relation to the protection, processing and retention of your personal
data and has been prepared to reflect the provisions of Regulation (EU)
2016/679 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 (herein after, the “General Data Protection Regulation” or “GDPR”).
This Policy applies to the processing by Target Traffic of personal data
relating to any natural person being one of our customers, employees,
contractors, interns, trainees, directors, delegates, visitor to our Website
(www.target-traffic.net), applicants for job opportunities, candidates for
business relationships and suppliers, hereinafter collectively
referred to as “Data Subjects”.
For the purposes of GDPR, Target Traffic is the controller.
The contract details of the controller are included below:
Target Traffic processes personal data lawfully, fairly and in a transparent
manner and we only collect personal data which is adequate, relevant and
limited to what is necessary in relation to the purposes for
which they are processed.
We invite you to read on and learn about the types of personal data we
collect, when we collect it, why we do so, what we do with it, how long
we keep it, who we may have to share it with and why.
What personal data do we process and when do we collect it?
The personal data that Target Traffic processes depends on its relationship
to the Data Subject in question, but shall largely include the following
Name and surname;
Place of birth;
Date of birth;
Social security number;
Bank account details;
Copies of Identity Cards and/or Passports;
Log-in details for access to laptops and work email accounts;
Qualifications and employment history together with any other information you listed on your resume or CV;
Web browser history;
Details about your current remuneration, pension and benefits;
Such personal data is typically collected or supplied voluntarily upon
the commencement of our relationship with you as a Data Subject. However,
we also collect information from the public domain about individuals who work
at companies with whom we are seeking to build a business relationship or employ.
In some cases, and where permitted, we use third party services that perform
these online searches for us. Furthermore, as part of our recruitment process,
we may also collect information from the public domain that individuals post on
social or professional networking sites and job boards (e.g., LinkedIn).
Why do we process personal data?
The reason why we process personal data largely depends on our relationship
to the Data Subject, but this purpose is limited generally to:
complying with our legal obligations as an employer or purchaser of goods and services;
complying with or enforcing a contract to which we are a party;
complying with law or regulation or direction from any enforcement agency, court of law or regulatory body;
promotion of the security and protection of people, premises, systems and assets;
monitoring of compliance with contractual agreements, internal policies and procedures;
paying salaries or service fees;
transfer to third parties (see paragraph 3.3);
keeping records of staff absences;
providing services to our customers;
investigating or responding to incidents and complaints.
Should we need to process the personal data of a Data Subject for any
other reason, we will request their consent in writing, which the Data
Subject may withdraw at any time, provided that the withdrawal of consent
shall not affect the lawfulness of processing based on consent
before its withdrawal.
As mentioned above, we may disclose your personal data to third parties.
Target Traffic may do this in the following circumstances.
To our suppliers. We may, for example, engage a supplier to carry out
administrative and operational work in support of our relationship with
you. The supplier(s) will be subject to contractual and other legal
obligations to preserve the confidentiality of your data and to respect
your privacy, and will only have access to the data they need to perform
their functions; the relevant suppliers are typically lawyers,
consultants, accountants, auditors, IT suppliers (who host or support
our IT systems, including information about you), premises management
companies (who look after physical security at our offices, and
therefore may need to know about you to allow access to our offices)
and back office finance and accounting management providers
(who might need to handle details of a Data Subject in order to process
accounts payable and receivable).
To government, police, regulators or law enforcement agencies.
We will share your data with government, police, regulators or law
enforcement agencies if, at our sole discretion, we consider that
we are legally obliged or authorised to do so or
it would be prudent to do so.
In the case of a business transaction or restructuring activity.
We may need to disclose your data to the prospective seller or
buyer and their advisers as part of the due diligence process for
a proposed merger, acquisition, restructuring or other
What can I do to correct inaccurate or incomplete personal data?
Target Traffic takes every reasonable step to ensure that the personal
data we have in our possession is accurate and kept up to date.
However, it is still possible for certain personal data to be incorrect
or incomplete. Should you, therefore, wish to correct or complete any
inaccurate or incomplete personal data that Target Traffic holds, you may
do so by sending an email to firstname.lastname@example.org highlighting the data
that requires correction or completion, as the case may be, and we will
update our records without undue delay and inform you once this has been done.
Can I ask Target Traffic to access and erase my personal data?
Under the GDPR, any Data Subject has the right to access their personal
data and, in certain situations, the right to request that a controller erase
their personal data without undue delay.
Should you like to access your personal data held by Target Traffic or
should you wish that Target Traffic erases your personal data, you are
kindly requested to send an email to email@example.com.
You may also request a copy of your personal data. This will be
released either to yourself or to a controller designated by yourself.
Target Traffic will erase your personal data as soon as possible,
provided that such personal data are no longer necessary in relation
to the purposes (as specified in section 3 of this Policy) for
which they were collected or processed.
Can we transfer your personal data outside the EEA?
There may be situations where your personal data can be transferred
and processed in one or more non-EEA countries. In any such situations,
we will take steps to ensure that your personal data receives the same level
of protection as if it remained within the EEA, including by entering into
data transfer agreements, using the European Commission’s approved contractual
clauses for data transfers to third countries, or by relying on certification
schemes such as the EU - US Privacy Shield or other valid mechanisms for
data transfers. You may also request information on the protective measures
implemented for any third country transfers of personal data.
How long do we keep your personal data?
Target Traffic seeks to ensure that personal data are kept in a form
which permits identification of Data Subjects for no longer than is necessary
for the purposes for which the personal data are processed, however,
we typically erase the personal data we have on record within ten (10)
years from the end of our relationship.
How will we notify you of changes to this Policy?
Certain terms in this Policy may be amended from time to time,
in which case we shall publish any material changes through appropriate
notices either on our Website or otherwise contacting you using
other communication channels.
How can I complain?
If you are a Data Subject and you feel that your rights under the
GDPR have been violated by Target Traffic you have the right to lodge a
complaint with the Data Protection Commissioner in Malta using the complaints
form included on the Data Protection Commissioner’s Website.
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