- This Privacy Notice sets out the way in whichFM Core Limited (Company registration number C-49204), FM Core Facility Services Limited (Company registration number C-52353) and FM Core Condominium Administration Limited (Company registration number C-68910)("we","us", “our”, or “Data Controller”), a Company incorporated and registered in Malta and forming part of In21Group, collects and processes Personal Information (as defined in paragraph 2.1 below) pertaining to “MainManager” (“the Mobile Application”).
- By using our Services, you (“your” or “the data subject”) acknowledge that you have read and understood the terms of this Privacy Notice and that you understand that we as well as any partners and subcontractors, will process your Personal Information in accordance with this Privacy Notice, including for the purposes set out in paragraph 4below. If you do not wish to provide your Personal Information on the basis set out in this Privacy Notice, you should not provide us with your Personal Information. However, if you do not provide your Personal Information, you may not be able to use the Services.
2. The information we collect
- "PersonalInformation" means any information from which a natural person can be directly or indirectly identified.
- In order to provide you with our Services in respect to condominium management, propertymanagement and the other reactive services one may require from time to time, our Mobile Applicationmay be utilised.
- We only use your personal data which you have already provided to usvia the Condominium Association upon engagement to carry out any of the above-mentioned Services.
- Moreover, upon reporting an incident, the Mobile Application requests certain permissions that allow it to access your device data as part of your Incident Reporting procedure.
- We will neither request nor accept any personal identifiable pictures of you.In the event that personal identifiable pictures are sent to us, these will be immediately deleted through manual means.
3. How we use your Personal Information
- In accordance with data protection legislation, we will only process your Personal Information where we have a legal basis to do so. In respect to the collection of Personal Information, the relevantlegal basesare as follows:
- where it is necessary to provide Services to you under the performance of acontract we have with you or in order to take steps at your request prior to entering into a contract;
- where we are required to do so in accordance with our statutory obligations;
- where you have provided us with your consent; and
- where it is in our legitimate interest to process your Personal Information, provided that,this does not prejudice your own rights, freedoms and interests.
- Should you decide to uninstall the mobile application, as part of our business legitimate interests,your personal data shall only be retained for the minimum amount of time necessary to satisfy the purpose/s for which your data is processed.
- The following are a list of the "Purposes" for which we process your Personal Information, and the lawful basis on which we carry out such processing:
Purpose Lawful Basis
To set-up, administer and manage your Account and records (including the prosing of service requests through the Mobile application)
Necessary for the performance of a contract.
To provide and personaliseour Services
Necessary for the performance of a contract.
To receive and respond to your communications and requests
Necessary for the performance of a contract where such communication relates specifically to our Services, otherwise your consent shall be requested.
To ensure that we are able to fulfil our regulatory obligations regarding your Account, including by verifying the accuracy of any information you provide to us through the use of our Services
Necessary to comply with our statutory obligations.
To carry out market research campaigns
Legitimate interests so that we can better understand the products and Services that our customers enjoy.
To prepare statistics relating to the use of our Services
Legitimate interests so we can understand the use of, and therefore improve, our Services.
To provide you with information about, and support for, our Services, including changes to our Services, technical updates to the applicationand changes to the Privacy Notice
Necessary for the performance of a contract, to comply with our statutory obligations and as part of our business legitimate interests.
4. Disclosure of your Personal Information
- Except as described in this Privacy Notice, we will not disclose your Personal Informationto third parties without your consent.We may disclose your Personal Information to third parties if you consent to us doing so, and solely for the purposes mentioned in Section 4 of this Privacy Notice.
- We may also disclose your Personal Information to any of the following recipients:
- any third party which assists us in providing our Services, including (but not limited to) providers and managers of the application;
- any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising us;
- any law enforcement or regulatory body which may have any reasonable requirement to access your Personal Information; and
- any actual purchaser of the In21Group’s business or any investors in it or in any company within our Group (including in the event of insolvency).
- We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
- If at any time you wish us to stop processing your Personal Information for any of the above Purposes, you should contact us, and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed, and you may no longermake use of our Services.
5. Data Subject Rights
- 5.1. We respect your privacy rights and shall provide you with reasonable access to your personal data. Your principal rights are:
- the right for information;
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to lodge a complaint with the supervisory authority and/or seek judicial remedy; and
- the right to withdraw consent.
- If you wish to exercise any such right, please contact us at [email protected]. We will acknowledge your request as soon as practically possible and will action such requests within one calendar month starting from the day after the request is received. This period may be extended for particularly complex requests in accordance with applicable data protection laws.
- Please note, however, that certain Personal Information may be exempt from such access, correction and erasure requests pursuant to applicable data protection laws or other laws and regulations.
- If you believe that we have not complied with your data protection rights, you can file a complaint with the Lead Supervisory Authorityof your member state or with the Lead Supervisory Authority we are governed by (The Office of the Information and Data Protection Commissioner) by following this link: https://idpc.org.mt/en/Pages/contact/complaints.aspx
6. Retention of your Personal Information
- We will retain your Personal Information for as long as your Account is active and/or only for the minimum amount of time necessary to satisfy the purpose/s for which your data was initially collected and processed, to provide you with our Services and/or to comply with our legal and regulatory responsibilities.
- Accordinglyor following the closure of your Account (if applicable), we will retain your Personal Informationfor a minimum of five(5) years .
- Where we no longer require your Personal Information, we will deleteitas soon as practicable.
- We may retain your Personal Informationwhere such retention is necessary for compliance with a legal obligation to which we are subject.
7. Storage and Security
- Your Personal Information will be stored on a database located in Europe, which is managed and hosted by third parties.
- We and the afore mentioned third parties have put into place appropriate technical and organisationalmeasures,adapted for the processing operations undertaken by the Company, to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
- In addition, we limit access to your personal data to authorised personnel who have a business need to know. They will only process your personal data on our strict instructions.
- We have put in place procedures to deal with any suspected data security breach and will notify you and the Supervisory Authority of a suspected breach where we are legally required to do so.
8. Transfers to third countries
- We have taken steps to ensure that appropriate safeguards are in place, which may include standard contractual clauses as established by the European Commission, to ensure that upon transfer your data is safeguarded as is necessary.
- We have also taken steps to ensure that the Personal Information transferred is not further transferred to another third country without our prior authorisation and that your rights and freedoms are still safeguarded.
- We take the security of your Personal Data seriously. We have in place appropriate measures, controls and internal policies to protect your Personal Data against loss, misuse and unauthorised access, alteration, disclosure, or destruction. Moreover, all efforts are taken to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and Services processing Personal Data. This includes requiring service providers to use appropriate measures to protect the confidentiality and security of your Personal Data.
- If we learn of a Personal Data breach, we will inform you of the occurrence of the breach in accordance with applicable Laws.
10. Contacting us
- You can contact us at [email protected]
- If at any time you believe that we have not adhered to this Privacy Notice, please contact our Customer Services team and we will seek to promptly determine and correct the problem if applicable.
11. Changes to this Privacy Notice
- We reserve the right to update this Privacy Notice at any time and will provide you with a new privacy notice when we make any substantial updates. We will also notify you in other ways from time to time about the processing of your personal data.