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BOV Asset Management Limited Privacy Notice

In this privacy notice (the “Notice”), “we”, “our” and “us” refers to BOV Asset Management Limited (the “Company”) as well as the Bank of Valletta Group (the “Group”, this being Bank of Valletta p.l.c. and its subsidiaries) of which the Company is a part of.  BOV Asset Management Limited, C18603, registered address 58, Triq San Żakkarija, Il-Belt Valletta, VLT 1130, Malta, is a fully owned subsidiary of Bank of Valletta p.l.c.

“You” includes any attorney duly appointed by means of a power of attorney/mandate, trustees, executors, curators or any other legitimate representatives.

This Policy Notice sets out the basis for which any of your personal data is collected and processed by us. 

The Group may process your data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 440 of the Laws of Malta) (the “Act”), as may be amended or replaced from time to time, and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “Regulation” or the “GDPR”).

PERSONAL DATA

“Personal Data” is data that identifies a natural person, including but not limited t

• Name and Surname (including maiden name where applicable);
• Address;
• Nationality;
• Gender;
• Civil Status;
• Tax Status;
• Email address;
• Postal address
• Account details and related contact information;
• Contact details (including mobile and home phone number);
• Date of birth;
• Identify Card and/or Passport Number;
• Localisation information,
• Photographic image, and other such electronic recordings.

Please note that personal data does not include information relating to a legal person (for example, a company or other legal entity).  In that regard, information such as a company name, its company number, registered address and VAT number does not amount to personal data in terms of both the Act and the GDPR.  Therefore, the collection and use of information strictly pertaining to a legal person does not give rise to data controller obligations at law.  Naturally, we will still treat any and all such information in a confidential manner, in accordance with our standard practices and professional secrecy obligations.

THE DATA WE COLLECT

The Group collects and processes your personal data mainly to provide you with access to our services and products, and to help us improve same.

We may collect personal data about you from different sources, data including the following:

• Data given to us directly by yourself;

• Data collected automatically when you use BOV Website, Internet Banking, Mobile Banking App, and ATMs;

• Data collected from other publicly available sources.

SCOPE OF PROCESSING

The Bank will process personal data for the following purposes only, namely:

• To be able to provide the investment or service that you have applied for, in order to fulfil our contract with you;

• To provide you with statements and other data regarding that investment and services;

• For internal assessment and analysis (including market, product analysis, risk management, and in order to protect our legitimate interest);

• To collate documentation which may be mandated from time to time by the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta), the Prevention of Money Laundering and Funding of Terrorism Regulations the Financial Intelligence Analysis Unit and/or any other competent authority or related legislation to which the Company is bound to report.  This will be done in order to fulfil our legal obligations and to safeguard our legitimate interest as well as the public interest, as we may need to;

• In furtherance of our legitimate interest in developing and improving the Company’s products and services;

• To safeguard our legal rights, such as in the case of enforcing or protecting our security, or recovering amounts owed to us by you or your co-debtors, or other persons whose borrowing you have secured.

We may use your data to protect you in the following ways:

• We may record phone calls to confirm details of our conversations, for your protection, to train our staff, to adhered to regulations and to maintain the quality of our service;

• We use CCTV to record images in and around our premises to prevent and detect crime;

• Before we provide any service, we will carry out lawful checks, which may include searches to confirm your identity.

Your data may be transferred to and stored in locations outside the European Economic Area (EEA), including countries that may not have the same level of protection for personal data.  When we do this, we will make sure that it has an appropriate level of protection and that the transfer is lawful.  We may need to transfer your data in this way to carry out our contract with you, to fulfil a legal obligation, to protect the public interest and/or for our legitimate interests. 

OTHER PRODUCTS AND SERVICES

Note that we may process your personal data pursuant to more than one lawful ground or basis, depending on the specific purpose for which we are using your data.  Any personal data you provide in the process of enquiring/arranging any of our other products and services is provided in the strictest confidence.  We will only use this for the purposes specified in your enquiry and we will never pass your personal details to third parties or any other companies for any other reason.

If you have already provided your consent, we will continue to rely on this permission until you request us to stop sending you data.

DATA WE SHARE

Your personal data may be disclosed to or exchanged with all employees of the Group and its subsidiaries, and their consultants, associates and agents. 

We do not share personal data with companies, organisations and individuals outside of the Group unless one of the following circumstances applies:

• With your consent - We will share personal data with companies, organisations or individuals outside of the Group when we have your consent to do so.  We require opt-in consent for the sharing of any sensitive personal data.

• For external processing - We provide personal data to trusted businesses or persons to whom we may outsource certain functions from time to time, in order to provide you with the products or services you have requested, and in compliance with our Privacy Notice and any other appropriate confidentiality and security measures.

• For legal reasons - We will share personal data with companies, organisations or individuals outside of the Group if we have a good-faith belief that access, use, preservation or disclosure of the data is reasonably necessary to:

o meet any applicable law, regulation, legal process or enforceable governmental request;

o enforce applicable terms of service, including investigation of potential violations;

o detect, prevent, or otherwise address fraud;

o protect against harm to the rights, property or safety of the Bank, our users or the public as required or permitted by law.

We may share non-personally identifiable data publicly.  For example, we may share data publicly to show trends about the general use of our services.

If the Company or the Group is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal data and give affected users notice before personal data is transferred or becomes subject to a different Privacy Notice.

DATA RETENTION
We will not retain your personal data for longer than it is required for the maintenance of your relationship with us, or for any legal or regulatory requirements.

DATA SECURITY
We make sure to use reasonable measures to protect the personal data within the Group.  If you have reason to believe that your interaction with us is no longer secure, please immediately advise us.

COOKIES

When you visit the Company’s Website, the web server automatically records details about you, such as IP address, the website from which you where redirected to the Company’s website, type of browser and the Group’s website pages visited by you including date and duration.

The Company and the Group will use your personal data:

• for the purposes of technical administration and research & development of the Company’s Website,

• for user administration and marketing,

• to inform you about our services and products.

DATA SUBJECT RIGHTS

Your rights in connection with personal data under certain circumstances, by law you have the right t

• Request access to your personal data.  This enables you to receive a copy of the personal data we hold about you and how we process it.

• Request correction of the personal data that we hold about you.  This enables you to have any incomplete or inaccurate data we hold about you corrected.

• Request erasure of your personal data.  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.  You also have the right to object where we are processing your personal data for direct marketing purposes.

• Request the restriction of processing of your personal data.  This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your personal data to another party. 

ACCESS REQUESTS AND MARKETING OPTIONS


If you wish to exercise your rights or change your marketing preferences, you may do so by,

• directly at one of the Bank of Valletta p.l.c. branches;

• at any licenced financial intermediary;

• submitting a written request to us;

• sending an email to – customercare@bov.com.

Should you not visit a Bank of Valletta p.l.c. branch or any licenced financial intermediary in person, we may need to contact you in order to verify your identity and request.

UPDATES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time.  The updated privacy notice will be published on our website (https://www.bov.com/Content/privacy).  If you have any questions about this Privacy Notice, please contact us at dpo@bov.com.

CONTACT DETAILS OF THE COMPANY, THE GROUP’S DATA PROTECTION OFFICER AND THE SUPERVISORY AUTHORITY

Company contact Details:
Land Line: (00356) 2122 7311
Address: 58, Triq San Żakkarija, Il-Belt Valletta, VLT 1130, Malta
Email:  customercare@bov.com

Bank Data Protection Officer Contact Details:
Land Line: (00356) 2275 3700
Address: Bank of Valletta p.l.c.
Centris Business Gateway, 2nd Floor, Suite 2
Triq il-Palazz l-Ahmar
Mriehel, Birkirkara SVR 1451
Email:  dpo@bov.com

Supervisory Authority Contact Details:
Land Line: (00356) 2328 7100
Email:  idpc.info@idpc.org.mt

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