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PRIVACY POLICY

Introduction

At ZD Academy, we are committed to ensure confidentiality, accuracy and security of your
personal information that we collect as part of our day-to-day business. Henceforth we have
issued this Privacy Policy (“the Policy”) to explain how we handle, process and use Personal
Information about you as our Client.
All references in this Policy to ZD Academy being a trade name of Zampa Debattista under
which we operate, “ZD Academy” “we”, “us”,“our” and like terms should be interpreted
accordingly.
Similarily, an reference to “you”, “your”, “yours” or “yourself” in this Privacy Policy is a
reference to our customers and potential customers as the context requires unless otherwise
stated.
This Policy is being implemented in accordance to the terms of the Data Protection Act (Cap.
440 of the Laws of Malta) and the General Data Protection Regulation (Regulation (EU)
2016/679), the most recent Regulation implemented within the European Union to regulate
data protection in order to guide on the activities of Zampa Debattista.
This Policy governs your personal information which is processed as part of your relationship
with us and, its collection which shall include legal and regulatory compliance, personnel,
security and operations management. It is important to us that you understand how we
handle your personal information.
This Policy may be updated from time to time to reflect the current legal obligations and
practices laid down by ZD Academy. You will be notified with any changes to this Policy and
where explicit consent is necessary, we will obtain such consent directly from you.

Who Are We?

This Privacy Policy applies to the activities undertaken by Zampa Debattista of 230, 2nd
Floor, Eucharistic Congress Road, Mosta Malta.

What is Personal Data?

Personal data refers to any information relating to an identified or identifiable natural person,
whom the latter can be identified, directly or indirectly, in particular by reference to an
identifier. This personal information may be processed – such processing refers to any
operation which is performed on personal data such as collection, recording, organisation,
structuring and storage.

Which Personal Data do we collect?

To conduct our business we collect personal data of our Clients. Most of the information that
we process is information that we are able to obtain about yourself, based on information
you provide to us or, from our interactions with you, or other personal data about yourself
that we receive from a third party with your knowledge.
In the process of collection of data, you should be aware that there may be instances in
which the personal information provided by yourself to us is considered as “Sensitive Data”

which may include among others, personal information for the determination of the
individual’s racial or ethnic origin, political opinions, religious beliefs, physical or mental
health or judicial data.
With respect to our Clients we may collect the following information:

 – Name
 – Gender
 – Maritial status
 – Identification Number
 – Location
 – Banking and other financial data
 – Date of Birth
 – Mainiling address
 – Email address
 – Cookies and similar technologies
 – Any other similar information

Procedure for the collection of Client Personal Data

Your personal information may be collected or accessed in a number of ways including:
1. Directly from yourself (whether directly or verbally)
2. Generated by us in correspondence etc.
3. Received by third parties in relation to the services provided by ourselves
following your permission, which may be obtained directly from you or indirectly
through your actions. In such instances, we will make sure that such third parties
are entitled to disclose such information to us.

We may also obtain personal information about you through the use of our website
(http://www.zampadebattista.com) or through the use of cookies on our website.

Processing for Personal Data

We will process personal data fairly and lawfully, and only to the extent necessary as may be
allowed in terms of law. When processing your personal data, we will make sure that the
processing shall be lawful only if and to the extent that at least one of the following applies:
1. You have given your clear affirmative consent, signifying agreement to the
processing of your personal data for one or more specific purposes
2. Processing is necessary for compliance with a legal obligation to which we are
subject;
3. Processing is necessary in order to protect your vital interests or another person;
4. Processing is necessary for the purposes of our legitimate interests or of a third
party except where such interests are overridden by your interests or
fundamental rights and freedoms which require protection of your personal data.

Restriction of Processing

We recognise your right to restrict the processing of personal data where one of the
following applies:

1. You contest the accuracy of the personal data for a period, enabling you to verify
the accuracy of the personal data or;
2. The processing is unlawful, and you oppose the erasure of the personal data and
request the restriction of personal data instead or;
3. We no longer need the personal data for the purposes of processing or;
4. You have objected to processing pending the verification whether our legitimate
grounds override yours;

Your Consent

When your consent is required for the collection, processing and disclosure of personal
data, we will ensure that such consent is freely given and is unambiguous.
Furthermore, subject to legal or contractual restrictions, you may withdraw your consent
to the processing of your personal data.
Any communications with respect to such withdrawal or variation of consent shall be in
writing and addressed at

Accuracy, Access and Rectification of Your Personal Data

We will employ reasonable means to keep your personal data accurate, complete and up to
date for its intended use, however you must immediately inform us if and when your
personal data changes.
In so far as your data in concerned, you shall have the right to to receive confirmation that
your data is being processed and may request access to your personal data. You may
further request a copy of the personal information obtained by ourselves – such request may
be made verbally or by electronic means. We will provide a copy of such in a commonly
used electronic form.
Provided however, your right to access to personal information that we hold about you is not
absolute. Where applicable law or regulatory requirements allow us to refuse to provide such
personal information, or where the request for access is manifestly unfounded or excessive,
we shall reserve our right not to respond, or charge a reasonable fee, taking into account the
administrative costs of providing the information.
In those circumstances where it is impossible to provide you with access to your personal
data, we will provide reasons as to why this is not possible, subject to any legal or regulatory
restrictions.
As our Client, you may review your personal data which we hold on yourself in order for you
to be able to verify the lawfulness of the processing carried out by ourselves. When you
become aware of any inaccurate or incompleteness in their personal data, you are to inform
the ZD Academy for rectification. Where it results that there is inaccurate information, we will
amend such data with the alternative text that you believe that it is accurate. Furthermore,
we shall take all the necessary steps to inform any relevant third parties which hold the
inaccurate information to rectify accordingly.

Your Right of Erasure

Unless we are obliged by law to retain your personal data, you may ask to have your data
concerning you to be erased and on such demand, we will take all the necessary measures
in order to erase all personal information concerning you without undue delay.

Disclosure of Your Personal Data

Your personal data may be shared with our employees, agents and other third parties which
may require such information in order to be able to assist us in handling the relationship
which we have with you. We may further obtain such technological information to assist us in
our day to day business operations.
When we share your personal information with such third parties, we make sure that such
parties make use of this data in a manner which ensures safety and security to your
personal data.

Protection of Your Personal Data

We will use appropriate administrative, technical and physical measures to safeguard your
personal data against loss, misuse, theft, modification, disclosure or destruction. We will
restrict access to your Personal Data under our control to our employees and agents of ZD
Academy who possess legitimate business needs for such access.

How do We Store Personal Data and For How Long is Your Personal Data Retained?

Safeguarding the privacy of your personal data is of utmost importance to us and henceforth,
all necessary technical and organizational measures will be taken in securing that your
personal data is stored safely and all precautions will be carried out to ensure that no
authorized or unlawful processing of personal data takes place.
We will retain your personal data for as long as we believe that such data is necessary to
fulfill the purposes for which the personal data was collected, except as otherwise allowed or
required by applicable laws and regulatory requirements. When we consider that such
personal data is no longer required, we will remove any details that will identify you or
destroy any records in relation to yourself.

Cookies

To improve our services, we sometimes collect already identified information from web
users. The information does not identify the individual however it provides us with useful
statistics which allows us to control, administer and improve our technological services.
Therefore, when visiting our website, we may collect the following information from your
browser:
– Your IP Address and/or domain name
– Your operating browser and platform
– Date, time and length of your visit
– Resources accessed

Kindly note that if no longer want your browser from accepting new cookies or disabling
cookies altogether, you may do this by changing your browser settings.

Direct Marketing

Zampa Debattista may use your personal information for the purpose of marketing its
services.
If you do not want to receive marketing material from us, you can contact us as detailed
below:
– For electronic communications, you can choose to click on the unsubscribe button in
the communication sent to you or;
– For hard copies of the communications, you can email us on
;
– Through our contact details on our Website

Complaints and Concerns

If you have any concerns with regards to our privacy methods and processes, you have the
right to contact us by telephone, in writing or by e-mail to make a complaint which will be
dealt within the shortest time possible.
In case you are not satisfied with our response, you may contact the Office of the
Information and Data Protection Officer. You can find the details about how to do this on the
IDPC website at https://idpc.org.mt/en/Pages/contact/complaints.aspx