Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We are Astra Consulting Malta Ltd. We are a company incorporated and registered in Malta. Our company registration number C50423 and VAT Number MT20103803. Our registered address is at 5 Majestic Court, Triq Santa Marija, Mellieħa, MLH 1337, Malta.
When we refer to "we", "us" or "our" in this policy, we are referring to Astra Consulting Malta Ltd. We are the 'controller' in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed and are responsible for it.
Questions, comments and requests regarding this policy are welcomed. You may either use our contact form to get in touch with us or you may write to our Data Privacy Manager at:
You should be aware that our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave one of our websites, we encourage you to read the privacy notice of every website you visit.
We use different methods to collect data from and about you including through:
You may give us your personal data by filling in forms on our websites or by corresponding with us in person, by email, by phone, by post or otherwise. This includes personal data you provide when requesting services or marketing communications from us.
Automated technologies or interactions
As you interact with our websites, we may automatically collect information about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies for further information.
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources. This includes, for example, information received from analytics providers such as Google.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time
Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect and process the following different kinds of personal data about you:
includes first name, last name, job title, company name
includes email address, postal and/or billing address, telephone number
includes information submitted through the contact us forms on our websites and details of any correspondence between you and us
Client account data:
includes correspondence data, business discussions, contract history
bank account details, payment card details
includes your preferences in receiving marketing from us and your communication preferences
includes demographic information such as your postcode
includes internet protocol (IP) address
If you want any further information about how we might collect or use your personal data, please contact us.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing
To respond to any query you make via our websites
Identity, contact and correspondence data
Necessary for our legitimate interests – in running our business
To manage our relationship with you which includes:
Identity, contact and client account data
Necessary in order to perform our contract with you.
To comply with our legal obligations.
Necessary for our legitimate interests – to run our business and keep our records accurate
To provide our services to you
Identity, contact, client account and financial data
Necessary in order to perform our contract with you.
To comply with our legal obligations.
Necessary for our legitimate interest – to run our business
To send you promotional or marketing materials and contact you about informative and/or commercial content (e.g. new features and services, special offers or updated information)
Identity, contact and marketing data
Necessary for our legitimate interest - in developing and growing our business and client base
To contact you to ask you to complete surveys or for other market research purposes
Identity, contact, demographic and marketing data
Necessary for our legitimate interest - in developing and growing our business
Necessary for our legitimate interests – to operate our websites and to improve client interactions and user experience
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal information for the purposes set out above with the following third parties:
including those who provide:
including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
including HMRC, regulators and other authorities who require reporting of processing activities in certain circumstances. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
includes third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
The table below provides detailed information on the service providers we use in the EU and the safeguards in place.
Description of the service
Please contact us if you want more information.
Some of our external third parties may, from time to time, be based outside the European Union (EU) so their processing of your personal data will involve a transfer of data outside the EU.
If we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
The table below sets out details of the service providers we use outside of the EU and the relevant safeguards in place.
Description of service
Application analysis services
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures in accordance with industry best practice to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology and using trusted third parties. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In all cases, our retention period will never be more than 10 years from when we collected the applicable data. When this term expires, your personal data will be deleted in such a way that it cannot be stored.
Below we set out the key retention periods. Further details can be obtained by contacting us.
How long will you keep my data?
10 years after the payment transaction
3 years after your last visit to one of our websites
This data is typically collected automatically when you use our website and anonymised shortly afterwards
Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under the data protection laws in relation to your personal data. Please read through the table below to find out more about these rights.
What this means
Access to your information
You have the right to ask for a copy of the information which we hold on you (commonly known as a 'data subject access request'). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Correcting personal data
You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us.
It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.
Deleting personal data
You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the 'right to be forgotten'. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Objecting to processing
You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us.
You may also object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Restriction of processing
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Transferring your personal data
In certain circumstances, you may request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.
Review by an independent authority
You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner's Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance if possible.
If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
This version was last updated on 7th October 2019.