1. Introduction of the Company and the Platform

Easy2choose provides a digital advertising technology platform. The concept of Easy2choose platforms is to facilitate and simplify online marketing for thousands of clients on a daily basis. Our key mission is to help people search smartly and to connect a wide range of areas with potential clients through our Easy2choose platform. This unified platform will facilitate the marketing expansion of various business segments to reach a huge number of potential clients by using our website, mobile application, and various social networks. In a nutshell, Easy2choose online platform is going to be a complete Online Guide to be used as a one-stop advertising platform for customers across Malta and Gozo.

The Service is provided and operated by E2C Business Ltd (C101530), Triq il-Kan. Gorg Bonello, Hamrun, HMR 1392 – Malta.

2 Introduction of the Privacy Policy

E2C Business Ltd.is committed to protect you, which is why we have adopted this Privacy Policy. This is intended to describe how your personal information is processed and used, and we will make every effort to ensure that our activities keep within the spirit of this Policy.

As a website user, you can tour through most of our site without giving any information that personally identifies you, reveals personal information or allows us to contact you. At times we do require information to respond to your requests.

The Privacy Policy applies to the following situations:

  • Provision of online and offline services of Easy2choose, including installation of Easy2choose services on the user’s end device and their (automatic) updating.
  • Reporting service malfunctions or problematic and illegal content (communication with technical support if personal data is processed to identify a natural person).
  • Subscribing to newsletters, etc.
  • Processing of personal data obtained in the context of presentations, trade fairs, seminars and other similar events.
  • Personal data collected by third parties for the benefit of Easy2choose, if applicable.

E2C Business Ltd. collects, uses, shares or otherwise processes personal information that you provide to us when you subscribe to our services, or that we may otherwise obtain or generate, which relates to you.

3. This statement explains the data we collect from you and its use.

There are the following two types of people in our platforms;

  • Those which are the users of the Website, Mobile Application and the social network This policy called them “users”
  • Those who are promoting and advertising their businesses, vacancies and events. This policy called them “clients”.

3.1. Website users

Every computer connected to the Internet is provided with a domain name (e.g., google.com) and an IP Address. When a visitor requests a page from within this site, our servers automatically identify and log the HTTP request that is made to our Web Server. Our website also uses a technology called “cookies”.  A cookie is an element of data that a website can send to your browser, which may then store it on your system. Cookies are created for each session when you visit our website. Cookies primarily contain information about the settings related to the website you have visited (e.g., your chosen language, login information or your preferences within the website you have visited). When you return to the website, your browser will return the identifiers it has associated with the website. Through this, the page retains your settings. Cookies can only be stored if you allow it. We use different types of cookies to operate our services, which you can view and manage in your browser. We do not use the cookie technology to capture individual e-mail addresses or any personally identifying information about you.

Furthermore, there is no need to logging in to get Easy2choose services.

In fact, very little information is automatically gathered and logged.

This information may include:

  • the date and time when you access our website;
  • the website pages that you view and any download that you may make through such pages;
  • whether or not such viewing or download is successful;
  • the IP address of the site that may have referred you to us;
  • Your IP address;
  • The operating system that you may be using;
  • The version and make of browser that you may be using.

There is nothing special about the information described, and the practice of collecting this data has been generally standardised by virtually every Web Server on the Internet today. E2C Business Ltd. has found it advantageous to observe visitor traffic in its aggregate, so that we can ensure maximum compatibility for the various browsers and operating systems that users like yourself use to visit our website.

Should you wish to reject all or certain cookies used by our website, you may modify your web browser preferences to do so. If, however you reject all cookies then you might be unable to use some of the services available on our website. Moreover, you may set your browser to notify you when you receive a cookie, giving you the opportunity to choose whether or not you wish to accept it. Usually, the information on how to change your options regarding cookies can be obtained by referring to your operating systems manual or to the ‘Help’ section of your web browser, or by contacting your Internet Service Provider.

3.2 What personal information do we collect for our clients and where do we obtain it from?

The personal information that we collect about you when you subscribe to one of our services may include:

  • your name or that of your representative;
  • email and mailing address;
  • phone number;
  • business hours;
  • your business or professional details.
  • Geolocation

We gather and generate information about you when you provide it to us or interact with us directly. We may also collect your personal information in the course of our normal business operations which include monitoring of businesses operating within Malta and Gozo and compiling data on such businesses.  Otherwise, we may also receive professional information about you from other sources, including publicly available sources.  We may combine information that we have about you from various sources, including the information that you have provided to us.

3.3. What other information does this site request?

We maintain a strict “No Spam” policy that means we do not intend to sell, rent, or otherwise give your e-mail address to a third-party, without your consent. In addition, E2C Business Ltd. will not send you e-mails that you have not agreed to receive, subscribed or otherwise communicate with you in ways which you have not authorised. If you wish to have specific communications with a member of the E2C Business Ltd. staff, you will be required to provide specific information that will be routed to the appropriate contact within E2C Business Ltd.

4. Use of your personal information

The personal information you submit on our website will be used for the purpose specified in the relevant part of the website and for any purpose which you give your consent to. Any and all processing of your data shall be in accordance with applicable data protection rules, regulations and guidelines and as specified in this Privacy Policy.

We will process any personal data supplied to us for all or any of the following purposes:

  • feature your business or services on Easy2choose platforms, including, our directory, websites and Mobile Apps when you subscribe to one of our services;
  • communicate with you and provide you with information about our products and services, including direct marketing communications;
  • answer your questions and request for services, and solicit your feedback;
  • process payments as agreed with you;
  • send important notices, such as changes to our terms, conditions and policies;
  • send you technical notices, updates, security alerts and support and administrative messages;
  • for internal purposes such as auditing, risk assessment purposes, internal management, research and statistics, systems administration and the development and improvement of our products and services;
  • to monitor and analyse trends, usage and activities in connection with our products and services to understand which parts of our digital platforms and services are of the most interest and to improve the design and content of our platforms;
  • to ensure we have up-to-date contact information for you;
  • to prevent, detect and/or prosecute any illegal and/or criminal activity which we are bound to report and to meet any other specific legal or contractual obligations;
  • to establish, exercise or defend any legal action;
  • to protect and promote our legitimate interests and the proper conduct of our business;
  • share identity, address and contact details of your business listing with third party search engines (such as Google) and other relevant websites so that we can help promote your business.
  • We may also record phone communications for training purposes.

We may also be required to processes your personal data for the purpose of:

 

  • compliance with applicable laws, rules, regulations, guidance and codes;
  • compliance with demands or requests made by local and foreign regulators, governments, courts and law enforcement authorities, and complying with a court process, or in connection with any litigation;

5. On what basis do we use your personal information?


For the performance of a contract: We process your personal data as necessary in order to provide you with the contracted services when you place an order for advertisement space to feature in one of our publications or website and Mobile App services.

 

We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, we will process your personal data for the purposes stipulated in the next section.
  • Where we need to comply with a legal or regulatory obligation, we will process your personal data for the following purposes:
    • To fulfil requirements stipulated by law, for example marketing. laws or data protection laws.
    • Where we have your consent as a legal basis for processing to send you any direct marketing from us or third parties via email. You have the right to withdraw consent to marketing at any time by contacting us at info@easy2choose.mt, you can also unsubscribe to our e-mails under the Newsletter section on the Website.

We may process your personal data for the following reasons on the basis of a ‘legitimate interest’:

  • To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.)
  • To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy.)
  • To make suggestions and recommendations to you about goods or services that may be of interest to you (to develop our products/services and grow our business.)
  • To detect and prevent fraud and misuse of our Website and our Service as well as to investigate potential criminal actions against us.

6. Recipients and sharing of your personal information


Your personal information will be received by E2C Business Ltd’s representatives and employees. 

We may also share your personal information with any of the following:

  • other companies forming part of the E2C Business Ltd, companies having the same shareholding as E2C Business Ltd. or in which E2C Business Ltd. has a controlling interest, for legitimate business purposes;
  • our agents, suppliers and business partners strictly as required in order to carry out the purposes outlined in this privacy notice;
    • our professional advisors and auditors strictly as required for consultation purposes or for compliance with our legal obligations;
    • regulators, governments and law enforcement authorities as and when this is required under applicable laws and regulations;
    • courts, tribunals, arbitrators or other competent bodies who may have authority to request such personal information;
    • other third parties in connection with our selling, merging, buying or reorganising all or any part of our business, or carrying out any similar change of our business (including any potential or actual purchaser of that business or that purchaser’s advisors).

 

7. Data about the devices which you use to access our service:

Whether you use a desktop, smartphone, tablet or combine devices according to your current needs, you prefer a predictable environment. At E2C Business Ltd, we always want to deliver a service developed for the specific type and operating system of the end device. To do this, we need to know which device the service has to deal with. In practice, this means what operating system our graphics are to be rendered for, what browser they will be displayed through, the device “privacy policy” settings, what IP address the device is accessing our service from, what language and time zone the device is in, etc. Equally important for us are reports about “system crash” events and other general activities.

8. Data from fan pages on social networks:

We have social media buttons and tools on our services for the following platforms: Facebook, Instagram, LinkedIn and Twitter. We never process personal and other data of visitors to fan pages other than as permitted by the settings of the individual social networks or for the purposes to which the user has consented.

The individual users or the operator of the social network in question are primarily responsible for the user-generated content on Easy2choose fan pages (e.g. comments on articles); however, if you send us a notice of objectionable content in such posts, we will deal with it appropriately.

Within our fan pages, we only collect the data about you that is provided to us by the relevant social network or by you personally if you comment on or tag one of our articles or content or send us a message. We do not consolidate your data in any way with the data from your profiles on the network in question, except when we visit your LinkedIn profile to see if your job profile posted by you on that network matches our requirements.

9. Privacy policies of social network platforms

Information on how your personal data is collected and used by the respective social network operator can be found here:

 

10. How long will we keep your personal information?

We have a data retention policy that sets out how long we keep your information. This policy is based on the type of information, the purpose of collection, and the system within our digital platforms in which the information is held. As a general rule, we keep your personal information for as long as we need to in order to carry out those purposes for which your data has been collected.

11. Security

We use reasonable efforts to safeguard the integrity, availability and confidentiality of all personal data that we process relating to you and regularly review and enhance our technical, physical and managerial procedures so as to ensure that your personal data is protected against data being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

All our employees and data processors, who have access to and are associated with the processing of personal data, are further obliged to respect the confidentiality of our clients’ and visitors’ personal data.

We use industry-standard technical and organizational security measures to help protect information transmitted over or stored on our systems. Please note, however, that no transmission or storage of information can ever be guaranteed to be completely secure, though we do take all reasonable precautions to protect against security incidents.

We shall accept no responsibility or liability whatsoever for the security of your data while in transit through the Internet.

12. Your Rights

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

12.1 Right of access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us using our contact details and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request. Before we can provide you with this information, we will have to ensure your identity so that the information is not disclosed to the wrong person.

12.2 Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by writing to us using our contact details and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

12.3 Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest, you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

You may also ask us to stop processing your personal data: (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using our contact details and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

12.4 Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third-party we are happy to consider such requests.

12.5 Your Right to Stop Receiving Communications

For details on your rights to ask us to stop sending you various kinds of communications, please contact us.

12.6 Exercising your rights

When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information, then we may delay actioning your request until you have provided us with additional information (and where this is the case, we will tell you).

13. Third party links

Our website may contain links to third party local and international websites. Please note that such links are not an endorsement by us of any information, products or services in such websites and we shall not accept any responsibility whatsoever for the content, use, availability, privacy practices or the content of any such websites. Please note that upon linking to such other websites, you will no longer be on our website and you will become subject to the privacy policy, if any, of such other website. For this purpose, we urge you to read the terms & conditions and privacy notices of these third-party websites.

No third party is permitted to link any other website to our website without obtaining our prior written consent.

14. Changes to this Privacy Policy

We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. If we make material changes to this policy, we will notify you of any material changes by posting the revised policy on this website, and where necessary, by any other means required by applicable law.

15. Contact Us

Easy2choose has appointed a Data Protection Officer. If you have any questions or believe your personal information has been used in a way that is not consistent with this policy or applicable legislation, or you have any other data protection related issues or queries, please contact our Data Protection Officer by e-mail sent to info@easy2choose.mt.  

Written inquiries may be addressed to: 

Data Protection Officer

E2C Business Ltd.

Triq il-Kan. Gorg Bonello,

Hamrun, HMR 1392 – Malta