This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site.

We use your Personal Information only for providing and improving the Site. By using our Site, you agree to the collection and use of information in accordance with this policy.

1. Introduction

This notice about our privacy policy contains a lot of information but we want you to be fully informed about your rights, and how Signature Private Office uses your data. It also explains how we will store your data and keep it safe.

For simplicity throughout this notice, ‘we’ and ‘us’ means Signature Private Office.

This notice explains in detail the types of personal data we may collect about you when you interact with us and how we may collect, use, and share your personal information, our legal bases for using your personal information, how long we keep your personal information, how we protect your personal information, the countries to which we may transfer your personal information, and your rights regarding your personal information.

You may have legal rights and, where relevant, we have described these as well.

It is likely that we will need to update this notice from time to time. Please come back to our Site and check it whenever you wish as we will post any changes here.

This notice applies to all Signature Private Office entities in the EU and in relevant countries throughout our international network.

2. About ‘Malta Residency Programs’

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the details of the company responsible for your personal data is Signature Private Office.

This Notice applies to all our companies except where we say otherwise.

3. Legal Background

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

• Consent – In specific situations, we collect and process your data with your consent. For example, when you transact business with us or ask to receive information about our services. When collecting your personal data, we will always be clear which data is necessary in connection with a particular service.
• Contractual obligations – In certain circumstances, we need your personal data to comply with our contractual obligations.
• Legal compliance – If the law requires us to, we may need to collect and process your personal data.
• Legitimate interest – In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business, for example to service existing business relationships and contracts, and which does not materially impact your rights, freedom, or interests. In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims. We will also use your address details to send you direct marketing information, to inform you about our services updates that we think might interest you.

4. Information Collection And Use

While using our Site we may ask you to provide us with certain personally identifiable information which can be used to contact or identify you. Personally identifiable information may include, but is not limited to: your name; Personal Information; Log Data. Like many site operators, we collect information that your browser sends whenever you visit our Site.

We want to give you the best possible client service and experience. One way to achieve that is to ensure we have all the relevant information which may also include your personal data. We then use this to inform Signature Private Office team and to tailor our services accordingly.

The data privacy law allows this as part of our legitimate interest in understanding our clients, so we provide the highest levels of service. If you wish to change how we may use your data, you will find details in the ‘Personal Data Rights’ section below.

Please be aware that if you choose not to share your personal data with us, or if you refuse certain contact permissions, we might not be able to provide some services that you may have asked for.

This is how we will collect your personal data and why:

(1) in the course of our business acceptance procedures to manage, administer and improve our provision of services to clients and to administer any service or support which you have requested, based on your consent given at the time of request;

(2) to provide information requested by you. We may also keep a record of your requests to inform any future communication and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience;

(3) to protect our business and you from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard our dealings with you. We will also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our website/app. We will do all of this as part of our legitimate interest;

(4) to process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our clients from fraud;

(5) if we discover any criminal activity or alleged criminal activity. We aim to protect the individuals we interact with from criminal activities;

(6) to follow up with you on a job application;

(7) with your consent, we will use your personal data to keep you informed by post, email and telephone about relevant services, events that you may be interested in, and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time;

(8) to send you relevant, personalised communications by post and email in relation to updates and services. We will do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post and/or email at any time;

(9) to send you communications required by law, or which are necessary to inform you about the services we provide to you. For example, legally required information relating to any service we have agreed to provide. These messages will not include any promotional content and do not require prior consent when sent by email, post, or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations;

(10) to display the most interesting content to you on our websites or apps, we will use data we hold and will do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device;

(11) to develop, test and improve the systems and services we provide to you. We will do this on the basis of our legitimate business interests;

(12) to comply with our contractual or legal obligations to share data with law enforcement.

Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected. We will delete your personal data from our systems unless we believe in good faith that we need to retain some information to place you on a ‘do not contact’ list or where the law or other regulation requires us to preserve it (for example, because of our obligations to tax or regulatory authorities).

We sometimes share your personal data with other Signature Private Office companies and with trusted third parties. The policies we apply to those organisations to keep your data safe and protect your privacy are:

• we provide only the information they need to perform their specific services;
• they may only use your data for the exact purposes we specify in our contract with them;
• we work closely with them to ensure that your privacy is respected and protected at all times;
• if we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

• IT companies who support our Site and other business systems.
• Operational companies such as delivery couriers;
• direct marketing companies who help us manage our electronic and printed communications with you;
• data insight companies to ensure your details are up to date and accurate.

We may also share your data with third parties for their own purposes. We will only do this in very specific circumstances, for example:

• for fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies;
• we may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our clients into consideration.

5. Log Data

This Log Data may include information such as your computers Internet Protocol & IP address; browser type; browser version; the pages of our Site that you visit; the time and date of your visit; the time spent on those pages and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyse this. The Log Data section is for businesses that use analytics or tracking services in websites or apps, like Google Analytics.

6. Communications

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information.

7. Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive. They are text files which are stored on your computer or other device when you visit our Site. Like many websites, we use “cookies” to collect information. Cookies allow us to distinguish you from other users of our Site. This helps us to provide you with a positive experience when you browse our Site and to improve our Site.

Our Site uses session cookies and persistent cookies. Session cookies are stored temporarily on your device whilst you browse our Site and are deleted from your device when you finish browsing. Persistent cookies are stored on your device after you have finished browsing our Site so that we can remember your preferences when you visit our Site in the future. Persistent cookies will automatically be deleted from your device after 30 days.

We use Google Analytics to provide us with information about how you use our Site, which we use to help us to improve our Site.

If you wish to restrict, block, or delete the cookies which are set by our Site and third parties, you can do this using your browser settings. If you set your browser preferences to block all cookies, you may not be able to access all or parts of our Site. If you delete cookies relating to our Site, including your cookie preferences, you will be treated as a first-time visitor the next time you visit our Site.

By using our Site without changing your browser settings, you consent to our use of cookies as set out above.

8. Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security due to the nature of the process. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it. We have in place technical and organizational measures to protect the personal information we collect about you from unauthorised, improper, or unlawful access, use, disclosure, alteration, or destruction consistent with applicable data protection laws. We secure access to all transactional areas of our websites using ‘https’ technology.

9. Where Your Personal Data May Be Processed

We may need to transfer your Personal Information to locations outside the jurisdiction in which you provide it, or from where you are viewing this website/app, in order to use it on the bases set out above. If you are an EU citizen or reside in the EU, we will transfer your Personal Information outside the EU in accordance with EU data protection laws to ensure that it remains protected and secure. To facilitate this, we have in place EU standard contractual clauses between the relevant Signature Private Office entities.

If you reside in a jurisdiction outside the EU, you may also have rights under applicable laws in connection with your Personal Information that we collect, hold and process. We may transfer Personal Information that we collect from you to third-party data processors in countries that are outside the EU such as the USA. For example, this might be required in order to fulfil any service we have agreed to provide, to process any payment or other details you provide to us or to provide any other support or commercial services. If we do this, we have procedures in place to ensure your Personal Information receives the same protection as if it were being processed inside the EU. For example, our contracts with third parties stipulate the standards they must follow at all times.

10. Personal Data Rights

If you are an EU citizen, you have the right to make a Data Subject Access Request (DSAR) and to request:

• access to the Personal Information we hold about you, free of charge in most cases;
• the correction of your Personal Information when incorrect, out of date or incomplete;
• that we stop using your Personal Information for direct marketing (either through specific channels, or all channels);
• that we stop any consent-based processing of your Personal Information after you withdraw that consent.

You can contact us to request to exercise these rights at any time.

Right to erasure – In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your Personal Information. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). If we choose not to action your request, we will explain to you the reasons for our refusal. Generally, we will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your Personal Information but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data is collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

Your right to withdraw consent – Whenever you have given us your consent to use your Personal Information, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest – In cases where we are processing your Personal Information on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your Personal Information.

Direct marketing – You have the right to stop the use of your Personal Information for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity – To protect the confidentiality of your Personal Information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

11. How To Stop The Use of Your Personal Information For Direct Marketing

There are several ways you can stop direct marketing communications from us:

• click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular team within Signature Private Office;
• in our apps, you can manage your preferences and opt out from one or all of the different push notifications by selecting or deselecting the relevant options in the ‘Manage Notifications’ section;
• email us at info@maltaresidencyprograms.com;
• write to us at: Signature Private Office Limited, Dragonara Business Centre, 5^th Floor, Dragonara Road, St. Julians STJ 3141, Malta.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

12. For All Non-EU Residents

Where this Notice is available in a language other than English, then in case of any dispute about its meaning, the English version will take precedence.

By using our services or providing your personal data to us, you expressly consent to the processing of your Personal Information by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we will need to transfer your Personal Information between countries to enable us to supply services you have requested. In the ordinary course of business, we may transfer your Personal Information from your country of residence to ourselves and to third parties located in the EU or elsewhere.

By dealing with us, you are giving your consent to this overseas use, transfer, and disclosure of your Personal Information outside your country of residence for our ordinary business purposes. This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your Personal Information on servers in the EU or elsewhere.

We will ensure that reasonable steps are taken to prevent third parties outside your country of residence using your Personal Information in any way that is not set out in this Notice. We will also make sure we adequately protect the confidentiality and privacy of your Personal Information.

We will ensure that any third parties process your Personal Information only in accordance with their legitimate interests. These third parties may be subject to different laws from those which apply in your country of residence. Please note that we do not take active steps to ensure that any overseas recipient of your Personal Information complies with the laws which apply in your country.

13. Changes To This Privacy Policy

This Privacy Policy is effective as of 27th October 2022 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our Site.

14. Contact Us

We hope this Notice has been helpful in setting out the way we handle your personal data and your rights to control it. If you have any questions that have not been covered, kindly contact us and we would be glad to assist you:

email us at: info@maltaresidencyprograms.com;

write to us at: Signature Private Office Limited, Dragonara Business Centre, 5^th Floor, Dragonara Road, St. Julians STJ 3141, Malta.

This notice was last updated on 27th October 2022.