PRIVACY POLICY

 

The following privacy policy provides an overview how your data is recorded and processed.

With the following information, we would like to give you an overview of how we process your personal data as well as your rights under the Data Protection Act. What specific data is processed in detail and how it will be used depends on the requested or agreed services.

 

1. Who is responsible for data processing and who can I contact?

Contact details as follows: 

GRENKE Renting Ltd.
Tagliaferro Business Centre, Level 2
Gaiety Lane c/w High Street
SLM1551, Sliema
Phone: +356 2258 8500
Fax: +356 2258 8509  

 

You can reach our operational data protection officer at: 

GRENKE Renting Ltd.

Data Protection Officer

Tagliaferro Business Centre, Level 2 Gaiety Lane c/w High Street

SLM1551, Sliema Malta

E-mail: [email protected]

 

2. What sources and data do we use? 

We process personal data that we receive from our customers as part of our business relationship. In addition, we process – as far as necessary for the provision of our services – personal data that we might collect from publicly accessible sources (e.g. debtor directories, land registers, trade and association registers, press, internet) or that was obtained from our distribution partners or from other third parties (e.g. a credit agency). 

Relevant personal data includes

• Personal details (name, address, birthday, place of birth and nationality)
• Contact details (telephone, e-mail address)
• Verification data (e.g. ID data)
• Authentication data (e.g. signature sample)
• Order data (e.g. payment order)
• Data from the fulfilment of our contractual obligations (e.g. sales data in payment transactions)
• Information about your financial situation (e.g. creditworthiness data, scoring/rating data, source of assets)
• Advertising and sales data (including advertising scores), documentation data (e.g. consultation minutes)

 and other data comparable to the aforementioned categories.

3. What do we process your data for (purpose of processing) and on what legal basis? 

We process personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and the Data Protection Act (Chapter 586 of the Laws of Malta) as may be amended from time to time.

a. For the fulfilment of contractual obligations (Article 6 (1) (b) of the GDPR) 

Data is processed in order to provide the relevant services as part of the execution of our contracts with our customers or to carry out pre-contractual actions, which are car-ried out upon request. The purposes of data processing are primarily geared towards the specific product and may include, but are not limited to, needs analysis, consulting and to perform transactions.

b. As part of the balance of interests (Article 6 (1) (f) of the GDPR)

As far as necessary, we process your data beyond the actual fulfilment of the contract for the protection of our legitimate interests or those of third parties, in particular: 

 

• Consultation and exchange of data with credit agencies  to identify credit risk or default risk

 

• For the purposes of examining possible credit risks and default risks as well as preventing criminal offences, we provide Creditinfo Malta Limited, 199, Eucharistic Congress Road, Mosta MST 9036, Malta, with data on the application and the applicant. Creditinfo Malta Limited will provide us with da-ta stored on your person if we have credibly demonstrated our legitimate interest.

 

• In addition, we transfer personal data collected in the context of this contract concerning the application, execution and termination of this business relationship which includes the transfer of data for debt collection purposes, as well as, data on non-contractual or fraudulent behaviour to Creditinfo Malta.

 

• The legal bases of these transfers are Article 6 (1) (b) and Article 6 (1) (f) of the GDPR. as well as Art. 6 (1) (a) GDPR. Transfers on the basis of Article 6 (1) (f) of the GDPR may only be made to the extent necessary to safeguard our legitimate interests or those of third parties and provided these interests do not outweigh the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data.

 

• The data exchange with the credit bureaus also serves the fulfilment of legal obligations to carry out creditworthiness checks of customers.Credit agencies process the data obtained and also use it for the purposes of profiling (scoring) in order to provide their contractors in the European Economic Area and in Switzerland and, where applicable, other third-party countries (if there is an adequacy decision by the European Commission) with information in order to, inter alia, make assessments on the creditworthiness of natural persons.

 

• Detailed information according to Article 14 of the GDPR on the activities of the credit agencies can be found for the respective credit agency following the link https://mt.creditinfo.com/privacy-policy/.

 

• Review and optimisation of requirements analysis procedures for direct customer contact.

 

• Optimisation and needs-based design of the website.

• Advertising or market and opinion research, provided that you have not objected to the use of your data.
• Asserting legal claims and defence in legal disputes.

 

• Ensuring the IT security and IT operation of our company.

 

• Use of personal data in testing situations where it is not possible to use dummy data.

 

• Prevention and investigation of criminal offences.

 

• Video surveillance for the protection of domiciliary rights, and for the collection of evidence in cases of robbery and fraud. 

 

• Measures for building and plant safety (e.g. access control).

 

• Measures to safeguard domiciliary rights.

 

• Measures for business management and further development of services and products.

 

c. On the basis of your consent (Article 6 (1) (a)  GDPR)

Insofar as you have given us your consent to process your personal data for specific purposes (e.g., disclosure of data within the Group, or analysis of payment transaction data for marketing purposes), the legality of this processing is assured on the basis of your consent. Consent that has been issued can be revoked at any time. This also applies to the revocation of declarations of consent that were issued to us before the GDPR came into effect, i.e. before 25 May 2018. The revocation of consent does not affect the legality of the data processed until the revocation.
 
d. Based on legal requirements (Article 6 (1) (c) GDPR), legitimate interests (Art. 6 para. 1 f GDPR)  or in the public interest (Article 6 (1) (e)  GDPR)

 In addition, we are subject to various legal obligations, i.e. legal requirements (e.g. the Money Laundering Act, and tax laws). The purposes of the processing include, but are not limited to, the creditworthiness check, identity and age checks, prevention of fraud and money laundering, the fulfilment of tax auditing and reporting obligations, and the assessment and management of risks.

 

4. Who receives my data?

Within our organisation, the entities that gain access to your data are those who need it in order to fulfil our contractual and legal obligations. Our service providers and vicarious agents may also receive data for these purposes. These are companies in the categories of financial services, IT services, logistics, printing services, telecommunications, debt collection, advising and consulting, as well as sales.

With respect to the disclosure of data to recipients outside our company, we may only disclose information about you if we are required to do so by law or if you have given us your consent to do so. Under these conditions, recipients of personal data may be, for example:

 

• Public authorities and institutions (e.g. the tax and law enforcement authorities) in the presence of a legal or regulatory obligation.
• Other credit and financial services institutions or
• comparable institutions to which we transfer personal data over the course of our business relationship with you (depending on the contract, e.g. credit agencies).
• Other companies within the group
• for risk management due to legal or regulatory obligations.

 Other data recipients may be those to whom you have given us your consent for your data to be submitted.

 

5. Is data transmitted to a third-party country or to an international organisation?

A transfer of data to bodies in countries outside the European Union (so-called third-party countries) takes place, as far as:

 

• this is required in order to execute your orders (e.g. payment orders),
• this is required by law (e.g. in order to comply with tax reporting obligations), or
• you have given us your consent.

 

6. How is my data processed on the website?

 

Unless otherwise stated, we process your data on our website either to action your request (Article 6 (1) (b) GDPR) or based on our legitimate interests (Article 6 (1) (f) GDPR) as follows:

a. Usage data

Every time you access a page and retrieve a file, this process automatically saves general data to a log file. The storage is exclusively system-related and is purely for security purposes or to report criminal offences in exceptional circumstances.

 The data is stored in httpd access logs in the data centers of our service provider Bloomreach and can be accessed in case of legitimate interest.  

A transfer of data to third parties or any other evaluation does not take place, unless there is a legal obligation to do so. Data will be deleted automatically after 4 weeks retention time.

In detail, the following data record is saved for each access:

 

• Device used
• Name of the accessed file
• Date and time of access
• Time zone
• Transferred data volume
• Report as to whether the access was successful
• Description of the type of web browser used
• Operating system used
• The previously visited site
• Provider
• User's IP address

We do not save your browser history. 

b. Contact forms

In order to be able to give you the best possible advice as part of a request via our contact forms, the appropriate group company that is best suited to respond to your request will be identified after inquiring about your specific interest at the top of the page. If you contact us (e.g. via contact forms), the designated company will save your data in order to process your request (Article 6 (1) (b) GDPR) or in case any further correspondence is required.

If you expressly agree to be contacted by e-mail, telephone or post (according to Art. 6 Para. 1 a GDPR) within the scope of the contact form, you grant grenke RENTING LTD the opportunity to inform you in future by telephone, e-mail or post about current products and services, in the selected category. We may also store your data for the purpose of sending you our newsletter. In addition, we store your email address and the date of your registration in order to be able to prove your newsletter subscription in case of doubt. The legal basis for this processing is Article 6 (1) (c) GDPR, as we are legally obliged to provide evidence of registrations. You can object to the use of your data for advertising purposes at any time or unsubscribe from the newsletter at any time by clicking on the unsubscribe link in the footer of the newsletter. 
 
If you do not give your consent to the subscription of our newsletter, your data will be deleted after your request has been processed. Excluded from this is data for which legal or otherwise prescribed storage obligations exist.

Within the framework of our contact forms we work with the Eloqua, a service of the provider ORACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, The Netherlands. For further information on the use of Eloqua, please refer to the additional notes under g.
 

c. Registration

The data provided during registration will only be used by us to enable you to use our services (Article 6 (1) (b) GDPR). 

We collect the following data for the registration process:

 

• E-mail address
• User name
• Password

 

d. Newsletter

We are happy to inform you on the basis of your consent (Article 6 (1) (a) GDPR) about the latest news with our newsletter.

In order to receive the newsletter, you must enter your name and e-mail address. You can also enter and submit further optional information. After you have submitted your e-mail address, you will receive an e-mail from us to the e-mail address you have specified, in which you must click a confirmation link to verify the e-mail address you provided.

 

Your data will be stored by us only for the purposes of sending our newsletter. In addition, we store your email address and the date of your registration in order to be able to prove the newsletter subscription in case of doubt. The legal basis for this processing is Article 6 (1) (c) GDPR, as we are legally obliged to provide evidence of registrations. In addition, in order to measure the success of our newsletter, we collect data on whether the newsletter is opened, when it is opened and which links are clicked.

For the delivery of our newsletter we work with the Eloqua service of the provider ORACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, The Netherlands. Newsletters sent with the help of Eloqua use tracking technologies. We use this data primarily to find out which topics are of interest to you by tracking whether our emails are opened and which links you click on. We then use this information to improve the e-mails we send you and the services we provide, and to link them to existing tracking or profiling information. We will not be able to track your emails if you have disabled the display of images in your email program by default. In this case, however, the newsletter will not be displayed in full and you may not be able to use all the features. If you display the images manually, the above-mentioned tracking will take place. For further information on using Eloqua, please refer to the additional notes under g.

You can unsubscribe from the newsletter at any time by clicking the unsubscribe link at the bottom of the newsletter.  

 

e. Use of cookies

aa) General information

In order to make your visit to our websites more pleasant and to enable the use of certain functions, we use so-called cookies on various sites. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your device and allow us or our affiliates to recognise your browser on your next visit (so-called persistent cookies).

 Cookies cannot access other files on your computer or identify your email address.

bb) Use of cookies

Like most websites you visit, our website also uses cookies to improve the user experience on both one-time and repeated website visits. This allows you to quickly and easily switch between sites, save your configurations, and use third-party tools (such as YouTube videos) on the website.

 Cookies are either placed on our website (first party cookies) or on other websites whose content appears on our website (third-party cookies). These third-party providers (such as Facebook) may set cookies if you are logged in to their pages and visit our website. We have no influence on the cookie settings of these websites. Please visit the third-party websites for more information on their use of cookies.

cc) Legitimacy of the storage of cookies

The essential and functional cookies are stored on the basis of our legitimate interests (Article 6 (1) (f) GDPR) for the optimisation and needs-based design of our website.

 

Statistical cookies and cookies for marketing purposes are stored on the basis of the user's consent (Article 6 (1) (a) GDPR). These cookies are therefore only set if the user agrees to the storage by issuing their consent to the cookie notification on the website.

dd) Deactivating and deleting cookies

The setting you choose on the first visit in response to the cookie notification will be saved. The selected settings can be adjusted here in the privacy settings at any time.

 

Most browsers are otherwise set to automatically accept cookies. If the default settings for cookies are stored in your browser, all processes run in the background without any notifications. However, you can change these settings at any time.

 

You can set your browser so that you are informed about the setting of cookies and can decide on a case-by-case basis whether they are to be accepted or deactivated for specific cases or in general.

 

A general objection to the use of cookies for marketing or advertising purposes can be issued for a variety of services via the website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the prevention of cookies can be achieved by switching them off in your browser settings. Please note that this may mean you won’t be able to use all the features of this website.

 

Statistical cookies

 

Statistical cookies collect information about the use of a website – such as the user’s most frequently visited pages and whether the user receives error messages when using a website. These cookies do not store information that allows the user to be identified. The information gathered is pooled and therefore evaluated anonymously. These cookies are used exclusively to improve a website's performance and thus the user experience.

 

f. Range analysis using Piwik

 

If you consent (Art. 6 Para. 1 a GDPR), we use Piwik, a software for statistical evaluation of user access.

 

Your IP address will be hashed before it is saved. However, Piwik uses cookies that are stored on users' computers and enable the user’s use of the website to be analysed. In this case, pseudonymous usage profiles of the users can be created from the processed data. The information generated by the cookie regarding your use of this online content is stored on our server and not passed on to third parties. 

 

You can revoke your consent to this data processing as follows:

g. Use of Eloqua

We use the Eloqua service to collect statistical data about the use of our website, to send our newsletters and to optimize our services accordingly. The Eloqua servers of the supplier ORACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, Netherlands are located in the EU.

 

If you have consented to the use of cookies for marketing purposes, Eloqua will use corresponding cookies that are stored on your computer and that enable an analysis of the use of the website (hereinafter referred to as usage behavior) If you have already used a website that uses Eloqua, you may already have an Eloqua cookie. Even if this cookie is set on other websites, the information from your visit to our websites is only visible to us and is not shared with Oracle or any other users of the Eloqua system. It is also not possible for us to use this cookie to record or view information about your visits to any other websites.

 

If you enter personal data (e.g. in the contact form) during your visit to the website, these data will be processed with the usage behavior in order to offer you content on the website and in our newsletter that is geared to your interests, as well as to be able to send you news and information about our company or our range of services based on your data, which are geared to your individual interests. For this purpose, it is technically necessary that we combine your accrued and given data in user profiles and evaluate them for the aforementioned purposes. This is done internally and only for the aforementioned purposes.

 

The legal basis for the  evaluation of the use of our website is your consent (Article 6 (1) ( a ) GDPR, which you may have given us in the course of using our website.

 

The information generated by the cookie about your use of this website is transferred to a server and stored there. On our behalf, Eloqua uses this information to evaluate your use of the website and to compile reports on website activity. If you wish to prevent the use of Eloqua cookies or the evaluation of usage behavior on your device in the future, this is possible via the following link: Eloqua Opt-Out .

 

You can find further information on data protection in connection with the use of Eloqua here: Oracle Privacy Policy.

 

h.Integration of Google Maps
 

We integrate the maps of the service "Google Maps" provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The data processed may include, but is not limited to, the IP addresses and location data of users, which, however, are not collected without their consent (usually performed as part of the settings of their mobile devices). Unless you have expressly consented to the use, our legal basis for this data processing is our legitimate interest (Art. 6 Para. 1 S. 1 lit. f DS-GVO) in order to design our website to meet your needs. The data could also be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated

 

i. Integration of YouTube videos

 

aa) Processed data

We have embedded YouTube videos on our website, which are hosted by YouTube but can be played directly from our website. These are all embedded in "extended data protection mode", i.e. according to YouTube's own statement, the playback of a video is not used for the personalisation of advertising to the user. However, we have no influence on this. YouTube is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

 

In order to increase the protection of your data when visiting our website, the videos are initially deactivated and integrated into the page using a so-called "2-click solution". This integration ensures that when you call up a sub-page of our website that contains such videos, no connection is established with the YouTube servers. Only when you activate the videos does your browser establish a direct connection to the YouTube servers.

 

By activating the video, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, basic data such as IP address and time stamp are transmitted. This takes place regardless of whether YouTube provides a user account via which you are logged in or whether no user account exists. If you are logged in to YouTube, your data will be directly assigned to your account. If you do not want your data to be associated with your YouTube profile, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research and/or designing their website to meet your needs. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, and to exercise this right you must contact YouTube or Google, e.g. at https://about.google/contact-google/.

 

The information collected is stored on Google servers, also in the USA as an unsafe third country. For these cases, the provider claims to have set itself a standard that corresponds to the former EU-US Privacy Shield and has promised to comply with the data protection laws applicable to the international transfer of data. We have also agreed so-called standard contractual clauses with YouTube, the purpose of which is to maintain an appropriate level of data protection in third countries.

 

For more information on the purpose and scope of data collection and processing by YouTube, please see Google's privacy policy. There you will also find further information on your rights and setting options to protect your privacy: www.google.de/intl/de/policies/privacy.

 

bb) Purposes of the processing of data

The data is processed and transmitted for the purpose of integrating and displaying YouTube videos.

 

cc) Legal basis

The legal basis for the display of the videos is consent, thus the integration only takes place after your consent.

 

dd) Duration of storage and control options

We store your data as long as we need it for the respective purpose, or as long as you have not objected to the storage of your data or have revoked your consent.

If you do not want data to be processed by YouTube, you can refuse or revoke your consent in this respect.

 

7. How long will my data be stored? 

 

Unless explicitly stated in this privacy statement, the usage and registration data stored with us is deleted as soon as it is no longer required for its intended use and the deletion does not conflict with any statutory retention obligations.

 

We process and store other personal data as long as it is necessary for the fulfilment of our contractual and legal obligations. It should be noted that our business relationship is a continuing obligation, which is designed to last for years. If the data is no longer required for the fulfilment of contractual or legal obligations, it is regularly deleted, unless its - temporary - further processing is necessary for the following purposes:

 

• Fulfilment of commercial and tax-related retention obligations which emanate from the Companies Act (Cap 386), the Income Tax Act (Cap 123) and the Prevention of Money Laundering Act (Cap 373) including their relevant subsidiary legislation.
• Preservation of evidence in the context of the statutory limitation periods, in terms of the Civil Code.

 

8. Which data protection rights do I have?
 

Every affected person has with respect to us

• the right of access under Art. 15 GDPR,
• the right to rectification under Art. 16 GDPR,
• the right to erasure under Art. 17 GDPR,
• the right to restriction of processing under Art. 18 GDPR,
• the right to object from Art. 21 GDPR,
• and the right to data portability under Art. 20 GDPR.

 

In addition, there is a right to lodge a complaint with a competent data protection supervisory authority (Article 77 GDPR) as well as the right to file a sworn application before the First Hall of the Civil Court (Malta) (Article 30 of the Data Protection Act – Cap 586).

You may revoke your consent to the processing of personal data at any time. This also applies to the revocation of declarations of consent that were issued to us before the GDPR came into effect, i.e. before 25 May 2018. Please note that the revocation is only applicable for the future. Processing that took place before the revocation is not affected.

 

9. Am I obligated to provide data?

 
As part of our business relationship, you must provide the personal data required in order to enter into a business relationship and perform its associated contractual obligations, or the personal data that we are required to collect by law. Without this information, we will generally not be able to conclude or execute the contract with you.
 
In particular, according to the money laundering regulations, we are obligated to identify you prior to entering into a business relationship with you on the basis of your identification document and to record and save your name, place of birth, date of birth, nationality, address and identification data. In order for us to be able to fulfil this legal obligation, you must provide us with the necessary information and documents in accordance with the Money Laundering Act and immediately notify us of any changes during the course of the business relationship. If you do not provide us with the necessary information and documents, we may not enter into or continue your desired business relationship.

 

 

10. To what extent is there an automated decision-making process?

 

In principle, we do not use any fully automated decision-making processes pursuant to Art. 22 GDPR in order to justify or maintain the business relationship. If we do use these procedures in individual cases, we will inform you about this separately, if this is required by law.

 

 

 

11. Does profiling take place?

 We sometimes process your data automatically with the aim of evaluating certain personal aspects (profiling). For example, we use profiling in the following cases:

• Due to legal and regulatory requirements, we are committed to combating money laundering, the financing of terrorism, and property-related offences. At the same time, data evaluations are also carried out (inter alia in payment transactions). These measures are also in place for your protection.
• In order to provide you with targeted information and advice on products, we use evaluation tools. These enable needs-based communication and advertising, including market and opinion research.
• We use the scoring to assess your creditworthiness. This calculates the probability with which a customer will meet their payment obligations in accordance with the contract. The calculation may include, for example, income, expenses, existing liabilities, occupation, employer, duration of employment, past business experience, past repayment of the loan, and information from credit reporting agencies. The scoring is based on a mathematically-statistically recognised and proven procedure. The calculated scores help us make decisions within the context of product sales and are part of ongoing risk management.