We are committed to safeguarding the privacy of our website visitors.
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.
Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive occasional newsletters from Spirit of Anima. You can access the newsletter sign-up from the footer of all pages within our website.
In this policy, “we”, “us” and “our” refer to Spirit of Anima.
2. HOW WE USE YOUR PERSONAL DATA
In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
We may process data about the general use of our website through Google Analytics (“usage data”). The usage data includes your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your website use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website.
We may process information contained in any enquiry you submit to us regarding services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is the proper administration of our website and business and communications with users.
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. PROVIDING YOUR PERSONAL DATA TO OTHERS
We may disclose your email address to any member of our company insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
We do not have offices or facilities in any countries other than Malta and will therefore not send your personal data outside of the country.
The hosting facilities for our website are situated in the UK. The European Commission has made an “adequacy decision” with respect to the data protection laws within the UK.
5. RETAINING AND DELETING PERSONAL DATA
This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
(a) Email addresses for those who have signed up to receive newsletters will be retained for a maximum period of 10 years following registration.
Notwithstanding the other provisions of this Section 5, 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 vital interests or the vital interests of another natural person.
6. YOUR RIGHTS
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 100); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
We may withhold personal information that you request to the extent permitted by law.
You may instruct us at any time not to process your personal information for marketing purposes.
In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
7. ABOUT COOKIES
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
8. COOKIES THAT WE USE
9. OUR DETAILS
This website is owned and operated by Spirit of Anima.
We are registered in Malta under registration number 182902, and our registered office is 114 The Strand, 1027 Gzira, Malta.
You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by email, using the email address published on our website.