1.    Introduction

The Convenience Shop Limited (“TCS”/”we”/”us”/”our”/”) are committed to protecting and respecting your privacy. We are pleased to provide you with our privacy notice and request you to read it carefully.

We have created this privacy notice to explain:

                i. How we use any personal data that we receive from you or may collect about you, and

                ii. Your privacy rights under applicable privacy laws.

Our use of your personal data is subject to your instructions, the EU General Data Protection Regulation (“GDPR”), other relevant Maltese and EU legislation and our professional duty of confidentiality.

For the purposes of the GDPR, the Data Controller is:

The Convenience Shop Limited of Marant Food Products, Mdina Road, Zebbug, ZBG 9017, Malta

If you wish to request any clarification or additional information in relation to this privacy notice, or you may wish to exercise any of your rights in relation to your personal data, please send us an email on cis@theconvenienceshop.com.  

This privacy notice is effective as of 28 April 2019. In the event that we modify this privacy notice, we will post a clear notice of this update in the homepage of our website. 

2.    Key terms

Data Controller

The person that determines the purposes and means of the processing of personal data

Personal data

Any information relating to an identified or identifiable natural person 

Processing

Any operation which is performed on personal data such as collection, storage, use and erasure

Special Category Data

Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic and biometric data and data concerning health, sex life or sexual orientation

 

 

3.  Personal Data that we collect, may process and for what we may use it

Most of the information we process is given to us directly by you. This includes information that you input via our website and that you provide us with over the telephone and email.

However, we may also collect personal data about you through our CCTV surveillance system “the CCTV system” which we have installed outside and inside our various outlets/premises around Malta.

Signs are placed throughout our premises to inform our clients that CCTV is in operation. The CCTV system is capable of being monitored for 24 hours every day of the year. Cameras are monitored in a secure area and accessible solely by authorized staff. All images captured by the CCTV System remain the property of The Convenience Shop Limited.

We can only use your personal data if we have a lawful reason for doing so. Under data protection laws we may process your personal data if you have given us your consent or it is necessary:

      for our legitimate interests, or

      to carry out our contractual obligations, or

      to comply with a legal obligation.

We normally process your personal data for the purpose of processing your request for using our services. We process your personal data on the ground of legitimate interest when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

However, with respect to sensitive data we will only process such data upon your explicit consent.

In summary, we collect 2 types of data from you: (i) personal data like contact details to enable us to fulfil our service and (ii)  behavioural data to better improve our service to you, which we will only collect if you Opt In.

The table below sets out the types of personal data that we may process, for what we may use it and our legal bases, which are our reasons for processing:

Activity

Personal data we may process

For what reasons we may use your personal data

Our legal bases

 

When you register and make use of our online shopping service

Contact details that you provide to us when you request register on our website.

These include your full name, address, email address, telephone number, date of birth, your order history, your account login details for our website including your user name and chosen password.

NOTE: Your payment details are not processed by us but are submitted directly to our third-party payment providers via a redirection to their website.

To provide you with our products and online shopping service.

To improve your shopping experience.

Analytics and profiling

Contacting you and responding to your communications with us.

 

Updating and enhancing our contacts/client base.

 

To provide you with all of our latest news, offers and activities.

Performance of a contract:

Enabling us to perform the contract with you and provide you with our products or services , such as order confirmation and dispatch.

For our legitimate interests:

Responding to your communications with us, including complaints or claims made by you.

Processing is necessary for us to conduct our business, as long as our interests are not overridden by your interests or rights.

Performance of a legal obligation

In satisfaction of any obligation imposed on us by law.

Consent

On the basis of the consent that you have provided us, where this is required.

Making use of our website when you make a general enquiry.

 

 

Contact details that you provide to us when you request information about our services through our “Contact Us” form on our website.

These include your full name, telephone number, email address and other personal data that you may provide us.

Responding to your communications with us.

Updating and enhancing our contacts/client base.

For our legitimate interests:

Managing business communications.

 

Responding to your communications with us.

 

Responding to your communications with us, including complaints or claims made by you.

When you communicate with us for any other reason by telephone.

 

 

Contact details that you provide us when you request information about any of our services, or when you wish to give us feedback or make a complaint via telephone.

These include any personal data that you may provide us in your communications with us.

Responding to your communications including service emails providing post-dining feedback.

 

Internal recording.

 

Improve our products and services.

For our legitimate interests:

Getting to know the relative contact person.

 

Managing business communications.

 

Responding to your communications with us, including complaints or claims made by you.

Signing up for email updates

Your name and surname, as well as, your email address you provide to us when subscribing to our newsletter through our “Join Newsletter” form on our website.

 

 

 

 

 

To provide you with all of our latest news, offers and activities or enable your attendance at an event.

 

 

For our legitimate interests:

Develop our network of contacts.

Share relevant content and promote our activities with persons who have previously expressed an interest in TCS.

Consent

On the basis of the consent that you have provided us, where this is required.

When you provide us with your CV to apply for a job at The Convenience Shop.

Contact details that you provide to us when you request information about our services through our “Vacancies” form on our website, or through any other method of providing us with your CV.

These include the Curriculum Vitae, including all information provided therein, and contact details such as personal email address and mobile phone number.

Special conditions (which may relate to disability, learning, specific learning difficulty, health issue)

Any other data that you may provide to us through the application process.

Process and follow up on your job application

For our legitimate interests:

Satisfy our staffing requirements and getting to know employees or potential employees.

Making sure any potential recruit is suitably qualified for the position.

Consent

You are consenting us to process your personal data upon the submission of your personal data in the context of your application, which would include conducting necessary checks to satisfy our legitimate interests.

Performance of a legal obligation

In satisfaction of our obligation to verify whether a candidate has the right to work in Malta.

For more information please refer to our Job Applicant and Employee Privacy Notice on.

Making use of our website when seeking business opportunities.

 

Contact details that you provide to us when you contact us via our website through our “Business Opportunities” form or via telephone.

These include full name, email address, and contact number.

Responding to your communications with us in order to provide you with the necessary information and commence negotiations.

Updating and enhancing our contacts base

For our legitimate interests:

Getting to know the relative contact person who could result in a new business venture with us.

 

Managing business communications.

 

Responding to your communications with us.

CCTV system

 

 

Images of clients captured through the use of CCTV cameras which are installed within and outside our outlets/premises.

Used for security and monitoring purposes of clients and employees

For our legitimate interests:

Keeping our clients and employees safe and secure by preventing crime, preventing employee misconduct and, ensuring compliance with health and safety procedures.

For more information please refer to our CCTV policy on

Use of our website

We may automatically collect technical information, including

your Internet Protocol (IP) Address, browsing type, operating system and other information about your visits from your IP address.

 

To be able to trace the computer used in cases of any kind of misuse of our website.

 

To improve our website.

 

To be able to report aggregate information to third parties.

For our legitimate interests:

To ensure the security of our website

To improve our website.

 

You agree to provide us personal data which is in all respects true, accurate and up to date and is not, in any respect, misleading, deceptive or inaccurate or likely to mislead or deceive.

4. Use of cookies

We use cookies to optimise the functionality of our website. A cookie is a small file that contains certain data such as the site’s name and unique user ID and is downloaded to and stored on your device when you visit a website. Cookies are generally used to make websites work more efficiently and enable website owners to gather information about the use of their website. Thus, they may be used for different purposes such as website analytics, targeted advertising, counting visitors and monitoring their behaviour.

We use cookies to enable us to remember the personal settings of our users when visiting our website. These cookies may obtain information about you, your device and your use of our website.

Most, but not all, of the cookies we use are automatically deleted from your computer when you leave our website or shortly afterwards.

Third party vendors, including Google, show adverts for The Convenience Shop on the internet. These vendors may use cookies to serve ads based on a user’s prior visits to The Convenience Shop. Users can opt out of Google’s use of cookies by visiting the Google advertising opt-out page.

 

Opting Out:

You can set your browser to not accept cookies, but this may limit your ability to use the services.

For more information about for what we use cookies and how you can change your settings to suit you please refer to our Cookie Policy.

5.   With whom we share your data

It is necessary to share and transfer your data, both internally and externally.

For us to be able to provide you with a service, information needs to be transferred internally. For example, if you make a purchase on our website, the details of the purchase are sent to one of our outlets, so the order can be completed.

We do not share your data with third parties, except with the following persons and in the indicated circumstances:

i.         service providers – we may disclose your personal data to third party service providers that provide us with services. These include “Cool” – our delivery service provider which delivers our products to you, “apcopay” – our payment processor which processed your payment to us, cloud storage providers and website hosting providers.

ii.       other third parties – where necessary to carry out your instructions.

 

We may also disclose your personal data in response to any requests made from law enforcement agencies, government entities or public authorities, where we have a duty to disclose or share your personal data in order to observe any legal or regulatory obligation or request.

 

We may also share your personal data with other parties in the event of a corporate reorganisation and/or disposition of our business, such as potential buyers of all or part of our business.

 

 

6.  Where your personal data is held

 

We hold your personal data at our offices and those of our third party service providers as described in clause 5 above. Some of these service providers may be located outside the European Economic Area (EEA). Any such transfers will be processed in accordance with specific EU and Maltese data protection laws as also provided in clause 7 below.

 

7. Transfers of your personal data outside the EEA

 

Transfers of personal data outside the EEA are subject to specific EU and Maltese data protection laws.

 

 

8. Third Party Sites

Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

When making a purchase order through our Site you will be redirected to the website of our third-party payment processor’s website.

 

 

9. Personal Data retention period

 

We will retain your personal data even after the completion of our services to you. We will need to keep your personal data after we have provided you with our services in order to comply with our record keeping requirements in terms of the law and to be able to respond to any questions, complaints or claims made by you.

 

Similarly, CCTV Surveillance footage derived from the CCTV system will be retained for a period of ****  in order to ensure compliance with record keeping laws and to be able to address questions, complaints or claims made by you.

 

We will not collect more data than we require or retain your data for longer than necessary to fulfil the purposes outlined in this notice.

 

9. Your rights with respect to your Personal Data

 

You have the following rights if you reside in the EU:

 

Right of Access

The right to access and be provided with a copy of your personal data.

 

Right to Rectification

The right to require us to correct any inaccurate personal data about you.

 

Right to be forgotten

The right to require us to delete your personal data in certain circumstances.

 

Right to restriction of processing

The right to require us to restrict processing your personal data in certain circumstances.

 

Right to data portability

The right to receive your personal data which you provided to us, in a structured, commonly used and machine-readable format and the right to transmit that data to another data controller in certain circumstances.

 

Right to object

The right to object to the processing of your personal data in certain circumstances which include continued processing of your data carried out for the purpose of our legitimate interests.

 

Right not to be subject to automated processing

The right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or significantly affects you.

 

Should you require any further information on each of the above rights or would like to exercise any of them, please contact us on 00356 80074600 or send an email on cis@theconvenienceshop.com.

 

 

10. Protecting your personal data

 

We have implemented security measures to protect your personal data that we collect from being used or accessed unlawfully or accidentally lost. We only grant access to your personal data to those persons who have a genuine need to access it. Those processing your personal data are subject to the duty of confidentiality.

 

11. Complaints

 

We would like to resolve any concern that you may have about the processing of your personal data directly with you. However, you have the right to lodge a complaint with a supervisory authority, in the EU state in which you work, reside or where the alleged infringement of data protection laws took place. The supervisory authority in Malta is the Office of the Information and Data Protection Commissioner which may be contacted at https://idpc.org.mt/en/Pages/contact/complaints.aspx.

 

 

Last updated on 28 April 2020