15 October 2018
1.1 We are conscious of the obligations imposed on us in terms of law, in particular the General Data Protection Regulation (herein referred to as “the GDPR”) effective as of the 25th May 2018, and we are committed to safeguarding the privacy of our customers.
1.2 For the purposes of the GDPR, the Company is the Data Controller when collecting information related to purchases of goods from the JYSK Outlets found in various localities in Malta and Gozo.
2.1 In this policy, “the Company”, “we”, “us” and “our” refer to MDF Trading Ltd.
2.2 MDF Trading Ltd is a limited liability company registered in Malta by means of company registration number C 74149 and with registered office at “Bonnici House”, Sardine Street, Burmarrad, St. Paul’s Bay.
2.3 Website means “www.jysk.com.mt”
3. Use of your personal data
3.1 We will also collect and process information relating to your account and transactions, including purchases of goods that you enter into with us. This information will be processed to keep proper account and records of said transactions and for after-sales service. The basis for this processing is the entering and execution of a contract between you and us and for the proper administration of our business.
3.2 Through our Website we will also be collecting information including name, surname and contact number, of those who opt to register for our Loyalty Card in order to benefit from our promotions as applicable from time to time.
3.2 We also collect the e-mail addresses information volunteered by those who communicate with us via e-mail or our facebook page or volunteered by the consumer, such as survey information and/or other details.
3.3 Furthermore, the Company may process your personal data for compliance with a legal obligation to which the Company is or may be subject.
4. Disclosure of your personal data to third parties
4.1 We do not partner with or have special relationships with any ad server companies. Any personal information you communicate to us is kept within our own records in accordance with the GDPR. We take all safeguards necessary to prevent unauthorized access and we do not pass on your details collected from you as a visitor, to any third party unless you give us your consent to do so.
5. Retention and deletion of personal data
5.1 Personal data that the Company processes for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.2 The Company will retain account and transaction information, for legal, contractual and internal financial accounting purposes. It is a requirement to retain this information for a period of 10 years.
5.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained.
5.4 Furthermore, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your and/or our interest.
6. Policy updates
6.1 This Policy may change from time to time and will be available on our website.
6.2 We may notify you of significant changes to this policy by email.
7. Data subject rights information
7.1 Your principal rights under data protection law, including the GDPR are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure (the right to be forgotten);
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.2 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.3 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.5 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.6 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.7 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.8 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.9 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.10 You may exercise any of your rights in relation to your personal data by written notice to us or by sending an email on email@example.com, in addition to the other stipulated methods.
8.1. You can contact us:
(a) by post, to the postal address given above; or
(b) by email on firstname.lastname@example.org