Privacy Policy

Privacy Policy for Website Users and End Customers

This website is operated by ANIcon Professional Services Ltd. having registered address at Startup Center Gozo, Office No. 50, 9 Triq L-Gharb, Gozo, Malta. This privacy policy describes how we collect and process your Personal Data acting as the data controller in connection with this website and other websites of our Company or with other services we are providing to you as an end customer.

1.General 

1.1 What is GDPR and DPA

GDPR is a EU regulation, which seeks to strengthen the protection given to Personal Data. In the highly digitized world
we live in today, information has become essential. We strive to ensure that any Personal Data that we have in our possession, is properly processed in terms of the law and shall strive to ensure proper protection for your Personal
Data. Your Personal Data is critical for our business and for the provision of our services and thus its security and proper use is of paramount importance to us. Additionally, in Malta complementing the GDPR, we find its transposition
within the Data Protection Act, Chapter 586 of the Laws of Malta. It is also notable to mention that apart from these main sources, there exists other subsidiary legislation implemented under Chapter 586 such as, amongst others, the Processing of Personal Data (Protection of Minors) Regulation.

1.2 What is Personal Data

Personal Data is personal information about an individual, like you. We collect such information about our customers, suppliers, and network partners for relationship management, statistical reasons and for marketing purposes. We may
also collect some personal information from other individuals who are not our customers, suppliers or network partners for marketing purposes, subject to their consent. 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 3 of this document. 

1.3 What are Controllers and Processors of Personal Data

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.

2. The Controller of your Personal Data

ANIcon Professional Services Ltd. is a consulting company for the support of transformation and/or digitalization processes of customers and a service provider for business development services. ANIcon Professional Services Ltd. generally collects Personal Data regarding our clients at the below stages of our relationship with our customers:

1. When we are approached to assess
   a client´s transformation and/or digitalization landscape
2. When we are about to start a
   new consulting project or a business development project, respectively,
   over lifetime from start to conclusion

We also Process Personal Data on our potential and actual suppliers and network partners within the framework of our specific interests.

2.1 When we are approached to assist a potential client seeking service and support

When ANIcon Professional Services Ltd. is approached by a potential client seeking consulting or business development support, Personal Data shall be collected by the client relationship responsible, who shall be Controller of this Personal Data. This Personal Data will however be shared with other employees of the Company, who shall also be a Controller of your Personal Data. Your Personal Data will be shared between the members of the Company so we can assist you in providing our services.

2.2 When we are working on a project during lifetime

Similarly, to the above, when our Company is approached by a client seeking consulting or business development service, Personal Data shall be collected by the consultant(s) in charge, who shall be Controller of this Personal Data. This
Personal Data will also be shared with other members of the Company, who shall also be a Controller of your Personal Data. Your Personal Data will be shared so we can assist you in providing our services.

3. Your Personal Data

3.1 What Personal Data we collect

During your visit of this website, we will automatically collect the following Personal
Data about you:

• information about the pages
  that you visit on this website;
• the date and time of your
  visit, 
• your IP address, 
• your web browser, 
• the website (https://greenlife-europe.com or https://anicon-consulting.com)
  that you visited before accessing this website.

If you looking for and seek consulting or business development support, we may obtain Personal Data from this website. The Personal Data we process in this context is:

• your name and surname;
• your address;
• your telephone number;
• your email address;
• listings and associated listing information an data concerning individual requirements from the client.

This information will only be obtained if you provide this information yourself to our members of the Company or if you input this data in our website. In cases where we ask you to provide any Personal Data, there is no obligation to do so,

but if you do not, you will not be able to use all functions of our website, apply with us or to make use of our services in general.

3.2 Specific Categories of Personal Data

Certain Personal Data is more sensitive and is classified as special categories of Personal Data, which relates to the following:

• Racial or ethnic origin;
• Political opinions;
• Religious or philosophical beliefs;
• Trade union membership;
• Genetic data;
• Biometric data for the purpose
  of uniquely identifying a natural person; 
• Data concerning health;
• Data concerning a natural
  person’s sex life or sexual orientation

In any case we will clearly explain the purposes for which we wish to use such Personal Data when it is being collected, and, if necessary, obtain your consent at that time.  In such cases, you will be able to withdraw your consent at any time. We will never process such Personal Data without obtaining your prior
written consent unless otherwise specified by law.

4. Purposes for which we use your data

We will use your Personal Data to provide this website to you as a user of this website, to
generate usage statistics, to improve and further develop this website, to
provide consulting and business development services to you, to respond to your
requests and messages, to send you our newsletters or announcements if you have
subscribed to it, to contact you about expert knowledge that may interest you,
and to analyse your data in aggregated form for business intelligence purposes.

 

 5. Legal basis for the processing

We shall always process your Personal Data in terms of the law and therefore we shall
always have a proper legal basis to Process your Personal Data;

1. Should you visit our premises, we will collect, and process visual data collected by a receptionist or
   member of the Company. The legal grounds for processing here shall be to
   protect our legitimate interest in terms of article 6(1)(f).
2. If we process certain Personal Data about you that we receive from our website, from queries, from our
   social media platforms or from another member of the consulting network, according
   to your prior consent, the legal basis for the processing will be your
   consent pursuant to Article 6(1)(a) GDPR that you will be asked for in a
   separate process. Where you will be asked for your consent, you may
   withdraw your consent at any time. However, doing so would not affect the
   lawfulness of the processing of your data based on the consent before its
   withdrawal. By withdrawing your consent, we may also be unable to provide
   you with our services. 
3. If we process your Personal Data due to the fact that you would like to seek consulting or business
   development advice, we would have entered into a contractual agreement
   with you and thus we would be processing your Personal Data to adhere to
   our contractual obligations in terms of article 6(1)(b) GDPR, due to
   certain legal obligations in terms of article 6(1)(c) GDPR and to protect
   our legitimate interest in terms of article 6(1)(f).
4. If however we are in the process of concluding a contractual agreement we shall also be processing additional Personal Data from each side of the transaction as required by law. The legal grounds for processing here shall be to adhere to our contractual obligations in terms of article 6(1)(b) GDPR, due to certain legal obligations in terms of article 6(1)(c) GDPR, specifically due to prevention of money laundering and financing of terrorism laws and to protect our legitimate interest in terms of article 6(1)(f).

6. Disclosures and data transfers

6.1 Independent Third Parties

As far as this is necessary for the purposes set out above, we may transfer your Personal Data to third parties as follows:

Name	Detail
Consultants or other employees	We shall be providing your Personal Data to other members of our Company.
Internal Databases	Your Personal Data shall may be found in our internal databases which is managed by an external service provider.
Marketing	Your Personal Data may be used in our marketing material and thus may be sent to marketing service providers.
Storage	Data on our servers, which may contain Personal Data is stored with external third parties and on the cloud through service providers.
Authorities	Your Personal Data may be shared with the relevant public authorities as required under law.

Should you require a detailed list of processors, kindly contact us as indicated below and we would provide you with more detail. 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 the Standard Contractual Clauses implemented through Commission Implementing Decision (EU) 2021/915 of 4 June 2021 on standard contractual clauses between controllers and processors under Article 28(7) of Regulation (EU) 2016/679 of the European Parliament and of the Council and Article 29(7) of Regulation (EU) 2018/1725 of the European Parliament and of the Council and the 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 as regards the introduction of an alternative set of standard contractual clauses for the transfer of Personal Data to third countries). Such agreements are accessible upon request from info@greenlife-europe.com or info@anicon-consulting.com or gm@anicon-services.eu

6.2 Regulatory Authorities

In terms ofcurrent laws, we may be required to transfer your Personal Data to certainregulatory or government authorities when subject to a proper and lawful request in terms of the law. We may be obliged to provide such data and we may
also be prevented from informing you that such data has been provided. 

6.3 Personal Data collected from third Parties

In certain cases, as allowed by law, we may receive Personal Data about you from third parties, such as public authorities. Any Personal Data collected in this regard shall be processed and stored in terms of the law. 

7. Retention periods

We will retain your data that we collect automatically when you visit this website for no longer than six months. 

If you have subscribed to our newsletter, we will retain you email address until you  unsubscribe from our newsletter. 

If you have registered on our website, we will retain your data for as long as your account exists and thereafter only for as long as there are any legal obligations to retain your data.

In this regard we shall keep;

1. Any of your general Personal
   Data up to at least five years after the end of our business relationship.
   Such Personal Data shall be kept protecting our legitimate interest due to
   statuary limitations. In addition, this data shall be kept due to our due
   diligence obligations under the current legislation to prevent money
   laundering and financing of terrorism. This period may be extended to 10
   years in certain situations as dictated under law;
2. Other Personal Data which may
   relate to transactions and other commercial matters shall be kept for at
   least ten years due to other obligations we have in terms of the law with
   the local authorities in relation to taxation matters

We also process your personal data communicated to a recepionist as stated previously.
Such recordings shall be kept for 7 days unless the need arises to keep the
recordings for a longer period of time due to legal obligations or to protect
our legitimate interest.    

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.

8. Your rights and remedies

Under applicable data protection law, you have these rights:

1. to check whether and what kind
   of Personal Data we hold about you and to access or to request copies of
   such data,
2. to request correction,
   supplementation or deletion of Personal Data about you that is inaccurate
   or processed in non-compliance with applicable requirements,
3. to request that we restrict the
   collection, processing or use of Personal Data about you,
4. in certain circumstances, to
   object for legitimate reasons to the processing of your Personal Data,
5. to request your Personal Data
   in a structured, commonly used and machine-readable format, as allowed by
   law,
6. to know the identities of third
   parties to which your Personal Data are transferred and
7. to provide instructions on how
   your data must be handled after your death when relevant. 

When you are making such requests please note the below:

1. That following your request, we
   shall have up to one (1) month to reply, except in extreme situations as
   allowed under law. In such a case, we shall provide you with information
   why your requests were not finalized within such one month period. In the above-mentioned
   exceptional situations, the one month time frame may be extended by a
   further two (2) months
2. That we have the right to
   charge a reasonable fee or refuse your request, if such requests are
   manifestly unfounded or excessive.
3. That when you are making a
   request, we may request documentation or information to confirm your
   identity. 

In case of any complaints, you also have the right to lodge a complaint with the competent
data protection authority in Malta or in the Member state in which you work or
reside.

9. Data Security Measures

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:

1. There is no unlawful
   destruction of your Personal Data;
2. That your Personal Data is not
   subject to unauthorized access;
3. That your Personal Data is not
   subject to unauthorized disclosure;
4. That your Personal Data is not
   subject to unauthorized modifications;

Despite our best efforts however, we cannot provide a 100% guarantee in relation to our system security.

 

10. Surveillance and Security

We apply certain surveillance and security measures at our offices and on our systems. This Personal Data shall be stored and managed in terms of current data protection law. 

11. Marketing

11. 1 Direct Marketing

We shall always send marketing material to you if authorised by law to do so and we shall never send unsolicited marketing material in this regard. If you subscribe to our services regard to announcements or events, we shall be sending you information regarding expertise that would interest you, in terms of the information you would have provided us. Thus we would be relying on your consent to send you such information which you can withdraw at any time. 

11.2 Social Media 

We also use social media to promote our services. Should you contact us through social media or should you provide us with Personal Data through social media, this privacy policy shall also apply and any Personal Data collected there shall be managed in terms of this policy. 

12. Hyperlinks

Our website contains hyperlinks to websites operated by other companies or businesses which are not related to us in any way. These websites are managed by companies who have their own data protection policies and procedures in place on which we have no control over. Therefore, we are not responsible for the way the owners of these websites process your Personal Data.

13. Updating of this Policy

We may at any time update the terms of this Privacy Policy in terms of the law. If you are our client, we shall inform you if we have carried out material changes to this policy. If you are not a client of ours, it shall be in your interest to regularly check this policy. 

 

14. Contacting us

Should you have any questions regarding our data protection policies or would like to make a request in relation to your Personal Data, please contact us on the below: 

ANIcon Professional Services Ltd.

Startup Center Gozo, Office No. 50

9, Triq L-Gharb, Gharb GRB1102, Gozo, Malta

info@anicon-consulting.com

info@greenlife-europe.com

gm@anicon-services.eu

+356 20330318
+49 176 5635 2812

The contact email of our DPO is:

info@greenlife-europe.com