Privacy Policy

We, the team at 1923 Investments Ltd take the confidentiality and security of your personal data very seriously. We strongly value privacy and therefore are committed to protect your personal data (i.e. information that identifies you).

One of your rights under the Data Protection laws (as defined below) is that you must be informed when your personal data – also known as personal information – is processed (collected, used, stored, etc ) by any organisation. You also have the right to know the details and purpose of that processing.

This privacy policy describes our policies and practices regarding how and why We generally process personal data and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.

For all our services, including our site and online facilities, the data controller (the company that’s responsible for your privacy), is 1923 Investments with its address at 1923 Investments, Nineteen Twenty Three, Valletta Road, Marsa, MRS 3000.

If you require any clarifications about how we protect your privacy, or would like to exercise any of your privacy rights get in touch with our Data Protection Officer on:

E-mail address: dataprivacy@1923investments.com, or

Address: 1923 Investments Ltd,

Nineteen Twenty Three,

Valletta Road,

Marsa, Malta MRS 3000

We assure you that we will only process any personal data collected from you in accordance with the manner set out in this policy.

As an entity established in Malta, EU, the main privacy laws that are applicable to Us in so far as You are concerned, are the following:

The Malta Data Protection Act (Chapter 586 of the Laws of Malta) as well as the various subsidiary legislation issued under the same – the ‘DPA’,
The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) – the ‘GDPR’.

Most of the personal information which we may collect about you through this website is given to us only if you choose to give it to us.
Such personal information may be requested from you when you fill in a field (eg. when you reach us through our contact form with your questions and comments) or any other form or application downloaded through or from 1923 Investments’ website. If you send us emails, then the personal data we process will depend on the data that you send us in the email.

The information we collect from you normally includes the following:

Name + Surname;
Contact Details
Information about your device (phone or laptop) with which you accessed our website

Some other information is provided to us because you accessed this website (e.g. logs, recorded through cookies). This is explained in the Cookies section below.

When we ask for such personal data, you may always decline, however should you decline to provide us with necessary data that we require to provide requested services, we may not necessarily be able to provide you with such services.

The next section will further explain how and why we use this information.

The table below clearly describes in a plain and concise manner what we use your personal data for and the legal ground(s) for doing so.

The Purpose of the processing	Personal Data	Legal Basis
To manage our relationship with you	Name Surname Contact details such as e-mail address Device information	Performance of a contract

The above categories of Personal data are collected directly from you.
Should we need to process Your data for a new purpose in the future, which is unrelated to the above, We will inform you of such processing in advance and You may exercise Your applicable rights (as explained in section below on ‘Your rights’), in relation to such processing.
You don’t have to give us any of this personal information but if you don’t, you may not be able to use our site or all of the services we offer on the site, and you are unlikely to receive an optimal customer experience.
We may also anonymise and aggregate personal information (so that it does not identify you) and use it for purposes including testing our IT systems, research, data analysis, improving our site and app, and developing new products and services. We also share this anonymised information with third parties – but don’t worry, they cannot identify you.

How we use your contact history

Why?

Provide user and customer and support

This is how we ensure that we have answered any queries you may have and to ensure we’ve carried out our contract with you to your best satisfaction

Enhance user experience in the future

For our team to be able to gain inside through “lessons learned” so that you get the best possible service

Information about your device (phone or laptop)

Information you give us when you browse our site, including your IP address and device type as well as how you use our website.

How we use information about your phone or laptop, and how you use our website

Why?

Improve our website and set default options for you (such as language and currency)

To give you the best possible experience on our website

Protect our website

To prevent and detect fraud against either you or us – and to meet our legal obligations about looking after your data

We will retain your personal data for as long as is necessary, considering the purpose(s) for which we first collected the data. The criteria we use to determine what is ‘necessary’ depend on the particular Personal Data in question and the specific relationship we have with you.

We may also retain some of your information if it becomes necessary or required to meet legal or regulatory obligations, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

As a guide:

We will keep personal data while your relationship with us is active (if you have an account) or until such time as you ask us to stop communications with you, unless we need to keep the data for longer to meet any legal or regulatory obligations, or to resolve a legal dispute;We may keep different types of personal data for different lengths of time if required by law (for instance, we may need to keep certain personal data relating to purchases for about 10 years to comply with tax/VAT reporting requirements);

You may obtain more information about the retention periods or the criteria used by contacting us at the e-mail address provided above.

If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information to us.

We will need to process personal data relating to parents or guardians in that case – and we may also need to request for verification documentation to ensure that consent is given or authorised by the holder of parental responsibility.

We do not, and will not, sell any of your personal data to any third party – including your name, address, contact details, or any other information you provide to us. It is not our business to do so – and we want to earn your trust and confidence.

Any data will be disclosed or shared as appropriate in line with the Data Protection Laws and the purposes listed in this Privacy Policy.

Besides sharing your data with members and staff of 1923 Investments, we share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out below:

1. Companies in the group to which 1923 Investments belongs, as sometimes different entities within our group are responsible for different activities (especially licensed ones). This includes 1923 Investments related entities/subsidiaries and members of the Hili Ventures Group (our mother group). Related entities and subsidiaries use the information collected to:

i. Help us improve the content and functionality of our websites;

ii. Better understand our customers and markets;

iii. Improve our products and services.

Members of the group vary from time to time.

2. Professional service providers, such as marketing agencies, advertising partners, and website hosts who service us in turn to operate our business.

3. Credit reference agencies, law enforcement, and fraud prevention agencies, So we can help tackle fraud.

4. Other companies that you may approve, such as social media sites (if you choose to link your accounts to us) or payment service providers.

In most circumstances, we will not disclose personal data without consent. However, there may be occasions where we might have to – e.g., with a court order, to comply with legal requirements and satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution, or similar event involving us and/or our subsidiaries and related entities.
When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended.
We may also provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you. Anonymous information means it is anonymous, and you will not be identified through this data.
If we ever have to share data with entities that are outside of the EEA, we will be sure to do so in a manner that complies with the requirements established by the GDPR.

What are cookies?

A cookie is a small text file (typically numbers and letters) that is downloaded onto ‘terminal equipment’ (e.g. your computer or smartphone) when you (or someone else) access a website using that device. Cookies are then sent back to originating website on each subsequent visit – and they are useful because they allow a website to recognise a user’s device and store some information about your preferences or past actions.

Some cookies are needed for the sole purpose of carrying out the transmission of a communication over an electronic communications network – others may be necessary for the provision of a service over the internet, in which case they have to be used.

Other cookies may be desirable to improve your experience, in which case we will ask you for your consent to use them.

What cookies do we use?

The cookies we use are the following:

Type of cookie	Why we use them	Who serves them
Analytics cookies	These are used to understand, improve, and research users visiting www.1923investments.com and their needs to improve our website’s user experience. For example, we may use cookies to understand what pages a user browses before submitting using the contact form. We do not share information about this analysis with any third parties.	Google Analytics cookies: _ga, _gat, _gid We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.

How do you change your cookie settings?

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

Other Passive Information which we collect

Apart from the information you provide us with when using our Website, other information is passively collected from you (without you actively furnishing such information) when you navigate through the website. We use various technologies and navigational data collection methods to gather such passive information for various reasons, for example to track how many visitors access our website, the date and time of their visit, the length of their stay and which pages they view. The passive information also aids us to determine which web browsers our visitors use and the address from which they accessed our website – for instance if they connect to our Website through clicking on one of our banner ads. This technology does not identify you personally.

Such passively collected information may be used and combined to improve our services to website visitors, customise the website based on your preferences, compile and analyse statistics and trends of our visitors and their use of the sites operated by us and our related entities or subsidiaries.

We assure you that, unless you have consented, such passive information shall not be combined with personally identifiable information collected elsewhere by our website or respective sites operated by our related entities or subsidiaries.

Before addressing any requests you make with us, we may first need to verify your identity. In all cases, we will try to act on your requests as soon as reasonably possible.

You enjoy several rights relating to your personal information. In certain circumstances, the following rights may be available to you. You may exercise these rights by sending a request to us. Where these rights are not available to you and we cannot fulfil them, we will inform you of this and provide our reasons for such refusal.

- The right to be informed about how your personal information is being used;

We need to be clear with you about how we process your personal data. We do this through this Privacy Policy, which we will keep as up-to-date as possible.

- The right to access the personal information we hold about you;

You may, at any time, contact us via the email address above to request access to the personal data we hold on you.

To process your request, we will ask you to complete a form that we will provide. We will carry out our best efforts to process your request within one month from receipt of the form, which may be extended by another month where necessary.

If we consider the frequency of your requests unreasonable, we may refuse to comply with your request. If you disagree, you can complain to the data protection authority—in Malta, the Information and Data Protection Commissioner.

We can provide you with a copy of your personal data in electronic format.

- The right to request the correction of inaccurate personal information we hold about you;

We appreciate feedback from you to ensure our records are accurate and up-to-date.

If you think the information we hold about you is inaccurate or incomplete, please ask us to correct it by contacting us at dataprivacy@1923investments.com. To ensure we process your request accurately, we will ask you to complete a form that we will provide.

- The right to request that we delete your data (Right to be forgotten);

You may ask us to delete your personal data; however, this is not an absolute right. In order to do so, you may contact us via the email address above, and we will kindly ask you to complete a form to process your request.

We may be justified in refusing your request and keeping personal data we are required to retain (e.g., to comply with a legal obligation, such as VAT reporting purposes) or in relation to the exercise or defense of any legal claims.

Other than as described above, we will always comply with your request promptly and will do our best to notify any third parties with whom we have shared your personal data.

- The right to restrict the use of your data;

You may ask us to restrict (i.e., retain but not process further) your personal data. Upon requesting us to restrict further processing of your data, we may not necessarily be able to provide you with further services.

Following your request for restriction, except for the retention of your personal data, we may only process your personal data:

- - Where we have your consent
  - For the establishment, exercise, or defence of a legal claim
  - For the protection of the rights of another natural or legal person
  - For reasons of important public interest
- The right to object to certain processing;

You have the right to object to our use of your personal information, including where we process it for our legitimate interests or where we use your personal information for profiling using automated means. Where an objection is entered, the processing of data shall cease, unless we, as data controller, provide compelling and legitimate grounds requiring the continuation of the data processing that outweigh the objections you may have raised.

For the avoidance of all doubt, when we process your personal data in relation to the performance of a contract, our legal and compliance obligations, or when processing is required to protect your vital interests or those of other natural persons, this right to object shall not subsist.

- The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;
- The right to withdraw consent for other consent-based processing at any time;

You have the right to withdraw your consent at any time in the same manner that you provided it to us. Should you exercise your right to withdraw consent, please write to us at dataprivacy@1923investments.com. We will determine whether an alternative legal basis exists for processing your personal data (e.g., based on a legal obligation to which we are subject) where we would be legally authorised to process your personal data without needing your consent. If this is the case, we will notify you accordingly.

- The right to request that we transfer or port elements of your data either to you or another service provider;

You have the right to move, copy, or transfer your personal data from one organisation to another. If you wish to transfer your personal data, we would be happy to help. If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used, and machine-readable form (e.g., CSV file format). We can provide the personal data to you directly or, if you request, to another organisation.

Please note that we are not required to adopt processing systems compatible with other organisations, so it may be that the recipient organisation cannot automatically use the personal data we provide. When making a transfer request, it would be helpful if you could identify exactly what personal data you wish us to transfer.

- The right to complain to your data protection regulator—in Malta, the Information and Data Protection Commissioner (IDPC);

If you want to exercise your rights, submit a complaint, or have questions, please contact us at the email address above.

When we receive requests, we may also request that you identify yourself and provide documentation or information for verification. Unreasonable requests may be subjected to a reasonable fee or refusal to respond.

Security of your personal data is very important to us.

Where it’s appropriate, our website uses HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.

To help protect the privacy of data and personally identifiable information you entrust us with, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

Security measures which have been implemented to secure information transmitted over our website or stored on our systems include the following:

Use of secure servers;
Use of firewalls;
Use of encryption;
Physical access controls at data centres;
Information access controls;
Use of back-up systems;

Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.

Our website is continually under review – new functions and features are periodically added and improved to interface, thus changes to our privacy policy may be required from time to time.

We therefore encourage you to check our privacy policy on a frequent basis.

This privacy notice does not cover the links within this site linking to other websites which are not controlled by us. We are not responsible for the collection or use of your personal information from these third-party websites.

Therefore, we encourage you to read the privacy statements on the other websites you visit.

Last Reviewed: September 2024