Welcome to Hilltop Gardens Retirement Village. privacy notice (the “Notice”).
Hilltop Gardens Retirement Village (C 65735) (“Hilltop Gardens”, “we”, “us” or “our”) having its registered office at Hilltop Gardens, Triq l-Inkwina, Naxxar, NXR2641, and its affiliates and subsidiaries, respect your privacy and are committed to protecting your personal data.
We process your data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 586 of the Laws of Malta) (the “Act”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) when it comes into force on 25th May 2018.
This Notice is provided in a layered format so you can click through to the specific areas set out below.
- Important Information and Who We Are;
- The Data We Collect About You;
- How is Your Personal Data Collected;
- How We Use Your Personal Data;
- Disclosures of Your Personal Data;
- International Transfers;
- Data Security;
- Data Retention;
- Your Legal Rights;
- Google Products & Bing Updates;
1. Important Information and Who We Are
1.1 General Information and the Purpose of this Notice
We have structured our Website so that you can visit us on the Internet without identifying yourself or revealing any personal information. Once you choose to provide us with personal information, we will protect such information and use it only in the ways described in this Notice.
This privacy notice aims to give you information on how Hilltop Gardens collects and processes your personal data through your use of this website, including any data you may provide through this website when browsing, when you sign up to our newsletter, use our Contact Form or when you use any of our Services.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Hilltop Gardens Retirement Village (C 65735) (“Hilltop Gardens”, “we”, “us” or “our”) having its registered office at Hilltop Gardens, Triq l-Inkwina, Naxxar is the data controller in relation to your personal data.
We have appointed a Data protection contact point who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise Your Legal Rights, please contact the Data protection contact point using the details set out below.
1.3 Contact details
Our full details are:
Full name of legal entity Hilltop Gardens Retirement Village (C 65735) having its registered office at Hilltop Gardens, Triq l-Inkwina, Naxxar, NXR2641
|Name or title of Data protection contact point:||Dr. David Wain|
|Postal address:||AX House, Mosta Road, Lija LJA9010, Malta, Europe|
You have the right to make a complaint at any time to the Information and Data Protection Commissioner (“IDPC”) as the supervisory authority for data protection issues (https://idpc.org.mt/en/Pages/Home.aspx). We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance.
1.4 Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 24.05.2018
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.5 Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
2.1 How we collect your personal data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, title, nationality, date of birth and gender.
- Contact Data includes, email address and telephone or mobile numbers.
- Compliance Data includes copy of your passport or national identification document
- Financial Data includes your credit card details
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site.
- Profile Data includes your username and password, purchases made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use the Site and Services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our business partners and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregate may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
2.1.1 When visiting our website
It is possible to visit our website without submitting any personal data. In order to provide you with the best experience when browsing our website, we may need to process certain data which can identify you and can therefore be considered to be personal data. In this regard we may collect the following information about you whenever you visit our website.
- Technical information: including the IP address used to connect your computer to the Internet, your login information, browser type and version, the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time) as well as other information regarding your experience on our Website such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
- Location Information: We may receive information about your location. We may determine your location through your IP address and, when accessing the Website through a mobile device, by using the data that we collect from this device. This includes precise location information from GPS or information about the wireless networks or cell towers near your mobile device at the time of access.
2.1.2 When using the ‘Contact Us’ Form
Our website allows you to submit an enquiry and get in touch with us in order to be able to provide assistance. In order to be able to reply to your query accurately and be of the most assistance to you, we shall require certain basic contact information (your name, surname and email address) as well as information relating to your query.
Based upon the information which you provide, one of our representatives will contact you in order to be able to provide assistance as per your request.
2.1.3 When using any of our Services
In order to be able to provide the Services which you request, we shall need to process personal data. This is necessary for us to take steps to enter into a contract or agreement with you or to be able to perform the contract with you and provide the Services which you request, mainly in order to be able to book your accommodation at our hotels and confirm your booking. Generally, this shall include your contact information, such as your name, surname, email, telephone number as well as your financial details.
The personal data which we request from you shall generally be restricted to the data which is strictly necessary for us to be able to provide the services which you request. In addition, we may also request certain personal data to ensure compliance with our legal obligations. This may include requesting copies of your passport whenever you check into our hotel in order to verify your identity and to be able to collect the Eco-Contribution Tax as we are required to do under the Eco-Contribution Act (Chapter 473 of the Laws of Malta) and regulations promulgated thereunder.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
In certain instances, you may ask us to store certain medication or provide additional services in order to be able to take additional measures in order to accommodate any medical conditions which you may have. We shall treat this data with the utmost confidentiality and only insofar and to the extent that is strictly necessary to safeguard your vital interests.
2.2 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
4. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To be able to take steps to enter into a contract with you to book your accommodation at any of our hotels.**In particular we shall maintain information on our Guest Registration cards||
|To check that you have the required funds in order to pay for your stay at any of our hotels**In particular we shall carry out credit limit reports using your credit card details||
|To respond to your queries and additional requests**We strive to make your stay as pleasant as possible, therefore we welcome any additional requests you may have and shall try our best to accede to your requests (e.g. booking a taxi, wake up calls etc.)||
|To manage our relationship with you which will include:
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
||Necessary for our legitimate interests (to develop our products/services and grow our business)|
4.1 Additional Data
In addition, in order to be able to ensure your safety and security when staying at any of our hotels, please note that we have installed CCTV surveillance in order to be able to detect and prevent illegal or otherwise illicit activity on our premises. In this regard, we may collect personal data relating to your appearance as well as your location at a given point in time. This is carried out in order to protect your vital interests as well as in furtherance of our legitimate interest to protect our premises. All CCTV footage is deleted after 30 days unless there is an over-riding interest to keep such personal data, such as in cases where there is a legal claim or an ongoing investigation.
In cases where you instruct us to provide certain specific accommodation or service requests, we shall accede to your requests in order to provide you with the best possible service. In order to be able to provide you with a more tailored visit upon you return to our hotels, we shall retain a record of your preferences so that we can improve your experience with us.
This analysis of your preferences is within our legitimate interest to ensure that we provide the best service possible to our guests. In order to carry our such analysis we use the following personal data:
- Contact data
- Profile data
- Any personal preferences or additional services which you may request during your stay
You have the right to object at any time to such processing of your personal data. You can exercise this right by contacting us on: firstname.lastname@example.org. For further information on your data subject rights, please see Section 9 of this Notice below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
4.3 Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have subscribed to our newsletter or you have subscribed to our Loyalty Scheme (AX Plus) or have an ongoing relationship with us such as in the event you are a bon-holder or else have entered into a time-share contract with us. This is within our legitimate interest to further our established relationship with you and inform you of any offers which may be of interest to you.
In all other cases, you shall be requested to provide your consent in order to receive marketing communications.
4.4 Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the AX group of companies for marketing purposes.
4.5 Opting out
If you have provided your consent to receive marketing material you can withdraw your consent at any time and you can ask us or third parties to stop sending you marketing messages at any time by following the ‘unsubscribe’ links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not affect the processing of personal data provided to us as a result of the Services which we provide to you or any personal data which we are obliged to retain as a result of our legal obligations.
4.7 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
We may also transfer your personal data to external third parties, namely our service providers which are necessary for us to be able to provide the Services we offer. In particular, we may transfer your personal data to our IT and software support service providers, our booking agents, our insurers and external legal counsel. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions
In particular we may transfer your personal data to the following service providers:
- HotelREZ limited having its registered office at Balderton Hall, Fernwood, Newark, Nottinghamshire, NG24 3JR, UK which provides booking services over our Website.
- Affilired S.L having its registered office at Avenida Asima, nº 20, 3º local 25 Palma de Mallorca 07009 Spain which organises our advertising and marketing operations.
We may also disclose your personal data to regulatory or governmental agencies as well as executive and judicial authorities which may have jurisdiction over our operations. We shall only make such disclosures in accordance with the appropriate authority and to comply with our legal obligations.
6. International transfers
We may transfer your personal data outside the EEA in any of the following circumstances:
- the transfer is necessary for the performance of a contract between you and AX or for the implementation of pre-contractual measures taken at your request;
- the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and another natural or legal person;
- the transfer is necessary for important reasons of public interest; or
- the transfer is necessary for the establishment, exercise or defence of legal claims.
In certain cases we may transfer your personal data to our third party suppliers, such as IT and system support providers which may be located outside of the EEA. In such cases we have agreements in place to regulate the processing of personal data and ensure that your personal data is handled responsibly and in line with applicable data protection laws.
In particular we may transfer your personal data to the RocketGroup LLC which operates MailChimp which is a marketing service. This service provider is subscribed to the EU-U.S Privacy Shield and any transfers of personal data are carried out on the basis of this adequacy decision.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
8.1 How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers, including contact details and details regarding any contracts which you may have entered into as a result of our Services for six years after the conclusion of the contract, taking into account the applicable prescriptive period at law. We may also retain certain personal data to ensure compliance with our legal obligations. In particular, we shall retain certain transactional and financial information for a period not exceeding ten years, in compliance with tax and accounting reporting legal obligations.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Under applicable data protection laws, you are entitled to exercise the following rights:
9.1 You have the right to
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
You also have the right to object to profiling and analysis of your preferences.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at email@example.com
9.2 No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9.3 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.4 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Google Products & Bing Ads
So as to improve the quality and overall user experience of the Website, we are using Google Features, including: Analytics and Adwords.
Analytics: we use Google Analytics which uses a set of cookies that helps us to understand how you engage with the website. These cookies collect information and report website usage statistics without personally identifying individual visitors. You can learn more about this here: https://support.google.com/analytics/answer/6004245
Adwords: we collect certain information from and about its users three ways: directly from our Web Server logs, the user, and with Cookies. When you visit our Website, we may track information to administer the site and analyze its usage for the purpose of serving our visitors and customers better.
This website uses Google AdWords’ free conversion tracking features on certain pages. If you contact us online, the destination page will have code on it that will help us understand the path you took to arrive on that page.
DoubleClick: We use Google AdWords remarketing codes to log when users view specific pages or take specific actions on a website. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.
If you would like to opt-out of Google Adwords for display advertising, you may do so by using the Ads Preference Manager. In addition, there is also a Google Analytics Opt-Out browser add-on that you can download at https://tools.google.com/dlpage/gaoptout
Bing Advertising: This website uses Microsoft’s free tracking features on its webpages. If you contact us online, the destination page will have code on it that will help us understand the path you took to arrive on that page.
We will not disclose personally identifiable information we collect from you to third parties without your permission except to the extent necessary including:
- To fulfill your requests for services.
- To protect ourselves from liability.
- To respond to legal process or comply with law, or in connection with a merger, acquisition, or liquidation of the company.
Any changes that we may make in the future to this Notice will be visibly posted on the Site and, if appropriate, notified to you via email.
|Address:||AX House, Mosta Road, Lija LJA9010, Malta|
|Telephone No:||+356 9999 2031|
Please check back frequently to see any updates or changed to this Policy.