Neworkom Local App

Privacy Policy

Privacy Policy-NWK Local App

 

Version 1.1

Date: 14 November 2019

Privacy Policy-NWK Local App 

Introduction 

Definitions and interpretation 

Scope of this privacy policy 

Our usage of Data 

Who we share Data with 

Merchants 

Data collected 

How we collect Data 

Data that is collected automatically 

Data that is given to us by you 

Users - Non-Registered and Registered Users 

Non-Registered Users 

Data Collected Automatically 

Registered Users 

Data collected 

How we collect Data 

Data that is collected automatically 

Data that is given to us by you 

Keeping Data secure 

Data retention 

Your rights 1

Transfers outside the European Economic Area 

Links to other websites 

Changes of business ownership and control 

Cookies 

General 

Children's Privacy 

Changes to this privacy policy 

Cookies 



 

Introduction

 

Welcome to the NWK Local App Privacy policy. We take your privacy very seriously and being compliant with the GDPR is a top priority for us.

This privacy policy applies between you, the user/merchant of this NWK Local app and Neworkom International Ltd, the owner and provider of this App. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions.

Please read this privacy policy carefully.

 

 

Definitions and interpretation

 

In this privacy policy, the following definitions are used:

 

 

Data

 

collectively all information that you submit to Neworkom International Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

 

Cookies

 

a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

 

GDPR

 

the General Data Protection Regulation (EU) 2016/679;

Neworkom International Ltd , or us

Neworkom International Ltd, a company incorporated in Malta whose registered office is at Level 5, Smart City Malta, Ricasoli, Kalkara, Malta, SCM 1001;

 

User or you

 

any third party that accesses the Website and is not either (i) employed by Neworkom International Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Neworkom International Ltd and accessing the Website in connection with the provision of such services;

 

  1. In this privacy policy, unless the context requires a different interpretation:

    1. The singular includes the plural and vice versa;

    2. References to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

    3. A reference to a person includes firms, companies, government entities, trusts and partnerships;

    4. "Including" is understood to mean "including without limitation";

    5. Reference to any statutory provision includes any modification or amendment of it;

    6. The headings and sub-headings do not form part of this privacy policy.

 

 

Scope of this privacy policy

 

  1. This privacy policy applies only to the actions of Neworkom International Ltd and Users with respect to this App. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

  2. For purposes of the applicable Data Protection Laws, Neworkom International Ltd is the "data controller". This means that Neworkom International Ltd determines the purposes for which, and the manner in which, your Data is processed.

 

 

Our usage of Data

 

  1. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

    1. Internal record keeping;

    2. Improvement of our products / services;

    3. Transmission by email of marketing materials that may be of interest to you (if you have opted to receive marketing materials from us);

    4. Contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;

In each case, in accordance with this privacy policy.

  1. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:

    1. Soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out;

    2. For other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide;

    3. If you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.

  2. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

  3. We may use your Data to show you Neworkom International Ltd adverts and other content on other websites. If you do not want us to use your data to show you NWK Local App or Neworkom International Ltd adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed "Cookies" below).

 

 

Who we share Data with

 

  1. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

  2. We may share your Data with the following groups of people for the following reasons:

    1. Any of our group companies or affiliates – to ensure the proper administration of our website, and for business marketing procedures;

    2. Our employees, agents and/or professional advisors - for accounting purposes and for marketing research;

    3. Third party service providers who provide services to us which require the processing of personal data - to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the website runs smoothly;

    4. Relevant authorities - to facilitate the detection of crime or the collection of taxes or duties;

in each case, in accordance with this privacy policy.

 

 

Merchants

 

Data collected

 

  1. We may collect the following Data, which includes personal Data, from you:

    1. Name of Company;

    2. Address;

    3. Vat and tax information;

    4. Business genre and information;

    5. Contact Information such as email addresses and telephone numbers;

    6. Social Accounts information

    7. IP address (automatically collected);

    8. Web browser type and version (automatically collected);

    9. Operating system (automatically collected);

    10. A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

    11. Geo-location.

In each case, in accordance with this privacy policy.

 

 

How we collect Data

 

  1. We collect Data in the following ways:

    1. Data is given to us by you; and

    2. Data is collected automatically.

 

Data that is collected automatically

 

  1. To the extent that you access the Website, we will collect your Data automatically, for example:

    1. We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

    2. We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies".

 

 

Data that is given to us by you

 

  1. Neworkom International Ltd will collect your Data in a number of ways, for example:

    1. When you register with us and set up an account to register your page on the NWK Local App;

    2. When you complete surveys that we use for research purposes (although you are not obliged to respond to them);

    3. When you elect to receive marketing communications from us;

    4. When you use our services;

In each case in accordance with this privacy policy.

 

 

 

Users - Non-Registered and Registered Users

 

Non-Registered Users

 

As long as you are not a registered user, we do not collect any of your data manually since there is no data which will be provided. However, data may still be collected automatically during your time browsing through our Web App.

 

 

 

Data Collected Automatically

 

    1. We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

    2. We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

 

 

Registered Users

 

Data collected

 

  1. We may collect the following Data, which includes personal Data, from you:

    1. Your Name and Last Name;

    2. Your Selfie;

    3. Items you are interested in;

    4. Contact Information such as email addresses and telephone numbers;

    5. IP address (automatically collected);

    6. Web browser type and version (automatically collected);

    7. Operating system (automatically collected);

    8. A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

    9. Geo-location

In each case, in accordance with this privacy policy.

 

 

How we collect Data

 

  1. We collect Data in the following ways:

    1. Data is given to us by you; and

    2. Data is collected automatically.

 

 

Data that is collected automatically

 

  1. To the extent that you access the Website, we will collect your Data automatically, for example:

    1. We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

    2. We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies".

 

 

Data that is given to us by you

 

  1. Neworkom International Ltd will collect your Data in a number of ways, for example:

    1. When you register with us and set up an account to register your page on the NWK Local App;

    2. When you complete surveys that we use for research purposes (although you are not obliged to respond to them);

    3. When you elect to receive marketing communications from us;

    4. When you use our services;

In each case in accordance with this privacy policy.

 

 

Keeping Data secure

 

  1. We will use technical and organisational measures to safeguard your Data, for example:

    1. Access to your account is controlled by a password and your e-mail.

    2. We store your Data on secure servers.

    3. All data will be stored in an encrypted manner, and we use high quality firewalls to make sure that your data is safe.

       

       

  2. We are certified to PCI DSS. This family of standards helps us manage your Data and keep it secure.

  3. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: support@neworkom.com

 

 

Data retention

 

  1. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until we receive your request that the Data be deleted.

  2. We will make sure that once we receive your request to cancel your information will be cancelled. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

 

 

Your rights

 

  1. You have the following rights in relation to your Data:

    1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive.” In the event where the requests are manifestly unfounded or excessive, the company may charge you for such requests. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

    2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.

    3. Right to erase - the right to request that we delete or remove your Data from our systems.

    4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.

    5. Right to data portability - the right to request that we move or copy or transfer your data.

    6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

  2. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: support@neworkom.com

  3. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For more information, please contact your local data protection authority in the European Economic Area (EEA).

  4. It is important that the Data we hold about you is accurate and current. Please keep us informed if your data changes during the period for which we hold it.

 

 

 

Transfers outside the European Economic Area

 

  1. Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.

  2. We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organisation in receipt of the Data is based in the United States of America.

  3. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with to ensure your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

 

 

Links to other websites

 

  1. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

  2. This website makes use of Google Maps API, as to provide geolocation of the shops of the merchants, and to provide users with the information in relation to the distance and the route the user needs to take as to reach the merchant. Such usage is in relation to the privacy policy of Maps, therefore it is of high importance that you visit and check the privacy policy and terms and conditions provided.

 

 

Changes of business ownership and control

 

  1. Neworkom International Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Neworkom International Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

  2. We may also disclose Data to a prospective purchaser of our business or any part of it.

  3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

 

 

Cookies

 

  1. This Website may place and access certain Cookies on your computer. Neworkom International Ltd uses Cookies to improve your experience of using the Website/app and to improve our range of services. Neworkom International Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

  2. All Cookies used by this Website are used in accordance with current Maltese and EU Cookie Law.

  3. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Neworkom International Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

  4. This Website may place the following Cookies:





Type of Cookie

 

Purpose

 

Strictly necessary cookies

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

 

 

Analytical/performance cookies

 

They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

 

 

Functionality cookies

 

These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

 

 

Targeting cookies

 

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

 

 

Social Media Cookies

 

These cookies are set by a range of social media services that we have added to our website to enable you to share our content with your peers or networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit.

 

 

Session Cookies

 

These cookies are temporary and expire once the user leaves the site. Session cookies are mainly used by webshops to hold items in the basket while the user is shopping online.

In general terms, if cookies track personal data, they are subject to the GDPR. Session cookies usually are of first party provenance and enable the necessary functioning of the website.

  1. You can find a list of Cookies that we use in the Cookies Schedule.

  2. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

  3. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

  4. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

  5. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete Cookies from your computer.

 

 

General

 

  1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

  2. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

  3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

  4. This Agreement will be governed by and interpreted according to the laws of Malta. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Maltese courts.

 

 

Children's Privacy

 

  1. We do not knowingly collect personally identifiable information from minors. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

 

 

Changes to this privacy policy

 

  1. Neworkom International Ltd reserves the right to change this privacy policy, as may be deemed necessary from time to time or as may be required by law. We will always indicate the date when the last changes where published, and we also offer access to archived versions for your review. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the website following the changes. Shall such changes be significant, we’ll provide you with a more prominent notice, (including, for certain services, email notification of Privacy Policy changes).

  2. You may contact Neworkom International Ltd by email at support@neworkom.com

 

 

Cookies

 

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.

 

 

Strictly necessary

 

We use the following strictly necessary cookies:

Description of Cookie

We use this session cookie to remember you and maintain your session whilst you are using our website;




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