The Lavazza Competition

PRIVACY & COOKIE NOTICE

1.          ABOUT US

1.1       Introduction

This privacy and cookie notice (‘the Privacy Notice’) sets out the ways in which P. Cutajar & Co. Ltd (registered in Malta, Europe with Registration Number C 293) (hereinafter ‘the Company’) may use your personal data.

1.2     Our Contact Details

         You can contact us:

(a)        by post, using the postal address below:

Capital Business Centre, Triq Taz-Zwejt, Industrial Estate, San Gwann, Malta. 

(b)     by email, on info@pcutajar.com.mt

2.          ABOUT YOUR DATA

2.1     Data We Process

The personal data we collect/process in Your regard may be any of the following:

DATA CATEGORY	TYPE OF DATA	WHAT IT’S USED FOR	OUR LEGAL BASIS
Communications and Purchasing DataData provided to us when You upload a receipt.	Name, Surname, Mobile Number, Email, Outlet/Shop Name from which the Lavazza Products were purchased, Date, Receipt Number, details of Lavazza Products purchased including total value of the products.	To cross-check the information submitted against the uploaded receipt, and contact the winners accordingly.	Fulfilment of contract/ Legitimate interest
Tracking DataData about Your use of the Website	IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation paths, and information about the timing, frequency and pattern of Your use.	For functionality, for security purposes, to analyse the use of the Website and to personalise and optimize content available to You on https://winwithlavazza.mt/ (‘the Website).	Legitimate interest

2.2       Cookies & Other Tracking Mechanisms 

A cookie is a small file of letters and numbers that are stored on your browser or the hard drive of your computer and contain information that is transferred to your computer’s hard drive. We use cookies on the Website to improve it functionality, and to allow Us to better the site. When You continue to browse the Website, You are agreeing to our use of cookies.

Please note that You can block cookies at any time by activating the setting on Your browser that allows You to refuse the setting of all or some cookies. Keep in mind, however, that blocking all cookies, or even some of them, will have a negative impact on the usability and possibly the rendering of many websites, including ours. If You block cookies You will not be able to use all the features on the Website and might not be able to view it correctly or in the way it was originally intended to be displayed. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them visit: www.allaboutcookies.org.

We use cookies as follows:

NAME	FUNCTION	INFORMATION COLLECTED
Google Analytics	We use this cookie to be able to optimize our website designs, gain insight on popular features, identify usage trends, track the delivery of our promotional content and, more generally, to know our market better.  Google Privacy Policy: https://policies.google.com/privacy?hl=en	Geographic location, Product Interest, Gender, Age, Browser, Operating System, Website usage, Website spend
Facebook Pixel	We use this cookie to be able to optimize our website designs, gain insight on popular features, identify usage trends, track the delivery of our promotional content and, more generally, to know our market better, retarget adverts to you, track sales.  Facebook Privacy Policy:https://www.facebook.com/policy.php	Geographic location, Product Interest, Gender, Age, Browser, Operating System, Website usage, Website spend
Google Tag Manager	We use this cookie to be able to optimize our website designs, gain insight on popular features, identify usage trends, track the delivery of our promotional content and, more generally, to know our market better.  Google Privacy Policy: https://policies.google.com/privacy?hl=en	Geographic location, Product Interest, Gender, Age, Browser, Operating System, Website usage, Website spend
Google Ads	We use this cookie to be able to advertise to you, track our advertising, track return on ad spend, advertising effectiveness. Google Privacy Policy: https://policies.google.com/privacy?hl=en	Geographic location, Product Interest, Gender, Age, Browser, Operating System, Website usage, Website spend
MailChimp	We use this cookie to be able to track newsletter effectiveness, gain insight on email mailshot effectiveness, identify usage trends, track the delivery of our promotional content and, more generally, to know our market better, send abandoned cart emails, send you emails customized to your preferred products.   Mailchimp Privacy Policy: https://mailchimp.com/legal/privacy/	Geographic location, Product Interest, Gender, Age, Browser, Operating System, Website usage, Website spend

2.3       Retention of Data

We retain Your personal data no longer than strictly necessary i) to realize the purpose for which your personal data was originally collected ii) as required by a specific law to which we may be subject and iii) to manage any legal claims in relation to which such data may be required in evidence. Transactional records may be kept for up to 10 years from the performance of a contract for accounting and VAT record purposes. Should You need to know the complete list of the retention periods we adhere to with respect to the indicated categories of personal data, please contact us on privacy@pcutajar.com.mt. 

2.4       Who has Access to Your Data

P. Cutajar & Co. Ltd is a Malta-domiciled organisation whose primary offices are in Malta. The website https://winwithlavazza.mt/ is hosted in Malta. The majority of the service providers who are able to access the Website or any of the personal information collected from or relating thereto are located within the EEA, and where personal data may be shared, we have data processing agreements in place with these parties. These include customer relationship management, online review service provider, email service provider, web developers, affiliates, payment gateway, SEO agents, product suppliers, delivery and logistics, providers of professional advice (accounting and legal). Personal data that we hold is at all times on a strict ‘need to know’ basis.

If we need to send data outside the EEA, we will ensure that we have appropriate legal and security relationships with these parties and have taken steps to ensure that they are complying with the General Data Protection Regulation, including, as necessary, execution of contracts based on the European Union’s Standard Contractual Clauses for cross-border data transfers.

2.5       Automated Decision-Making

Other than ‘profiling’ activities carried out in order to display advertisements that will be relevant to You as explained in Paragraph 2.2 above, we do not engage in any automated decision-making.

2.6       Personal Data relating to Children

The Website should only be accessible by individuals over the age of 18. It is a parent’s or legal guardian’s responsibility to ensure that persons do not use Our Website. If We have reason to believe that We hold Personal Data of a person under that age, We will delete it immediately.

3           ABOUT YOUR RIGHTS

At any point in time during Our processing of Your data, You have the following rights. All requests in this regard may be made by sending an email to privacy@pcutajar.com.mt. We will also forward Your request to the relevant 3^rd Parties mentioned above as required. 

·     Right of access – You can request a copy of the information that We hold about You.

·     Right of rectification – You can ask Us to correct data that We hold about You if it’s inaccurate or incomplete. 

·     Right to be forgotten – in some situations, You may ask Us to delete certain data We hold about You and We will always comply to the extent allowed or required by any applicable law.

·     Right to restriction of processing – in some situations, You may ask Us to restrict the processing of Your data.

·     Right of portability – You may ask Us to transfer certain data We hold about You to another organization.

·     Right to object – You have the right to object to certain types of processing such as direct marketing.

·     Right to object to automated processing, including profiling – You also have the right to object to the legal effects of automated processing or profiling.

·     Right to complain about how your Personal Data is being processed by Us (or third parties), or about how Your complaint has been handled, – You can lodge a complaint directly with the Office of the Information and Data Protection Commissioner (https://idpc.org.mt/) and with Us on privacy@pcutajar.com.mt.

RIGHT TO WIRHDRAW – you have the right to withdraw Your consent, where given, at any time. This applies in particular to receiving marketing communications, where You are able to opt-out of receiving further notifications by clicking on the ‘unsubscribe’ link found in all such communications. You may also send an email to privacy@pcutajar.com.mt. 

The version of this Privacy & Cookies Policy is currently Version 1.1 and was last updated on 11^th October 2022. It is valid and applies to You until a new version uploaded on the Website and is accepted by You.