Multibuy Company Ltd (“Multibuy” below) as data controller wishes to inform users (“Users”) of the website https://www.multibuycompany.com (“Website”) about the methods of processing personal data provided to Multibuy, as required by law D. Lgs. n. 196/2003 (“Privacy Code”) and by new European Regulation n. 679/2016 about personal data protection (“European Privacy Regulation”), in force since 25th May 2018.
1. Processing data owner and responsible
The Data Controller is Multibuy Company Ltd with registered office in 64/1, Agiton Building St. Anthony Street, San Gwann, SGN 1437 Malta and can be contacted at the following email address: email@example.com The processing personal data responsible full list, appointed by Multibuy, is available upon written request sent to the email address above.
2. Collected personal data
a) personal and contact data provided when creating an account on the Website
b) personal and contact data provided when creating an account through a Commercial Activity associated with Multibuy Circuit
Health data and in general particular categories of personal data are not processed, according to the Article 9 of the European Privacy Regulation. Minor data will be processed according to the procedures described in paragraph 8 below.
Above data are processed only to the extent that they are necessary to achieve the purposes described in paragraph 4 of this statement.
3. Data processing methods
Users personal data are processed with the support of electronic and/or paper media and are protected by appropriate security measures to guarantee the confidentiality and security of personal data. In particular, Multibuy adopts appropriate organizational and technical measures to protect personal data in its possession against loss, theft, as well as unauthorized use, disclosure or modification of personal data.
Multibuy proceeds to the anonymization of personal data and the removal of identification data if there is no need to process personal data in an identifiable form for the purposes of processing and at the expiry of the retention period indicated in paragraph 10 below.
4. Purposes of data treatment
The purposes for which the User is required to provide Multibuy his personal data are as follows:
a) to allow the User to register on the Website by creating a personal account and using the services made available through the Website and asserting and defending the rights towards the User and third parts (hereafter referred to as “Contractual Purposes”);
b) ottemperare ad eventuali obblighi di legge e regolamentari (hereafter referred to as “Law Purposes”);
c) with User authorization, to send newsletters and commercial communications, through traditional and remote communication media, including email, SMS, MMS, social networks, instant messages, mobile applications, banners, fax, mail and telephone, for the promotion and/or sale of products and/or services marketed or simply managed by Multibuy and/or partner companies and for customer satisfaction surveys (“Multibuy Marketing Purposes”);
d) under User consent, to send marketing communications from other Multibuy Group companies to which Multibuy Company Ltd belongs (Multibuy Group Kft – MB Service & Travel Srls – Multibuy World Ltd) and/or commercial partners belonging to the following categories: Tour Operators – Commercial activities belonging to the Multibuy Circuit – Distributors of consumer goods, in relation to their products and services according to above paragraph c), whose list is available upon request of the User (“Third Party Marketing Purposes”);
e) under User consent, to send commercial communications according to the procedures set out in paragraphs c) and d) considering preferences, characteristics and consumption habits of Users or to perform analysis based on the characteristics above (“Profiling Purposes”);
f) in the case of the User has given his consent to data processing for Multibuy’s Marketing Purposes, to send newsletters and communications relating to the products and services marketed or offered by Multibuy by email, SMS with a frequency not exceeding 3 communications per month to Users identified solely on the base of non-invasive categories they belong to, such as, age group, the possible opening of previous newsletters received, purchase User mode (“Legitimate Interest of Marketing Purposes” );
g) to carry out activities related to sale of companies and business units, acquisitions, mergers, demergers or other transformations and for the execution of such transactions (“Legitimate Business Interest Purposes”).
5. Processing data legal basis
The processing of personal data for Contractual Purposes is mandatory as necessary for the purposes of registration, the performance of the activities referred to in the Conditions of Sale and Website Terms and Conditions, the purchase of products online and for the use of specific services offered through the Website. The provision of personal data for the Law Purposes is mandatory as required by applicable laws. In the event that the User does not want his personal data to be processed for these purposes it will not be possible for him/herself to use the Website and the services made available through it.
The processing of personal data for the Marketing Purposes of Multibuy, Third Parts Marketing and Profiling is optional and subject to the prior consent of the User. Failing to provide consent shall result in the impossibility for Multibuy, the Multibuy group companies and/or the selected business partners to keep the User updated on new products or services, promotions, customized offers, as well as to carry out market surveys and send communications or other information material that could be in line with their interests.
The data treatment for the Legitimate Business Interests Purposes is carried out referred to article 24, paragraph 1, letter d) of the Privacy Code and for the pursuit of the legitimate interest of De Agostini and its counterparties to the performance of the economic operations indicated therein, referred to in article 6, letter f) of the Privacy Regulation, adequately balanced with the interests of the Users as the processing takes place within the limits strictly necessary for the execution of these operations.
6. Scope of data communication and diffusion
Multibuy, for the purposes referred to in paragraph 4, may communicate Users’ data, strictly necessary for each type of treatment, to the following categories of subjects:
a) to collaborators, employees and suppliers of Multibuy, as part of their duties and/or any contractual obligations with them, concerning the commercial relationships with the Users;
b) to subcontractors and/or subcontractors engaged in activities related to the execution of the services and products offered by Multibuy;
c) to legal, administrative and fiscal consultants within the necessary limits or functional limits to the carrying out the activities of Multibuy, in the manner and for the purposes described above.
The Users’ personal data will not be disclosed.
7. Personal data is transferred abroad
Personal data may be freely transferred outside the Maltese national territory to countries located in the European Union.
8. Under 18 years old
9. User Rights
User may, at any time and for free (a) obtain confirmation of the existence or not of data concerning him and obtain communication thereof; (b) know data origin, processing purposes and its methods, as well as the logic applied to the processing carried out through electronic tools; (c) request the updating, correction or – if interested – integration of data; (d) obtain cancellation, transformation into anonymous form or blocking of personal data that may be processed in violation of the law, as well as to object, for legitimate reasons, processing; (e) object, in whole or in part, to data processing concerning him for the purposes of direct marketing carried out through automated methods and / or traditional methods; (f) revoke, at any time, the consent to the processing of data, without prejudice in any way to the lawfulness of the treatment based on the consent given prior to the revocation.
At any time the User can exercise the above rights, change the contact details, notify Multibuy of any updates to their data, request the removal of their personal data communicated by third parts, or to obtain further information about the use of Multibuy of their personal data by contacting Multibuy at the address firstname.lastname@example.org
10. Provisions applicable since 25 May 2018
The following provisions will become effective since May 25th, 2018, as a consequence of the beginning of the effectiveness of the Privacy Regulation.
a) Term of personal data retention: Multibuy will retain personal data for the necessary period to fulfill the purposes for which they were collected in accordance with paragraph 2 above. In any case, following retention periods apply to personal data processing for the following purposes:
➢ data collected for Contractual Purposes referred to in paragraph 4, lett. a) are kept for the duration of the contract and for the 10 years following the expiration of the same for defense purposes and/or to avail a right of Multibuy in court and/or out-of-court in case of disputes related to the execution of the contract ;
➢ the data collected for Law Purposes referred to in paragraph 4, lett. b) are kept for a period equal to the duration prescribed for each type of data by law;
➢ data collected for the Multibuy Marketing Purposes referred to in paragraph 4, lett. c) are kept for a period equal to the entire duration of the User’s registration to the Site through their account and for the 2 years following the end, deactivation and/or cancellation of the same;
➢ data collected for Third Party Marketing and Profiling Purposes referred to in paragraph 4, lett. d) and e) are kept for a period of 12 months from collection;
➢ data collected for Legitimate Marketing Interest Purposes referred to in paragraph 4, lett. f) are kept for a period equal to the entire duration of the User’s registration to the Site, through their account and for two years after the end, deactivation and / or cancellation of the same;
➢ data collected for Legitimate Business Interest Purposes referred to in paragraph 4, lett. g) are kept for a period of 10 years from the time of collection.
Once the terms indicated above have elapsed, the User’s data may be deleted, anonymised and/or aggregated.
b) Additional rights: at any time User may, in the manner referred to in paragraph 9 above, (a) request the limitation of personal data processing in the event that (i) context the accuracy of personal data; the necessary period to verify the accuracy of such personal data; (ii) the processing is unlawful and the User opposes the deletion of personal data and requests instead that its use be limited; (iii) although Multibuy no longer needs it for processing purposes, personal data are necessary for the User to ascertain, exercise or defend a right in court; (iv) the User has opposed the treatment according to the art. 21, paragraph 1, of the Privacy Regulation pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested one; (b) oppose at any time the processing of personal data; (c) request cancellation of personal data concerning him without undue delay; (d) obtain the portability of personal data concerning him; (e) propose a complaint to the Data Protection Authority where the conditions exist.
11. Changes and updates
If User has doubts, comments or complaints about the methods of collection or use of his personal data, please contact Multibuy through the Contact section of the Website.