1. General
1.1. Organization is committed to maintaining the privacy and security of the Personal Data of all persons who have submitted their personal details to this website www.comskill.com (hereinafter Website). As part of that commitment, we have implemented this Privacy Policy to reflect what information we collect, why we collect it, where it goes, as well as to satisfy regulatory requirements. Personal Data comprise any information about you that identifies you or by which your identity can be reasonably determined. For the purposes of the EU General Data Protection Regulation, the Controller is Evora International Limited, Maltese company with registration number C 53225.
1.2. Furthermore, Evora International Limited as “Evora International” or “we”.
1.3. Furthermore, Client or “you”.
2. Personal data controller
2.1. For the purpose of processing of personal data, the Personal Data controller is:
Evora International Limited
Registry code: C 53225
Address: 120, The Strand, Unit 6, Triq ix-Xatt, Gzira GZR1027, Malta
E-mail: [email protected]
If you have any questions regarding the processing of Your Personal Data, please contact us by using the e-mail address mentioned above.
3. How do we collect personal data?
- As part of our Client engagement procedures;
- When We provide services to You;
- When you post a query, complaint or observation through our Website;
- When you contact us voluntarily in other circumstances.
4. The personal data Evora International collects and processes
There are various categories of Personal Data that We collect about You, namely:
CONTACT DETAILS:
- Name, surname
- Company name
- Email address
MARKETING DATA:
- Name, surname
- Company name
- Email address
- Proof of opt-in consent (where needed)
- Objections to marketing
- Website data
- Online identifiers (including IP addresses and information generated via Your browser)
FINANCIAL INFORMATION:
- Bank account details
- Credit card information
CASE DATA
- Contact Details
- Financial Information
- Due Diligence Data
- Other personal data relating to Your specific case
5. The basis and aim of the processing of Your personal data
5.1. The basis and aim of the processing of Your Personal Data is based on:
5.1.1. compliance with legal requirements – we have to process Your Personal Data in accordance with applicable law and it is not a matter of choice by you or us whether to obey the compliance with laws;
5.1.2. execution of mutual agreement – agreements, general rules, individual provisions, etc, which are respective to you and us and to which you have agreed upon;
5.1.3. Our legitimate interests;
5.1.4. Your consent, in which case, Our processing shall be limited to the purposes specifically indicated when your consent was requested.
| Purpose of processing | Legal basis | Categories |
|---|---|---|
| Customization of the content of communication information via email | Consent, the execution of an Agreement | Marketing data |
| Improvement and development of the Website and the Service | Legitime interest or Your consent | Contact details |
| Client service and communication | Legitime interest | Contact details and Marketing data |
| Analysis of statistic | Legitime interest | Contact details |
| Ensuring the safety of the Service by detecting and preventing the use of interfering software, devices, techniques, etc | Legitime interest | All data |
| Erasure of Your personal data | Laws | All data |
We may process Your Personal Data for other purposes provided and before the processing of the data we disclose the purposes and use to you, and in a case where your consent is needed, except if the new purpose essentially is identical to a pre-existing purpose.
6. Personal data retention period
6.1. Your Personal Data shall be stored insofar as reasonably necessary to attain the purposes stated in this Policy, or until the applicable law stipulates that we do so. For example:
– Contact details – after terminating the agreement, except the particular content of the communication, that is stored for 3 years;
– All other data – 5 years from the day when they are received.
6.2. The retention period may be extended if necessary after a decision of Evora International in order to comply with our legal requirements, resolve disputes and enforce the agreement or to anonymize Your Personal Data and retain this anonymized information indefinitely.
7. Your rights
7.1. At any given moment You may exercise the following rights with respect to our processing of Your Personal Data by contacting us.
| Rights | Explanation |
|---|---|
| To access | You have the right to request access to any data that can be considered Your Personal Data. This includes the right to be informed on whether we process Your Personal Data, what Personal Data categories are being processed by us, and the purpose of our data processing |
| To rectificate | You have the right to request that we correct any of Your Personal Data if it is inaccurate or incomplete |
| To object | You are entitled to object to certain processing of Your Personal Data, including for example, when we otherwise base the processing of Your Personal Data on our legitimate interest |
| To restrict Personal Data processing | You have the right to request that we restrict the processing of Your Personal Data if you wish to: (i) object the lawfulness of the processing; (ii) fix unlawful processing of Your Personal Data; (iii) receive or avoid deletion of Your Personal Data for establishing or defending against legal claims; or (iv) demand restriction of the processing until assessing the plausibility of Evora International’s legitimate interest in the specific processing activity |
| To erasure | You may also request Your Personal Data to be erased if Your Personal Data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful, or if you consider that Your Personal Data must be erased to enable us to comply with a legal requirement |
| Data portability | If Your Personal Data is being automatically processed with your consent or on the basis of a mutual contractual relationship, you may request that we provide you you’re your Personal Data in a structured, commonly used and machine-readable format. Moreover, you may request that Your Personal Data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible |
| To withdraw your consent | In cases where the processing is based on Your consent, you have the right to withdraw your consent to such processing at any time |
| To submit your claim with the supervisory authority | If you are not satisfied with our response to your request in relation to Your Personal Data or you believe we are processing Your Personal Data not in accordance with the law, you can submit your claim with the appropriate Data Protection Supervisory Authority. The competent authority in Malta is the Office of the Information and Data Protection Commissioner (OIDPC) |
8. Sharing your personal data and data transfers
8.1. Evora International discloses Your Personal Data to third parties only in accordance with this Policy, internal data processing and to persons authorized to process Personal Data, who have undertaken to observe confidentiality or are subject to appropriate statutory confidentiality according to applicable laws or if you have given consent to such disclosure. Evora International may disclose Your Personal Data to the following recipients (including data processors) in its data processing activities:
| Type of the recipient | Purpose of disclosure | Location of the recipient |
|---|---|---|
| Identification and authentication service providers | Providing identification and authentication services to provide you access to the Service; and deter and detect fraud | European Union |
| Payment service providers (including payment institutions, e.g. banks) and other money transfer service providers | Transfer of funds from a payment service to your online Service account and transfer of the winning amount payment to your account | European Union |
| Law enforcement and data protection authorities | Execution of a legitimate legal request if the request has been submitted by a competent national authority | European Union |
| Operational service providers (legal advisors, accounting etc. bound to confidentiality) | Legitimate interests in ensuring Evora International’s economic activity; conducting of regular business activities | European Union |
| IT-services providers | Providing IT solutions necessary for operating the economic activity of Evora International or Service | European Union |
| Third party service providers | Certain services related to Service enhancements or user-friendliness enhancements | European Union |
| ENLABS AB group | For the purposes utilizing the shared administrative infrastructure and business development purposes | European Union |
8.2. Evora International does not transfer Your Personal Data outside European Union or European Economic Area, however Evora International reserves the right to transfer the Data outside European Union or European Economic Area in certain cases. We may transfer Your Personal Data outside the European Union or European Economic Area, if the respective operational services are provided outside the European Union or European Economic Area. We shall opt to use special Personal Data protection safeguards, in order to ensure the safety of Your Personal Data. You have the right to get acquainted with or obtain information on the transferring of Your Personal Data outside the European Union or European Economic Area and the safeguards implied thereof by contacting us using the contact information specified in this Policy.
9. Amendments to this Policy
This Policy may be amended from time to time to reflect changes in the way we process Your Personal Data and, in such case, the most recent version of the Policy will appear on this page. If you do not agree to any of the changes you have made, you may immediately withdraw your consent and discontinue using our Services or contact us. Please check back periodically, and especially before you provide any new personally identifiable information.