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This document applies to all personal information held by Cleverbit as the controllers of your personal data and goes into detail on how we process your data, why do we process it, with whom this data may be shared, in what situations we may share this data and all the measures we are taking to ensure that your data is safe and secure. The terms of this policy will apply as long as you are a client of Cleverbit but will also continue to apply after you cease to be a client. It also applies if you have sent us your data to be part of our marketing mailing list and also if you have applied for a position with Cleverbit.
Cleverbit refers to the following company as Controller of your Personal Data. Cleverbit refers to the following
company: Cleverbit Software Ltd, a company incorporated under the laws of Malta, having company registration
number C 80200 and address at 50, Triq Giorgio Preca, San Gwann, SGN 3510, Malta
On our website, you may also find links to other websites which are not managed or owned by Cleverbit. Cleverbit
is not responsible for any such websites and this privacy policy shall not apply in this regard. The businesses
operating these websites, may or may not have their own privacy policy and in this regard, Cleverbit is no way
responsible for the way such companies manage the processing of your personal data. That’s where Cleverbit
Software came in.
The data controller as defined under the Regulation (EU) 2016/679 which is generally referred to as the General Data Protection Regulation (hereinafter referred to as “GDPR”), is Cleverbit as defined above.
The data controller as defined under the Regulation (EU) 2016/679 which is generally referred to as the General Data Protection Regulation (hereinafter referred to as “GDPR”), is Cleverbit as defined above.
Personal Data is personal information about an individual, like you. We collect such information about our
customers for relationship management, statistical reasons and for marketing purposes and also on our
employees or potential employees when they apply for a position with us. We may also collect some personal
information from other individuals who are not our customers, for marketing purposes, subject to their
consent. As Cleverbit, we also process Personal Data of the customers of our clients when they engage us to
provide services to them.
Personal Data may also be of a general nature and of a special nature. Generic Personal Data refers to data
such as names, surnames, contact details and similar data which can be used to identify a person. Special
categories of Personal Data relate to more confidential kind of Personal Data such as health data.
Information regarding the different kinds of Personal Data we collect can be found in section 6 of this
document.
Certain more sensitive kind of Personal Data is defined under law as Special Categories of Personal Data, which relates to:
We generally do not process such Personal Data. However, when we provide our services to our Clients, the customer data of our clients will need to be processed by Cleverbit so that Cleverbit can provide its service. However such processing shall always be in line with the relevant legal requirements. In any case, we will always specify the purpose where such Personal Data shall be used and on what legal basis. We will also only use such Personal Data for the purposes that such Personal Data would have been collected and not for any other purposes.
When you provide your Personal Data to a third party, you are passing such data to either a controller or a
processor.
A Controller of your Personal Data is an individual or a company who has the power to determine the exact
uses of the Personal Data you have supplied to him. On the other hand, a Processor is a third party who is
processing and thus utilising your Personal Data on behalf of a controller.
This section shall outline the various ways we collect Personal Data from you from different situations. In this regard, all Personal Data collected must have a proper legal ground justifying collection and such is stated in each situation were Personal Data is Collected. Finally, the retention period for each set of Personal Data Collected is also listed herein.
Description
Data Collected
Legal Basis
Retention Period
When you browse this website, we may collect data through some tracking cookies as explained in the cookie section of this Policy. Otherwise, we do not collect Personal Data unless you voluntarily and knowingly provide it to us, for example by signing up to our mailing list.
Kindly refer to cookie section.
i) Consent, when dealing with non-essential cookies.
Kindly refer to cookie section.
Description
Data Collected
Legal Basis
Retention Period
_ga_*
1 year 1 month 4 days
Google Analytics sets this cookie to store and count page views.
When contacting us through our website, we would need some personal data to be able to reply to your query.
i) Name and Surname
ii) Email
ii) Contact Number
i) Consent
1 year unless the party is engaged.
Description
Data Collected
Legal Basis
Retention Period
When you call our offices, our telephone equipment will record the conversation for the protection of our legal interest.
i) Telephone Recording
i) Legitimate Interest
30 days
Description
Data Collected
Legal Basis
Retention Period
When you engage us to provide services, we would require significant amounts of personal data
i) Name and Surname
ii) Contact Details
iii) Email
iv) Names and surnames of employees and their contact details
v) Bank Details
i) Contract
ii) Legitimate Interest
iii) Compliance with laws and regulations
5 years from when we stop providing you with our services.
Description
Data Collected
Legal Basis
Retention Period
When we engage with you for the provision of goods and services to us, we collect personal data
i) Name and Surname
ii) Contact Details
iii) Email
iv) Names and surnames of employees and their contact details
v) Bank Details
i) Contract
ii) Legitimate Interest
iii) Compliance with laws and regulations
5 years from when we stop providing you with our services.
Description
Data Collected
Legal Basis
Retention Period
When we engage with you for the provision of goods and services to us, we collect personal data
i) Name and Surname
ii) Contact Details
iii) Email
i) To protect our legitimate interest
3 months
Description
Data Collected
Legal Basis
Retention Period
When you apply for a position with us, we would need to process your Personal Data to be able to verify your suitability for the role you have applied to.
i) Name and Surname
ii) Your CV and Personal Data contained within
iii) Residential Address
iv) Contact Number
v) Email
vi) Date of Birth
i) To protect our legitimate interest
ii) Consent
4 months minimum. One year of consent is obtained.
Description
Data Collected
Legal Basis
Retention Period
When you visit our premises, we collect CCTV data for security purposes.
i) CCTV Footage
i) To protect our legitimate interest
7 Days
Should in any event, we are required to keep your Personal Data for any longer period as allowed by law, your Personal Data shall be kept secure and shall be deleted when we are allowed by law to delete such Personal Data.
In addition to the required information sharing described above, we use the services of third party agents,
such as e-mail service providers, hosting services providers, data centers and mail houses for the purpose
of providing our services or mailing materials to our clients. These parties are contractually prohibited
from using Personal Data for any purpose other than for the purpose specified in their respective contracts.
We do provide non-personally identifiable information to certain service providers for their use on an
aggregated basis for the purpose of performing their contractual obligations to us. We do not permit the
sale of Personal Data to third parties for any use unrelated to our operations or use of Personal Data by
third party for their own purposes.
Below is a list of sub processors:
Name of Process
Address
Task to be performed and Personal Data to be Processed
Location of Processing
Avepoint
Systems Data Backups
Microsoft
Microsoft Ireland Operations, Ltd. Attn: Data Protection, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland.
Systems Data Backups
EU
Freshdesk
EU
Helpdesk software used by our support team
EU
Sub-contractors
Malta
Individual Sub-Contractor - Software Developer
Malta
Intercomp
Malta
Systems Consultants
Malta
Our website only uses “cookie” technology as a tracking tool. Cookies do not retain registered guests’
information provided during the online reservations. Cookies identify your browser, rather than you and
cannot be used by themselves to disclose your individual identity. Cookies enable us to track the number of
page visits from the same computer or browser to be aggregated for statistical purposes.
Cookies do not corrupt or damage your computer, programs, or computer files. The purpose for which cookies —
other than those which are either exclusively intended to enable or facilitate communication by electronic
means or strictly necessary for the provision of an online communication service at your express request —
are used on our website is set forth in a banner appearing the first time you land on such website.
For more information,
kindly visit our cookie policy.
You have certain rights under law to your Personal Data.
We shall strive to send your data only to other EU countries or other countries which ensure proper protection for your data. When transferring your data to countries which are not deemed as such, proper measures in terms of the law shall be applied to ensure the protection of your Personal Data. In cases where such measures cannot be achieved, Personal Data shall only be sent to these countries if necessary, to perform our services and also subject to any of the required measures imposed under GDPR. Some of the recipients referred to above are located in or process Personal Data outside of your country. The level of data protection in another country may not be equivalent to that in your country. However, we only transfer your Personal Data to countries where the EU Commission has decided that they have an adequate level of data protection or we take measures to ensure that all recipients provide an adequate level of data protection. We do this for example by entering into appropriate data transfer agreements based on Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of Personal Data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council).
We shall take all the necessary measures as required by law to ensure proper security and protection to your Personal Data. Such measures may include encryption, use of firewalls, anti-virus software and specialized security software, access restrictions and limitations, strict enforcement of policies and any other measures that we may enforce from time to time. Our measures shall strive to ensure that:
Despite our best efforts however, we cannot provide a 100% guarantee in relation to our system security.
In the event of a Data Breach following your Personal Data, we shall always abide by the law and inform you and the competent authorities as required.
This data privacy statement was last updated on the 1st July 2023 in line with the last EU legislation to meet the GDPR requirements. In the future, we may need to make additional changes. All additional changes will be included in the latest data privacy statement published on this website, so that you will always understand our current practices with respect to the information we gather, how we might use that information and disclosures of that information to third parties. You can tell when this privacy statement was last updated by looking at the date at the top of the statement. Any changes to our statement will become effective upon posting of the revised statement on this site. We will seek your express consent to any changes to how we use or disclose your Personal Data if requested by law but otherwise use of this site or our services following such changes constitutes your acceptance of the revised statement then in effect.
Kindly note that our website contains hyperlinks to other websites. Please note that Cleverbit is not responsible for the content of these other websites or their respective adherence to data protection laws and rules. Cleverbit does not provide any quality controls to such websites and shall accept no responsibility for their performance, security, accuracy, content or privacy in relation to your personal data.
If you wish to make any inquiry regarding your personal data, wish to have any of your data corrected or
request access to your personal data, you may contact us on the below details. Please note that we may
charge a fee or refuse requests which are manifestly repetitive or excessive.
Any request must be in writing and must also include your name, address and a description of the information
or correction required. We may also ask for other identification documentation. Such information is
essential so that we can identify you properly.
Email: [email protected]
Name: Dr Annalisa Debono
Address: 50, Triq Giorgio Preca, San Gwann, SGN 3510, Malta
This Policy has been updated on: 1st June 2025
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