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1. Who are we and what is the purpose of this policy?
Empleo is the name of the legal practice carried on by Dr. Mariella Baldacchino (“we”, “us”. “”our” or “Empleo”). Our office is situated at Office 3, The Agora Business Centre, Triq l-Ahwa Galea, Mosta, MST3340, Malta.
Empleo takes privacy seriously and we are committed to protecting the data you provide to us.
This policy is intended to provide a high-level overview of:
a. the personal data that is collected by us;
b. how this personal data is collected;
c. why do we need to collect such personal data; and
d. how we comply with the provisions of laws relating to the protection of personal data as applicable to us, in particular Regulation (EU) 2016/679 (“GDPR”).
This policy is not intended to apply to the processing of personal data by Empleo in the context of the provision of legal services to our clients. Such processing is governed by and subject to the terms of a separate privacy statement which we have prepared specifically for such engagement and which we send to all clients upon our engagement by clients to provide legal services.
In terms of the provisions of the GDPR, the term “personal data” is defined as ‘any information relating to an identified or identifiable natural person (‘data subject’)’. Furthermore, the term “processing” is also given a wide meaning and is defined as ‘any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means.’ This includes collection, recording, storage, adaptation, and use of personal data.
In its role as a data controller, Empleo determines why and how the personal data it collects is processed. This privacy policy applies solely to the extent that where we are deemed to be data controllers in terms of the GDPR.
2. How do we get personal data?
We collect or get access to personal data as follows:
a. Information that you provided to us directly:
i. When you make an enquiry, or when you engage us to provide services;
ii. Personal data that you make available to us whilst corresponding with us (including through the social media channels of Empleo);
b. We may also collect other types of personal data, automatically, from your device or browser, such as:
We may also receive information about you from third parties, as further detailed hereunder:
IMPORTANT – If you provide us with personal data concerning third-party data subjects, it is your responsibility to ensure that we are duly authorised to process such personal data, and that each third-party data subject has reviewed and agreed to the contents of this policy.
3. Why do we collect
personal data and what is the legal basis for doing so?
We will only process personal information when we have a proper reason for doing so, and particularly to manage our relationship with our customers. Furthermore, we are required to have a legal basis for using and processing any of your personal data. The following table provides an overview of how we will be using your data along with the legal grounds on which we rely:
Purpose | Description | Legal Basis |
Provision of services
| to administer and perform our services, including to carry out our obligations arising from any agreements entered into, and to engage third party contractors.
| contract performance; legitimate interests (to enable us to perform our obligations and provide our services to you); consent. |
Management of client relationship & customer support | To contact you, manage your queries and to manage our relationship with you. | contract performance; legitimate interests (ensuring our customer service quality standards are met); consent
|
Safeguard of our interests | to administer and protect our business (including troubleshooting), to keep our solutions secure, including through identity management and security monitoring to detect, prevent and respond to suspicious activity, fraud, intellectual property infringement, violations of our terms or law and for other similar purposes; to institute and/or participate in legal, court and other proceedings
| legitimate interest (to safeguard our interest and to keep our systems secure and as further set out in the second column) |
For marketing and business development purposes | to provide you with details of new services, updates. | legitimate interests (to develop and grow our business); consent |
Internal testing | to evaluate and assess our solutions so that we can identify any issues which could disrupt our solutions; to generally improve the performance and features of our solutions.
| legitimate interest (as further set out in the second column)
|
Reorganisation | To make certain information available to third parties that may be interested in acquiring our practice (either prior to or as part of the transaction), or otherwise required as part of a reorganisation as to how we carry out our practice. | legitimate interests (to ensure that we are able to sell our practice, should we decide to do so). |
Where we have indicated that the legal basis for the processing of personal data is our legitimate interest, please note that we have carried out a legitimate interest assessment as required by the GDPR. Should you require more information on this matter, please get in touch with us through the contact details set out hereunder.
If you fail to provide personal information
If you choose not to provide your personal data, it may prevent us from meeting legal obligations, fulfilling a contract or performing services. Not providing your personal data may mean we are unable to provide you with our services.
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you, and as otherwise provided hereunder.
We share personal data with:
The majority of the personal data is processed within the European Economic Area (EEA). It is however possible that personal data will be made available or otherwise processed outside of the EEA, namely when we engage certain third-party contractors.
If we do so, we will take adequate measures to ensure that personal data is safeguarded to the same standards as it would have been if processed in the EEA, by relying on one of the following:
The GDPR grants data subjects a number of rights that can be exercised in certain circumstances, including:
We do not carry out any automated decision-making or profiling.
Where the legal basis of processing is based on your consent, you may withdraw such consent at any time by notifying us accordingly. This shall be without prejudice to the lawfulness processing based on consent before such withdrawal. We may continue to process such personal data when we have other legal grounds to do so.
In those situations where Empleo is considered to be a data controller in terms of the GDPR, and you are located in the EEA, you may be entitled to exercise the data subject rights outlined above. For more information about these rights and how to exercise them (when we are acting in our capacity as data controllers), kindly contact our Privacy Manager on the contact details set out hereunder in point 8.
We will not be in a position to entertain any requests in relation to any situation where we are considered to be acting as data processors. If you have questions or would like to exercise your legal rights in such situations, you will be required to contact the association or the merchant (as the case may be) directly.
We will not retain your personal data for longer than necessary. The length of time for which we hold personal data depends on a number of factors, such as regulatory rules and any legal requirements. If you would like further information about our data retention policies, please get in touch with our Privacy Manager on the contact details set out hereunder.
We have appointed a Privacy Manager to oversee compliance with the GDPR and general data protection related queries. If you need more information about this this privacy notice or how we handle personal information, please contact the Privacy Manager at info@empleo.com.mt.
If you are not satisfied with the way we manage personal data, you have the right to file a complaint with any relevant data protection authority (particularly the one situated where you habitually reside).
The supervisory authority located in Malta can be contacted through the following contact details:
Address – Information and Data Protection Commissioner, Floor 2, Airways House, High Street, Sliema, SLM 1549, Malta.
Telephone – (+356) 2328 7100
Email – idpc.info@idpc.org.mt
Version 1
Date 1st September 2022
NOTE: We may update this Privacy Policy from time to time as our services and privacy practices change, or as required by law. The effective date of our Privacy Policy is indicated above, and we encourage you to visit our corporate webpages periodically to stay informed about our privacy practices. We will post the updated version of the Privacy Policy on our corporate websites, and ask for your consent to the changes if legally required.
Mariella graduated from the University of Malta with a doctorate in law in 2005. She completed a master’s degree in ‘European Private Law’ from the La Sapienza, University of Rome, and was admitted to the bar in Malta in 2006.
Mariella is a people person – and it is this attribute which has really characterised and shaped her career.
Over the years, she headed the legal departments of several corporate services firms. Due to her skillset, she was also entrusted with managing and overseeing operations and human resources, where she gained technical and practical experience in various corporate, commercial and employment matters.
Her practical hands-on experience and insight perfectly complement Mariella’s technical knowledge of employment law, thus placing her in an ideal position to understand and advise employers and employees alike on various matters that may arise at the workplace.
Mariella is passionate about employment law matters and provides her clients with the highest-quality legal service to achieve the best possible outcome and resolve any employment law related issues and concerns.
Bradley graduated Doctor of Laws from the University of Malta in 2005 and was admitted to the Bar in Malta in 2006. He advises clients on various corporate, commercial, employment and regulatory matters, with particular focus on company and financial services law.
He has assisted clients in various corporate and commercial matters by providing company law advice and assisting in the implementation of corporate finance, restructuring, mergers and acquisitions and similar transactions.
Bradley has also advised and assisted investment funds, fund managers and other investment services providers, banks and financial institutions, on various legal and regulatory matters relating to the setting up, authorisation and ongoing conduct of their activities in Malta.
His practice also covers general employment law matters. Bradley’s experience in company and financial services law enables him to focus on various corporate and regulatory aspects of employment relationships. In particular, he advises organisations on the implementation of employee share option and participation schemes, the implications of business transfers on employment relationships, as well as relations with senior employees.
Karl graduated Doctor of Laws from the University of Malta in 2005 and was admitted to the Bar in Malta in 2006.
Karl has gained considerable expertise in technology law and regularly assists clients in relation to intellectual property issues, commercial contracts and ways to ensure compliance with the General Data Protection Regulation (GDPR) and privacy laws. Whilst such matters used to be only given incidental importance when dealing with employment matters, they are now widely acknowledged to be vital in all employment relationships.
He is also regularly engaged by C-level executives to assist in negotiating employment contracts and settlement agreements.
Karl advises across a multitude of industries including technology; marketing; adtech; financial services; gaming; esports; consumer products; and media and telecommunications.