Greenroads Malta website & Breeze App
1.1 application’,‘app’: means our proprietary mobile application breeze for use amongst registered Users to this mobile application.
1.2 we’; ‘us’: means Greenroads Malta
1.3 ‘website’,‘site’: means our website or our social media pages
2.Purpose of this Policy
3. Who are we and what do we do
3.1 Greenroads Malta is a private partnership and owner to all intellectual property of the breeze application.
3.2 Greenroads Malta is the data controller responsible for your personal information processed via the aite and the app.
4. How to contact us
sending an email to: ;
5. What personal information do we collect
We may collect personal information from you in the course of our business, including through your use of our website and application, when you contact or request information from us, when you register with our application or use our application or as a result of your relationship with one or more of our staff or other users.
Our primary goal in collecting personal information from you is to help us:
verify your identity
deliver our services through our application
improve, develop and market our application
carry out requests made by you on the aite or in relation to our application
investigate or settle inquiries or disputes which may arise in relation to your use of our application
comply with any applicable law, court order, other judicial process, or the requirements of a regulator
protect the rights, property or safety of us or third parties, including our other users of the site or our application
use as otherwise required or permitted by law.
For you to be able to use our mobile app, we may require to process the following personal information:
If you are a visitor to the site or a user of the app:
Name and surname;
Driving licence and all details it contains about you;
Details about your vehicle;
Photograph of you;
Demographic information such as your address, preferred routes;
Details of trips you may have done using our app;
Information about your interactions with our site or app;
Details of any communication and exchanges between you and us;
Other information relevant to the use of our mobile app;
6. How do we use your personal information
We may use your information for the following purposes:
6.1 In connection with your use of our app or your interactions with us on our site or social media pages.
6.2 We collect and maintain personal information that you voluntarily submit to us during your use of the app or our site to enable us to provide you with our app services.
7. What is our legal basis?
It is necessary for us to process your information to ensure the proper functioning of our app and to ensure the legitimate nature of our users.
Our site and our app use various user interfaces to allow you to request information about our app services including electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, together with details of other personal information that is relevant to your service enquiry. This information is used in order to enable us to respond to your requests.
What is our legal basis?
It is in our legitimate interest to ensure that we provide the very best client service we can to you or others.
Business administration and legal compliance
We use your personal information for the following business administration and legal compliance purposes:
to comply with our legal obligations;
to enforce our legal rights;
to protect the rights of third parties; and
What is our legal basis?
Where we use your personal information in connection with a legal or compliance request by an authorised Law Enforcement Agency, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us at law.
We carry out the following marketing activities using your personal information:
Email marketing - We use information that we observe about you from your interactions with our site or app, or our email communications to you (see the Client Insight and Analysis section below for more details of the information collected and how it is collected) to send you marketing communications.
What is our legal basis?
It is in our legitimate interest to use your personal information for marketing purposes. We will only send you marketing communications where you have consented to receive such marketing communications, or where we have a lawful right to do so.
Client insight and analysis
We analyse your contact details with other personal information that we observe about you from your interactions with our site, our email communications to you and/or with our app.
an IP address to monitor site/app traffic and volume;
a session ID to track usage statistics on our site/app;
information regarding your experiences with our app and contact preferences;
information about your usage of our app;
Our web pages contain “cookies”, “web beacons” or “pixel tags” (“Tags”). Tags allow us to track receipt of an email to you, to count users that have visited a web page or opened an email and collect other types of aggregate information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source email and the relevant Tag.
In some of our email messages, we use a “click-through URL” linked to certain website administered by us or on our behalf.
By using this information, we are able to measure the effectiveness of our content and how visitors use our site and our app. This allows us to learn what pages of our site or app are most attractive to our users, which parts of our site or app are the most interesting.
We also use this information for marketing purposes (see the marketing section above for further details).
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best experience to you and our other app users.
Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details, where available.
8. Who do we share your personal information with
We may share any information that we collect or that you provide to us with some third-party entities’ employees, to the extent covered by the agreement between us and them and strictly to the extent necessary and required in promoting our services and the app.
We may share personal information with a variety of the following categories of third parties as necessary:
· Our professional advisers such as lawyers and accountants;
· Government or regulatory authorities;
· Professional indemnity or other relevant insurers;
· Regulators/tax authorities/corporate registries;
· Third parties to whom we outsource certain services such as, without limitation, IT and software development service providers, document and information storage providers;
· Third parties engaged in the course of the services we provide to clients;
· Third party service providers to assist us with client insight analytics, such as Google Analytics;
· Third party e-mail providers who assist us in delivering our e-mail marketing campaigns to you, or delivering documents related to a matter;
Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the app as effectively as we can.
9. Third party contractors and other controllers
As mentioned above, we may appoint sub-contractor data processors as required to support the app, such as, without limitation, document processing and, IT systems or software providers, IT Support service providers, document and information storage providers, who will process personal information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.
What is our legal basis?
It is necessary for us to perform our obligations in accordance with any contract that we may have with you.
It is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the app services in the best way that we can.
10. Where do we transfer your data to?
In order to provide the app services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it.
If you are based within the European Economic Area (EEA), please note that where necessary to deliver the app services we will transfer personal information to countries only within the EEA.
11.How long do we keep your personal information for?
For visitors to the site or users of the app, we will retain relevant personal information for at least three years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation, or for longer if we are required to do so according to our regulatory obligations or professional indemnity obligations. We may then destroy such files without further notice or liability.
If personal information is only useful for a short period e.g. for specific marketing campaigns we may delete it earlier.
12. Confidentiality and the security of your personal information
We are committed to keeping the personal information provided to us secure and we have implemented appropriate information security policies, rules and technical measures to protect the personal information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
All of our partners, employees, consultants, workers and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information.
13. How to access your information and your other rights
You have the following rights in relation to the personal information we hold about you:
· Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
· Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
· Your right to erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
· Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. You must note however that restricting your data may hinder or impede your use of our app as its utility is based on sharing of user data with other users.
· Your right to data portability
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
· Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are:
relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
processing your personal information for direct marketing purposes.
· Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
· Your right to lodge a complaint with the law enforcement agency
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the relevant law enforcement agency in Malta.
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.
14. Collection of information by third-party sites and sponsors
The site or the app may contain links to other sites whose information practices may be different than ours. Visitors/users should consult the other sites’ privacy notices as we have no control over information that is submitted to, or collected by, these third parties.
15. Your password
You have chosen a password to be able to access our app and you are solely responsible for keeping this password secret at all times.
Greenroads Malta © 01.10.2018