Privacy Policy



Introduction

This privacy policy (hereinafter referred to as the “Policy”) sets out information about how the Ministry for Environment, Energy and Enterprise (h ereinafter referred to as the “Ministry”, “We” or “Our”) processes and uses Personal Data pertaining to individuals who apply for the Qatra Qatra game competition. We are firmly committed to respecting individual’s’ privacy and confidentiality of their Personal Data. In fact, we shall not collect any personal information about you unless you provide it voluntarily.

All Personal Data shall be processed in accordance with the Data Protection Act (Chapter 586 of the Laws of Malta) (hereinafter referred to as the “Act”) and subsidiary legislations thereunder and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the "General Data Protection Regulation" or "GDPR").


Key Definitions

"Applicant“ refers to any individual who opts to apply for the Competition, including the parent /guardian and the minor.

"Application" or "App" refers to the Water conservation game app, Qatra Qatra, which App has as its primary objective the raising of awareness on water conservation.

"Competition“ refers to the competition in relation to the App, as further described in the Competition Terms and Conditions.

"Controller" or "Data Controller" means any natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

"Data subject" refers to any living person (natural person) whose Personal Data is being collected, held or processed.

"Minors" refers to natural persons below the age of eighteen (18) years.

"Personal Data" or "Personal Information" means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processor" or "Data Processor" means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.

"Processing" means any operation/s which is/are performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.


The Controller of Personal Data

The Data Controller responsible for the Processing of Personal Data of Data Subjects for the purposes outlined in this Policy is the Ministry for Environment, Energy and Enterprise located at Barriera Wharf, Valletta Malta.


What Personal Data we collect

Personal Data shall be collected solely from those individuals who opt to apply for the Competition. Registration shall be carried out by filling out the registration forms which can be found here. The Qatra Qatra Competition Terms and Conditions and Privacy Policy can be found here. The personal data that is processed for this purpose is the following:

Upon registration, the App shall automatically create a nick name (using the first two (2) characters of the name, first two (2) characters of the surname and three (3) random numbers). This nickname shall be shown on the scoreboard which will be publicly available on social media. The nickname is created to limit possible identification of the users since the game is targeted for minors falling within the 8- to 10-year-old bracket.


Collection of Personal Data of Minors

In the event that We become aware of any Personal Data collected from a Minor without parental consent, the necessary steps will be taken to ensure that the said Personal Data is removed expeditiously and efficiently. Should the public be aware or believe that We may be holding any Personal Data collected with regards to a Minor without obtaining prior consent of the parents or legal guardian/s, kindly inform us as soon as possible by sending an email on dpo.meee@gov.mt.


How we collect your Personal Data

Your Personal Data will be collected in the process of submission of a registration form to apply for the Competition, as per previous section “What Personal Data we collect”.


Legal bases for Processing your Personal Data

The following are the legal bases for Processing Personal Data in relation to the Competition:

The legal basis relied upon shall be Article 6(1)(a) of the GDPR, since upon registration holders of parental authority (with respect to 8-10 year old) of the minor will be providing his/her consent to the processing of Personal Data to apply for the Competition.


What We do with your Personal Data

There may be instances where We have to share your Personal Data with various categories of persons. We may disclose your personal data with our employees, officers and professional advisors. Your Personal Data may be shared with other government departments, agencies and public bodies. It may also be shared with Our technology suppliers, for example Our hosting provider. However, We shall not:

When We share your Personal Data with third parties, We make sure that such parties process this Personal Data in a safe and secure manner.

We will also share your data if we are required to do so by law.

Personal data shall not be transferred to third parties located outside the EU or European Economic Area (EEA) unless specifically instructed to do so in writing by the Data Subject or mandated by provision of law or ordered by a duly empowered competent body.

This privacy notice does not cover the links within this site linking to other websites which are not controlled by us. We are not responsible for the collection or use of your personal information from these third-party websites. Therefore, we encourage you to read the privacy statements on the other websites you visit.


Your Rights

The rights afforded to yourself in connection to your Personal Data are the following:

  1. The Right to Access Personal Data – the Data Subject may send Us a request to access all Personal Data that the Ministry holds in his/her respect. To avail of this right, kindly send an e-mail to dpo.meee@gov.mt. We will do Our best to attend to the Data Subject’s request within one (1) month. In case of more complex requests, the timeframe will be extended by a further one (1) month. Should the Data Subject disagree with Our judgement, s/he can complain to the Information and Data Protection Commissioner (hereinafter referred to as the "IDPC") on https://register.idpc.org.mt/report-breach/complaint/  
  2. The Right to Rectification – the Data Subject’s right to request that any inaccurate or incomplete Personal Data held by the Ministry is corrected accordingly. In such instances, kindly send an e-mail to dpo.meee@gov.mt;
  3. The Right to Erasure ("Right to be Forgotten") – the Data Subject’s right to request that his/her Personal Data is deleted. On a general note, we will comply with the Data Subject’s request in this regard. However, we may have the necessity not to comply with the request if retention of the data is required for us to be compliant with a legal obligation and/or such data would be required by Us to exercise or defend any legal claims.
  4. The Right to be Informed – the Data Subject has the right to be given clear information regarding how his/her Personal Data is processed. We do this by means of this Policy which will be duly revised from time to time and by means of any future communications directly with the Data Subject on a case-by-case basis.
  5. Right to Object – the Data Subject may object regarding his/her Personal Data being processed including when such Processing is based on legitimate interest and the right to object to his/her Personal Data being processed for direct marketing purposes;
  6. Right to Data Portability – the Data Subject has the right to put forward a request asking Us to provide him/her with certain personal data which s/he had provided the Ministry in a structured, commonly used and machine-readable format. When technically feasible, the Data Subject may also request that his/her Personal Data be transferred to a third-party controller of his/her choice;
  7. The Right to Withdraw Consent - the Data Subject can also withdraw any consent given at any time; and
  8. The Right to Lodge a Complaint - the Data Subject has the right to lodge a complaint against any Personal Data breach by communicating such breach to the IDPC. The IDPC may be notified by filling in the complaint form available at https://register.idpc.org.mt/report-breach/complaint/

How long we keep your data

The Controller shall only retain the Personal Data until the Competition is concluded. The Personal Data shall be automatically deleted from the server once the Competition is concluded. Should the user delete his/her profile, they will no longer be eligible for participation in any competitions related to Qatra Qatra.


Cookies

Cookies are small pieces of data that the site transfers to the user’s computer hard drive when the user visits the website. We hereby confirm that this App does not make use of cookies.


Security

We are committed to doing all that we can to keep your data secure. We undertake to put in Our best efforts to keep any disclosed Personal Information secure by implementing the appropriate technical and organizational measures with the aim of protecting such Personal Data. For example, we protect your data using encryption. We also make sure that any third parties that We deal with keep all personal data they process on our behalf secure by entering into Data Processing Agreement setting out the standards that such parties must adhere to whilst processing Personal Data.

Notwithstanding Our efforts to protect Personal Data, no system can guarantee that Personal Data will not be compromised at any point.


Accuracy of information

The Ministry undertakes to hold accurate and where necessary up-to-date Personal Data. In view of this, Data Subjects are asked to keep Us informed of any changes that might occur to Personal Data throughout the previously stipulated data retention timeframes.


Changes

We may update the Policy from time to time in order to reflect changes to Our practices or for other operational, legal or regulatory reasons.


Complaints and concerns

If you have any concerns with regards to Our privacy methods and processes, please contact Our Data Protection Officer by email on dpo.meee@gov.mt.

In case you are not satisfied with Our response, you may contact the Information and Data Protection Commissioner of Level 2, Airways House, High Street, Sliema SLM 1549 or by visiting their website at https://idpc.org.mt.


Your Rights

Click here to delete account.



Last Updated: 15th September 2023