Privacy & Cookie Policy

Privacy Policy

1. WHAT DOES THIS PRIVACY POLICY COVER AND WHO DOES IT CONCERN?

The Company is the controller of the personal data (e.g., information that identifies a specific person, such as full name or email address) that we collect from and about you through the Company’s Services, which are processed in accordance with the provisions of this Privacy Policy.

This Privacy Policy and our Cookie Policy apply to all users.

2. WHAT KIND OF PERSONAL DATA DO WE COLLECT ABOUT YOU?

The Company collects data at the time of registration or in order to obtain a Company Service. More specifically, the Company collects the following types of data from and about the User:

Registration Information: is the information you submit to register for a Company Service. Registration Information may include, for example, your first name, last name, e-mail address, gender, country, postal code and date of birth.

We do not collect:

• Financial Information from Payment Service Providers: In some cases, we may use an unaffiliated payment service to enable you to purchase a product or make a payment (“Payment Service”). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a web page of the Payment Service. Any information you provide to a Payment Service will be subject to the applicable privacy policy of the Payment Service, rather than this Privacy Policy. We do not have access to the payment details relating to the Payment Service.

• Sensitive Information: We ask that you do not send or disclose to us any sensitive personal information (e.g., social security numbers, information relating to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal history or trade union membership) on or through the Company Services or otherwise.

3. WHY DO WE COLLECT YOUR PERSONAL DATA?

We use the personal data collected from you and about you for:

a) Providing the Company’s services and other functionalities;

b) Measuring and improving these Company services and functionalities;

c) Improve the user experience both online and offline with regard to the Company’s services by providing more relevant and interesting content;

d) Safeguard the rights of the Company, protect the safety, privacy and security of the users of the Company’s services or people in general;

e) Comply with laws or legal obligations and/or respond to requests from public and governmental authorities;

4. ON WHAT LEGAL BASIS DO WE PROCESS PERSONAL DATA?

The processing of personal data for the purposes referred to:

• in Section 3, letters a) to d) of this Privacy Policy: necessary for the provision of the Company’s Services and therefore mandatory as otherwise the services could not be provided;

• in Section 3(e) of this Privacy Policy: mandatory as required by applicable laws;

You may revoke your consent to the processing of your personal data for the purposes set out in Section 3 at any time by sending a communication to the e-mail address indicated in Section 11 below.

If you wish to revoke your consent, or to know specifically what personal data is stored and processed, please contact us at the email address given in Section 11.

5. HOW DO WE PROCESS YOUR PERSONAL DATA?

With regard to the aforementioned purposes, data are processed by both electronic and manual means, and are protected by appropriate security measures, taking into account the state of the art, the cost of implementation and the nature, scope, context and purpose of the processing as well as the risk of varying likelihood and severity with regard to the rights and freedoms of individuals. In this regard, the Company uses appropriate administrative, technical, physical and personnel measures to safeguard the personal data in its possession against loss, theft and unauthorized use, disclosure or modification.

6. WHO CAN ACCESS YOUR PERSONAL DATA?

For purposes consistent with the purposes set out in Section 3 of this Privacy Policy, the Company may share personal data with the following categories of recipients located inside or outside the European Union, in accordance with and subject to the provisions of Section 7 below:

Third party service providers entrusted with processing activities and duly appointed as external data controllers when required by applicable laws, e.g. cloud service providers, other group companies, providers of services instrumental to or supporting the Company’s Services – including, without limitation, companies providing IT services, experts, consultants and lawyers –

Third party vendors who work with us to provide our Services, process payments, customize advertising, prevent, detect, mitigate and investigate potential wrongdoing, violations of the User Agreement, fraud and/or security breaches, collect invoices, set up membership and rewards programs, issue co-branded credit cards and other business activities.

Third-party shipping providers (e.g., DHL, UPS, USPS, etc.) with whom we share delivery addresses, contact information, and tracking numbers in order to facilitate delivery of purchased items and other delivery-related communications.

Business Partners. With your consent, we may share your personal data with business partners in the entertainment industry for the purpose of sending you marketing communications.

Competent national authorities in order to comply with applicable laws.

7. IS PERSONAL DATA TRANSFERRED ABROAD?

Personal data may be transferred to countries within and outside the European Economic Area.

You have the right to request a copy of the above provision or further information about your personal data by contacting the Company at the address given in Section 11 of this Privacy Policy.

8. WHAT ARE YOUR RIGHTS WITH REGARD TO YOUR PERSONAL DATA?

The user has the right, at any time, to:

a) Receive confirmation of the existence or otherwise of personal data and be informed of their content and source, verify their accuracy or request their rectification, updating or amendment;

b) Request the deletion, conversion into anonymous form or restriction of any personal data processed in breach of the applicable law;

c) Oppose their processing, in any case, for legitimate reasons.

In this regard, you may send your request to the address indicated in Section 11 of this Privacy Policy. In your request, please include your e-mail address, name, address and telephone number and clearly specify the information that you wish to access or that you wish to change, update, delete or suppress.

Please note that if you request that we delete your personal data, copies of certain account information may remain visible in certain circumstances where, for example, you share the information with social media or other services or, for example, where retention of such copies is necessary to comply with legal obligations or legal defence.

You can withdraw your consent at any time for:

• Your receipt of electronic communications from us. If you no longer wish to receive marketing emails from a certain point in time, you may opt out of receiving them by simply changing your preferences in your user profile settings, if you are registered, or by following the unsubscribe instructions in our communications. You may also send a request to the address listed in Section 11 of the Privacy Policy. However, the Company may continue to send you administrative communications relating to the provision of the Company Services.

9. Period of retention of your personal data

We will retain data only for the period necessary to fulfil the purposes for which the data was collected, as set out in this Privacy Policy. In any event, the following retention periods apply to the processing of personal data for the purposes set out below:

The data collected for the purposes set out in Section 3(a) to (e) of this Privacy Policy is retained for the time of the provision of the Company Services plus the length of any applicable statutory retention period following termination of the Company Services;

At the end of the retention period, personal data will be deleted, anonymized or aggregated.

Additional rights

In addition to the rights set out in paragraph 8 of this Privacy Policy and following the application of the Privacy Regulation, you will also have the right, at any time, to:

a) Request the Company to restrict the processing of personal data in the event that:

The accuracy of personal data is disputed until we have taken sufficient measures to correct or verify them;

The processing is illegal, but you do not want us to delete the data;

We no longer require personal data for processing purposes, but you do require personal data for the establishment, exercise or defence of a legal matter;

The user has objected to the processing justified on grounds of legitimate interest pending verification that the Company has valid legitimate grounds for continuing the processing.

b) Oppose the processing of personal data;

c) Request deletion of personal data without undue delay;

d) Receive an electronic copy of the personal data provided to us, if you wish to transfer the personal data to yourself or to another provider (“data portability”), where the personal data is processed by automated means and the processing is based on consent or on the fact that the processing is necessary for the provision of the Company’s Service;

e) Complain to the competent supervisory authority.

10. UPDATES TO THE PRIVACY POLICY

We may change or update this Privacy Policy for any reason (including, but not limited to, changes in applicable law and interpretations, decisions, opinions, and orders relating to such applicable law). Please refer to the effective date at the top of this Privacy Policy to see when it was last updated. Any changes to this Privacy Policy will be notified in advance by posting the updated version of the Privacy Policy on the Company’s services. If we make any material changes to this Privacy Policy that would change the nature of, or transform or expand our rights to use, personal information that we have already collected, we will notify you in advance and provide you with a choice regarding the future use of your personal information as may be required by applicable law.

11. CONTACTS

If you have any questions about this Privacy Policy, please contact the Company at the following e-mail address: info@medfilminmalta.com

12. OWNER, MANAGERS AND CATEGORIES OF APPOINTEES

The data controller is Costantino Films Ltd

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