This Privacy Notice is applicable to the Website www.loonynews.com. Capitalized terms used herein shall be attributed the same meaning attributed thereto in the T&Cs accessible at https://www.loonynews.com/termsandconditions/.
We, namely, Loonytainment a company registered in Fgura, Malta, bearing company registration number C 84755 and having its registered address at at 204, Silhouette, Triq il-Kampanella, Fgura, Malta are the controller of your personal data.
We are committed to respecting your privacy. If you wish to contact Us about Our privacy practices please feel free to do so by post on the abovementioned address or by email at email@example.com, or by telephone on 00356 7946 8813.
Please read this Privacy Notice carefully to understand our practices with respect to your personal data.
We may update this Privacy Notice in Our sole discretion including as result of a change in applicable law or processing activities. Any such changes will be communicated to you prior to the commencement of the relevant processing activity.
What amounts to personal data?
The term “personal data” refers to all personally identifiable information about you, such as your name, surname and username, and includes all information which may arise that can be identified with you personally and all information that you provide to Us when creating or updating your Account.
How do we collect personal data?
We generally collect personal data that you would have provided Us:
- When registering or updating your Account or subscription details; and
- When you post a query, complain or otherwise contact Us voluntarily including if you contact Us through the form on Our Website or via the chat system with Our Website administrators.
You may also choose to provide Us your data from third party sources such as Facebook, when you choose to create or log in to your Account via your Facebook account.
What personal data do we process?
The personal data we typically collect and process are your:
- Account registration details;
- IP address;
- Clicks on Offers and Points accrued;
- Personal data that We may process as a result of legal obligations imposed on Us;
- Any information you provide to Us when posting a query, complaint or otherwise contact Us; and
- Any personal data which you may voluntarily provide to Us.
How do we use your personal data?
We will only process your personal data for the purposes of giving you access to Our Offers and Reward System and purposes which are inherently related thereto, including the fulfilment of any resulting legal or regulatory obligation imposed on Us.
We might also process your personal data on the basis of your explicit consent, in which case we will process your data for the purposes for which your explicit consent was requested.
From time to time we would like to contact you about Our products and services, Offers, rewards and other information we may deem useful to you (“Marketing Communications”).
Marketing Communications may be carried out using only your email address.
You are to tick the appropriate box to confirm that you wish to be contacted for Marketing purposes:
- Yes I would like to hear about your offers and services by email
- No I would not like to hear about your offers and services
You can change your mind and may withdraw your consent to the processing of your personal data for Marketing Communication purposes at any time by clicking “unsubscribe” in any Marketing Communications which you may have received or by accessing your Account and clicking the “unsubscribe” button which is available at the footer of the Website once you have logged in to your Account.
Withdrawal of your consent does not affect the lawfulness of the processing based on your consent prior to the withdrawal.
Legal Bases of Processing Personal Data
We process your personal data on the basis of the following legal bases:
- Entering into and performing a contract – in particular to provide you with all services accessible on Our Website that require you to register an Account. Providing you personal data is necessary for Our performance of the T&Cs and the consequence for not doing such processing would be that we would be unable to provide you with access to the Website services that are available to holders of an Account;
- Our legitimate interests – in particular legitimate interests which may arise directly or indirectly in relation to your use of Our Website. When we process your personal data on the basis of Our legitimate interests, we ensure that the legitimate interests pursued by Us are not overridden by your interests, rights and freedoms;
- Your explicit consent – in which case, Our processing shall be limited to the purposes specifically indicated when your consent was requested. You shall have a right to withdraw your consent at will. Processing on the basis of your consent is envisaged with respect to Marketing Communications and any other instance where your prior request has been requested such as for the placement of certain cookies in your computer. and
- Compliance with legal obligations imposed on Us – in particular obligations imposed on Us as a result of your use of the Website.
On the basis of Our legitimate interests or compliance with legal obligations, as applicable, We may also process your personal data for the purposes of establishing, exercising or defending legal proceedings.
Note that special categories of personal data include data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic, biometric or health data, sexual orientation and data related to your conviction and offences. Typically, we do not envisage any processing of special categories of personal data.
We may share your personal data with third party recipients who are:
- selected individuals within Our company, on a need-to-know basis;
- any service providers that may have access to your personal data in rendering Us with their support services, including IT (such as MailChimp), legal and accounting service providers; and
- third parties to whom disclosure may be required as a result of the relationship with you;
- any third parties to whom you may have requested that we transfer your personal data; and
- third parties to whom disclosure may be required as a result of legal obligations imposed on Us.
Unless specifically instructed and consented by you, we do not share your personal data with any entity located outside of the EU or EEA.
Automated Decision-Making and Profiling
Your personal data will not be used for any decision solely taken on the basis of automated decision-making processes, including profiling, without human intervention.
We retain your personal data exclusively for the period which is lawfully permissible to retain your personal data. Thereafter, your personal data shall be immediately and irrevocably destroyed.
We retain your personal data for as long as you hold an Account with Us. Thereafter, we typically erase your data unless We choose that it may be in Our legitimate interest to hold your data for personal data for up to five (5) years from the end of Our contractual relationship established through the T&Cs on the basis of Our legitimate interests to protect ourselves from civil cases which you might institute against Us in relation to Our contractual relationship.
We may have a legitimate interest to hold your data for longer periods such as when your data is required for exercising or defending legal claims.
Any personal data which We may hold on the basis of your consent shall be retained exclusively until when you withdraw your consent.
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. 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, you have the right to withdraw 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 in terms of the applicable laws, your rights in relation to your personal data are not absolute.
You may exercise the rights indicated in this section by contacting Us at the details indicated above.
Keeping your data secure
We shall keep your personal data secure and shall commit to take appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, including against accidental loss, destruction, storage or access. Your personal data may be stored in paper files or electronically on our technology systems or on technology systems of our IT service providers.
If you have any complaints regarding Our processing of your personal data, please note that you may contact Us at the details indicated above. You also have a right to lodge a complaint with the Office of the Information and data Protection Commissioner in Malta (www.idpc.gov.mt).