Data Privacy Policy
(Last updated: 25 May 2018)
Thank you for visiting our website and for your interest in our company. The protection of your personal data is a matter of great importance to us. Below we inform you according to art. 12, 13 and 21 of the General Data Protection Regulation (GDPR) about the handling of your personal data when visiting our website www.msales.com.
Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person. This includes information such as the civil name, address, telephone number and date of birth.
msales Ltd.
48 Stella Maris Street,
SLM1765 Sliema, Malta
Mail: info@msales.com
Michal Pokorny
48 Stella Maris Street, Sliema, SLM1765, Malta
michal.pokorny.ext@msales.com
+356 277 818 04
You can visit our website without providing any personal information. If you use our website for informational purposes only, i.e. contact us or otherwise provide us with information about yourself, we do not collect any personal data, with the exception of the data that your browser transmits to enable you to visit the website as well as information that is transmitted to us through cookies used for statistical analysis of the use of our website.
For the purpose of the technical provision of the website, it is necessary that we process certain automatically transmitted information about you so that your browser can display our website and you can use the website. This information is automatically collected for each visit of our website and stored in our server log files. This information refers to the computer system of the requesting computer. The following information is collected thereby:
– IP-adresse
– Browser type / -version (e.g.: Firefox 59.0.2 (64 Bit));
– Browser language (e.g.: German);
– Operating system (e.g.: Windows 10);
– Internal resolution of the browser window;
– Screen resolution;
– Javascript activation;
– Java on / off;
– Cookies on / off;
– Color depth;
– Time of access.
Furthermore, we use cookies to make our website available to you for use. Cookies are text files that are stored in the internet browser or by the internet browser when you visit a website on your computer system. A cookie contains a characteristic string of characters that enables a unique identification of the browser when the website is called up again. We use these cookies exclusively to provide you with our website and its technical functions. Some functions of our website may not be offered without the use of cookies. The following information is stored in the cookies and transferred to us:
– Browser type / -version (e.g.: Firefox 59.0.2 (64 Bit));
– Browser language (e.g.: German);
– Operating system (e.g.: Windows 10);
– Internal resolution of the browser window;
– Screen resolution;
– Javascript activation;
– Java on / off;
– Cookies on / off;
– Color depth;
– Time of access.
– Session ID;
– Cookie ID;
Your information, collected by us through the aforementioned cookies, will not be used by us to create user profiles or to evaluate your browsing behavior.
We process your personal data for the technical provision of our website on the following legal basis:
– for the fulfilment of a contract or for the implementation of pre-contractual measures pursuant to Art. 6 para. 1 letter b GDPR, provided you visit our website to obtain information about our services and our events; and
– to protect our legitimate interests pursuant to Art. 6 para. 1 letter f GDPR in order to make the website technically available to you. Our legitimate interest is to offer you an appealing, technically functioning and user-friendly website.
For the purpose of statistical analysis of the use of our website, we use Google Analytics, Google Analytics Audience, DoubleClick, Hotjar and thus cookies, which enable an analysis of your browsing behaviour. This enables us to improve the quality of our website and its content. We learn how the website is used and can thus continuously optimize our offer.
The information obtained in the context of the statistical analysis of our website will not be merged with your other data collected in the context of the website.
We process your personal data for statistical analysis of the use of our website on the following legal basis:
– Your consent pursuant to art. 6 para. 1 letter a GDPR.
Google Analytics
On our website we use Google Analytics, a web analysis service of Google Inc. Google Analytics uses so-called “cookies”: text files placed on your computer, enabling an analysis of the use of the website by you. The information generated by the cookie about your use of our website is usually transferred to a Google server in the USA and stored there. However, if IP anonymisation is activated on our website, Google will shorten your IP address within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activities and to provide the website operator with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that in this case you may not be able to use the full scope of functions on our website.
You can prevent the collection of data generated by the cookie and relating to your use of our website (including your IP address) and the transmission to Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout
As an alternative to the browser plugin, you can click this link to prevent Google Analytics from collecting data about our website in the future. An opt-out cookie is stored on your device. If you delete your cookies, you must click the link again.
For more information on Google Analytics’ Terms of Use and Privacy Policy, please visit http://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies/
GA Audience
Our website uses GA Audience, a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“GA Audience”). GA Audience uses cookies which are stored on your computer or other mobile devices (e.g. smartphones, tablets, etc.) and which enable use of the corresponding devices to be analyzed. In the process, this data is partly evaluated across multiple devices. In doing so, Google Audience receives access to the cookies created as part of the use of Google AdWords and Google Analytics. Within the scope of the use, data such as IP addresses and activities of the user is transmitted to a server of the company Google Inc and stored there. Google Inc. will transfer this information to third parties if this is required by law or if this data is to be processed by third parties.
You can prevent personal data (in particular your IP address) from being collected and passed on as well as being processed by deactivating the execution of JavaScript in your browser or installing a tool such as “”NoScript””. You can also prevent Google from collecting and processing the data generated by the cookie relating to your use of the website (incl. your IP address) by downloading and installing the browser plugin available at http://tools.google.com/dlpage/gaoptout?hl=en .
You can find further information on data protection when using GA Audience at the following link: https://support.google.com/analytics/answer/2700409?hl=en&ref_topic=2611283
DoubleClick by Google
We sometimes conduct advertising campaigns using DoubleClick, a Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) service. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Google DoubleClick cookie) together to inform, optimise and serve ads based on someone’s past visits to our website and to report how ad impressions, other uses of ad services and interactions with these ad impressions and ad services are related to visits to our site.
You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that in this case you may not be able to use the full scope of functions on our website.
You can prevent the collection of data generated by downloading and installing the browser plugin available at the following [link] under the item DoubleClick deactivation extension. Alternatively, you can disable the Doubleclick cookies on the Digital Advertising Alliance site by clicking the following [link].
To find out about DoubleClick cookies and how to control those cookies, please see here: http://www.google.co.uk/policies/privacy/ads/.
Hotjar
We may use Hotjar, a mainly tracking code based web analysis tool of Hotjar Ltd., Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta. Hotjar records the interactions of randomly selected individual visitors to our website in anonymised form. This creates a protocol of e.g. mouse movements and clicks with the aim of identifying possible improvements to our offer. In addition, information on the operating system, browser, incoming and outgoing links, geographical origin, as well as resolution and type of the terminal device accessing our website are evaluated for statistical purposes using Hotjar. Moreover, we offer the possibility of anonymous user feedback by means of so-called “feedback pools” via Hotjar. The information collected is not personal, is stored by Hotjar Ltd. and is not passed on to any other third parties. Additional information on functions and data usage using Hotjar can be found at: https://www.hotjar.com/privacy. If you do not want a website analysis using Hotjar, you can deactivate it by setting a DoNotTrack header in your browser (opt-out): https://www.hotjar.com/opt-out.
Google Maps
Our website uses the Google Maps plugin. This service is offered by Google.
This website uses Google Maps to display maps and generate route maps. Google Maps is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States. By using this website, you agree with the collection, processing and use of the automatically collected data and the data entered by you (including your IP address) by Google, one of its representatives or third-party providers.
The purpose and scope of the data collection and the further processing and use of the data by Google as well as your rights and setting options for the protection of your privacy can be found in Google’s data protection information at https://www.google.com/policies/privacy/partners/?hl=de
In addition to the merely informational use of our website, you can also actively use our website to contact. In addition to the above-mentioned processing of your personal data for merely informational purposes, we will also process other personal data that we require from you to process your order or to process and respond to your inquiry.
In order to process and answer your inquiries to us, e.g. via the contact form or our e-mail address, we process your personal data provided by you in this context. In any case, this includes your name and e-mail address in order to send you an answer, as well as the other information that you send us in the context of your message.
We process your personal data in order to respond to user inquiries on the following legal basis:
– to protect our legitimate interests pursuant to art. 6 para. 1 lit f GDPR; our legitimate interest is to answer customer inquiries appropriately.
We process your personal data in the context of your application, as far as you make it available to us. The application documents may contain special categories of personal data.
Processing of personal data
The applicant data usually includes the following: First and last name, if applicable your academic degree, date and place of birth, contact details (address, e-mail, telephone and/or mobile phone number), application documents (cover letter, CV, certificates), language skills, abilities. In addition, we process the data that you send us by e-mail when contacting us.
We base our decisions in the application process on the personal data you provide within the legal requirements. For example, we use your professional qualifications to decide whether we consider you in the shortlist or a personal impression in an interview to decide whether we are offering you the position for which you are applying.
We process your personal data on the basis of the following legal bases:
– Data processing for the decision on the establishment of an employment relationship, Art. 88 para. 1 GDPR in connection with Section 26 (1) sentence 1 BDSG-new
Processing of special personal data
According to Art. 9 GDPR, special categories of personal data are personal data which reveal racial and ethnic origin, political opinion, religious (e.g. information on religion/confession) or ideological beliefs or trade union membership, as well as the processing of biometric data for unique identification (e.g. photos), health data (e.g. information on the degree of severe disability) or data on sex life or sexual orientation. If your CV contains special categories of personal data, we do not collect them intentionally. We expressly ask you not to send us such data.
If, as part of your application documents, you voluntarily and against our express request, provide us with special categories of personal data pursuant to Art. 9 para. 1 GDPR (e.g. your photo or details of your religious affiliation/denomination), we will store these on the basis of your consent pursuant to Art. 88 para. 1 GDPR in connection with your application. Section 26 (3) sentence 2 BDSG-new. This also applies if you provide us with further special personal data in the course of the application process. By voluntarily submitting this data, you agree to the storage of this special personal data within the application process.
We do not take this special personal data into account when making a selection decision, unless it is required by law to take this special personal data into account. It is possible, for example, in some job advertisements that people with disabilities are given preferential treatment in accordance with the applicable labor laws. In these cases, the information is always voluntary and is provided with your express consent, which you provide by voluntarily submitting this data.
We process your special personal data on the basis of the following legal bases:
– according to Art. 9 para. 1 GDPR on the basis of your consent according to Art. 88 para. 1 GDPR in connection with Section 26 (3) sentence 2 BDSG-new.
If you leave comments or other contributions to articles on our blog, we will process your e-mail address and your name. Your e-mail address will not be published.
We process your personal data for the production of your comment on the basis of the following legal bases:
– to protect our legitimate interests according to art. 6 par. 1 lit. f DSGVO; our legitimate interest consists on the one hand in fulfilling your wish and providing the commentary to the article, on the other hand in our security, if someone leaves illegal contents in comments and contributions (insults, forbidden political propaganda, etc.). In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
We also process your personal data in order to be able to defend ourselves against legal claims. Finally, we process your personal data to the extent necessary to defend against or prosecute criminal offences.
We process your data for the above purposes on the following legal basis:
– to protect our legitimate interests pursuant to art. 6 para 1 letter f GDPR, insofar as we assert legal claims or defend ourselves in legal disputes or we prevent or clarify criminal offences.
Some sections of our web pages contain links to the web pages of third parties. These websites are subject to their own data protection principles. We are not responsible for their operation including the data handling. If you send information to or about such third party sites, you should review the privacy statements of those sites before you submit any information that may assigned to you.
The website includes links to services such as Facebook, Twitter, Xing, LinkedIn, Instagram and Pinterest. After clicking on the link you will be redirected to the page of the respective provider, i.e. only then will user information be transferred to the respective provider. For information on the handling of your data when using the websites of other providers, please refer to the respective data privacy policies by these providers.
Firstly, only our employees will be informed of your personal data. In addition, we share your personal data with other recipients who provide services to us in connection with our website, insofar as this is legally permitted or prescribed. We limit the transfer of your personal data to what is necessary, in particular to be able to complete your request. In some cases, our service providers receive your personal data as contract data processors and are then strictly bound by our instructions when handling your personal data. In some cases, the recipients act independently with your data, which we transmit to them.
Below, we describe the categories of recipients of your personal data:
– External service providers for sending invoices by post,
– IT service providers who administrate and host our website,
– Possibly further categories of recipients.
As part of the use of Google tools, we transfer your shortened IP address to the USA. The data transfer is based on the EU Commission implementing decision (EU) 2016/1250 of 12 July 2016 pursuant to Directive 95/46/EG of the European Parliament and of the Council on the adequacy of the protection provided by the EU-US data privacy shield.
Furthermore, we do not transfer your personal data to countries outside the EU or the EEA or to international organisations.
When using our website for information purposes only, we store your personal data on our servers exclusively for the duration of your visit to our website. After you have left our website, your personal data will be deleted immediately. Cookies installed by us are usually also deleted after leaving our website. You also have the option to delete installed cookies yourself at any time.
If you actively use our website, we initially store your personal data for the duration of responding to your inquiry or for the duration of our business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the execution of a contract.
In addition, we will store your personal data until any legal claims arising from the relationship with you become time-barred, in order to use them as evidence if necessary. The limitation period is generally between 12 and 36 months, but can also be up to 30 years.
Upon expiry of the limitation period, we delete your personal data, unless there is a legal obligation to store such data, for example from the German Commercial Code (sec. 238, 257 para. 4 HGB) or from the Tax Code (sec. 147 para. 3, 4 AO). These retention obligations can last from two to ten years.
Under the legal provisions you are entitled to the following rights as data subject, which you can assert against us:
Right to information: You are entitled to request confirmation from us at any time within the scope of art. 15 GDPR as to whether we are processing personal data relating to you; If this is the case, you are also entitled under art. 15 GDPR to receive information about such personal data as well as other specific information (inter alia, processing purposes, categories of personal data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and, in the case of transfers to third countries, the appropriate guarantees) and a copy of the data.
Right to correction: According to art. 16 GDPR, you are entitled to demand correction of the personal data stored about you if it is inaccurate or incorrect.
Right to deletion: You are entitled, under the conditions of art. 17 GDPR, to request from us the deletion of personal data relating to you without delay. Among other things, there is no right of deletion if the processing of personal data is necessary for (i) the exercise of the right to freedom of expression and information, (ii) the fulfilment of a legal obligation to which we are subject (e.g. statutory retention obligations) or (iii) the assertion, exercise or defence of legal claims.
Right to limitation of processing: Under the conditions of art. 18 GDPR you are entitled to request from us the limitation of the processing of your personal data.
Right to data transferability: You are entitled, under the conditions of art. 20 GDPR, to request from us the provision to you of the personal data relating to you that you have submitted to us in a structured, current and machine-readable format.
Right of revocation: You have the right to revoke your consent to the processing of personal data at any time with effect for the future without incurring any costs other than the transmission costs according to the basic rates.
Right to objection: You are entitled to object to the processing of your personal data under the conditions of art. 21 GDPR, meaning that we have to terminate the processing of your personal data. The right of objection exists only within the limits provided for in art. 21 GDPR. In addition, our interests may prevent the processing from being terminated, so that we are entitled to process your personal data despite your objection.
Right of appeal to a supervisory authority: You are entitled to file a complaint with a supervisory authority, in particular in the Member State of your place of residence, work or suspected infringement, under the conditions laid down in Article 77 GDPR, if you believe that the processing of personal data concerning you infringes the GDPR. The right of appeal is not prejudicial to any other administrative or judicial remedy.
The supervisory authority responsible for us is:
Information and Data Protection Commissioner
Level 2, Airways House
High Street
Sliema SLM 1549
Malta
Phone: (+356) 2328 7100
Email: idpc.info@idpc.org.mt
However, we recommend that you always address a complaint to our data protection officer first.
If possible, your applications for the execution of your rights should be addressed in writing to the above address or directly to our data protection officer.
Generally, you are not obliged to provide us with your personal data. However, if you do not provide this information, we will not be able to make our website available to you, answer your questions and enter into a contract with you. Personal data which we do not necessarily require for the above-mentioned processing purposes are marked as voluntary information by a ” if applicable ” or another symbol.
We do not use automated decision making or profiling (an automated analysis of your personal circumstances).
We reserve the right to change this privacy policy at any time. Any changes will be announced by publishing the amended privacy policy on our website. Unless otherwise specified, such amendments shall take immediate effect. Please check this privacy policy regularly to ensure you have the latest version.
Last updated in May 2018