Privacy Policy

This privacy policy will explain how Hi-Calibr uses the personal data we collect from you when you use our website.

This website is not intended for children and we do not knowingly collect 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 Hi-Calibr as a result of your use of this website, Hi-Calibr social media pages or our apps is governed by the provisions of the Maltese Data Protection Act.

Definitions

All definitions within this Privacy Policy have the same meaning as in our Terms and Conditions, unless specifically stated otherwise herein.

Changes to our Privacy Policy

Hi-Calibr keeps its Privacy Policy under regular review and places any updates on this web page. This Privacy Policy was last updated on 28^th September 2020

What data do we collect?

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 identity has been removed (anonymous data).

Hi-Calibr collects the following personal data:

• Identity Data includes first name, last name, username or similar identifier, date of birth and gender.
• Contact Data includes email addresses
• 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.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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 your 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.

If you 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 (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How do we collect your data?

You directly provide Hi-Calibr with most of the data we collect. We collect data and process data when you:

• Voluntarily complete a poll or survey or provide feedback or comments on any of our message boards or via email.
• Produce content for the Website
• Use or view our website via your browser’s cookies or other similar technologies
• Technical Data from the following parties analytics providers such as Google based outside the EU;
• Via third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  • Google
  • Facebook
  • WordPress

How will we use your personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• 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.

Google Analytics: If you use Google Analytics on WordPress site to track user interactions, chances are you’re collecting personal data like IP addresses, user IDs, and cookies for behavior profiling.

WordPress comments: If commenting is enabled on your site, you’re also collecting personal data like the name and email address of your users. After commenting on a website, personal data is also saved in browser cookies, so commenters don’t have to resubmit them next time. This makes commenting more convenient on WordPress websites.

Advertisement: If you serve advertisements through third-party websites, like Google AdSense, then you’re likely sharing user behavioral information with your advertising partners.

Purposes for which we use your personal data

The below table describes 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, where appropriate, our legitimate interests. 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.

Change of purpose

We will only use your personal data for the purposes for which we 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.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us 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.

Disclosures of your personal data

We may have to share your personal data with internal third parties (other entities owned or controlled by Hi-Calibr) and external third parties (IT and system administration services, professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EEA and/or UK who provide consultancy, banking, legal, insurance and accounting services) below for the purposes set out in the table in section 7 above.

In addition, we may have to share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

To deliver the Websites and our Services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg: with your and our service providers located outside the EEA if you are based outside the EEA.

These transfers are subject to special rules under European and UK data protection law.

The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the USA (limited to the Privacy Shield framework).

Except for the countries listed above, non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission (as permitted under Article 46(2) of the General Data Protection Regulation) and that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. If you would like further information please contact us.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

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.

Data Retention

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.

You may obtain further details on the retention periods for different aspects of your personal by contacting us.

In some circumstances, you can ask us to delete your data, as further detailed in section 13 below.

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.

What are your data protection rights?

Hi-Calibr would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

1. The right to access – You have the right to request Hi-Calibr for copies of your personal data. We may charge you a small fee for this service.
2. The right to rectification – You have the right to request that Hi-Calibr correct any information you believe is inaccurate. You also have the right to request Hi-Calibr to complete the information you believe is incomplete.
3. The right to erasure – You have the right to request that Hi-Calibr erase your personal data, under certain conditions.
4. The right to restrict processing – You have the right to request that Hi-Calibr restrict the processing of your personal data, under certain conditions.
5. The right to object to processing – You have the right to object to Hi-Calibr’s processing of your personal data, under certain conditions.
6. The right to data portability – You have the right to request that Hi-Calibr transfer the data that we have collected to another organization, or directly to you, under certain conditions.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

1   How do we use cookies?

Hi-Calibr uses cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in
• Understanding how you use our website

2   What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

Functionality – Hi-Calibr uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

Advertising – Hi-Calibr uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Hi-Calibr sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

[Add any other types of cookies Hi-Calibr uses]

3    How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

The Hi-Calibr website contains links to other websites. Our Privacy Policy applies only to our website, so if you click on a link to another website, you should read their Privacy Policy.

How to contact us

If you have any questions about Hi-Calibr’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: jvassallo@popcornperspective.com

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Hi-Calibr has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.

Email: idpc.info@idpc.org.mt

Address: Floor 2, Airways House, Triq il-Kbira, Tas-Sliema SLM 1549