Company Registration Number: C 84827
Company Name: Edjowa Ltd
Registration Date: Feb 13, 2018
Registered Office: Abacus Business Centre, Level 1 Dun Karm Street, B’Kara Bypass
City/Locality: Birkirkara BKR9037
Personal data is any information relating to an identified or identifiable natural person (hereinafter the „data subject“). A natural person is considered to be identifiable who directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier or to one or more special features,which are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person, can be identified.
Affected person is any identified or identifiable natural person whose personal data is processed by the controller.
Processing means any process or series of operations related to personal data, such as collecting, collecting, organizing, organizing, storing, adapting or modifying, reading, querying, using, with or without the aid of automated procedures; disclosure by submission, dissemination or other form of provision, reconciliation or association, restriction, erasure or destruction.
Restriction of the processing is the marking of stored personal data with the aim to limit their future processing.
Profiling is any kind of automated processing of personal data that consists in using that personal information to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.
Pseudonymisation is the processing of personal data in such a way that personal data can no longer be attributed to a specific data subject without the need for additional information, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.
The controller or controller is the natural or legal person, public authority, body or body that, alone or in concert with others, decides on the purposes and means of processing personal data. Where the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or the specific criteria for his designation may be provided for under Union or national law.
The processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Recipient is a natural or legal person, agency, agency or other entity to whom Personal Data is disclosed, whether or not it is a third party. However, authorities which may receive personal data under Union or national law in connection with a particular mission are not considered as beneficiaries.
Third is a natural or legal person, public authority, body or body other than the data subject, the controller, the processor and the persons under the immediate jurisdiction Responsibility of the controller or the processor are authorized to process the personal data.
Consent is any voluntarily given and unambiguously expressed in the form of a statement or other unambiguous confirmatory act by the data subject for the particular case, by which the data subject indicates that they consent to the processing of the personal data concerning him / her is.
The person responsible within the meaning of the General Data Protection Regulation, other data protection laws in the Member States of the European Union and other provisions of a data protection character is: Edjowa Ltd Abacus Business Centre, Level 1 Dun Karm Street, B’Kara Bypass Birkirkara BKR9037-MALTA www.edjowa-holding.com email@example.com
The website of Edjowa Holding Ltd collects a series of general data and information each time the website is accessed by an affected person or an automated system. This general data and information is stored in the log files of the server. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrers), (4) the sub-web pages, which can be accessed via (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information used in the event of attacks on our information technology systems. In using this general data and information, Edjowa Holding Ltd does not draw any conclusions about the data subject. Rather, this information is required to (1) correctly deliver the contents of our website, (2) to optimize the content of our website and to advertise it, (3) to ensure the continued functioning of our information technology systems and the technology of our website, and ( 4) to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyberattack. This anonymously collected data and information is evaluated by Edjowa Holding Ltd on the one hand statistically and also with the aim to increase the data protection and data security in our company, in order to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by an affected person.
On the website of Edjowa Holding Ltd, users are given the opportunity to subscribe to the newsletter of our company. Which personal data are transmitted to the data controller when the newsletter is ordered results from the input mask used for this purpose. Edjowa Holding Ltd informs its customers and business partners at regular intervals by means of a newsletter about offers of the company. The newsletter of our company can only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter. For legal reasons, a confirmation e-mail will be sent to the e-mail address entered by an affected person for the first time for the newsletter dispatch in the double-opt-in procedure. This confirmation email is used to check whether the owner of the e-mail address as the person concerned authorized the receipt of the newsletter. When subscribing to the newsletter, we also store the IP address of the computer system used by the person concerned at the time of registration, as well as the date and time of registration, as assigned by the Internet Service Provider (ISP). The collection of this data is necessary in order to understand the (possible) misuse of an affected person’s e-mail address at a later date and therefore serves as legal safeguards for the controller. The personal data collected in the context of registering for the newsletter will be used exclusively to send our newsletter. Subscribers to the newsletter may also be notified by e-mail if this is necessary for the operation of the newsletter service or registration, as might be the case in the event of changes to the newsletter or technical changes. There will be no transfer of the personal data collected as part of the newsletter service to third parties. Subscription to our newsletter may be terminated by the person concerned at any time. The consent to the storage of personal data that the data subject has given us for the newsletter dispatch can be revoked at any time. For the purpose of revoking the consent, there is a corresponding link in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the controller’s website, or to inform the controller in a different way.
The newsletters of Edjowa Holding Ltd contain so-called counting pixels. A counting pixel is a miniature graphic that is embedded in such emails that are sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded pixel, Edjowa Holding Ltd can detect if and when an e-mail was opened by an affected person and which links in the e-mail were accessed by the person concerned. Such personal data collected via the counting pixels contained in the newsletters are stored and evaluated by the controller in order to optimize the delivery of the newsletter and to better adapt the content of future newsletters to the interests of the data subject. This personal data will not be disclosed to third parties. Affected persons are at any time entitled to revoke the separate declaration of consent issued via the double-opt-in procedure. After revocation, this personal data will be deleted by the controller. A deregistration from the receipt of the newsletter, the Edjowa Holding Ltd automatically interpreted as a revocation.
Due to legal regulations, the website of Edjowa Holding Ltd contains information that enables us to contact our company quickly and communicate directly with us, which also includes a general address of the so-called electronic mail (e-mail address). If an affected person contacts the data controller by e-mail or through a contact form, the personal data provided by the data subject will be automatically saved. Such personal data, voluntarily transmitted by an individual to the controller, is stored for the purpose of processing or contacting the data subject. There is no disclosure of this personal data to third parties.
The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of the storage or, as the case may be, by the European directives or regulations or by any other legislator in laws or regulations which the controller was provided for. If the storage purpose is omitted or if a storage period prescribed by the European directives and regulations or any other relevant legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
Each data subject has the right, as granted by the European Regulators and Regulators, to require the controller to confirm whether personal data relating to him / her are being processed. If an affected person wishes to make use of this right of confirmation, they can contact an employee of the controller at any time.
Any person affected by the processing of personal data shall have the right granted by the European Di- rective and Regulatory Authority to obtain at any time, free of charge, from the controller any personal data stored about him or her and a copy of that information. Furthermore, the European legislator and regulator has provided the data subject with the following information: o the processing purposes o the categories of personal data being processed o the recipients or categories of recipients to whom the personal data have been disclosed or are still being disclosed, in particular to recipients in third countries or to international organizations o if possible, the planned duration for which the personal data will be stored or, if that is not possible, the criteria for determining that duration o the right of rectification or erasure of the personal data concerning them or restriction of processing by the controller or a right to object to such processing o the existence of a right of appeal to a supervisory authority o if the personal data are not collected from the data subject: all available information on the source of the data o the existence of automated decision-making, including profiling, in accordance with Article 22 (1) and (4) of the GDPR and – at least in these cases – meaningful information about the logic involved and the scope and intended impact of such processing on the data subject In addition, the data subject has a right of access as to whether personal data has been transmitted to a third country or to an international organization. If that is the case, then the data subject has the right to obtain information about the appropriate guarantees in connection with the transfer. If an interested party wishes to exercise this right to information, they may at any time contact an employee of the controller.
Any person affected by the processing of personal data has the right granted by the European legislator to demand the immediate correction of inaccurate personal data concerning him. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing. If an affected person wishes to exercise this right of rectification, they may, at any time, contact an employee of the controller.
o The personal data were processed unlawfully. o The deletion of personal data is required to fulfill a legal obligation under Union or national law to which the controller is subject. o The personal data were collected in relation to information society services offered pursuant to Art. 8 para. 1 DS-GVO. If one of the above reasons is correct and an interested party wishes to arrange for the deletion of personal data held by Edjowa Holding Ltd, it may, at any time, contact an employee of the controller. The employee of Edjowa Holding Ltd will arrange for the extinguishing request to be fulfilled immediately. If the personal data have been made public by Edjowa Holding Ltd and our company is responsible for the deletion of personal data as the person responsible pursuant to Art. 17 (1) DS-GVO, Edjowa Holding Ltd will take appropriate measures, taking into account the available technology and the implementation costs also of a technical nature, to inform other data controllers processing the personal data published that the data subject of these other data controllers shall delete any links to such personal data or copies or replications thereof personal data unless the processing is required. The employee of Edjowa Holding Ltd will arrange the necessary in individual cases.
Any person affected by the processing of personal data has the right, granted by the European directive and regulatory authority, to require the controller to restrict the processing if one of the following conditions applies: o The accuracy of the personal data is contested by the data subject for a period of time that enables the person responsible to verify the accuracy of the personal data. o The processing is unlawful, the data subject refuses to delete the personal data and instead requests the restriction of the use of personal data. o The data controller no longer needs the personal data for processing purposes, but the data subject requires them to assert, exercise or defend their rights. o The person concerned has objection to the processing acc. Art. 21 para. 1 DS-GVO and it is not yet clear whether the legitimate reasons of the person responsible outweigh those of the person concerned. If one of the above conditions is met and a data subject wishes to request the restriction of personal data held by Edjowa Holding Ltd, he may, at any time, contact an employee of the controller. The employee of Edjowa Holding Ltd will initiate the restriction of processing.
Any person affected by the processing of personal data shall have the right conferred by the European Directives and Regulations to obtain the personal data concerning him / her provided to a controller by the data subject in a structured, common and machine-readable format. It also has the right to transfer this data to another person responsible without hindrance by the controller to whom the personal data was provided, provided that the processing is based on the consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 Abs 2 letter a of the GDPR or on a contract pursuant to Article 6 (1) (b) of the GDPR and processing by means of automated procedures, provided that the Processing is not necessary for the performance of a task in the public interest or in the exercise of official authority which has been entrusted to the controller. Furthermore, in exercising their right to data portability under Article 20 (1) of the GDPR, the data subject has the right to obtain that the personal data are transmitted directly from one controller to another, insofar as this is technically feasible and provided that this does not affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may, at any time, contact an employee of Edjowa Holding Ltd.
Any person concerned by the processing of personal data shall have the right conferred by the European directive and regulatory authority at any time, for reasons arising from its particular situation, against the processing of personal data relating to it pursuant to Article 6 (1) (e) or f DS-GVO takes an objection. This also applies to profiling based on these provisions. Edjowa Holding Ltd no longer processes the personal data in the event of an objection, unless we can prove compelling legitimate reasons for the processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves the purpose of asserting, exercising or Defense of legal claims. If Edjowa Holding Ltd processes personal data in order to operate direct mail, the data subject has the right to object at any time to the processing of personal data for the purposes of such advertising. This also applies to the profiling, as far as it is associated with such direct mail. If the data subject objects to Edjowa Holding Ltd for direct marketing purposes, Edjowa Holding Ltd will no longer process the personal data for these purposes. In addition, the data subject has the right, for reasons arising from his / her particular situation, against the processing of personal data relating to him or her at Edjowa Holding Ltd for scientific or historical research purposes or for statistical purposes under Article 89 (1) of the DS GMOs to object, unless such processing is necessary to fulfill a task of public interest. In order to exercise the right to object, the data subject may directly contact any employee of Edjowa Holding Ltd or any other employee. The data subject is also free, in the context of the use of information society services, notwithstanding Directive 2002/58 / EC, to exercise its right of objection by means of automated procedures using technical specifications.
Any person concerned by the processing of personal data shall have the right, as granted by the European legislature and the legislature, not to be subject to a decision based solely on automated processing, including profiling, which has a legal effect on it or, in a similar manner, significantly affects it; unless the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller; or (2) permitted by Union or Member State legislation to which the controller is subject, and that legislation provides for appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject; or (3) with the express consent of the data subject. If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller or (2) it is done with the express consent of the data subject, Edjowa Holding Ltd shall take appropriate measures to safeguard the rights and freedoms and the rights of legitimate interests of the data subject, including at least the right to obtain the intervention of a person by the controller, to express his / her own position and to contest the decision.If the data subject wishes to exercise his rights with respect to automated decisions, he may, at any time, contact an employee of the controller.
Any person affected by the processing of personal data has the right, granted by the European directive and regulatory authority, to revoke consent to the processing of personal data at any time. If the data subject wishes to assert their right to withdraw consent, they may, at any time, contact an employee of the controller.
The controller has integrated components of the company Facebook on this website. Facebook is a social network. A social network is an Internet-based social meeting place, an online community that typically allows users to communicate with each other and interact in virtual space. A social network can serve as a platform to exchange views and experiences, or allows the Internet community to provide personal or business information. Facebook allows social network users to create private profiles, upload photos and socialize via friend requests. The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. Persons responsible for the processing of personal data, if an affected person lives outside the US or Canada, are Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland. Each visit to one of the individual pages of this website, which is operated by the controller and on which a Facebook component (Facebook plug-in) was integrated, the Internet browser on the information technology system of the person concerned automatically by the respective Facebook Component causes a representation of the corresponding Facebook component of Facebook to download. An overview of all Facebook plug-ins can be found at https://developers.facebook.com/docs/plugins/?locale=en_US. As part of this technical process, Facebook receives information about which specific underside of our website is visited by the person concerned. If the data subject is simultaneously logged into Facebook, Facebook recognizes with each visit to our website by the data subject and during the entire duration of the respective stay on our website, which specific underside of our website the data subject visits. This information is collected through the Facebook component and assigned by Facebook to the respective Facebook account of the data subject. If the person concerned activates one of the Facebook buttons integrated on our website, for example the „Like“ button, or if the person concerned makes a comment, Facebook assigns this information to the personal Facebook user account of the person concerned and saves this personal data , Facebook always receives information via the Facebook component that the data subject has visited our website if the data subject is logged in to Facebook at the same time as accessing our website; this happens regardless of whether the person clicks on the Facebook component or not. If such a transfer of this information to Facebook is not wanted by the data subject, it can prevent the transfer by logging out of their Facebook account before calling our website. The data policy published by Facebook, which is available at https://de-de.facebook.com/about/privacy/, provides information on the collection, processing and use of personal data by Facebook. It also explains which options Facebook offers to protect the privacy of the data subject. In addition, different applications are available, which make it possible to suppress data transmission to Facebook. Such applications can be used by the data subject to suppress data transmission to Facebook.
The controller has integrated Twitter components on this website. Twitter is a multilingual publicly available microblogging service where users can post and distribute tweets, which are limited to 140 characters. These short messages are available to anyone, including non-Twitter subscribers. The tweets are also displayed to the so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Twitter also allows you to address a broad audience via hashtags, links or retweets. The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. Each time one of the individual pages of this website, which is operated by the controller and on which a Twitter component (Twitter button) has been integrated, the Internet browser on the information technology system of the person concerned is automatically activated by the respective Twitter component causes to download a presentation of the corresponding Twitter component of Twitter. Further information on the Twitter buttons is available at https://about.twitter.com/en/resources/buttons. As part of this technical process, Twitter receives information about which specific subpage of our website is visited by the person concerned. The purpose of the integration of the Twitter component is to allow our users to redistribute the contents of this website, to promote this website in the digital world and to increase our visitor numbers. If the data subject is simultaneously logged in to Twitter, Twitter recognizes with each visit to our website by the data subject and during the entire duration of the respective stay on our website, which specific underside of our website visits the data subject. This information is collected through the Twitter component and assigned through Twitter to the affected person’s Twitter account. If the person concerned activates one of the Twitter buttons integrated on our website, the data and information transmitted with it are assigned to the personal Twitter user account of the person concerned and stored and processed by Twitter. Twitter always receives information via the Twitter component that the data subject has visited our website if the data subject is simultaneously logged in to Twitter at the time of access to our website; this happens regardless of whether or not the subject clicks on the Twitter component. If such a transfer of this information to Twitter is not wanted by the person concerned, it can prevent the transfer by logging out of their Twitter account before calling our website. The applicable privacy policies of Twitter are available at https://twitter.com/privacy?lang=en.
Art. 6 I lit. A DS-GMO serves our company as the legal basis for processing operations where we obtain consent for a particular processing purpose. If the processing of personal data is necessary to fulfill a contract of which the data subject is a party, as is the case, for example, in processing operations necessary for the supply of goods or the provision of any other service or consideration, processing shall be based on Art. 6 I lit. b DS-GMO. The same applies to processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries regarding our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c DS-GMO. In rare cases, the processing of personal data may be required to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our premises were injured and his or her name, age, health insurance or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d DS-GMO are based. Ultimately, processing operations could be based on Art. 6 I lit. f DS-GMOs are based. On this legal basis, processing operations that are not covered by any of the above legal bases are required if processing is necessary to safeguard the legitimate interests of our company or a third party, unless the interests, fundamental rights and fundamental freedoms of the person concerned prevail. Such processing operations are particularly permitted because they have been specifically mentioned by the European legislator. In that regard, it considered that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47, second sentence, DS-BER).
Is the processing of personal data based on Article 6 I lit. f DS-GMO is our legitimate interest in conducting our business for the benefit of all of our employees and our shareholders.
The criterion for the duration of the storage of personal data is the respective statutory retention period. After the deadline, the corresponding data will be routinely deleted, if they are no longer required to fulfill the contract or to initiate a contract.
We clarify that the provision of personal information is in part required by law (such as tax regulations) or may result from contractual arrangements (such as details of the contractor). Occasionally it may be necessary for a contract to be concluded that an affected person provides us with personal data that must subsequently be processed by us. For example, the data subject is required to provide us with personal information when our company enters into a contract with her. Failure to provide the personal data would mean that the contract with the person concerned could not be closed. Prior to any personal data being provided by the person concerned, the person concerned must contact one of our employees. Our employee will inform the individual on a case-by-case basis whether the provision of the personal data is required by law or contract or required for the conclusion of the contract, whether there is an obligation to provide the personal data, and what would be the consequence of the non-provision of the personal data.
As a responsible company we refrain from automatic decision-making or profiling.