Last reviewed: 10th November 2024
We, the team at [Company Name], take the confidentiality and security of your personal data very seriously. We strongly value privacy and therefore are committed to protect your personal data (i.e. information that identifies you).
One of your rights under the Data Protection laws (as defined below) is that you must be informed when your personal data, also known as personal information – is processed (collected, used, stored) by any organisation. You also have the right to know the details and purpose of that processing.
This privacy policy describes, in a layered format, our policies and practices regarding how and why we generally process personal data and sets forth your privacy rights.
We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.
For all our services, including our site and online facilities, the data controller (the company that’s responsible for your privacy),is [Company name] with its address at Hili Building, Nineteen Twenty Three, Valletta Road, Marsa, MRS3000 Malta.
We assure you that we will only process any personal data collected from you in accordance with the manner set out in this policy.
We are always happy to hear from you, whether to make a suggestion but especially if you feel we can do better.
If you require any clarifications about how we protect your privacy, or would like to exercise any of your privacy rights please get in touch with our Data Protection Officer s on:
E-mail address: [email protected]
Address:
Harvest Technology p.l.c
Nineteen Twenty Three,
Valletta Road,
Marsa, Malta MRS 3000
As an entity established in Malta, EU, the main privacy laws that are applicable to us in so far as you are concerned, are the following:
Most of the personal data which we may collect about you through this website, is given to us only if you choose to give it to us.
Such personal information may be requested from you when you fill in a form (e.g. to submit a vacancy, sign up for our newsletter or fill in any other form with your questions and comments, or any other form or application downloaded through or from Harvest Technology’s website. If you send us emails, then the personal data we process will depend on what you send us in the email.
There are various categories of personal data that we collect about you, namely:
If you apply for a vacancy other information will be requested (see the section on vacanies below)
Some other information is given to us because you accessed this website (e.g. logs, or recorded through cookies). This is explained in the Cookies section below.
When we ask for such personal data, you may always decline, however should you decline to provide us with necessary data that we require to provide the requested services, we may not necessarily be able to provide you with such services.
The sub-section below provides further explanation on how and why we use this information.
The table below clearly describes in a plain and concise manner what we use your personal data for and the legal ground(s) for doing so.
| The purpose of the processing | Personal Data | Legal Basis |
| To manage our relationship with you. |
|
Performance of a contract |
| To provide you with the best personalised customer service and support. | Your consent | |
| Knowing what you and other customers like to ensure we are giving you what you want and staying ahead of the competition. | Legitimate interest | |
| Fraud Prevention and detection. | Legal obligation | |
| To improve our website, set default options and give you the best user experience.
To ensure the security of the website (for example, for statistical, testing and analytical purposes, troubleshooting) |
|
Legitimate interest |
The above categories of personal data are collected directly from you.
We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data. The criteria we use to determine what is ‘necessary’ depends on the particular personal data in question and the specific relationship we have with you.
We may also keep hold of some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
As a guide:
You may obtain more information as to the retention periods or the criteria used by us to determine the retention periods by contacting us on [email protected].
If you are less than 18 years old, please get your parent/guardian’s permission before you provide any personal information to us.
In that case, we will need to process personal data relating to parents or guardians – and we may also need to request verification documentation to ensure that consent is given or authorised by the holder of parental responsibility.
We do not, and will not, sell any of your personal data to any third party – including your name, surname, email address or any other information you provide to us. It is not our business to do so – and we want to earn your trust and confidence.
Any data will be disclosed or shared as appropriate in line with the Data Protection Laws and the purposes listed in this Privacy Policy.
Besides sharing your data with members and staff of Harvest Technology plc, we share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out below:
1. Companies in the group to which Harvest Technology plc belongs as sometimes different entities within our group are responsible for different activities (especially licensed ones). This includes Harvest Technology plc related entities/subsidiaries and members of 1923 Investments plc (our holding company) as well as Hili Ventures Group (our mother group). Related entities and subsidiaries use the information collected to:
i. help us improve the content and functionality of our websites;
ii. better understand our customers and markets;
iii. improve our products and services.
Members of the group vary from time to time.
2. Other companies that are involved in the process of getting your purchases from us to you, such as payment service providers, warehouses, order packers, and delivery companies.
3. Professional service providers, such as marketing agencies, advertising partners and website hosts who service us in turn to operate our business.
4. Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud.
5. Other companies that you may approve, such as social media sites (if you choose to link your accounts to us) or payment service providers.
In most circumstances we will not disclose personal data without consent. However there may be occasions where we might have to – e.g. with a court order, to comply with legal requirements and satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our subsidiaries and related entities.
When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended – again, we don’t want you to have any surprises.
We may also provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you. Anonymous information means it is anonymous and you will not be identified through this data.
If we ever have to share data with entities that are outside of the EEA, we will be sure to do so in a manner that complies with the requirements established by the GDPR.
A cookie is a small text file (typically numbers and letters) that is downloaded onto ‘terminal equipment’ (e.g. your computer or smartphone) when you (or someone else) accesses a website using that device. Cookies are then sent back to originating website on each subsequent visit – and they are useful because they allow a website to recognize a user’s device and store some information about your preferences or past actions.
Some cookies are needed for the sole purpose of carrying out the transmission of a communication over an electronic communications network – others may be necessary for the provision of a service over the internet, in which case they have to be used.
Other cookies may be desirable to improve your experience, in which case we will ask you for your consent to use them.
We use are the following cookies:
| TYPE | PURPOSE | WHO SERVES THEM |
| Analytics cookies | These are used to understand, improve, and research users visiting our website and their needs to improve our website’s user experience. For example, we may use cookies to understand what pages a user browses before submitting using the contact form. We do not share information about this analysis with any third parties. |
Google Analytics cookies: _ga, _gat, _gid We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page. |
| Necessary cookies | These are used as an extra layer of security.
Cloudflare cookies: __cf_bm, cf_clearance Laravel cookies: Laravel_session, XSRF-token Cloudflare is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis. |
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
Apart from the information you provide us with when using our Website, other information is passively collected from you (without you actively furnishing such information) when you navigate through the website. We use various technologies and navigational data collection methods to gather such passive information for various reasons, for example to track how many visitors access our website, the date and time of their visit, the length of their stay and which pages they view. The passive information also aids us to determine which web browsers our visitors use and the address from which they accessed our website – for instance if they connect to our Website through clicking on one of our banner ads. This technology does not identify you personally.
Such passively collected information may be used and combined to improve our services to website visitors, customise the website based on user preferences, compile and analyse statistics and trends of our visitors and their use of the sites operated by us and our related entities or subsidiaries.
We assure you that, unless you have consented, such passive information shall not be combined with personally identifiable information collected elsewhere by our website or respective sites operated by our related entities or subsidiaries.
Our website includes a section with which candidates may submit their information for vacancies we have.
We are the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information, please contact us at data [email protected]
All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements where necessary.
We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.
We will use the contact details you provide to us, to contact you to progress your application.
We will use the other information you provide to assess your suitability for the role you have applied for.
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. The information we ask for is used to assess your suitability for employment.
You don’t have to provide all the information that we ask for, but it might affect your application if you don’t – as your application will be incomplete.
If you use our online application system, the information you give us will be collected by our recruitment section. This may mean that it will be processed by us, or by the Human Resources department of the affiliated companies within the Harvest Division.
We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.
Once we receive your application, the applications will be assessed for suitability for the post and the application passed to the relevant manager or department head for assessment and shortlisting for interview.
We might ask you to participate in further recruitment tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us and if so, this information is held by us for the recruitment exercise and perhaps afterwards if you are selected.
If we make a conditional offer of employment we may ask you for information so that we can carry out pre-employment checks – which may be required to seek assurance as to trustworthiness, integrity and reliability and the possibility to work with us. Further processing of your information would be required if we are to apply for a work permit.
Depending on the job requirements, you may be required to provide: Proof of your identity; Proof of your qualifications; References from past Employers; Police Conduct; and declaration of any unspent convictions.
We may also ask you to provide a certificate issued by a medical professional in order to ensure that you are fit for work in advance. If we make a final offer, we will also ask you for the following:
Final recruitment decisions are made by hiring managers and members of our recruitment team. All of the information gathered during the application process is taken into account.
If you are unsuccessful following assessment for the position you have applied for, we will promptly delete your application documents.
If you are employed with us, we will keep your personal data throughout the employment and for a period after that in accordance with our HR procedure.
Before addressing any requests you make with us, we may first need to verify your identity. In all cases we will try to act on your requests as soon as reasonably possible.
You enjoy several rights relating to your personal information. In certain circumstances, the following rights may be available to you and you may exercise these rights by sending a request to us. Where these rights are not available to you and we cannot fulfil them, we will inform you of this and provide our reasons for such refusal.
We need to be clear with you about how we process your personal data. We do this through this Privacy Policy, which we will keep as up to date as possible.
You can access the personal data we hold on you by filling the relevant form below and sending it to [Name of Company] by email: dataprivacy@XXXXXXXX} or deliver to the Data Protection Officer at [Company Name] , Nineteen Twenty Three, Valetta Road, Marsa MRS 3000 Malta.
We appreciate feedback from you to ensure our records are accurate and up-to-date.
If you think that the information we hold about you is inaccurate or incomplete please fill in the relevant form below and send it to [Name of Company] by email: dataprivacy@XXXXXXXX} or deliver to the Data Protection Officer at [Company Name] , Nineteen Twenty Three, Valetta Road, Marsa MRS 3000 Malta.
You can ask us to delete your personal data; however, this is not an absolute right.
In spite of such a request we may be justified in refusing your request and keep personal data which we are required to keep, e.g. (i) to comply with a legal obligation (for instance, we are required by personal data for VAT reporting purposes); and (ii) in relation to the exercise or defence of any legal claims.
When you ask us to delete your personal data, we assume that you do not want to hear from us again.
If you would like to exercise your right to be forgotten, please fill in the relevant form below and send it to [Name of Company] by email: dataprivacy@XXXXXXXX} or deliver to the Data Protection Officer at [Company Name] , Nineteen Twenty Three, Valetta Road, Marsa MRS 3000 Malta.
Other than as described above, we will always comply with your request and do so promptly. We would carry out our best efforts to notify any third parties with whom we have shared your personal data about your request so that they could also comply.
You may ask us to restrict (that is, retain but not process further) your personal data. Upon requesting us to restrict further processing of your data we may not necessarily be able to provide you with further services that we offer.
Following your request for restriction, except for retention of your personal data we may only process your personal data:
You have a right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling using automated means. Where an objection is entered, the processing of data shall cease, unless we as data controller provide compelling and legitimate grounds requiring the continuation of the data processing which outweigh the objections you may have raised.
For the avoidance of all doubt, when we process your personal data in relation to the performance of a contract, our legal and compliance obligations or when processing is required to protect your vital interests or those of other natural persons, this right to object shall not subsist.
You have the right to withdraw your consent at any time in the same manner that you provided it to us. Should you exercise your right to withdraw consent at any time by writing to us at dataprivacy@[Company name] , we will determine whether at that stage an alternative legal basis exists for processing your personal data ( for example on the basis of a legal obligation to which we are subject) where we would be legally authorised, to process your personal data without needing you consent. Should this be the case we will notify you accordingly.
You have the right to move, copy or transfer your personal data from one organisation to another. If you do wish to transfer your personal data we would be happy to help.
If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation.
Please note that we are not required to adopt processing systems that are compatible with other organisations, so it may be that the recipient organisation cannot automatically use the personal data we provide.
When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.
If you want to exercise your rights, submit a complaint, or just have questions, please contact us on the e-mail address above.
Security of your personal data is very important to us.
Where it’s appropriate, our website uses HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.
To help protect the privacy of data and personally identifiable information you entrust us with, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
Security measures which we have implemented to secure information transmitted over our website, or stored on our systems include the following :-
1. Use of secure servers
2. Use of firewalls;
3. Use of encryption;
4. Physical access controls at data centres
5. Information access controls;
6. Use of back-up systems;
Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.
Our website is continually under review– new functions and features are periodically added and improved to interface, thus changes to our privacy policy may be required from time to time.
We therefore encourage you to check our privacy policy on a frequent basis.
This privacy notice does not cover the links within this site linking to other websites which are not controlled by us. We are not responsible for the collection or use of your personal information from these third-party websites.
Therefore, we encourage you to read the privacy statements on the other websites you visit.
[Company name] may hold conferences and events from time to time. At such events, we may take pictures or videos of attendees. The legal basis for such processing is the Company’s legitimate interest to build a community and promote its programs and activities. To this end, we have completed a legitimate interest assessment, a copy of which is available upon request.
You have the right to object to such processing at any time by contacting the event organisers or getting in touch with us on [dataprivacy@XXXXXXXX]. The photos and videos may be shared with other
group companies. The photos and videos will be stored by the Company for a period of five (5) years from the date of the event. With respect to the data collected to note your attendance to these events, we will delete it 2 years after the event, unless you have a direct working relationship with [Company Name].
You will always be informed in advance of such processing and should contact the event organizers should you prefer not to feature in photos and videos taken at an event. Should you wish to exercise any of your rights in relation to your personal data, please refer to the section above entitled “Your Rights”. Should you have any queries about how we process your data, please contact us on [dataprivacy@XXXXXXX]
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