Towards GDPR Compliance
[as at 22.05.2018]
Protecting Your Privacy
We, the team at Paloma Cosmetics Ltd., strongly value our own privacy – and therefore are committed to protect your personal data (i.e. information that identifies you) as though it is our own.
If you have any questions about how we protect your privacy, get in touch here or by sending an email to [email protected]
One of your rights under EU law – the General Data Protection Regulation (GDPR) – 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.
We assure you that we will only use and disclose any personal data collected from you in accordance with the manner set out in this policy.
- Information which we collect
- How & Why we use your information
- Children Under 18
- Sharing your information
- Marketing Messages
- Vacancies – Job Applicants
- Your rights
- Security of your Personal Data
- Changes to how we protect your privacy
- Links to other websites
- How to contact us
Information we collect
Most of the personal information 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 field (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 the Roseberry Cosmetics / NYX Cosmetics / Sophie La Girafe Websites). If you send us emails, then the personal data we process will depend on what you send us in the email.
The information we collect from you normally includes the following:
- Name + Surname;
- Contact Details;
- Email address
- Telephone Number
- Company Name;
- Your responses to our surveys and competitions;
- Information about your device (phone, tablet, laptop, desktop) with which how used our website;
- Details in a Curriculum Vitae, and the actual Curriculum Vitae itself, if you apply for a vacancy (see the section on recruitment below).
Check out the next sections to understand how and why we use this information.
Some other information is given to us because you accessed this website (e.g. logs, recorded through cookies). This is explained in the Cookies section below.
How & Why we use your information
We use your information in a number of different ways — what we do with it then depends on the information and the purpose for which we collected. The tables below set this out in detail, showing what we do, and why we do it.
- Your name and contact details
|How we use your Name + surname + contact details||Why?|
|To send you information by email, SMS, or post, about our current and/or new products and services as well as our brand communications||To keep you up to date. We only send this with your permission – and you can ask us to stop. (You can read more about how we use your information for marketing here).|
|Knowing what you, and other customers, like||To ensure we are giving you what you want, and to stay ahead of the competition|
- Your contact history with us
What you’ve said to us — for example, over email or contact forms.
|How we use your contact history||Why?|
|Provide customer service and support||We’ve got to do this to perform our contract with you to your best satisfaction|
|Train our staff||For our team to remain up to scratch so that you get the best possible customer service.|
- Information about your device (phone or laptop) with which how used our website
Information you give us when you browse our site, including your IP address and device type and, if you choose to share it with us, your location data, as well as how you use our website.
|How we use information about your phone, tablet, laptop or desktop, and how you use our website||Why?|
|Protect our website||To prevent and detect fraud against either you or us — and to meet our legal obligations about looking after your data|
- Your responses to surveys, competitions and promotions
|How we use your responses to surveys, competitions and promotions||Why?|
|Run the survey, competition or promotion||We’ve got to do this to perform our contract with you once you participate.|
- You don’t have to give us any of this personal information but if you don’t, you may not be able to use our site or all of the services we offer on the site, and you are unlikely to receive an optimal customer experience.
- We also anonymise and aggregate personal information (so that it does not identify you) and use it for purposes including testing our IT systems, research, data analysis, improving our site, and developing new products and services. We also share this anonymised information with third parties – but don’t worry, they cannot identify you.
The Legal Basis for Processing
- For some of the uses of your personal data (as described above) there is a legal basis under applicable data protection laws for us to use such personal data without having obtained your consent.
This includes, for example, where it is necessary for us to use the information to perform a contract with you, to keep contact with you, or take steps at your request prior to entering into a contract with you, such as provide customer-care and support services to you.
It also includes circumstances (such as we have described below) where we have a legitimate interest to use your data, provided that proper care is taken in relation to your rights and interests:
- to ensure that we organise our databases efficiently and understand how our clients may make contact with us, also by areas of interest;
- to carry out research and analysis of your data as this helps us understand our clients and online audience better, who they are and how they interact with us;
- to improve and ensure the security of the website (for example, for statistical, testing and analytical purposes, troubleshooting).
- 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.
- 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:
- we will keep personal data until such time as you ask us to stop communications with you, unless we need to keep the data for longer;
- we may keep certain categories of personal data for longer in order to meet any legal or regulatory requirements, or to resolve a legal dispute;
- and, we may keep different types of personal data for different lengths of time if required by law.
Children Under 18
If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information to us.
We will need to process personal data relating to parents or guardians in that case – and we may also need to request for verification documentation to ensure that consent is given or authorised by the holder of parental responsibility.
Sharing your information
We do not, and will not, sell any of your personal data to any third party – including your name, address, email address or any other personal information. It is not our business to do so – and we want to earn your trust and confidence.
- However, 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 in this statement:
- Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud.
- Other companies that you may approve.
- 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 website/s 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.
- 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.
We would normally communicate to you about products or services – we understand that you would be interested in receiving this information as it is of use with the product or service. But rest assured, you can ask us to stop.
Also, if you have said we can (i.e. you gave us your clear confirmation), we will send you marketing messages by email, to keep you aware of what we’re up to and to help you see and find our products.
How to stop marketing messages from us
You can stop receiving marketing messages from us at any time through any of the following methods:
- By clicking on the ‘unsubscribe’ link in any email we send you
- By getting in touch here or by sending an email to [email protected]
Once you do this, we will ensure that you don’t receive further marketing messages. Please note that, it might take a few days for all our systems to be updated, so you might get messages from us while we process your request.
What are cookies?
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) access 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.
How do you change your cookie settings?
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.
Other Passive Information which we collect
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 your 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. Together with our related entities and subsidiaries we will use this information and share it with third parties to improve the content, functionality and administration of our websites, to better understand our customers and markets, and to improve our products and services.
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.
Vacancies – Job Applicants
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 get in touch here or by sending an email to [email protected]
What will we do with the information you provide to us?
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 if 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.
What information do we ask for, and why?
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 what we ask for but it might affect your application if you don’t.
Application stage & Short Listing
If you use our online application system, this will be collected by our Directors as listed on the Registry of Companies within the Malta Financial Services Authority.
We ask you for your personal details including name and contact details as well as your CV to be uploaded onto our system. Such information will typically include background information 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.
Our hiring managers shortlist applications for interview. They will be provided with your name or contact details.
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 after 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 in Malta. 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; Police Conduct; declaration to declare any unspent convictions.
- We will provide your email address to the Government Recruitment Service who will contact you to complete an application for a Basic Criminal Record check via the Disclosure and Barring Service, or Access NI, which will verify your declaration of unspent convictions.
- We will contact your referees, using the details you provide in your application, directly to obtain references.
- We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work.
If we make a final offer, we will also ask you for information in our ‘New Payee Registration Form’ in order to on-board you onto our payroll system, which form and information / attachments forwarded are kept by us in a secure digital and physical filing system.
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.
- Retention Periods
If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of two (2) years. If you say yes, we may proactively contact you should any further suitable vacancies arise within that period. You may ask us to cancel this at any time – however we normally keep information about your application for at least six (6) months in case you raise any questions about the process.
You enjoy several rights relating to your personal information:
- The right to be informed about how your personal information is being used;
- The right to access the personal information we hold about you;
To process your request, we will ask you to send us proof of identity so that we can be sure we are releasing your personal data to the right person.
We will carry out our best efforts to process your request within one (1) month or, if the request is particularly complex, two (2) months. We can provide you with a copy of your personal data in electronic format or hard copy.
If we consider the frequency of your requests as being unreasonable, we may refuse to comply with your request. In those circumstances, if you disagree, you can complain to the data protection authority – in Malta, the Information and Data Protection Commissioner.
- The right to request the correction of inaccurate personal information we hold about you;
We appreciate feedback from you to ensure our records are accurate and up-to-date.
- The right to request that we delete your data, or stop processing it or collecting it;
You can ask us to delete your personal data; however, this is not an absolute right.
In spite of a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation; and (ii) in relation to the exercise or defence of any legal claims.
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.
- The right to stop direct marketing messages;
- The right to object to certain processing based on legitimate interest;
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.
- The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;
- The right to withdraw consent for other consent-based processing at any time;
- The right to request that we transfer or port elements of your data either to you or another service provider;
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 another organisation, 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.
- The right to complain to your data protection regulator — in Malta – the Information and Data Protection Commissioner (IDPC)
Please appreciate that the rights must be exercised within some limitation – for example, if you ask us for information we can only give you what relates to you and not what relates to other persons. When we receive requests, we may also request that you identify yourself and provide documentation or information for verification (we would not want to disclose information to the wrong person). Unreasonable requests may be subjected to a reasonable fee or refusal to respond.
Security of your Personal Data
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.
You may complete a registration process when you sign up to use parts of the websites. This may include the creation of a username, password and/or other identification information. Any such details should be kept confidential by you and should not be disclosed to or shared with anyone.
Where you do disclose any of these details, you are solely responsible for all activities undertaken where they are used.
Whenever you create a password, then to protect your account you should choose a strong password, meaning it should be lengthy and include a mixture of letters and numbers with mix of CAPS.
We do our best to keep the information you disclose to us secure. However, we can’t guarantee or warrant the security of any information which you send to us.
Security measures which have implemented to secure information transmitted over our website or stored on our systems include the following:
- Use of secure servers;
- Use of firewalls;
- Use of encryption;
- Physical access controls at our server room;
- Information access controls;
- Use of back-up systems.
Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.
Changes to how we protect your privacy
Links to Other Websites
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.
How to contact us
We are always happy to hear from you, whether to make a suggestion but especially if you feel we can do better.
We have appointed a Data Protection Officer who may be contacted here: [email protected]