Privacy Policy

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Last updated: 17 January 2023.

This website is operated by Executive Gaming and Risk Advisory Ltd. (EGARA/we/us/our) and any matters concerning the collection and/or use of your personal data when visiting or providing information through the website www.egara.co and any associated sites or pages (together, the Website) are governed by this Privacy Policy. Therefore, please read this Privacy Policy carefully and ensure that you understand and agree to our practices before providing any of your personal data or other information to us.

This Privacy Policy contains information about:

1. The personal data we collect and how we collect it
2. How we use your personal data
3. How we share your personal data
4. Storing and securing your personal data
5. Your rights
6. International data transfers
7. Use of cookies
8. Privacy policies of other websites
9. Changes to this Privacy Policy
10. Contact information

1. What data do we collect and how do we collect it?

Personal data is information that can be used to contact or identify you, such as your name, email address, phone number, etc.

We collect and process the following personal data and information:

• Information that you provide to us directly when you contact us via our “Contact Us” form or when subscribing to our newsletter. This will include your email address and any information you decide to share with us.
• Information that you provide to us when applying for one of our open positions. This will include your first and last name, e-mail address, phone number, CV, etc.
• Information we obtain from social media platforms when you subscribe or otherwise interact with us through our corporate social media pages/EGARA posts (e.g. on LinkedIn). When doing so, you are agreeing to the social media platform provider’s privacy statement, which may include sharing your name, profile, photos, reactions and comments to our posts, etc. with us. The social media platform provider’s privacy statement applies to your interactions and their collection, use and processing of your personal data. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
• Information collected by automated means from your browser and device through cookies and other tracking technologies. With your permission where such is required by applicable laws, we and/or relevant business partners may automatically log information about you, your browser, your computer or mobile device, and your activity on the Website. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, the website you visited before browsing to our Website, general location information such as city, state or geographic area; and information about your use of and actions on the Website, such as pages you viewed, access times, how long you spent on a certain page, navigation paths between pages, or information about your activity on a page. 

2. How we use your information

In line with data protection laws, we will only process personal data where we have a legal basis to do so. 

The relevant legal bases for us using your information are: 

• where you provide your consent (consent); 
• where it is necessary to provide services to you under the performance of a contract (contractual necessity); 
• where it is in our legitimate interests to process your information, provided that these interests do not prejudice your own rights, freedoms and interests (legitimate interest); and
• where we are obliged by law to process your personal data (legal obligation).

Against this background, we may use your information in the following ways:

• to manage our relationship with you including to respond to your request/inquiry or otherwise communicate with you (consent/legitimate interest/contractual necessity/legal obligation) to enter into and manage a business and/or contractual relationship with you, including the provision of estimates and/or quotes and to invoice for our services (contractual necessity) and/or to provide you with information about our company and our services (legitimate interest);
• to process your job application (contractual necessity);
• to verify your identity for due diligence and/or security purposes (contractual necessity/legal obligation);
• to provide our services to you (contractual necessity);
• to notify you about changes or additions to our services (contractual necessity);
• sending you newsletters and updates regarding our services (consent);
• for internal business purposes such as to ensure proper functioning of our Website and to carry out related statistical analysis on the use of the Website and checks to prevent fraudulent or other inappropriate activities to maintain content integrity on our Website (legitimate interest);
• to generate data analytics to enable us to improve our Website for you and/or deliver relevant Website content to you (consent); and
• to comply with legal obligations that apply to us including but not limited to disclosing your personal data to courts, law enforcement or regulatory authorities (legal obligation).

On occasion, we may further ask for your consent for using your information in other ways/for other purposes. The legal basis for any such use of your information will then be consent, provided that you give your consent.

3. How we share your information

We keep your information confidential and will only share your information with third parties (such as business partners/service providers, government agencies, regulators and professional advisors) where it is necessary, namely when required to do so, which will be with your consent/at your instruction (consent), if this is necessary to provide our services (contractual obligation) or to comply with a legal obligation (legal obligation). Yet, we will only ever share the information that is necessary to share for the respective purpose. 

4. Storing and securing your information

EGARA secures your personal information from unauthorized access, use or disclosure and we will do our best to protect your information. We maintain appropriate administrative, technical and physical safeguards to protect personal data against accidental or unlawful destruction, accidental loss, alternation, unauthorised disclosure or access, use and all other unlawful forms of processing of the personal data in our possession. Unfortunately, the transmission of information via the internet is, by its very nature, not completely secure. We therefore cannot guarantee the security of the information that you provide to us and any transmission of information is ultimately at your own risk. In terms of duration, we will keep your personal data only for as long as necessary to fulfil the purposes for which it was collected. This typically will be for the duration in which we provide services to you but we may store your information after we have stopped providing you our services should it be necessary to meet regulatory requirements, support or defend a legal claim or to otherwise comply with data protection laws. When we no longer require the personal data, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. If we fully anonymize your personal data (so that it can no longer be associated with you), we may use this information indefinitely.

5. Your rights

You have the following data protection rights in respect of your personal data:

The right of access – you have the right to request copies of the information we hold about you.

The right to rectification – if the personal data we hold about you is inaccurate or incomplete, you have the right to request that your information be corrected/completed.

The right to erasure – you have the right to request deletion or removal of your personal data where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing, where we may have processed your data 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 of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request;

The right to restrict processing – you have the right to request that we suspend the processing of your personal data if you want us to establish the data's accuracy, where our use of the data is unlawful but you do not want us to erase it, where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

The right to object to processing – you have the right to object to us processing your information where we are relying on a legitimate interest (or those of a third party) and you feel that the processing impacts on your fundamental rights and freedoms;

The right to data portability – you have the right to request that we transfer the information that we have collected to another organisation, or directly to you, in certain circumstances. Please note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you; and

Right to withdraw consent at any time – where we are relying on consent to process your personal data, you may request to withdraw consent at any time. Please note, however, that this will not affect the lawfulness of any processing carried out before you withdrew your consent. 

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the personal data or where certain exemptions apply.

To exercise any of these rights or to voice any concerns, please contact us using the contact details provided below.

Although we kindly ask you to contact us first to find a solution for any concern you may have, please be aware that you always have the right to lodge a complaint with the competent data protection authority in the country you reside.

6. International data transfers

Should we ever need to transfer your personal data outside of the European Union, please note that we will take reasonable steps to ensure that appropriate security measures are taken to ensure that your privacy rights are protected adequately as shown in this Privacy Policy. By using this website and providing information to us, you are agreeing to related transfers, storing and processing of your information. 

7. Use of cookies

Cookies are text files placed on your computer or device to collect standard internet log information and visitor behaviour information. When you visit our Website, we may collect information from you automatically through cookies or similar technology. You do not need to allow most cookies to visit the Website. However, enabling certain cookies may allow for a more tailored browsing experience and may be required for certain parts of the Website or services provided by third party business partners to work. In the majority of cases, a cookie does not provide us with any of your personal data.

The cookies that may be used on our Website can be distinguished as follows:

• Strictly necessary cookies: These do not require your consent but are necessary for the Website to function. They cannot be switched off in our systems. You can set your browser to block or alert you about these cookies, but some parts of the site may then not work. 
• Other cookies (functional, performance/analytics, targeting): These require your consent and are only necessary for us and/or third party business partners (Google/LinkedIn - please refer to their respective privacy policies for details) to provide you with enhanced and personalised functionalities and/or targeted advertising. Further details will be provided when we ask for your consent regarding these cookies, as will details on how to opt-out of them after consent has been given.

8. Privacy policies of other websites

Our Website may contain links to other websites that are not operated or controlled by EGARA. Collection, processing and disclosure of personal data through such other websites falls outside the responsibility of EGARA and are not covered by this Privacy Policy. Instead, your usage and browsing on any such website are subject to that website's terms and privacy policies. We therefore recommend that you familiarize yourself with these.

9. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect any changes to our use of your personal data or as required to comply with changes in applicable law or regulatory requirements. Any changes shall become effective upon posting on this Website. To ensure that you are always aware of how we use your personal data, we recommend that you review this page regularly for the latest version of our Privacy Policy.

10. Contact Information

You may contact us at office@egara.co or by post at Executive Gaming and Risk Advisory Ltd., Level 5 St. Julian’s Business Centre Elia Zammit Street St. Julian’s, STJ 3153, Malta.