Privacy Policy

Welcome to the privacy policy for Unravel Malta, a website owned and operated by Alpha Group (www.alphagrp.eu) (referred to in this policy as “UM”, “we” or “us”).

UM respects your privacy and is committed to protecting your personal data. This privacy notice will tell you how we handle your personal data when you visit our website (regardless of where you visit it from) and inform you of your privacy rights and how the law protects you.

  1. What is the purpose of this privacy notice?

This privacy notice aims to give you information on how UM collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, contact us through the contact form on our site, or take part in a competition.

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This website is not intended for use by children and we do not knowingly collect personal data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Any processing of personal information gathered by UM as a result of your use of this website, UM social media pages or our apps is governed by the provisions of the General Data Protection Regulation (GDPR), the Data Protection Act (Chapter, 586, Laws of Malta), and any other data protection legislation that may be in force.

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  1. Who is the Data Controller?

The data controller – the company responsible for your privacy – is Unravel Malta.

We have appointed a data protection representative who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection representative using the details set out below:

Ryan Borg

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Data Protection Representative

Email: [email protected]

  1. What personal data is collected?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the individuals’’ identity has been removed (anonymous data).

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We may collect, use, store and transfer different kinds of personal data about you which we have grouped together, as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes postal address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences where you have provided these to us.

We also collect, use and share Aggregated Data such as statistical or demographic data for a purpose legitimate biz reason. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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  1. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your identity and contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • subscribe to our newsletter;
    • enter a competition, promotion, survey or event; or
    • contact us for about a story, to give us feedback, to file a complaint, etc
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  • Identity and Contact Data from data brokers or aggregators based inside the EU:

Some of your personal data may be collected through the use of cookies. For further information about how we use cookies, please visit our cookie policy.


  1. On what grounds is personal data collected?

We will only use your personal data when we have a lawful reason to do so. Most commonly, we will use your personal data in the following circumstances:

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  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where we have obtained your consent, for instance when you subscribe to our newsletter. You can withdraw your consent at any time by contacting us.
  1. What are the purposes for processing my personal data?

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To send you our newsletter when you have opted in

Identity

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Contact

Consent

To manage our relationship with you which may include:

(a) Notifying you about changes to our terms or privacy policy

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(b) Replying to messages you send us

Identity

Contact

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Marketing and Communications

Performance of a contract with you

Necessary to comply with a legal obligation

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Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

Identity

Contact

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Marketing and Communications

Performance of a contract with you

Consent

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To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Identity

Contact

Technical

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Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you on our website, third party websites and social media channels, and measure or understand the effectiveness of the advertising we serve to you

Identity

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Contact

Marketing and Communications

Technical

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Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Technical Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Your personal data is not subject to automated decision making.

Change of purpose

We will only use your personal data for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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If we need to use your personal data for an unrelated purpose not reasonably compatible with the purpose for which your personal data was originally provided, we will seek your consent when required to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Marketing

Promotional offers from us

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You will only receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted in to receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

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Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time or clicking “unsubscribe” at the bottom of the emails.

  1. What if I fail to provide personal data?

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

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  1. Will you disclose my personal data to anyone?

We will not share your personal data with third parties without your permission, except where strictly necessary and where we are authorised to do so by law.

We may have to share your personal data with service providers acting as processors based Ireland, the UK and/or Malta who provide IT and system administration services, or with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Malta who provide consultancy, banking, legal, insurance and accounting services.

If we ever have to share your personal data with an entity outside the EU, we will do so in accordance with the requirements of the GDPR and any other applicable law.

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  1. How do you keep my personal data safe?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We also regularly review and, where practicable, improve upon these security measures.

While we do our utmost to safeguard your personal data, no data transmission over the internet can be totally secure and therefore we cannot guarantee or warrant that no unauthorised access will occur.

  1. How long will you keep my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. What are my rights?

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

  1. How can I exercise my rights?

If you would like to exercise any of your rights, please email, or write to us at [email protected] and provide us with the following information:

  • Your contact details
  • Proof of your identity
  • Details of what right you want to exercise and the information to which your request relates

If you would like to unsubscribe from any email newsletter you can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to 14 days for this to take place.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request further, more specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You also have the right to file a complaint with the Information and Data Protection Commissioner (IDPC), the Maltese authority responsible for data protection issues (www.idpc.org.mt), and to pursue your legal rights to a judicial remedy. They can be contacted at:

Level 2, Airways House High Street Sliema SUM 1549 Malta Tel: (+356) 2328 7100 Email: [email protected]

We would, however, appreciate the opportunity to deal with your concerns before you approach the IDPC or take any other action, so please contact us in the first instance at [email protected].

  1. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. Changes to this privacy policy

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We may change this privacy notice from time to time, when we do we will we will post the changes here and on the Website. Where the changes are significant, we will inform all of our subscribers by email. Where required by law, will we obtain your consent to make these changes.