transmission standards. AML’s staff is subject to a code of conduct which requires them to adhere to privacy principles.
Right to Access/Questions
You have a right to request access to and/or correction of your personal data processed by AML. Any such request must be made in writing to AML at the address indicated on the homepage of the website and must be signed by yourself as the Data Subject to whom the particular data relates. The processing of such requests sometimes attracts the imposition of a nominal fee.
Data Subject Rights
The full list of Data Subject Rights:
- Right to access
- Right to be forgotten
- Right to rectification
- Right to restriction of processing
- Right to data portability
- Right to object
- Right to withdraw your consent
- Right to lodge a complaint with a supervisory authority
Who we are and how to contact us
If you have any questions about AML’s privacy / data protection policy or the use of data in a particular service, you should contact us on the following email address: email@example.com.
Last Updated: 30th July 2018
17G, Dolphin Court
Ta’ Xbiex XBX 1071 Malta
T: +356 2133 0820
F: +356 2133 0797