AvatarUX website (www.avatarux.com) (hereafter referred to as the ‘Website’) respects the privacy of all parties viewing and otherwise making use of the Website, (hereafter referred to as ‘you’, ‘your’ or the ‘Visitors’), and is committed to protecting their privacy. The Website may collect and use ‘Personal Data’ (defined below) relating to its Visitors in order to provide them with the services provided by the Website and only for any purpose which has been expressly stated hereunder.
The controller of data collected and used from Visitors of the Website is Epic88 LTD (hereafter referred to as the “Controller”) and is responsible for this Website.
The Controller and the Provider (defined below) can be contacted on firstname.lastname@example.org
1. Purpose of this Policy
The purpose of this Policy is to:
● set out the type of Personal Data the Controller will collect from you and how we will use your personal information;
● the basis on which any Personal Data is processed by the Controller;
● make you aware of how the Controller will handle your Personal Data;
● clarify the Controller’s obligations under the data protection regulations with regards to processing your Personal Data lawfully and responsibly; and
● inform you of your data protection rights,
The Controller processes your Personal Data in an appropriate and lawful manner, in accordance with applicable data protection regulations and the General Data Protection Regulation EU 2016/679 (the “GDPR”) which is in force as of 25 May 2018.
2. Collection of Personal Data
2.1 What data is collected and how is it collected?
Visitors are under no obligation to provide their Personal Data or to permit their Personal Data to be collected by the Website. However, the Website may not be able to provide the Visitors not consenting to the collection of their Personal Data with all services offered by the Website.
Although Visitors may have consented to the Website using their respective Personal Data, they are entitled to subsequently revoke their respective consent for whatever reason by contacting email@example.com or by using the unsubscribe options available. In case of revocation of consent, the additional or advance services provided on the Website after registration will no longer be available.
3. Your Rights as a Data Subject
The Provider would like to make sure you are fully aware of all of your data protection rights. Every Visitor is entitled to the following:
3.1 Right to Access
Visitors are entitled to request that the Controller provides them with written information on which of their respective Personal Data it has collected and/or used. A request can be made by submitting a request in writing to the Controller.
The Website undertakes to make all reasonable efforts to keep the Personal Data collected updated. However, Visitors are invited to inform the Controller of any changes to their Personal Data which is held by the Website.
3.2 Right to rectification
You have the right to obtain rectification of any inaccurate Personal Data about you that we have processed, update any data which is out-of-date and the right to have incomplete Personal Data completed, including by means of a supplementary statement.
Visitors also have the right to request the Controller to block or delete their respective Personal Data if it has been processed unlawfully.
3.3 Right to erasure
You have the right to obtain the erasure of Personal Data we have concerning you when your personal data is no longer required where:
● you withdraw your consent to us processing your Personal Data;
● your Personal Data no longer needs to be processed; or
● your Personal Data has been unlawfully processed.
3.4 Right to Restriction of Processing
You have the right to restrict our processing activities where:
● you consent the accuracy of this Personal Data, for a period enabling us to verify the accuracy of the same Personal Data;
● our processing is deemed unlawful, and you oppose the erasure of your Personal Data and request restriction of its use instead;
● we no longer need your Personal Data for the purposes stated herein, but you require it for the establishment, exercising or defending of legal claims; or
● you have objected to our processing pending the verification whether the legitimate grounds of our processing activities overrode those pertaining to you.
3.5 Right to object to processing
You may contact us at any time at firstname.lastname@example.org to ask us not to process your Personal Data for marketing purposes e.g. receiving information from us about upcoming events, newsletters and publications and your data will no longer be processed for such purposes.
3.6 Right of Data Portability
As from 25 May 2018, you have the right to receive your Personal Data in a structured and machine-readable format and transmit this data to another controller (as defined in the GDPR).
3.7 Right to withdraw consent
You have the right to withdraw your consent to this Policy, and the processing practices described herein, at any time by sending an email to email@example.com. This will not affect the lawfulness of processing which we carried out on the basis of such consent before its withdrawal. Withdrawal of consent will result in us having to terminate our services immediately.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: firstname.lastname@example.org.
4. Purposes for the collection and use of Personal Data and its storage
The Personal Data collected by the Website shall be processed in accordance with the provisions of the Data Protection Act (Chapter 440 of the Laws of Malta) and subsidiary legislation enacted thereunder and solely processed for the purposes of:
1. Communicating with the Visitors;
2. Sending Visitors new password to their respective personal account;
3. Providing any advanced services which are possible to configure the Website to some extent;
4. Improving the content offered by the Website;
5. Providing Visitors with personalised Website content and/or layout,
5. Legal basis for processing
We shall only process your Personal Data where you have provided your consent or insofar as this is necessary for us to be able to provide the services we offer and/or for the Purposes indicated in this Policy.
We may also process your Personal Data collected in any manner mentioned in this Policy on the basis of any legitimate interest or in order to comply with any legal obligations at law. This may include the exercise of defence of legal claims or in order to comply with an order of any court, tribunal or authority.
You will receive marketing communication from us if you have requested such marketing information from us by providing us with your details through the Website and have opted-in to receiving such information. If you agree to receive marketing information from us, you may always opt out at a later date. If you no longer wish to be contacted for marketing purposes, please unsubscribe through the options available.
We will not share your Personal Data with any third party for marketing purposes without your unambiguous consent.
7. Disclosure of Personal Data to third parties
The Provider does not sell, trade or rent or otherwise disclose Personal Data appertaining to Visitors to any third party without their prior respective unambiguous consent. However, Personal Data would be disclosed to third parties in the eventuality of the Provider being involved in a bankruptcy, merger, acquisition, reorganisation, or sale of assets including a sale of the Website.
The above is without prejudice to any legal obligation incumbent on the Website to disclose Visitors’ Personal Data to third parties.
The above is also without prejudice to disclosures which are absolutely necessary as part of one or more of the Purposes for collecting and using Personal Data. In this case the Website shall seek the prior express consent of the Visitors concerned.
The Provider reserves the right to provide statistics about Visitors, sales, traffic, and other statistical information relating to the Website to third parties, however, without identifying any particular Visitor.
8. Log Files
In order to better administer the Website and to collect broad demographic information of Visitors for aggregate use, the Website automatically logs the IP address of all Visitors and the pages viewed by each Visitor respectively.
9. Cookie Disclaimer
10. Transfers of Personal Data to Third Countries
As a general rule, the Information we Process about you will be stored and Processed within the European Union (EU)/European Economic Area (EEA) or any other non-EEA country deemed by the European Commission to offer an adequate level of protection. Nonetheless, in some cases, it may be necessary for us to transfer your Information to a non-EEA country not considered by the European Commission to offer an adequate level of protection. In such cases, apart from all appropriate safeguards that we already implement to protect your Information, we have in place additional adequate measures such as ensuring that the recipient is bound by the EU Standard Contractual Clauses (the EU Model Clauses) designed to protect your personal information as though it were an intra-EEA transfer.
The Website and the Controller have adopted various measures, both technical and organisational, to help protect communication against the destruction, loss, misuse and alteration of Personal Data which has been collected and used (including ensuring that any transfers of data are secured) through Secured communication between Visitor’s device and Provider’s servers “HTTPS”. Additionally, all passwords you set up are stored using BCrypt standard. Notwithstanding these efforts, the Provider cannot guarantee that such event will not occur.
12. The period for which Personal Data is kept
The Personal Data is kept only for the time period required to meet the Purposes for which it was collected. In case of user account inactivity for one (1) year, all collected user Personal Data will be deleted.
13. Third party websites/apps
The Provider is Epic88 LTD of 56, Innovation Centre, Level 1, Tower Street, Swatar, Birkirkara BKR 4011, Malta (herein referred to as the “Provider”, “we”, “us” or “our”). To contact us, please email us at email@example.com
16. How to contact the appropriate authority
Should you wish to report a complaint or if you feel that the Provider has not addressed your concern in a satisfactory manner, you may contact the Information and Data Protection Commissioner’s Office.
Address: Information and Data Protection Commissioner, Floor 2, Airways House, High Street, Sliema, SLM 1549 Malta.