- the UK`s Data Protection Act (“DPA”),
- the EU`s General Data Protection Regulations (“GDPR”) and the relevant implementation provisions:
- Malta’s Data Protection Act 2018 (Chapter 586 of the Laws of Malta) (the “DPA”);
- Portugal’s Law no. 58/2019, as amended (“PDPL”);
- Cyprus’ Law No. 125(I)/2018 as amended (“DPA”);
- Italy’s Data Protection Code (“DPC”);
- the UAE`s Federal Decree Law No. 45(“Law No. 45”); and
- the Turkish Law No. 6698 on Protection of Personal Data (“PDPL”).
If you have any questions about the cookies we use or about our data protection practices in general, please contact us.
a) “Business Partner” means any entity of our group of company, subcontractor, supplier or other entity with which we have an ongoing business relationship to provide our services or information.
b) “Personal Data” means information that may directly or indirectly identify/identify you, such as your name, telephone number, email address, IP (Internet Protocol) address and location data.
c) “Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Our use of your Personal Data is subject to the above mentioned laws, and of course we process your Personal Data accordingly.
Each mandate is exclusively handled by the relevant geographical entity and depending on the geographical location area of the mandate.
RHJ Group is the responsible party for data processing. If you have any questions about this policy or our data protection practices, please contact us.
Data we collect
We may ask you to provide us with Personal Data:
- When you use our websites.
- When you request offers, services, support, or information.
- When you place orders for services or request a consultation.
- When you participate in our promotional activities.
- When you subscribe to newsletters, advertising and promotional emails or other materials.
- When you contact us.
The categories of Personal Data processed by us are depending on how you use our services. In that sense, you may provide your name, email address, business address, telephone numbers, contact information, location data, passport, proof of profession, income information, visas, bank accounts etc.
They may also include information about your work such as your title and other business, company or corporate information.
We may also collect demographic information, such as information about your interests and preferences.
In order to provide you with a more consistent and personalised experience in your interactions with us, information collected through one source may be combined with information we receive from other sources. This may include information that allows us to recognize you across multiple devices through which you access our website.
We may also supplement the information we collect with information we receive from other parties, including our Business Partners and other third parties.
Information we collect automatically
We may automatically collect behavioural and usage information about your visits to our website, including the pages you view, the links you click, and other actions you take in connection with our website and our services. We may also collect certain information from the browser you use to access our website, such as your IP address, device ID, location data, browser type and language, access times.
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage.
There are different types of cookies:
- Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and
- Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies).
Information from Third Party Sources
We may receive information about you from third party sources such as services and contents we have integrated in our website, our Business Partners, social media platforms and other third parties.
We may use the data to better understand you in order to improve our ability to offer you relevant advertising, products and services, and to help prevent and detect fraud.
Data processing through integration of third-party services and content
We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (“content”).
This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.
The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any:
- Analytics and Tracking: Google Analytics by Google.
- Tag Management: Google Tag Manager and Google Site Tag by Google,
- Spam Protection: reCAPTCHA by Google
- Hosting: SiteGround
- CRM: OpenCRM
- Content Management System: WordPress by Automattic Inc
- Pixel Cookies and Tags: Facebook, and Instagram
- Advertising: Google Ads by Google
If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioural advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative or AdChoices.
How we use Personal Data
We may use your Personal Data for the following purposes:
- Providing our services and support or carrying out the works and services you have requested,
- Sending communications to you, including information and the stages of your transactions with us for example our case review, case management or support services.
- Facilitating your use of our website and online chat and communication tools and services.
- Help via online chat and communication tools and services to answer your queries.
- Facilitate communication from our Business Partners.
- Customise, analyse and improve our services (including content and our advertising campaigns), technologies, communications and relationship with you.
- Better understanding of our customers and website users, including their interests and interactions with our site.
- Content personalization and application of your preferences.
- Enforce our terms of service, website terms and separate agreements (where applicable) with you.
- Preventing Fraud and Other Prohibited or Illegal Activities.
- Protecting the security or integrity of our websites, our businesses, and our services.
- Perform other functions or serve other purposes as communicated to you at the point of collection, or as required or permitted by law.
Legal Basis for Processing
You have the right to withdraw your consent at any time by contacting us at any time. If you withdraw your consent, this will not affect the lawfulness of any processing based on your consent prior to its withdrawal. Where applicable, we may ask for your consent for processing at the point of providing your Personal Data.
- To comply with a contractual obligation. We will inform you at the time of collection whether the provision of your Personal Data is mandatory and the possible consequences if you do not provide us with your data.
- To comply with our legal obligations where other laws require us to process your Personal Data (for example, health and safety, tax and other applicable laws and regulations).
- In our legitimate interest which include providing this website and/or related services, and/or conducting marketing and advertising activities, provided always that our legitimate interests do not override any reservation or prejudice your rights and freedoms.
If you have questions or need more information about the legal basis under which we collect your Personal Data, please contact us.
Retention of your data
How we may share your Personal Data
We share your Personal Data only with Business Partners who agree to protect and use your Personal Data solely for the purposes specified by us.
We may also disclose your Personal Data for any purpose with your consent or for law enforcement, fraud prevention or other legal actions as required by law or regulation, or if we reasonably believe that we must protect us, our customers or other business interests.
Except as described above of which you will be informed in advance, we will not disclose your Personal Data.
You can exercise the following rights:
- Right to information
- Right to rectification
- Right to deletion
- Right to data portability
- Right of objection
- Right to withdraw consent
- Right to complain to a supervisory authority
- Right not to be subject to a decision based solely on automated processing.
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in relation to our services are:
- The Information Commissioner’s Office (ICO), Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk.
- Office of the Information and Data Protection Commissioner (IDPC), 2 Airways House, Second Floor, High Street, Sliema SLM 1549, Malta www.idpc.gov.mt
- Comissão Nacional de Proteção de Dados (“CNPD”), Avenida D. Carlos I, no. 134, 1st floor, 1200-651 Lisbon, Portugal, www.cnpd.pt
- The Commissioner for the Protection of Personal Data (the “Commissioner”) 1 Iasonos Street, 2nd Floor, 1082 Nicosia, Cyprus, www.dataprotection.gov.cy.
- The UAE Data Office, Abu Dhabi, United Arab Emirates, https://u.ae/
- The Turkish Personal Data Protection Authority, Nasuh Akar Mahallesi Ziyabey Caddesi, 1407 Sokak No:4 06520, Çankaya , Ankara, Türkiye, www.kvkk.gov.tr
However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.
How we secure your Personal Data
We take all reasonable steps to protect your Personal Data from misuse, interference and loss, and from unauthorised access, modification or disclosure. The ways we achieve this are:
- The use of encryption when collecting or transferring Personal Data.
- The existence of technical and organisational measures designed to ensure the continued integrity, availability and resilience of processing systems and services.
- Limiting physical access to our offices.
- Limiting access to the information we collect about you.
- Ensuring that we and our Business Partners have appropriate security measures in place to protect your Personal Data.
- Where required by law, destroying or de-identifying your Personal Data.
Collection and Use of Children’s Personal Data
We take children’s privacy seriously. We do not knowingly collect Personal Data from children through our websites. If you are a child, as defined by the laws of your country, do not submit Personal Data through our websites without the express consent and participation of your parent or guardian.
Links to third-party websites and services
Does this policy change?
Who should I contact for more information?