1. WHO WE ARE

We are Venus Distribution Malta and we process your personal data.  This means that we are responsible for how we process and protect your data.

2. WHAT WE USE YOUR DATA FOR

We will use your data, among other purposes, to manage your registration as a user, to manage your purchases of products or services, to respond to your queries and, if you wish, to send you our customised communications.

3. WHY WE USE YOUR DATA

We have legal standing to process your data for various reasons. The main reason is that we need to process your data to perform the contract that you accept with us when you register and when you make a purchase or enjoy any of our services or functionalities. We also use your data for other reasons, for example, to respond to your queries or to send you newsletters that you have asked to receive from us.

By submitting opt-in forms, you consent to receive marketing and promotional SMS messages from Venus Distribution Malta Ltd. Message frequency may vary. You can reply “STOP” to unsubscribe. Text HELP for assistance. Standard message and data rates may apply. Your information will be handled in accordance with our Privacy Policy.

4. WHO WE SHARE YOUR DATA WITH

We share your data with service providers who provide us with assistance or support, these being third party providers in the European Union.

5. YOUR RIGHTS

You have the right to access, rectify or delete your personal data. In certain cases, you are also entitled to other rights, such as, for example, to object to us using your data, or to transferring your data, as explained in depth below.

We encourage you to read our full Privacy Policy below to understand in depth the manner in which we will use your personal data and your rights over your data.

BEFORE YOU START

In this Privacy Policy, you will find all relevant information applicable to our users’ and clients’ personal data, regardless of the channel or means of Venus Distribution Malta that you use to interact with us. We are transparent about what we do with your personal data, to help you to understand the implications of the way in which we use your data, and the rights you are entitled to in relation to your data: We permanently make available for you all the information included in this Privacy Policy, that you can check when you consider appropriate, and in addition you will also find further information on how we use your data as you interact with us. These are some terms we regularly use in this Privacy Policy: When we speak about our Platform, we refer to our Website: www.venusmalta.com

1. WHO IS THE CONTROLLER OF YOUR DATA?

Your data controllers are:

Venus Distribution Malta

• Postal address: Flat 9, Block 2 Yacht Marina Apartments, Triq ix-xatt, Pietà, PTA9041, Malta.
• E-mail address of the Data Protection Officer: info@venusmalta.com

In other words, Venus Distribution Malta are controllers of the data. This means that we have regulated and are responsible for processing and protecting your personal data.

2. WHY WE PROCESS YOUR PERSONAL DATA

Depending on the purpose for which we process your data from time to time, as explained above, we need to process one or other data, which will in general be, depending on each case, as follows:

• Your identity data (for example your name, surname, language and country from which you interact with us, contact data, etc.);
• Economic and transactions information (for example, your payment or card data, information on your purchases, orders, returns, etc.);
• Connection, geolocation and/or browsing data (if you interact with us from your mobile phone, for example);
• Commercial information (for example, if you have subscribed to our newsletter)
• Information about your tastes and preferences.

Remember that, when we ask you to fill in your personal data to give you access to any functionality or service of the Platform, we will mark certain fields as compulsory, since this is information that we need to be able to provide the service or give you access to the functionality in question. Please take into account that if you decide not to make such data available to us, you may be unable to complete your user registration or may not be able to enjoy those services or functionalities.

Depending on how you interact with our Platform, i.e. depending on the services, products or functionalities that you wish to enjoy, we will process your personal data for the following purposes:

A. To manage your registration as user of the Platform.

If you decide to become a registered user of our Platform, Venus Distribution Malta needs to process your data to identify you as a user of the Platform and grant you access to its various functionalities, products and services available to you as a registered user. You may cancel your registered user account by contacting us. You may also use the access or login through a social network such as Facebook, either to register as a new user or to link the login to your current account. In that case, your login credentials as well as your email (if you authorise it) will be imported from your social network account. On using this login option, the social network may send Venus Distribution Malta certain additional information on your public profile, such as, for example: your name, gender, approximate age or profile, photograph, in accordance with the terms of use of the social network which Venus Distribution Malta advise you to read carefully. Unless you give Venus Distribution Malta your authorisation, it will not keep these additional data. Moreover, using this functionality may imply that you will be sharing with the social network some information on your activity. In any case Venus Distribution Malta recommends that you review the setting up of your privacy and the privacy policies of the social networks to understand how such social networks use your data.

B. For the development, performance and execution of the purchase or services contract that you executed with us on the Platform.

This purpose includes that we will process your data, mainly:

• To contact you for updates or informative notices related to the contracted functionalities, products or services, including quality surveys and to be able to establish the degree of customer satisfaction with the provided service.
• To manage payment of the products that you purchase, regardless of the payment procedure used. For example: If on purchasing any of our products through the Website, you opt to activate the functionality of save your card data for future purchases, we need to process the indicated data for activation and development of that functionality. Consent to the activation of this functionality enables your autocompleted payment data to appear in subsequent purchases so that you do not need to introduce them in each new process and these data will be deemed valid and effective for subsequent purchases. You may change or cancel your cards at any time through the section on payment information of your Website registered user account.
• Activate the necessary arrangements in order to control and prevent potential fraud against you and against us during the purchase process. If we consider that the transaction can be fraudulent, this processing may cause the blocking of the transaction.
• To manage potential returns after you have purchased and manage requests of availability information for articles, reservations of products through the Platform, depending on the availability of such options from time to time.
• For invoicing purposes and to make available to you the tickets and invoices of the purchases you have made through the Platform.
• To ensure that you are able to use other available functionalities or services, such as the purchase, management and use of the Voucher.

C. To meet requests or applications that you make through the Customer Services channels

We only process the personal data that are strictly necessary to manage or resolve your request or application.

D. For marketing purposes.

Venus Distribution Malta will process your data, mainly for:

• If and when you subscribe to our Newsletter, Venus Distribution Malta will process your personal data to manage your subscription, including to send customised information on our products or services through various means (such as e-mail or SMS). Venus Distribution Malta may also make available to you this information through push notifications in case you have activated them in your mobile device.
  • Accordingly, please take into account that this data processing implies analysis of your user or customer profile to establish your preferences and therefore which products and services are most fit to your style when sending you information. For example, based on your purchases and browsing history (i.e., depending on the articles that you clicked), Venus Distribution Malta will make you suggestions on products that Venus Distribution Malta believes may interest you and, if you are a registered user we will provide you with the “recover cart ” functionality.
  • If you subscribe to our Newsletter and are a registered user of Instagram, Facebook o Twitter with the same email account with which you have subscribed to the Newsletter, we may share with these social networks your e-mail address so that they can show you Venus Distribution Malta ads and, in general, targeted advertising to your profile on such social networks.
  • Remember that you may unsubscribe from the Newsletter at any time without cost through the “Newsletter” section of the Platform, in addition to through the instructions that we provide you with in each notice. If you do not want to receive push notifications, you can deactivate this option in your mobile device.
• To perform promotional actions (for example, for the organization of competitions or to send the list of items stored to the e-mail you designate).
• To disseminate in the Platform or through our channels in the social networks photographs or pictures that you shared publicly, provided that you expressly give Venus Distribution Malta your consent for the purpose.

E. Analysis of usability and quality to improve our services

If you access our Platform, Venus Distribution Malta informs you that it will treat your browsing data for analytic and statistic purposes, i.e., to understand the manner in which users interact with the Platform and thus be capable of introducing improvements in the Platform. In addition, Venus Distribution Malta occasionally performs quality surveys and actions to know the degree of satisfaction of our customers and users and detect those areas in which we may improve.

3. HOW WE ARE LEGALLY PERMITTED TO PROCESS YOUR DATA?

The legal terms on which we are permitted to process your personal data also depends on the purpose for which we process them, as explained below:

A. To manage your Platform user registration

Venus Distribution Malta processes your data because this is necessary on the terms regulating the use of the Platform. In other words, for you to be able to register as a user on the Platform, Venus Distribution Malta needs to process your personal data since it would otherwise be unable to manage your registration.

B. Development, performance and making of the purchase or services contract

If you opt to use the access or login through a social network, Venus Distribution Malta is legally permitted to process your data given the consent that you give when authorising the assignment of your data from the social network. We process your data because their processing is necessary for us to make the purchase or services contract with you. Certain processing of data related to the purchase process is activated only because you request or authorise it, as is the case of the storage of payment (card) data for future purchase. In this case, our processing of your data is supported by your own consent. We consider that we have a legitimate interest to carry out the necessary verifications to detect and prevent potential fraud when you make a purchase. We understand that the processing of these data is positive for all the participating parties when a purchase is paid and in particular for you, since this allows us to establish measures to protect you from fraud attempts by third parties.

C. Customer Service

We consider that we have legitimate interest in answering the requests or consultations raised by you through the existing different contact channels. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the consultations raised. When you get in touch with us, in particular, for the management of incidents related to your order or the product/service acquired through the Platform, the processing of your data is necessary to perform the purchase contract. When your consultation is related to the exercise of your rights on which we inform you below, or to claims on our products or services, we are legally permitted to process your data for compliance with our legal obligations.

D. Marketing

Venus Distribution Malta is legally permitted to process your data for marketing purposes due to the consent that you give it, for example when you accept receiving customized information through multiple channels, when authorizing the sending of push notifications in your mobile device or to publish your pictures on the Platform or on the social networks’ channels. Venus Distribution Malta will also use your consent to cross your data with the social networks to display you advertising tailored to your tastes, habits and browsing in order to show you customised information. Venus Distribution Malta considers that has a legitimate interest to conduct a profiling with the information that it has about you (such as your browsing, preferences or purchase history) and the personal data that you have provided it, such as the age range or language, since Venus Distribution Malta understands that the data processing of these data is also beneficial to you because it allows you to improve your user experience and access the information in accordance with your preferences.

E. Analysis of usability and quality

We consider that Venus Distribution Malta has a legitimate interest in analysing the Platform usability and the user’s satisfaction degree, since we understand that that the processing of these data is also beneficial for you because the purpose is to improve the user experience and provide a higher quality service.

4. HOW LONG WILL WE KEEP YOUR DATA?

The time for which we will keep your data will depend on the purposes for which we process them, as explained below:

A. To manage your Platform user registration

Venus Distribution Malta will process your data for the time during which you remain a registered user (meaning, until you decide to unsubscribe).

B. Development, performance and execution of the purchase or services contract

We will process your data for the time necessary to manage the purchase of the products or services that you buy, including potential returns, complaints or claims related to the purchase of the product or service in question. Sometimes we will only process the data until the time when you decide, as is the case of payment (card) data that you requested us to store for future purchases.

C. Customer Support

We will process your data for the time necessary to meet your request or application.

D. Marketing

Venus Distribution Malta will process your data until you unsubscribe or cancel your subscription to the newsletter.

E. Analysis of usability and quality

Venus Distribution Malta will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey or until it anonymise your browsing data.

Not with standing the fact that we will process your data for the time strictly necessary to achieve the purpose in question, we will subsequently keep them duly stored and protected for the time during which liability may arise for their processing, in compliance with legislation in force from time to time. Once each of the potential actions is time-barred we will proceed to delete the personal data.

5. DO WE SHARE YOUR DATA WITH THIRD PARTIES?

To achieve the purposes mentioned in this Privacy Policy, Venus Distribution Malta must give access to your personal data to third parties that provide us with support in the services that we offer your, i.e.:

• Financial institutions
• Anti-fraud detection and prevention entities
• Technological service providers
• Logistic, transport and delivery partners and service providers
• Providers of customer support related services
• Advertising and marketing related partners and service providers

6. WHAT YOUR RIGHTS ARE WHEN MAKING YOUR DATA AVAILABLE TO US

We undertake to keep your personal data confidential and to ensure that you may exercise your rights. Bearing that in mind, we have agreed that you may exercise your rights free of charge by writing us an e-mail to a single e-mail address (info@www.venusmalta.com), simply informing us of the reason for your request and the right that you wish to exercise. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity.

In particular, notwithstanding the purpose or legal basis we use to process your data, you have the following rights:

• To request access to your personal data that we hold. We remind you that where you are a Platform registered user you may also consult this information in the relevant section of your online account.
• To request that we rectify the personal data that we hold. Please bear in mind that if you are a
  registered user on the Platform, you may also access the relevant personal data section of your online account to change or update your personal data. In any case, please take into account that on actively making your personal data available to us through any procedure, you guarantee that they are true and accurate and you undertake to notify to us any change or modification of your data. You will be liable for any loss or damage caused to the Platform or to the person responsible for the Platform or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms. Please remember that, as a general rule, you must provide us only with your own data, not with those of third parties, other than to the extent otherwise permitted in this Privacy Policy.
• To request that we erase your personal data to the extent that they are no longer necessary for the purpose for which we need to keep processing them, as we have explained above, or when we are no longer legally permitted to process them.
• To request that we cancel or limit the processing of your personal data, which entails that in certain cases you can request us to temporally suspend the processing of the data or that we keep them for not longer than necessary.

If you have given us your consent to process your data for any purpose, you also have the right to withdraw such consent at any time. Some of the circumstances in which you may withdraw your consent are detailed in section 2 where we explain for which purposes we process your data.
When we are legally permitted to process your data due to your consent or to for the purposes of a contract, as explained in section 3, you will also have the right to request the portability of your personal data. This means that you will have the right to receive the personal data that you made available to us in a structured, commonly used and machine-legible format, to be able to transmit them to another entity directly without impediments on our part. In addition, where the processing of your data is based on our legitimate interest, you will also have the right to object to the processing of your data. Finally, we inform you that you have the right to file a claim before the responsible data protection regulatory authority, in particular before:

The Maltese Data Protection Authority (https://idpc.org.mt/en/Pages/Home.aspx)

7. WHAT HAPPENS WHEN YOU PROVIDE US WITH DATA OF THIRD PARTIES?

We offer functionalities or services that require us to process the personal data of a third party that you must provide, such as in the case of Voucher or shipping to a third party. If you provide us with personal data of third parties, you confirm that you informed them of the purposes and of the manner in which we need to process their personal data.

8. CHANGES TO THE PRIVACY POLICY

We may amend the information contained in this Privacy Policy when we consider this appropriate. Should we do so, we will notify you by various procedures through the Platform (for example, through a banner, a pop-up or a push notification), or we may even send you a notice to your e-mail address when the change in question is relevant to your privacy, for you to be able to review the changes, assess them and, as the case may be, object or unsubscribe from any service or functionality. In any case, we suggest you to review this Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our Website.

9. INFORMATION ON COOKIES

We use cookies and similar devices to facilitate your browsing in the Platform, understand how you interact with us and, in certain cases, to be able to show you advertisements in accordance with your browsing habits.