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Privacy Notice
Last updated on 01.10.2020
Welcome to https://www.reformstudiossc.com/ (the ‘Website’)
1. Who We Are
1.2. By visiting Our Website and using Our Services, You acknowledge reading and fully considering this Privacy Notice.
1.3. The Company acknowledges that in collecting Your Personal Data We are bound by the laws of Malta and will process Your Personal Data in accordance with the GDPR. For any further request or query about how We use Your Personal Data, You may address Our Data Protection Officer through the following email address: [email protected].
1.4. Any notice, demand, request or other communication which You address to the Company shall either be sent by certified mail, return receipt requested, or by e-mail. All communication done by e-mail shall be deemed received on the business day following the day of transmission.
2. Definitions
Capitalised terms in this Notice shall have the meaning assigned to them under the GDPR, and shall be construed accordingly. Furthermore, the following definitions shall apply:
2.1. Account – an account provided to You by the Company upon Your registration.
2.2. GDPR – the General Data Protection 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of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced or superseded and in force from time to time.
2.3. Services – the Services provided by the Company through the Website.
2.4. User – any person who registers an Account or accesses and browses the Website (‘You’, ‘Your’).
3. Subject Matter
3.1. This Privacy Notice sets out the terms and conditions which the Company follows in order to protect the privacy of Our Users. It describes the conditions under which We make any collection and processing of Your Personal Data and ensure their security and confidentiality.
3.2. The Company reserves the right to amend and update this Privacy Notice, whenever it deems appropriate, and any changes thereof shall come in force and effect from the instance they appear online on the Website. Any substantial modifications to this Privacy Notice will communicated to You.
4. Principles of Data Processing
4.1. We fully respect Your fundamental rights and consider protection of Your Personal Data to be a priority. Accordingly, when processing Your Personal Data, We follow the following basic principles:
4.1.1. We submit Your Personal Data only to lawful and fair processing, and We maintain full transparency vis-à-vis the way We handle Your Personal Data.
4.1.2. We collect and process Your Personal Data only for specified, explicit, and legitimate purposes as outlined in this Privacy Notice, and We do not process it further in any manner incompatible with these purposes.
4.1.3. We process Your Personal Data only to the extent that it is necessary and appropriate to purposes for which it is collected.
4.1.4. We make reasonable efforts to ensure that Your Personal Data is accurate and, where necessary, updated with regard to the purposes of the processing, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.
4.1.5. We process Your Personal Data in a manner that guarantees its security by using appropriate technical and organizational measures.
4.2. In general, We comply with all applicable laws statutory obligations, as Data Controller of Your Personal Data.
5. Information we collect from other sources
5.1. Where you have asked us to provide a restricted product or service, we may collect information from One Account Mobile Limited (1account) and third-party providers of identity data to 1account. This is necessary for 1account to verify that you meet the minimum age and identity verification requirements as determined by relevant UK age restriction and other legislation. We will record that you have been successfully verified so that you don’t need to go through the process again. You can find information about how 1account manage your personal data and view their privacy policy by visiting their website:?1account.net.
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6. Who we share your information with
6.1. Where you have asked us to provide an restricted product or service, we may share your information with One Account Mobile Limited (1account), and third-party providers of identity data to 1account. This is necessary for 1account to verify that you meet the minimum age and identity verification requirements as determined by relevant UK age restriction and other legislation. 1account may retain relevant data for the purpose of future verifications. All data processed by 1account is subject to appropriate security measures. Data retained by 1account is subject to periodic review to ensure it is not held for longer than necessary. You can find information about 1account how manage your personal data and view their privacy policy by visiting their website:?1account.net.??
7. Types of Personal Data Collected
The Company collects and processes the following Personal Data:
7.1. At the point of Your access and use of the Website:
IP Address;
End user device data;
Browsing data; and
Information on user preferences regarding the Website.
7.2. At the point of Your Account registration:
E-mail address;
Password;
Date of Birth; and
Region.
7.3. Upon your participation in Our surveys and User recruitment exercises:
Surname;
Age;
Gender;
Residential address;
Contact details;
7.4. Any other Personal Data directly provided by You during Your interaction with Us.
8. Purposes and Legal Basis for Data Processing
8.1. The Company may process Your Personal Data to fulfill its obligations under the Terms and Conditions, for the following purposes:
Administration and development of the Website and the Services;
Enhancement of user experience, including the provision of personalized Services and improvement of the Website and the Services;
Development of new products, utilities and offerings;
Collection, processing and performing statistical and other research and analysis of information; and
Verifying compliance with the Terms and Conditions of the Website.
8.2. The Company may process Your Personal Data only with Your lawful consent for the following purposes:
Commercial communication, marketing and advertising of Our Services or third-party services; and
Conducting surveys for research purposes and User recruitment exercises.
8.3. You have the right to withdraw Your consent at any time in writing to Our contact details mentioned in this Notice. Withdrawal of Your consent does not affect the lawfulness of the treatment of Your data prior to its revocation.
9. Data Recipients
9.1. For the execution of the purposes mentioned in this Privacy Notice, We may provide access or transmit Your Personal Data to the following recipients:
Third-party providers for the smooth operation and enhancement of the Website; and
Third-party providers for age verification services.
9.2. The processing of Your Personal Data by Our Data Processors is done under a contract compelling Data Processors to the same level of data protection provided under this Privacy Notice.
9.3. We will not disclose Your Personal Data with any third parties outside of the European Union . However, in the event that such a data transfer occurs, We will take all reasonable steps possible to ensure that Your data is treated as securely as it is within the European Union and in accordance with this Privacy Notice and applicable legislation. Additionally, We will update this Privacy Notice to reflect the cross-border data transfer and the relevant safeguards for Your privacy.
9.4. In the event that We are required by a court or other administrative authority, pursuant to an investigation relating to unlawful activities, the Company may transfer Your Personal Data to public authorities to the extent specified by law.
10. Data Security and Confidentiality
10.1. In order to ensure the proper use and integrity of Your Personal Data and to prevent unauthorised or accidental access, processing, deletion, alteration or other use, the Company applies appropriate internal policies and takes all appropriate organizational, technical and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.
10.2. The processing of Your Personal Data by the Company is conducted in a manner that ensures confidentiality and security, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for Your rights and freedoms, which are applicable in each circumstance.
10.3. Your Personal Data is processed solely by authorised personnel of the Company, bound by strict obligations of confidentiality.
11. Retention of Personal Data
11.1. We retain Your Personal Data for as long as is necessary to fulfill the relevant purposes of processing explained in this Notice, in accordance with the Data Minimisation and Storage Limitation principles. After the period of retention, Your Personal Data is erased from Our databases and systems.
12. Your Rights
12.1. You have the right:
To request access to Your Personal Data and information related to their processing and obtain a copy thereof;
To request for the rectification of any inaccuracies in your Personal Data;
To request for the erasure of Your Personal Data;
To request for the restriction of the processing of Your Personal Data in cases explicitly provided for by law;
To request for the portability of Your Personal Data to another Data Controller in a structured, commonly used and machine-readable format;
To object to the processing of Your Personal Data in cases explicitly provided for by law; and
To object to a decision taken solely on the basis of automated processing, including profiling, which has impact on You or significantly affects You.
12.2. Any requests relevant to the above Section 10.1 must be addressed in writing to [email protected].
12.3. If You feel that Your rights are infringed, You have the right to file a complaint with the Office of the Information and Data Protection Commissioner at the following page https://idpc.org.mt/en/Pages/contact/complaints.aspx.
13. Your Obligations
13.1. By using Our Website and by providing Your Personal Data, You acknowledge that You are required to provide Your actual, accurate and complete data as requested by the Company. Furthermore, You must inform Us of any changes to Your information so as to ensure it is kept up-to-date and accurate.
13.2. If You are found to be in breach of Your obligations or if We have reasonable suspicion that the information You provide is false or incomplete or in any way contrary to applicable law or this Privacy Notice, We retain the right to reject Your application for registration or to suspend or terminate Your Account immediately without notice. In this case, You have no right to any compensation due to the rejection of Your application, or the suspension or termination of Your Account.
14. Cookies
14.1. Our Website uses cookies. For more information please review Our Cookie Notice.
