Version 2. Last updated: 9 November 2022
This Privacy Notice (“Notice”) applies where Junior Achievement (Young Enterprise) Malta Foundation (hereinafter referred to as “JA” “We”, “Us” or “Our”) are acting as a Controller with respect to Our Processing of Your Personal Data.
By accessing this Privacy Notice, you acknowledge and confirm that you have been provided with and understood this Privacy Notice and, where applicable, explained this privacy notice to the minor or minors under your care.
Any Personal Data We Process is kept within Our own records in accordance with the relevant data protection and privacy laws to which We are subject including but not limited to the Data Protection Regulation (EU) 2016/679 (the “GDPR”) and the Data Protection Act (Chapter 586 of the Laws of Malta) and the subsidiary legislation issued thereto, as may be amended from time to time (hereinafter collectively referred to as the “Applicable Laws”).
References to “Controller”, “Data Subject”, “Personal Data”, and “Process”, “Processed”, “Processing” in this Privacy Notice have the meanings set out in, and will be interpreted in accordance with the Applicable Laws. “You” and “Your” refers to the Data Subject.
Data Controller Details
The Controller of your Personal Data is Junior Achievement (Young Enterprise) Malta Foundation (VO//0705). We are committed to respecting your privacy. If you wish to contact Us about Our privacy practices please feel free to do so by contacting Our Data Protection Officer, Matthew Caruana, by post at 1 Clock Tower Building, Tigne Point, Sliema, TP01, Malta or by email at hello@jamalta.org. You may also wish to contact Us by telephone on +356 21245054 between 09:00 and 17:00 on weekdays.
Categories of Personal Data
The term “Personal Data” refers to all personally identifiable information about you and includes all the information you provide to Us or information that is provided to Us by third parties, which can be identified with you personally.
The following are the categories of Personal Data that We Process:
- Name;
- Surname;
- Job title;
- Telephone and mobile numbers;
- Email addresses;
- IP address;
- Social media handles;
- ID Card numbers;
- Medical history;
- Education history;
- Photos and videos;
- Cookies;
We may collect information relating to your medical history so that We are aware of any immediate action which may need to be undertaken should you fall ill. We do not collect and/or otherwise Process any other special categories of Personal Data.
We may also be required to collect other categories of Personal Data in order to satisfy Our legal obligations, including those obligations imposed on Us under the Protection of Minors (Registration) Act (Chapter 518 of the Laws of Malta).
Categories of Data Subjects
We typically Process Personal Data pertaining to the following categories of persons:
- Students;
- Board members;
- Staff;
- Mentors and advisors;
- Link teachers;
- Alumni;
- Volunteers;
- Sponsors and their representatives;
- Emergency contacts; and
- Parents and guardians.
Purposes of Processing
The purposes of processing for which your Personal Data are intended include:
- Entering into agreements with Us, including program enrolments and sponsorship agreements;
- Handling any query submitted to Us via the ‘Contact Us’ page found on Our website or any other medium through which query may be sent to Us;
- Maintaining an account with Us for the duration of your enrolment;
- Running Our ‘Alumni Outreach Program’; and
- Employment contracts or other legal and administrative documents as required by MBR and CVO.
From time to time, We would also like to contact you about Our products and services, promotional offers, information relating to Our operations as well as information in relation to products and services provided by third parties and their offers and promotions (“Marketing”).
Legal Basis
Our legal bases for Processing your Personal Data are:
- Contract: The Processing is necessary for performance of a contract to which you (in your personal capacity or in your capacity as a legal representative) are a party or in order to take steps prior to entering into a contract. Such lawful basis applies where We Process your Personal Data in order to enrol you into one of Our programs or to execute sponsorship (or similar) agreements;
- Vital Interests: In certain situations, We may be required to Process your Personal Data in order to protect your vital interests (namely in life or death situations);
- Legal Obligation: We may be required to Process your Personal Data in order to comply with laws and regulations that are imposed upon Us, including those obligations imposed on Us under the Protection of Minors (Registration) Act (Chapter 518 of the Laws of Malta);
- Legitimate Interest: We may be required to Process your Personal Data in order to pursue Our (or a third party’s) legitimate interests. Such legitimate interests may arise where We wish to initiate, or have to defend, legal claims. We also have a legitimate interest to process your Personal Data for safety and security. When We process your Personal Data on the basis of Our (or a third party’s) legitimate interests, We ensure that the legitimate interests pursued by Us (or the third party) are not overridden by your interests, rights and freedoms; and
- Consent: This lawful basis of Processing mainly applies to the Marketing activities that WE carry out. In particular, We require your consent in order for you to receive Our newsletter and to become part of Our Alumni Outreach Program.
Recipients
The recipients of your Personal Data are:
- selected individuals within JA;
- Our intra-group companies, members and affiliates;
- Our agents and third parties that provide services to Us; and
- Third parties to whom disclosure may be required.
Individuals with access to your Personal Data shall be subject to the same limitations under this Privacy Notice and are located within the EU.
Processing Requirement
The Processing of your Personal Data by JA may be required for statutory purposes as well as contractual requirements. Where the lawful basis of Processing your Personal Data is either statutory or a contractual requirement, failure to provide your Personal Data to JA in either scenario would result in JA being unable to enter into a relationship and this may result in you being unable to enrol in Our programs.
Automated Decision-Making and Profiling
Your Personal Data will not be used for any automated decision-making or profiling.
Data Retention Period
Your Personal Data shall be held for definitive periods of time in accordance with Our internal retention policy. The retention period depends on the purposes of Processing. Once the retention period expires, the Personal Data shall be immediately and irrevocably erased unless We need to keep your Personal Data to comply with a legal obligation, or to exercise or defend any legal claim.
Your Rights
For as long as We retain your Personal Data, you have certain rights in relation to your Personal Data including:
- Right of access – you have the right to ascertain the Personal Data We hold about you and to receive a copy of such Personal Data;
- Right to complain – you have the right to lodge a complaint regarding the processing of your Personal Data with the supervisory authority for data protection matters. In Malta this is the Information and Data Protection Commissioner (contact details provided below);
- Right to Erasure – in certain circumstances you may request that We delete the Personal Data that We hold about you;
- Right to Object – you have a right to object and request that We cease the processing of your Personal Data where We rely on Our, or a third party’s legitimate interest for processing your Personal Data;
- Right to Portability – you may request that We provide you with certain Personal Data which you have provided to Us in a structured, commonly used and machine-readable format (except where such Personal Data is provided to Us in hand-written format, in which case such Personal Data will be provided to you, upon your request, in such hand-written form). Where technically feasible, you may also request that We transmit such Personal Data to a third party controller indicated by you;
- Right to Rectification – you have the right to update or correct any inaccurate Personal Data which We hold about you;
- Right to Restriction – you have the right to request that We stop using your Personal Data in certain circumstances, including if you believe that We are unlawfully processing your Personal Data or the Personal Data that We hold about you is inaccurate;
- Right to withdraw your consent – where Our processing is based on your consent. Withdrawal of your consent shall not affect the lawfulness of the processing based on your consent prior to the withdrawal of your consent; and,
- Right to be informed of the source – where the Personal Data We hold about you was not provided to Us directly by you, you may also have the right to be informed of the source from which your Personal Data originates.
Please note that your rights in relation to your Personal Data are not absolute and We may not be able to entertain such a request if We are prevented from doing so in term of an applicable law.
You may exercise the rights indicated in this section by contacting Us at the details indicated above.
Complaints
If you have any complaints regarding Our processing of your Personal Data, We kindly ask that you please attempt to resolve any issues you may have with Us first by contacting Us at the contact details included above. However, please note that you always have a right to lodge a complaint with the Office of the Information and Data Protection Commissioner in Malta (www.idpc.gov.mt).
Cookies
We will ask for your consent to Our use of cookies in accordance with the terms of this Privacy Notice when you first visit Our website.
Strictly necessary cookies: These cookies enable the user to have the best possible service when browsing the website.
Performance and tracking cookies: Performance and tracking cookies are used to further improve the website. These cookies collect information about how the website is being used. All information gathered is anonymous and no personal data is obtained which might identify you as an individual.
Functionality cookies: These cookies are used to memorize the options that you choose. The information these cookies collect is anonymous and they cannot track your browsing activity on other websites.
Session cookies: These expire when you close the browser.
Why We use cookies:
Below is a list of why we use cookies:
- You may see a pop-up welcome message when you first visit Our website;
- We will store a cookie so that your computer memorizes that the webpage was previously visited, and such pop-ups would not show up again on your subsequent visits;
- We collect a session ID to anonymously identify your browsing session;
- To improve Our understanding of how you navigate through Our website so We can identify improvements;
- To temporarily store input information in Our calculators, tools, illustrations and demonstrations;
- To provide you with adverts that are more relevant to your interests, improve Our targeting and enhance your journey through Our website and partner websites;
- To ensure your security and your privacy when browsing Our website;
- To evaluate Our site’s advertising and promotional effectiveness and We use both Our own (first-party) and partner companies’ (third-party) cookies to support these activities; and
- To find out which pages are most relevant to you.
We do not use cookies that:
- Keep details that can personally identify you;
- Track your browsing after you left Our websites; and/or
- Sell or distribute information about you without your consent.
Cookies used by Our service providers:
- We use Google Analytics to analyze the use of Our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to Our website is used to create reports about the use of Our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
- Disable cookies: To ensure that We can provide suitable content to meet your needs, all cookies must be enabled. You may not be able to access certain parts of the website if you opt out of all cookies.
- You may disable cookies through your internet browser. Find out more by either accessing www.allaboutcookies.org/manage-cookies/ or by sending Us an email on hello@jamalta.org
- For more information about cookies please refer to allaboutcookies.org.
Where You Provide Us with Personal Data Related to Third-Party Data Subjects
If you are a non-natural person and you supply Us with Personal Data of third-party Data Subjects such as your employees, children, affiliates, service providers, underlying clients/customers, directors or any other individuals connected to your business, you shall be solely responsible to ensure that:
- you immediately bring this Privacy Notice to the attention of such Data Subjects and direct them to it;
- the collection, transfer, provision and any Processing of such Personal Data by You fully complies any applicable laws;
- as data Controller you remain fully liable towards such Data Subjects and shall adhere to the Applicable Law;
- you collect any information notices, approval, consents or other requirements that may be required from such Data Subject before providing Us with their Personal Data; and
- you remain responsible for making sure the information you give Us is accurate and up to date, and you must tell Us if anything changes as soon as possible.
- You hereby fully indemnify Us and shall render Us completely harmless on first written demand against all costs, damages or liability of whatsoever nature resulting from any claims or litigation (instituted or threatened) against Us as a result of your provision of said Personal Data to Us.
- This clause shall supersede and extinguish all previous agreements, promises, assurances, warranties, representations and understandings between Us and the non-natural person, as applicable, whether written or oral, relating to its subject matter.
Processing of Personal Data relating to Minors
We may Process Personal Data relating to minors. In certain situations, this Personal Data may not be provided to Us by the minors themselves but by a third party individual, such as a parent or guardian. Where this type of Processing takes place, We require that such third party individual provides and explains this privacy notice to the minor and ensures that the minor understands the activities that are being undertaken by Us with respect to the minor’s Personal Data.