Our Terms

Privacy Notice

1. Introduction

Ninety Six Real Estate (“Ninety Six Real Estate”/ “we”/ “our”/ “us”) are committed to protecting and respecting our visitors’ privacy. This privacy notice has been created to provide website visitors and clients of Ninety Six Real Estate (“you”) with a clear explanation as to:

  1. How we use any personal data that we receive from you or may collect about you, and
  2. Your privacy rights under applicable privacy laws.

All personal data will be processed in accordance with your instructions, the EU General Data Protection Regulation (“GDPR”), other relevant Maltese and EU legislation and our professional duty of confidentiality (the “Data Protection Laws”).

For the purposes of the GDPR, the Data Controller is:

Ninety Six Real Estate Limited a company incorporated and registered in Malta with company registration number C 97248.

Should you wish to request any clarification or additional information in relation to this privacy notice, or you may wish to exercise any of your rights in relation to your personal data, please send us an email on privacy@ninetysix.mt.

By using our services, you acknowledge that you have read, and agree to, the terms of this Privacy Notice and that you consent to the use by us, of your personal data for the purposes as set out in this Privacy Notice. If you do not wish to provide your personal information on the basis set out in this Privacy Notice, you should not enter the relevant information on the Website or provide your personal data to us in any other way. However, you understand that if you do not provide your personal data, we will not be able to provide you with our services.

This Privacy Notice is effective as from 7th January 2021. In the event that we modify this privacy notice, we will post a clear notice of the update in the homepage of our website.

2. Key Terms

Data Controller The person that determines the purposes and means of the processing of personal data.
Data Processor Any individual or organisation that processes personal data on behalf of the data controller.
Personal data Any information relating to an identified or identifiable natural person.
Processing Any operation which is performed on personal data such as collection, storage, use and erasure.

3. Scope

This notice applies in all cases where we act as data controller or data processor of personal data, regardless of who created the data and where it is stored. In this case it applies to all employees who process such personal data. Disciplinary action may be taken as a result of non-compliance with this notice.

4. Collection and Processing of Personal Data

We are bound by data protection laws to respect and protect any personal data we collect from you and we will abide by such duty. We take all safeguards necessary to prevent unauthorised access. All data collected is processed in accordance with the data protection laws.

Most of the information we process is given to us directly by you. This includes information that you input via our website and that you provide us with whether in person, over the telephone and/or via email or other social media platforms.

We can only use your personal data if we have a lawful reason for doing so. In terms of the data protection laws, we may process personal data if you have given us your consent or it is necessary:

  1. for our legitimate interests
  2. to carry out our contractual obligations, or
  3. to comply with a legal obligation.

We collect 2 types of data from you: (i) personal data like contact details to enable us to fulfil our service and (ii) behavioural data to better improve our service to you, which we will only collect if you Opt In.

The below table sets out the types of personal data that we may process, for what we may use it and our legal bases, which are our reasons for processing:

Activity Personal data we may process For what reasons we may use your personal data Our legal bases
When you make use of our sales and/or letting services General billing information, being:
– Full name
– Email address
– Address
– Mobile/Phone number

Where the client is a company, the following details are processed:
– contact person’s full name
– contact person’s email address
– contact person’s mobile/phone number
To provide you with our service.

To improve your experience.

Contacting you and responding to your communications with us.

Updating and enhancing our client database.
Performance of a contract:
Enabling us to perform the contract with you and provide you with our services.

For our legitimate interests:
Responding to your communications with us.
Processing is necessary for us to conduct our business, as long as our interests are not overridden by your interests or rights.

Performance of a legal obligation
In satisfaction of any obligation imposed on us by law.
When you visit our website We may automatically collect technical information, including:
– Your IP Address;
– Cookies;
– Date and time when you accessed the website;
– Details of the requested webpage and/or downloaded;
– Whether your request was successful or not;
To improve the content and functionality of our website.

To better understand the categories of visitors to our website.

To improve our services.
For system administration, bug tracking and producing usage statistics. This information may be kept indefinitely and will not be disclosed to third parties.
For our legitimate interests:
To understand the category of visitors of our website and to ensure that the visitors have the best possible experience when visiting the website.

Consent
On the basis of the consent that you have provided us, where this is required.
When you make a general enquiry or complaint Contact details that you provide to us when you request information.

These include your full name, mobile number, email address and other personal data that you may provide us.
To be able to trace the computer used in cases of any kind of misuse of our website.

Responding to your communications with us.

Updating and enhancing our contacts/client base.
For our legitimate interests:

Managing business communications.

Responding to your communications with us.

Resolving any enquiry, complaint or claim raised.
Communicating with us whether by email, call and/or through social media platforms Any data you may provide us during our discussions. To provide you with our service.

To improve your experience.

Contacting you and responding to your communications with us.
Performance of a contract:
Enabling us to perform the contract with you and provide you with our services.

For our legitimate interests:
Responding to your communications with us.

You shall take full responsibility for the integrity and the accuracy of the data provided. All personal data provided to us shall be in all respects true, accurate and up to date and is not, in any respect, misleading, deceptive or inaccurate or likely to mislead or deceive.

5. Cookies and Data Tracking

Ninety Six Real Estate uses cookies to optimise the functionality of our website. Cookies are small text files that contain certain data such as the site’s name and unique user ID and is downloaded to and stored on your device when you visit a website. We use cookies to help identify your computer so we can tailor your user experience. These cookies may obtain information about you, your device and your use of our website.

Most, but not all, of the cookies we use are automatically deleted from your computer when you leave our website or shortly afterwards. You can disable any cookies already stored on your computer, but these may stop our website from functioning properly.

Third party vendors, including Google, LinkedIn and Facebook, may show adverts for Ninety Six Real Estate on the internet. These vendors may use cookies to serve ads based on a user’s prior visits to Ninety Six Real Estate. Users can opt out of Google, LinkedIn and Facebook’s use of cookies by visiting the respective advertising opt-out page.

Opting Out:

You can set your browser to not accept cookies, but this may limit your ability to use the services.

For more information about our use of cookies and how you can change your settings to suit your please refer to our Cookie Policy. https://ninetysix.mt/privacy-notice

6. With whom we share your data

For us to be able to provide you with our service, data needs to be transferred both internally and externally.

Internal transfer of data is required for us to be able to provide you with our services and for the issuance of invoices and quotes. Internal sharing of data is only limited to employees who require the personal data and have been provided with relevant permission to access it.

We do not share your data with other third parties, except with the following persons and in the indicated circumstances:

  1. service providers – where necessary to carry out our services.
  2. other third parties– only where necessary to carry out your instructions and such third parties will only use your personal data for the purposes described above and only in accordance with our instructions.

We may also disclose your personal data in response to any requests made from law enforcement agencies, government entities or public authorities, where we have a duty to disclose or share your personal data in order to observe any legal or regulatory obligation or request.

We may also share your personal data with other parties in the event of a corporate reorganisation and/or disposition of our business, such as potential buyers of all or part of our business.

7. Where your personal data is held

We hold your personal data on our database

8. Transfer of Personal Data outside the EEA

In the event that personal data is transferred outside the EEA, the transfers shall be subject to specific EU and Maltese data protection laws.

9. How long do we keep your personal data?

Subject to your rights in Clause 10 hereunder, we retain your personal data included on your profile for as long as this is necessary to provide you with our services and for long as it is necessary for us to comply with our record-keeping requirements in terms of the law and to be able to respond to any questions, complaints or claims made by you or on your behalf. Hence, we will retain your personal data even after the completion of our services to you.
We will not collect more data than we require or retain your data for longer than necessary to fulfil the purposes outlined in this notice.

10. Your Rights as a Data Subject

We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of our services. Your principal rights under data protection laws by virtue of residing in the EU are:

Right of Access
The right to access and be provided with a copy of your personal data.
Right to Rectification
The right to require us to correct any inaccurate personal data about you.
Right to be forgotten
The right to require us to delete your personal data in certain circumstances.
Right to restriction of processing
The right to require us to restrict processing your personal data in certain circumstances.
Right to data portability
The right to receive your personal data which you provided to us, in a structured, commonly used and machine-readable format and the right to transmit that data to another data controller in certain circumstances.
Right to object
The right to object to the processing of your personal data in certain circumstances which include continued processing of your data carried out for the purpose of our legitimate interests.
Right not to be subject to automated processing
The right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or significantly affects you.

Should you require any further information on each of the above rights or would like to exercise any of them, please contact us on 9999 2027 or contact us via email on privacy@ninetysix.mt

11. Third Party Websites

Our site may contain links to other websites. Please note third party links are not associated with Ninety Six Real Estate and we do not have control over how your personal data is collected, stored or used by other websites. Hence, you are advised to refer to their privacy policies prior to providing your data.

Upon placing an order through our website, you will be redirected to the website of our third-party payment processor’s website.

12. Protecting your personal data

We are committed to take all appropriate measures to protect the confidentiality and security of the data you provide to us. Ninety Six Real Estate has implemented security measures to protect your personal data that we collect from being used or accessed unlawfully or accidentally lost. We only grant access to your personal data to those persons who have a genuine need to access it.

13. Complaints

We would like to resolve any concern that you may have about the processing of your personal data directly with you. However, you have the right to lodge a complaint with a supervisory authority, in the EU state in which you work, reside or where the alleged infringement of data protection laws took place. The supervisory authority in Malta is the Office of the Information and Data Protection Commissioner which may be contacted at https://idpc.org.mt/en/Pages/contact/complaints.aspx.

Last updated on 01/03/2021