Vallettasoft Limited (“we”, “our”, “us” or “Vallettasoft”) is committed to protecting the

the privacy of all users of our website vallettasoft.com, or mobile applicationsprivacy of all users of our website vallettasoft.com, or mobile applications (together, the “Sites”). Please read the following privacy policy that explains how we use and protect your information. We are the “data controller” of the information we process, unless otherwise stated.

1. Contact Details

If you have any queries or requests concerning this privacy policy or how we handle your data more generally, please get in touch with us using the following details.

• By contacting our general customer services team at: info@vallettasoft.com
• By contacting our Data Protection Officer: info@vallettasoft.com

2. How We Collect Your Information

We collect your personal information when you interact with us or use our services, such as when you use our Sites to place an order. We also look at how visitors use our Sites, to help us improve our services and optimise customer experience.

We collect information:

1. when you create an account with us or you change your account settings;
2. when you place an order with us and during the order process (including for payment and order delivery);
3. when you give us your consent to contact you via email, phone, post, message or via our chat function to send you marketing campaigns,
4. when you contact us directly via email, phone, post, message or via our chat function; and
5. when you browse and use our Sites (before and after you create an account with us).

3. Information We Collect From You

As part of our commitment to the privacy of our customers and visitors to our Sites more generally, we want to be clear about the sorts of information we will collect from you.

When you visit the Site or Mobile Apps, or make a Vallettasoft order through the Site or Mobile APPs, you are asked to provide information about yourself including your name, contact details, delivery address, order details and payment information such as credit or debit card information. We may also collect your date of birth to verify your age when you purchase age restricted items.

We also collect information about your usage of the Sites and information about you from any messages you post to the Sites or when you contact us or provide us with feedback, including via e-mail, letter, phone or chat function. If you contact us by phone, we record the call for training and service improvement purposes, and make notes in relation to your call.

We collect technical information from your mobile device or computer, such as its operating system, the device and connection type and the IP address from which you are accessing our Sites.

4. Use Of Your Information

We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law.

Where we need to in order to provide you with the service you have requested or to enter into a contract, we use your information:

• to enable us to provide you with access to the relevant parts of the Sites;
• to supply the services you have requested;
• to enable us to collect payment from you; and
• to contact you where necessary concerning our services, such as to resolve issues you may have with your order.

We also process your data where we have a legitimate interest for doing so— for example personalisation of our service, including processing data to make it easier and faster for you to place orders. We have listed these reasons below:

• to improve the effectiveness and quality of service that our customers can expect from us in the future;
• to enable our customer support team to help you with any enquiries or complaints in the most efficient way possible and to provide a positive customer experience;
• to contact you for your views and feedback on our services or our partners’ services and/or products and to notify you if there are any important changes or developments to the Sites or our services, including letting you know that our services are operating in a new area, where you have asked us to do so;
• to send you information by post about our products, services and promotions (if you do not want to receive these, you can let us know by getting in touch (see Contact Details https://vallettasoft.com/contact/ ));
• to analyse your activity on the Sites so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us to prevent fraud;

We also process your data to enforce our contractual terms with you and any other agreement, and for the exercise or defence of legal claims and to protect the rights of Vallettasoft , digital partners or others (including to prevent fraud);

If you submit comments and feedback regarding the Sites and the services, we may use such comments and feedback on the Sites and in any marketing or advertising materials. We will only identify you for this purpose by your first name and the city in which you live.We may send push notifications to you through our mobile application, we may send you push notifications relating to the services about our services and offers. If you want to stop receiving push notifications from us at any time, you can send an email to us (see info@vallettasoft.com or contact page on our website: vallettasoft.com).

We will also analyse data about your use of our services from your location data to create profiles relating to you and for you. This means that we may make certain assumptions about what you may be interested in and use this, for example, to send you more tailored marketing communications, to present you with digital partners or others that we think you will prefer, or to let you know about special offers or products which we think you may be interested in (including Vallettasoft for Business). This activity is referred to as profiling. You have certain rights in relation to this type of processing. Please see ‘Your Rights’ section below for more information.

5. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy https://vallettasoft.com/cookies

6. Retention Of Your Information

We will not retain your information for any longer than we think is necessary.

Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the ‘Use of my information’ section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes.

When determining the relevant retention periods, we will take into account factors including:

• our contractual obligations and rights in relation to the information involved;
• legal obligation(s) under applicable law to retain data for a certain period of time;
• statute of limitations under applicable law(s);
• our legitimate interests where we have carried out balancing tests (see section on ‘How we use your personal information’ above);
• (potential) disputes; and
• guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information where we no longer require your information for the purposes collected.

7. Disclosure Of Your Information

The information we collect about you will be transferred to and stored on our servers located within the EU. We are very careful and transparent about who else your information is shared with.

We share your information with other Vallettasoft group companies only where necessary for the purposes set out in section 4. We share your information with third party service providers which provide services on our behalf. The types of third party service providers whom we share your information with include for example:

• Payment providers (including online payment providers and fraud detection providers);
• IT service providers (including cloud providers);
• Digital partners or others
• Customer support partners; and
• Marketing and advertising partners.

Vallettasoft will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy when it is transferred to third parties.

If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.

We may also share your information:

• if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention;
• in order to enforce our contractual terms with you and any other agreement;
• to protect the rights of Vallettasoft , digital partners, riders, or others, including to prevent fraud; and
• with such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police or for health and safety purposes.

International transfers of data:

• We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. your personal data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
2. we use the EU approved Standard Contractual Clauses; and
3. where your personal data is transferred to third party providers based in the US, data may be transferred to them if they have self-certified under the Privacy Shield framework in relation to the type of data being transferred, which requires them to provide similar protection to personal data shared between the EU and the US.

Please contact us using the contact details above if you want further information on the countries to which personal data may be transferred and the specific mechanism used by us when transferring your personal data out of the EEA.

8. Security

We adopt robust technologies and policies to ensure the personal information we hold about you is suitably protected.

We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.

Where you have chosen a password that allows you to access certain parts of the Sites, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9. Your Rights

Subject to applicable law, you may have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact our Data Protection Officer using the contact details set out above. For additional information on your rights please contact your data protection authority and see below.

10. Changes To Our Privacy Policy

Any changes to our privacy policy will be posted to the Sites and, where appropriate, we may notify you of the changes for example by email or push notification.

This privacy policy was last updated: 01/07/2021

11. Complaints

If you have any questions or comments regarding this Privacy Notice, please contact us by sending an email.

Website: https://vallettasoft.com/contact

Triq L-Imghazel, IVY Mansion FL 16, Swieqi, 1024 Malta