1. Why this Privacy policy

    We collect personal data as from the date of first use of the website and/or services. This personal data can be used for all types of purposes. Through this Privacy policy we aim to inform the User on the responsible parties, the processing purposes and the processing operations.

    The processing operations always occur in accordance with the relevant (Maltese and European) laws, and in specific the Maltese law Chapter 440, Data Protection Act concerning the protection of the personal sphere with regards to the processing up personal data (Privacylaw). If you’d like to receive more information hereon we gladly direct you to the website of the supervisory authorities http://justiceservices.gov.mt/DownloadDocument.aspx?app=lom&itemid=8906&l=1.

    This Privacy policy is an integral part of our Terms of Use. The User shall be deemed to take note hereof. By making use of the website and/or services the User gives his implicit permission to process the acquired data in accordance with this Privacy policy.

    Considering the current state of technology it is impossible to make a projection of all of our future processing operations. The content of this Privacy policy can therefore be modified at any given moment. The User is deemed to take note of the content of this Privacy policy on a regular basis.

  2. Who is responsible for the processing of data

    The Website www.stevesandco.com (hereafter referred to as “Website”) including all sub-domains are managed by:

    The Ciantar Holdings Company Ltd.
    Halmann Vella Building
    Mosta Road Lija LJA9601
    T: +356 2149 4215
    www.stevesandco.com
    hello@stevesandco.com

    Via the Website multiple parties can receive personal data and apply them for their own purposes. This Privacy policy only concerns the processing operations for which Steves&Co. has been appointed as the responsible for the processing.

    Article 5 of this Privacy policy will list the other responsibles and actual processors.

  3. Collecting the personal data

    The personal data is collected in the following ways:

    • Via user registration.
    • Via accessing and using the website and services.
    • Via different technical resources, such as cookies and log-information.

    The user will be able to determine the quality and quantity of the personal data he provides through www.stevesandco.com. The processing of data will expand when the use of the website and services increases. We will by no means collect and process personal data that is qualified as sensitive. This includes data concerning health, race, creed, political views or sexual preferences.

  4. Purposes of the processing of data

    The personal data is exclusively processed with regards to the following purposes:

    • Correct access and use of the website and services;
    • Sending various commercial and non-commercial messages, both on behalf of ourselves as on behalf of our partners;
    • Actions concerning “general members management”;
    • Detecting fraud and misuse.
  5. Is personal data shared with third parties?

    The personal data collected is not shared with or transferred to third parties, with exception of the situations described in the following articles;

    1. Actual processors

      Steves&Co. can use several external parties to effectively process the personal data. These external parties only act hereto commissioned by Steves&Co. and are appointed as “actual processors.” Steves&Co. can guarantee the following concerning the data processing:

      • Actual processors are only appointed following a comparative selection in which a qualitative and safe processing procedure is a priority.
      • Steves&Co. has made clear agreements concerning the quality of the data processing in its agreement with the actual processor.
      • The actual processors can solely use the data for the purposes as determined by Steves&Co..

      Your personal data will never be processed by an actual processor that does not abide or guarantee the European principles concerning the protection of personal data.

      Actual processors dispose of a specialized knowledge on data processing. These processors therefore have the choice between different techniques and procedures, for which they bear full responsibility.

    2. Other responsible processors

      Our website uses several plug-ins from third parties. Through these plug-ins these third parties acquire personal data which they can put to use for their own processing operations.

      The following parties are appointed as a responsible processor:

      • Google Analytics.
      • Facebook Inc.
      • Twitter Inc.

      Steves&Co. is not a party to the processing operations of these third parties. The User is deemed to have taken knowledge of the Privacy policy of these third parties with regards to receiving more information concerning the purposes of this data process.

    3. Transfer of data hereto obligated by a court order or applicable regulation

      Steves&Co. can be obligated to, in whole or in part, give insight to the processed personal data pursuant by a court order or an applicable regulation. Steves&Co. will always have a certain reluctance when allowing access to this data but will have no other choice to abide by the order, yet within its limits.

  6. What are the User’s rights?

    www.stevesandco.com will make every effort it reasonably can to ensure the personal data is processed in accordance with the legal standards. The data processing occurs with special attention for:

    • The processing is done in a just and legitimate way with a view to specific, explicitly described and justified purposes;
    • The processing operations happen merely adequate, relevant and not excessive in relation to the specific purposes;
    • The Personal data is not kept any longer than required for the attainment of the purposes. Furthermore, the User enjoys the rights as granted in the Privacylaw. The User shall exercise its rights by means of a dated and signed request by email sent to hello@stevesandco.com. A proof of identity must be attached to this request (preferably a copy of an ID card).

    If these conditions are met, Steves&Co. is obligated to act within 30 days after receipt of the request. If Steves&Co. remains unresponsive, refuses or if the reply is unsatisfactory, the User can always turn to the Privacy Commission to obtain the respect of its rights.

    1. Right of access

      The User has a right to know about the existence of processing of data relating to him and should at the very least gain access to information concerning the purposes of the processing, the categories of data the processing concern and categories of recipients to whom the data are disclosed.

      Steves&Co. maintains a certain policy margin concerning this right of access. Steves&Co. is not obligated to give the User access to his personal file with personal data, nor give the User a copy of this file.

      The term for a correct access can be extended to 45 days after receipt of the request, in accordance with the legal regulations concerning this topic.

    2. Right of resist and rectification

      The User is justified to have all incorrect personal data related to him rectified, and this free of charge.

      Furthermore, the User is justified to resist the processing of data for compelling and legitimate grounds relating to his peculiar situation.

      If the personal data is acquired with direct marketing purposes, the User can resist the intended processing of his personal data free of charge and without any motivation.