OK HOME – PRIVACY POLICY Last updated on 1^st July 2020

ABOUT US AND THIS PRIVACY POLICY

This privacy policy sets out the current policies and practices concerning personal data collected by OK Home via its website https://www.okhome.com.mt/ (the ‘Site’). The Site is operated and managed by O.K. Limited, a Maltese registered company bearing company registration number C-3506 and with VAT registration number MT* (the ‘Company’ or ‘we’).

This Privacy Policy complies with the General Data Protection Regulation (Regulation (EU) 2016/679) and the Data Protection Act (Cap 586 of the laws of Malta) on the processing of personal data and the protection of privacy in the electronic communications sector. Within this Privacy Policy, the term personal data means any information relating to the client (hereinafter referred to as ‘data subject’, ‘you’, ‘your’ or ‘user’). The supply of such information means that you can be identified, directly or indirectly, such as by means of your name and surname, birth date, gender, email address, delivery and billing addresses, phone number, signature (for delivery or collection of online purchase orders), payment details, historical purchase information and other factors specific to you.

CHANGES TO OUR PRIVACY POLICY

Visiting the site and/or using any of the services thereon shall be deemed to signify the user’s unequivocal acceptance of this policy.

The Company reserves the right to amend or modify this policy without any prior permission or intimation to the user. The user agrees that any such amendments or modifications shall immediately come into effect. The user has a duty to periodically check this policy and to stay updated on their provisions and requirements. If the user continues to use the Site following such update, the user will be deemed to have consented to any and all amendments or modifications made to this policy.
We take the privacy of our users very seriously and whenever this Privacy Policy is updated you will be notified of any such updates on the Site.

THE PERSONAL DATA WE COLLECT

1. Visiting Site
   When you visit the Site, we automatically collect certain information about your device for security and information purposes. This may include information about your web-browser, IP address, time-zone and other data about how you are using the Site. This data is not shared or disclosed with third parties save for the exception as stated below.

2. Submitting and Enquiry List
   When you opt to use the ‘Enquiry List’ function on the Site, you will be requested to fill in e-form and to disclose your name, surname and email address. You may also choose to include your contact number and/or a message. This information will not be stored on the Site server but will be sent through an electronic mail addressed to the Company for review. We will only store your personal information for the length of time required for the purpose for which it is collected.

3. Shopping Online
   In order to be able to shop online, new users will be requested to register by creating an account with us. Upon registration, you will be requested to submit your name, surname, email address and contact number. You will also be asked to set up a password to be used when logging onto the Site. All information provided by you as the data subject to the Company is passed through a Secure Sockets Layer (‘SSL’) connection and password encryption systems. Any such details including user name and password should be kept confidential by you and should not be disclosed to or shared with anyone. Where you do disclose any of these details, you are solely responsible for all activities undertaken where they are used.

In order to process your purchase request, certain personal data attributable to you is required. In general, and on a case by case basis, the personal data that the Company will require shall include:

1. Information about your identity.
   Including your name, surname, postal and billing address, language, identification document number, contact information etc.

2. Information of economic and financial nature.
   Including your payment option information such as your bank card details, purchase orders, returns history etc.

3. Information of your geographic nature. Including your address, connectivity data such as if you are accessing the Site via mobile device or from a desktop device etc.

On clicking “pay” you will be directed to a third-party payment gateway provider which will process payment according to the bank card type. In order to process payment, you shall be required to disclose the bank card number, expiry date, the card verification value (‘CVV’) and the name and surname as found on the said bank card. Where applicable, the system will go through additional security checks such as 3D Secure Services etc.

If you choose not to provide the Company with your personal data, we will not be in a position to fulfil our services to you including fulfilling any purchase order and will not be able to deliver the items to you.

WHY WE USE YOUR DATA

Certain personal data is required from you in order to allow you to access functionality or service of the Site. A number of fields will be marked as compulsory due to the fact that such information is required to be able to fulfil your orders and deliver the items of choice to you. The Company processes your data for the following purposes:

1. To fulfil your orders
   If you wish to purchase an item or items from our Site we will request your personal data to be able to execute and fulfil and deliver your order, prepare an invoice for the completion of the sale contract between you and the Company and manage a request for returns of purchased if required. This data may also be used to contact you via the contact means you provide including email, telephone or SMS to update you on the status of your purchase order and other communication related to the purchase order.
   
   We therefore use your payment information to take payment and give refunds and this is required in order to perform our contract with you.

2. To meet the requests made to Customer Care
   Only personal data which is strictly necessary to manage or resolve a request made by you will be processed.

Should you not wish to provide such personal data, you may be unable to carry on with the purchase order of the products.

Remember that the data you provide the Company with should be suitable, relevant and correct. If the data you provide us with is false, incomplete, inaccurate or not up to date, the Company reserves the right to terminate the contracted services or any agreement that has been signed.

OUR PARTNERS AND WHO WE SHARE YOUR DATA WITH

In order to allow you to access functionality or service of the Site and to fulfil your purchase order, the Company may need to give access to and communicate your personal data to third parties, both internal and external to the Company. Therefore, your personal data may, when necessary, be shared with the following:

• Financial institutions (such as PayPal, Revolut and other payment service providers);
• Credit Institutions (such as any of the local banks registered with and regulated by the MFSA in Malta);
• Logistic, transport and delivery service providers (such as couriers to deliver your purchase order);
• Companies working in assembly and installation
• Customer support representatives of the Company (to assist you with any queries or problems you may have in connection with the purchase order);
• Group companies operating under the OK Group.

By requesting a purchase order, you are expressly authorising the Company to disclose and/or transfer such data to the aforementioned entities for the purpose of executing your purchase orders or requests. The Company discloses such personal data only if it is required and permitted to do so by law or if we believe, in good faith, that such action is necessary to:

1. Comply with legal provisions;
2. Protect and defend our rights and property;
3. Protect against the misuse of unauthorised use of the Site and its content; or
4. Protect the personal safety or property of the users or that of the public.

DATA RETENTION

The Company will keep your data for the time required in order to comply with the purposes for which it was gathered and no longer than necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data. The Company may however keep your data for a longer period for legal or regulatory reasons which may include:

• Responding to your purchase order requests or queries, complaints or questions;
• Compliance with tax or VAT reporting requirements;
• Maintaining records according to rules which apply to the Company;
• Establishing, bringing or defending legal claims;
• If it becomes necessary or required to meet legal or regulatory requirements, prevent fraud and abuse, or enforce our terms and conditions; and
• Evidencing that the Company has treated you fairly.

USER DATA RIGHTS

You enjoy several rights relating to your personal information. For this reason, the request to exercise any of your rights given to you as a data subjects in terms of the General Data Protection Regulation and the Data Protection Act may be made to us in writing and at no expense.

• Right of Access
  

  The Company will provide the data subject with information about any of its personal data that the Company is processing. In this regard, the Company will seek to ensure that data is kept in an accessible format so as to facilitate access and transferability to the data subject. The contact details may be found in the last section of this Privacy Policy. To process this request, you will be asked to provide proof of identity so that we can ensure we are releasing the personal data to the correct person and no one else. We will do our best to process your request within twenty-one (21) days, or if the request is particularly complex, within two (2) months. Your personal data will be provided to you in either digital format or hard copy.

• Right to Data Portability
  

  The data subject shall have a right to request a copy of their personal information which the Company possesses. The data subject may also request to have said information transferred, moved or copied to another organisation in a format that may be easily used. We will do our best to process your request within twenty-one (21) days, or if the request is particularly complex, within two (2) months. We can provide the personal data to you directly or, if you request, to another organisation. Your personal data will be provided to you in either digital format or hard copy.

• Right to Object
  

  If you have given us your consent to process your data for any purpose, you have the right to withdraw such consent at any time. Data subject shall also have a right to object to direct marketing, including profiling analysis made for direct marketing purposes.

• Right to Verification and Rectification
  

  You may write to us to request us to rectify the personal data that we hold. You hereby guarantee that the personal data provided to the Company are true and accurate and undertake to notify us of any change or alteration of them. Any loss of damage to the Site or the Company, or to any third party through the provision of erroneous, inexact or incomplete information on the purchase request form, will be exclusively the responsibility of the user.

• Right to Erasure
  

  You may request the Company to delete all personal data that it holds to the extent that the information is no longer necessary for the purpose for which the Company must hold it for processing or when we are no longer legally allowed to process the information. For avoidance of any doubt we may be justified to keep personal data which we need to keep such as to comply with a legal obligation (e.g. for VAT reporting purposes) and in relation to the exercise or defense of any legal claims among others.

• Right to complain and file a claim
  

  You have the right to file a claim before the responsible data protection regulatory authority in Malta, that is, the Office of the Information and Data Protection Commissioner in Malta: https://idpc.org.mt/

COOKIES

We use so-called ‘cookies’ or other instruments to analyse the usage of our Site. Cookies are small files which are saved on your hard drive and which provide us with specific information. This information above all includes the IP address, your browser type, the date and the time of your visit on our website as well as the cookie number.

Using cookies and similar instruments makes it possible to recognize you whenever you as a user access our internet sites again after the expiration of a session. Cookies also allow us to ideally adapt our products and services to your individual needs. The Company uses cookies to statistically record how often our Site is viewed as well as the general navigation and use.

We also use an additional cookie to provide you with shopping cart functionality and which allows you to submit orders online.

If you want to disable the use of cookies, you can set your browser to reject and block any new cookies. Details about how this can be done in your browser can be found, for instance, in your browser’s help section. However, please note that, if you set your browser to automatically rejects cookies, you may no longer be able to use certain features of the Site.

If you want to change your settings and stop Google Analytics tracking, please visit this page for further instructions https://tools.google.com/dlpage/gaoptout.

OTHER PASSIVE INFORMATION COLLECTED BY USE OF THE SITE

It is possible other information shall be passively collected from you (without you actively furnishing such information) when you use and browse through the Site. Various technologies and navigational data collection methods are utilised to collect such passive information including but not limited to understanding how many visitors have accessed the Site, the date and time of the visit, the length of their browsing, the pages viewed and accessed and which web browsers utilised to access the Site and from where the access has been generated, for example by clicking on an advert featured on social media.

We collect this information to improve our services available on the Site visitors, customise the Site based on the preferences of the user, compile and analyse statistics and trends of the users of the Site. We will only use this information to improve the content, functionality and administration of our Site to improve our products and services via the Site and share such information with third parties.

Such passive information shall not be combined with personally data which can identify you unless you have consented to provide it to us.

TRANSFER OF PERSONAL DATA OUTSIDE OF YOUR JURSIDICTION

To the extent that we need to transfer personal information outside your jurisdiction, whether it is transferred to our affiliates, if any, or to third-party service providers, we shall do so in accordance with the applicable laws. In particular, in order to ensure that all such transfers comply with applicable local data protection law, we will implement appropriate security safeguards.

LINK TO THIRD PARTY WEBSITES

We are not in any way responsible for the content, views, opinions or advice expressed or given on the third party websites or links and their presence on our Site cannot in any way be deemed to constitute an approval or endorsement of the content or opinion or views or products/services in that link or site. We are unable to guarantee that the third-party information is free from errors or omissions and we shall have no liability however it may occur to our users for any loss or damage or expense incurred by reason of any person using or relying on the information obtained from the third party website or link.

SECURITY OF YOUR PERSONAL DATA

The security of your personal data is an important aspect of our business. We endeavour to use HTTPS to help keep information about you secure whenever possible and appropriate however, no data transmission via the internet can be guaranteed to be completely secure. We do our best to keep the information you disclose to us secure, however, we are not in a position to guarantee or warrant the security of any information which you send to us. The security measures which we have implemented to secure information transmitted over our Site or stored on our systems include the following:

• Use of secure servers;
• Use of firewalls;
• Use of encryption;
• Physical access controls at data centres;
• Information access controls;
• Use of back-up systems;
• Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.

DISCLAIMER OF WARRANTIES AND LIMITATION OF LIABILITY

Any information accessed through the use of the Site is obtained entirely at your own risk and the Company shall not in any way be held responsible for any damage resulting to any software or computer systems.

We do not guarantee, represent or warrant that your use of our Site will be uninterrupted, timely, secure or error-free. The service and all products and services delivered to you through the Site are (except when expressly stated by us) provided ‘as is’ and ‘as available’ for your use, without any representation, warranties or conditions of any kind, either express or implied, including all implied warranties or conditions. The Company shall in no case be held liable for any damages arising from your use of the Site.

LAW AND JURISIDCTION

This Policy shall be governed by the laws of Malta. Any dispute arising from, or related to this Privacy Policy shall be subject to the non-exclusive jurisdiction of the courts of Malta, Europe.

CONTACT DETAILS

If you have any questions in connection with this Privacy Policy or if you wish to make a complaint about the processing of your personal data, please contact us at any time:

1. By post at:
   Attn: CEO
   OK Home
   Pantar Road,
   Lija,
   Malta
2. Via email on info@okhome.com.mt
3. By using the applicable contact form available and updated on the Site.

Any method listed above may be utilised in order to contact us in connection with this Privacy Policy and/or any request concerning your personal data.