Privacy Policy

This document describes how we use and process your personal data.

If you have questions about your personal data, which we’re more than happy to answer. Please also read our Cookie Statement further below, which tells you how wr.sultech.com.mt makes use of cookies and other similar technologies. For a better understanding of certain terms please read the Terms and Conditions.

Sultech Ltd offers a wide array of services through our own websites and mobile apps. Hence, all the information that follows applies to not one, not two, but all of these platforms. This privacy statement applies to any kind of information we collect through these platforms or other ancillary means to these platforms (such as contacting our various teams and departments via phone or email or other direct marketing to you via phone or email).

We might amend the following Privacy Statement, Cookie Policy and other Terms and Conditions from time to time. If you care about your privacy and your rights, visit this page regularly and you’ll know exactly where you stand. If we make changes to the Privacy Statement, Cookie Policy and other Terms and Conditions which will have an impact on you (for example, if we intend to process your personal data for other purposes than communicated in the past), we will notify you of these changes before the new activities begin.

Thus, if you disagree with this Privacy Statement, Cookie Policy and other Terms and Conditions, you should immediately discontinue using our services. However, if you agree with our Privacy Statement, Cookie Policy and other Terms and Condition then you’re all set to book your next pickup through the Sultech Platform.

Therefore, we kindly advice you to read the following:

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:
   

   Account	Sultech Ltd users can create a user account on our websites or platforms. We use the information you give us to administer this account, allowing you to do a number of useful things. You can manage your Orders / Bookings, make future bookings/orders easily and manage your personal settings. Managing personal settings can allow you to keep booking details, and to check other related information you have provided. It can also allow you to see any reviews you have submitted. Sultech Ltd for Business account holders can save contact details in their account facility, manage their business reservations and link other account holders to the Sultech platform for Business account.
   Data	Collectively all information that you submit to Sultech Ltd or we collect via the Website or/and mobile apps, as well as through other online platforms such as partners’ websites and social media. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
   Communicate	To communicate with the user, shall include but not exclusively, the following: To send order/booking confirmations; To send alerts and notifications you have subscribed to, including to your mobile device; To solicit reviews; To communicate with you if you have contacted our consumer/client support; To send you information servicing and administrative emails; To send you information about services, offered by Sultech Ltd, that we believe you would be interested in;
   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);
   Data Protection Laws	Any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any other national legislation, for as long as the GDPR is effective in Malta;
   GDPR	The General Data Protection Regulation (EU) 2016/679;
   NAME OF BUSINESS Hereinafter referred to either as ‘We’, ‘Our’ or ‘Us’	Sultech Ltd, a company incorporated in Malta bearing the Company Registration Number C 100455, whose registered office is at GGX803, New Street off Jean de La Vallette Street, Xewkija Gozo, Malta; (Hereinafter referred to as Sultech);
   Platform/s	Website/s and mobile app/s, as well as other online platforms such as partners’ websites and social media;
   Malta and EU Cookie law	The Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (directive on privacy and electronic communications), as amended by Directive 2009/136/EC of the European Parliament and of the Council of 25 November 2009 amending Directive 2002/22/EC on universal service and users’ rights relating to electronic communications networks and services, Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector and Regulation (EC) No 2006/2004 on cooperation between national authorities responsible for the enforcement of consumer protection law;
   User or you	Any third party that accesses our Website and our mobile apps, as well as through other online platforms such as partners’ websites and social media, and who is not either employed by us and acting in the course of their employment or engaged as a consultant or otherwise providing services to us and accessing the Website in connection with the provision of such services; and
   Website	The website that you are currently using, wr.sultech.com.mt, and any sub-domains of this site unless expressly excluded by their own terms and conditions

2. 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, trust 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 of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of Sultech and Users with respect to any of our platform. However, it does not extend to any third party platform.

4. This policy may also apply to any Data inputted by the User on any of our platform linking to a third-party payment gateway / payment processor system.

5. For purposes of the applicable Data Protection Laws, Sultech is the ‘data controller’. This means that Sultech determines the purposes for which, and the manner in which, your Data is processed.

Scope of this privacy policy

6. We may collect the following Data, which includes personal Data, from you;
   1. Name;
   2. Date of Birth;
   3. Gender;
   4. Job title;
   5. VAT Number;
   6. Contact information such as email addresses and telephone numbers;
   7. Identification Documents and all data contained on such documents;
   8. Demographic information such as postcode, preferences and interests;
   9. Account identification pertaining to any third party payment gateway or payment processor;
   10. IP address (automatically collected);
   11. Web browser type and version (automatically collected);
   12. Operating System (automatically collected);
   13. A list of URLs’ starting with a referring site, you activity on this Website, and the site you exit to (automatically collected);
   14. Screen resolution;
   15. Access times;
   16. Device details;

   In each case, in accordance with this privacy policy.

   The categories of Personal Information we collect:

   Platform information: When you visit the Platforms, we may collect information from you. Some of it may be personal information. This information can include search history, IP address, screen resolution, browser used, operating system and settings, access times and referring URL. If you are using a mobile device, we may also collect data that identifies your device, your settings and your location.

   Order information: If you book/order a product / service via the Platforms, and/or website we may need additional information from you. This information can include your name, name of business name, (if different), VAT No., Locations (of pick up / collection), date, email address, telephone number, credit card information (never accessed and never stored by Sultech), billing address, and other ancilliary details details. You can also choose to store personal information in your user account for future order.

   Account information: We will collect your email address, password and address, VAT Number, number of outlets, address of business / outlet, details of responsible person, and other preference information you provide us. Thus, you are permitting us to use and store that information related to the account.

   Bookings / order: If you make an order on the platforms or within our mobile applications, this will automatically be linked to your account / and account information,

   Account: By having an account this will give you access to our service, where we will collect your order information to create and maintain your orders. This can include the personal information that may be included in the confirmation emails you give us access to and all other Account information.

   Consumer support:

   If you choose to contact our consumer support services we will collect any inquires, complaint or other information that you may submit to our support team.

   When you give us personal information, you are telling us that the information is true, accurate, complete and current. You are also telling us that you have the authorisation to provide it to us.

How we collect Data

7. We collect Data in the following ways;
   1. Data is given to us by you. Sultech will collect your Data in a number of ways, for example:
      1. When you contact us through our platform, by telephone, post, e-mail or through any other means;
      2. When you register with us and set up an account to purchase or place our products/services;
      3. When you make payments to us, through our platform;
      4. When you elected to receive marketing communications from us;
      5. When you use our services;
      In each case, in accordance with this privacy policy
   2. Data is collected automatically. To the extent that you access our platform, we will collect your Data automatically, for example:
      1. We automatically collect some information about your visit to our platform. This information helps us to make improvements to Website content and navigation, and includes your IP address, the data, times and frequency with which you access the Website and the way you use and interact with its content;
      2. We will collect your, IP Address, in order to be able to enhance and personalise your experience on our platforms to be able to provide you with relevant offers and services that may be of interest to you;
      3. 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’.

Use of your data

8. Your personal information may be used in the following ways:
   1. Improving our services: To provide you with and improve our Platforms and services, to better understand the users of our Platforms and services, and to protect our property and to prevent any damage to.
   2. Communication with you.
   3. Legal purposes: In certain cases, we may need to use your information to handle and resolve legal disputes, for regulatory investigations and compliance or to enforce the terms of use of the service.
      1. Performance of a contract: The use of your personal information may be necessary to perform the services and provide you products that you have requested from us. For example, if you make a booking on our Platform, we need to collect personal information from you in order to complete the booking, in order prevent fraud and to improve its services.
      2. Legitimate interest: We may use your personal information for our legitimate interests, such as displaying relevant advertising and recommendations and for legal purposes
      3. Consent: We may rely on your consent to use your data for certain purposes (unrelated to any orders / services you acquire from us) You can withdraw your consent anytime by contacting us or change your settings in your account as described below
      4. Legal obligations: We may rely also where applicable on compliance with legal obligations (such as lawful law enforcement requests).

9. Where needed under applicable law, Sultech will obtain your consent prior to processing your personal data for direct marketing purposes.
10. If you wish to object to the processing set out above and no opt-out mechanism is available to you directly (for example, in your account settings), to the extent applicable, please contact our Data Protection Officer at: info@sultech.com.mt

Who we share Data with

11. We may share your Data with the following groups of people for the following reasons;
    1. Our employees, agents and/or professional advisors: We may share your personal information with our employees, agents and/or professional advisors, however these are all bound not to disclose your information to any other third party unless done in accordance with this policy.
    2. Third Party Service providers: We may share your personal information with suppliers who perform services on our behalf and have agreed in writing to protect and not further disclose your information.
    3. Payment service providers and vendors: When booking through the Platform, we may share your personal information with the payment service providers and the vendors you have booked with. This can include vehicle operators, waste collectors, Schemes, regulatory authorities and similiar entities / bodies / services providers. These third parties will process your personal information as data controllers in accordance with their own privacy policies. If you contact our consumer support, they may need to share information about your request with the relevant third party in order to assist you.
    4. Business partners: We may share your personal information with various business partners. Some of these business partners may use your personal information to process any order or anything connected/ancillary to. We may also share your information as otherwise described to you at the time of collection. For example, if you provide information to enter a sweepstakes, we may share your information with partners. We may also share anonymous aggregated usage information with partners.
    5. Authorities: We may disclose personal information if required by law, for example to law enforcement or other authorities. This includes court orders, subpoenas and orders arising from legal processes, and administrative or criminal investigations. We may also disclose your personal information if the disclosure is necessary for the prevention, detection or prosecution of criminal acts or to prevent other damage, or in response to a legal action or to enforce our rights and claims.
    6. We may also share anonymous aggregated usage information with others.
    In each case, in accordance with this privacy policy.

Keeping Data Secure

12. We will use technical and organization measures to safeguard your Data, for example:
    1. Access to your account is controlled by a password and a user name that is unique to you.
    2. We store your Data on secure servers.
    3. All communication between your device and our servers is encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.
13. Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us via this e-mail address: info@sultech.com.mt

Data retention

14. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for as long as your account is active and for a period of time thereafter to allow you to re-activate your account without loss of information and/or for the period necessary to fulfil the purposes outlined in this privacy policy, whichever is the longest or until you request that the Data be deleted.
15. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
16. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

17. 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’. When 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 you 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, 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.
18. 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 email address: info@sultech.com.mt
19. 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 Regulatory body.
20. 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.

Links to other websites

21. 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.

Transfers outside the European Economic Area

22. 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 services are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We may also share information with any of our group companies, some of which may be located outside the EEA. As a result, your personal information may be subject to access requests from governments, courts, or law enforcement in those countries according to laws in those countries. Subject to the applicable laws in such other countries, we will provide the necessary safeguards to maintain protections of your personal information, e.g. by obtaining from the data recipients contractual commitments based on the EU model clauses.
23. 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 the 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 organization in receipt of the Data is based in the United States of America.
24. 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. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Protecting your information

25. Sultech has a security program intended to keep the personal information stored in our systems protected from unauthorised access and misuse. Our systems are configured with data encryption, or scrambling technologies and firewalls constructed to industry standards. We also use Secure Socket Layer (SSL) technology that protects the data you send over the Internet. Personal information may only be accessed by persons within our organisations, or our third parties to carry out the uses indicated in this Privacy Policy.

Change of business ownership and control

26. Sultech 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 Sultech. Data provided by the 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.
27. We may also disclose Data to a prospective purchaser of our business or any part of it.
28. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Contacting us and how to lodge a complaint with us

29. Sultech Ltd controls the processing of personal information on its Platforms. To exercise your rights, or if you have questions about our privacy practices or need assistance with exercising or understanding your privacy choices, please contact our Data Protection Officer at info@sultech.com.mt or you may write to:

    Sultech Ltd
    Attention: Data Protection Officer
    GGX803, New Street off Jean de La Vallette Street,
    Xewkija (Gozo), Malta
    

Cookies and tracking tools

30. Sultech may use cookies and tracking tools.
31. If Sultech uses tracking tools such as cookies these will be the following:
    1. We (or our suppliers) use several common tracking tools. We use these tools to collect usage information about you over time. Tools we use may include browser cookies. Your browser will store these cookies on your computer in a small file.
    2. By using the Platforms, you give us your free, unambiguous and informed consent to the use of any of the cookies and tracking tools mentioned in this policy.
    3. Sultech uses tracking tools for following purposes:
       1. To store your username and password if you are registered with us.
       2. To help improve our website offering and for capacity planning purposes.

Controlling tracking tools and opt-out of online behavioural advertising

32. Your browser may give you the ability to control cookies. How to do this varies from browser to browser. You should view the Help menu on the browser you use for further information. Your opt out choice is stored in opt out cookies only in that browser, so you should separately set your preferences for other browsers, computers, or devices you may use. If your browser blocks cookies, your opt out preferences may not be effective. Deleting browser cookies can remove your opt out preferences, so you should visit this page periodically to review your preferences. If you block or delete cookies or opt out of online behavioural advertising, not all of the tracking that we have described in this policy will stop.
33. Please also note that opting out of a third party cookie does not mean that you will no longer receive or be subject to online advertising or marketing. It means that the third party service from which you opted out will no longer deliver ads tailored to your web preferences and online behavioural. To opt out of having your online behaviour tracked by Sultech for advertising purposes click here; this means that Sultech will no longer use information derived from your online behaviour, collected by Sultech or third parties acting on behalf of Sultech, for the purpose of providing you interest-based advertising from Sultech only. Note that opting out of receiving interest-based advertising through the link above does not mean you will no longer receive advertising from Sultech or third parties at all; rather it means that most of the advertising that you will see will not be based on your particular interest. In addition, Sultech may still collect information for other purposes consistent with this Privacy Policy.

How we respond to ‘Do Not Track’ signals

34. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals.

If you have any questions on our use of tracking tools, please contact us on info@sultech.com.mt