Privacy Policy


 

1. Who We Are

1.1. Pacific Digital Ltd (the ‘Company’) is committed to protect the privacy of individuals who visit our website. This Privacy Policy is to let you know how the Company protects the privacy of your communications and collects, processes, uses and stores your personal data through our Website as well as the rights you have with regard to the foregoing collection and processing of your personal data. By visiting our Website and using our services you acknowledge of having read and fully taken into account this Privacy Policy. The Company acknowledges that in collecting your personal details it is bound by the Laws of Republic of Malta and will process your personal data in accordance with the General Data Protection Regulation. For any further request or query about how we use your personal information, you may address us by using the following email address: hello@pacific.org

1.2. Any notice, demand, request or other communication which you address to the Company shall either be sent by certified mail, return receipt requested, or by email. All notices given by e-mail shall be deemed given as of the business day following the day of transmission.

 

2. Definitions

For the purposes of this Privacy Policy the following definitions shall apply:

2.1. "The Company Parties" means the Company and its respective past, present and future officers, contractors, consultants, attorneys, accountants, financial advisors, intra group legal entities, suppliers, vendors, service providers, affiliates, agents, representatives, predecessors, successors and assigns. "The Company Party" means one of the foregoing, as the case may be.

2.2. “Consent” - Any explicit, specific and freely given indication by which the User, after having been fully informed, signifies her agreement to personal data relating to her being processed.

2.3. “Cookie” - short text of software code, which is transmitted from the web server of the Company and stored at your device each time that you enter the Website.

2.4. “GDPR” - the General Data Protection Regulation (EU) 2016/679, of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced or superseded and in force from time to time and as transposed into member-state legislation.

2.5. “Personal Data” - Any information relating to an identified or identifiable user of https://pacific.org/

2.6. “Processing” - Any operation or set of operations which is performed by the Company upon the personal data of the users of https://pacific.org/ whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction;

2.7. “Services” – the online services at the Website;

2.8. “User” – Any internet user who accesses and browses or registers the User Account on https://pacific.org/

2.9. “User Account” means an account provided to you by the Company upon registration for use of the Services, as well as obtaining access to specific additional other products, utilities and offerings provided by the Company Parties.

2.10. “Website” – The worldwide web website which is accessible through the domain name https://pacific.org/ including all of its webpages.

 

3. Subject Matter

3.1. The present Policy sets out the terms and conditions under which the Company follows in order to protect the privacy of our clients. It describes the conditions under which we make any collection and processing of your personal data and ensure their confidentiality (“Privacy Policy”).

3.2. The Company reserves the right to amend and update this Privacy Policy, whenever it deems it appropriate, and any changes thereof shall come in force and effect from the instance they appear online at the present webpage of https://pacific.org/.

3.3. If any provision of this Privacy Policy is declared void or unenforceable, such provision shall be severed from this Privacy Policy, which shall otherwise remain in full force and effect to the extent that the original intent of this Privacy Policy will not be altered in any material respect.

 

 

4. Principles of Data Processing

We fully respect your fundamental rights and render protection of your privacy a priority of the Company. In this context, when processing your personal data, we follow the following basic principles:

4.1. We submit your personal data only to legitimate processing, and we maintain full transparency vis-à-vis the way we handle your personal data.

4.2. We collect and process your data only for specified, explicit, and legitimate purposes as outlined in this policy, and we do not process it further in a manner incompatible with these purposes.

4.3. We process your personal data only to the extent that it is appropriate and relevant to the above purposes, while limiting the processing to the measure necessary for these purposes.

4.4. We make reasonable efforts with your own assistance to ensure that your processed data is accurate and, where necessary, updated with regard to the purposes of the processing, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.

4.5. We keep your personal data in a form that allows you to identify yourself only for the time required for the above processing purposes.

4.6. We process your personal data in a way that guarantees its security by using appropriate technical or organizational measures.

4.7. We do not intend to further process your personal data for purposes other than the ones for which they are collected.

4.8. We inform you that there is no obligation to provide your personal data and that there are no possible consequences from the choice not to provide it. Furthermore, we inform you that your personal data will not be used for automated decision making, including profiling.

4.9. Without prejudice to what is stated in this policy, we do not disclose and transmit your personal data to third parties without your consent, unless permitted by law or by our contractual agreement with you.

4.10. Please be advised that we do not pass on your personal data to a third country or international organization for which there is no European Commission decision under the GDPR.

4.11. In general, we comply with all applicable laws and comply with all our statutory obligations, as data controllers of your personal data.

 

5. Types of Data Collected

5.1. At the point of registering for and creating of User Account, you shall provide to the Company your personal identification information, such as:

Name and Surname
E-mail address
Mailing address

5.2. At the point of your access and during the use of https://pacific.org/

IP Address.
End user device data
General communication data.
Browsing data.
Information on user preferences regarding https://pacific.org/

5.3.At the point of accepting the receipt of advertisements [e.g. banners, hyperlinks or plugins] and any other type of commercial communications placed at or communicated through https://pacific.org/ or through our social media channels:

All personal data directly provided by you.
Non-personally identifiable information regarding the popularity of such commercial communications.

5.4. Any other personally identifiable information directly provided by you during interaction with our social media channels.

5.5. The Company does not collect or gain access in any way to special categories ("sensitive") of personal data or data relating to criminal convictions and offenses by its clients. You have an obligation to refrain from posting such data concerning yourself or third party data subjects. In the event that you submit such data to our Website, these will be removed as soon as we become aware of them. We have no liability to you or to any third parties for any processing of sensitive data due to your actions or omissions in breach of this obligation.

 

6. Purposes and Legal Bases of Data Processing

6.1. Personal data necessary for the navigation and use of our Website and the Services is collected and processed by the Company pursuant to Article 6(1)(b) of the GDPR (‘Performance of contract’) for the following purposes:

Administration and development of the Website and the Services
Enhancement of user experience, including the provision of personalized Services and improvement of the Website and the Services
Development of new products, utilities and offerings
Detection, investigation and prevention of fraudulent transactions and other illegal activities and protection of your rights and rights of the Company Parties
Collection, processing and performing statistical and other research and analysis of information for enhancement of the Website and the Services
Communication with you about products, services, promotions, events and other news and information we think will be of interest to you
Verifying compliance with the Terms of Use of the Website.


7. Consent

7.1. The Company may process personal data only with your lawful consent for the following purposes:

For the purposes of commercial communication, marketing and advertising of our services or third party services via e-mail, internet, fax, mail, social media and / or any other appropriate communication channels.
For personified market research and / or analysis purposes to better understand your needs, preferences, interests, experiences and / or habits as a consumer.
To operate and manage any reward programs.

7.2. You give us your consent to the processing of your personal data for the above purposes with an electronic statement in a manner clearly distinguishable from other consents or notice and in an intelligible and easily accessible form using clear and plain language. Your consent is freely given and your personal data is given without such a provision being a legal or contractual obligation or a requirement on behalf of the Company for the performance of a contract between us.

7.3. You have the right to withdraw your consent at any time in writing to our contact details mentioned in this Policy. Withdrawal of your consent does not affect the lawfulness of the treatment of your data prior to its revocation. Your consent is also revoked in the same manner as provided.

 

8. Data Recipients

8.1. The Company shares your data with the Company’s Parties in the process of pursuing the purposes of data processing at Group level.

8.2. The Company does not assign your personal data or interconnect its database with any third parties, public authorities or other organizations for financial or other consideration.

8.3. For the execution of the purposes mentioned in this Policy, the Company may provide access to or transmit the following types of your data to the following processors for and on behalf of:

Your personal data to our internet and data hosting providers for hosting purposes.
Your personal data to our information technology maintenance and support providers for the smooth operation of Website and our information and communication systems.
Your personal data to third-party consultants to provide data analysis services.

8.4. The processing of your personal data by our data processors mentioned above is executed under a contract with us subject to, compelling such data processors to the same level of data protection provided by this policy.

8.5. In the event that we are required by a court or other administrative authority, pursuant to an investigation relating to unlawful activities such as money laundering and in any other case that we are legally bound to do so, the Company may transfer your personal data to public authorities to the extent specified by law prior to you being informed.

 

9. Data Security and Confidentiality

9.1. In order to ensure the proper use and integrity of your personal data and to prevent their unauthorized or accidental access, processing, deletion, alteration or other use, the Company applies appropriate internal policies and takes all appropriate organizational, technical, physical, logical and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.

9.2. The processing of your data by the Company is conducted in a manner that ensures their confidentiality and physical and logical security, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for your rights and freedoms, which are applicable in each circumstance.

9.3. Your personal data is processed solely by authorized personnel of the Company, bound by strict obligations of confidentiality.

 

10. Retention of Personal Data

10.1. We keep your personal data for as long as it is each time necessary for the relevant purposes of their processing, in alignment with the Data Minimisation and Storage Limitation principles as defined in Article 5 of the GDPR.

10.2. The Company may retain your Date as long as your User Account is active.

10.3. The Company may retain your personal data after the expiration of their relevant processing purposes in the following limited cases:

In case that there is a legal obligation under a relevant statutory provision.
For research or statistical purposes of for the proper organization and operation of our business provided that anonymity or pseudonymization of your data takes place.
In case of any claims against the Company, for as long as necessary to defend our rights and legitimate interests before any competent court and any other public authority.

10.4. After the period of retention, your personal data is erased from our databases and systems in accordance with our data protection policies and provided that their retention is no longer required for the fulfillment of the purposes we have described above.

10.5. For more information about data retention terms in relation to specific personal data, please contact us at hello@pacific.org.

 

11. Your Rights

11.1. Without prejudice to applicable law and subject to any limitations thereof, you have the following rights:

Request for access to your personal data and information related to their processing and obtain a copy thereof.
Request for the rectification of any inaccuracies or any missing personal data of yours.
Request for the erasure of your personal data.
Request for the restriction of the processing of your personal data in cases explicitly provided for by law.
Object to the processing of your personal data in cases explicitly provided for by law.
Object to a decision taken solely on the basis of automated processing, including profiling, which has impact on you or significantly affects you.

11.2. Any requests relevant to the above are addressed in writing to our contact details mentioned in this Policy.

11.3. The Company will respond to any of your requests within one month from their receipt. Upon prior notice, this period may be extended by a further two months if necessary, taking into account the complexity of the request and the number of any other pending requests. In case of rejection of your request, we will provide relevant justification.

11.4. If your request does not meet the requirements of applicable law, the Company reserves the right either to: (a) impose a reasonable fee, taking into account the administrative costs of providing the information or communicating or executing the requested action, or (b) reject your request.

11.5. In the event of any violation of your personal data, which may place your rights and freedoms at a high risk, and provided that it does not fall under one of the exceptions expressly provided for by applicable law, we undertake to inform you without undue delay.

11.6. If there are any doubts as to the identity of the individual submitting the request, we reserve the right to request the provision of additional information necessary to confirm his / her identity.

11.7. If your rights are infringed, we inform you that you have the right to file a complaint with the Malta Data Protection Authority or with any other competent supervisory authority.

 

12. Your Obligations

12.1. By using our Website and by providing your personal data upon your consent, you acknowledge that you are required to state your actual, accurate and complete information requested by the Company. Furthermore, you must inform the Company of any changes to your information so as to ensure it is kept up-to-date and accurate.

12.2. If you are found to be in breach of your obligations or if the Company has reasonable suspicion that the information you provide is false or incomplete or in any way contrary to applicable law or this Privacy Policy, we retain the right to reject your application for registration or to suspend or terminate your account immediately without notice. In this case, you have no right to any compensation due to the rejection of your application, or the suspension or termination of your account.

12.3. You acknowledge that the Company may delete, cross-check, supplement or modify the information you provide based on information lawfully provided by third parties. In this case, the Company will provide you with relevant notice in compliance with applicable law.

12.4. By using our Website you confirm that you are over eighteen (18) years old. If you are under the age of eighteen (18) you have the obligation to abstain from any use of our Website and from any transfer of your personal data without the consent of the person who exercises your parental responsibility. If you fail to comply with the foregoing obligations, you must immediately notify the Company. In any case, using the Site, you acknowledge that the Company is not responsible for your violation of the obligations mentioned above to the extent that it is unable, even if it makes reasonable efforts, to verify your age or to receive consent from your guardian.

 

13. Cookies

Our Website uses cookies. For more information please proceed to Cookie Policy.

 

14. International Jurisdiction and Applicable law

14.1. Any dispute between you and the Company arising from or in relation to the subject matter of this Privacy Notice shall be governed and construed in accordance with Malta law without reference to its conflict of laws principles and shall be subjected to the exclusive jurisdiction of the competent courts of Malta.

14.2. If a provision of the present Privacy Notice is canceled by a decision of a competent court as unlawful, invalid or unenforceable, this will not affect the validity and enforceability rest of its provisions, which will remain in full force and will be accordingly applied.

 

Cookie Policy

This Cookie Policy (together with the Privacy Policy and any other documents referred to in it) sets out how we use cookies. This Website, like those of many other reputable online companies, makes use of cookies. Please take the time to read and understand this Cookie Policy which has been provided for your information, as the user of this Website (‘You’ or ‘User’), for transparency and clarity purposes on our use of cookies.

 

What is a cookie?

A cookie is a small file of information that is automatically stored by your browser on your computer’s hard drive or mobile device when you access our Website. Cookies can only identify your computer or mobile device and not the individual user, by storing some basic information which will enable us to identify if you have previously visited our website. Cookies are only read by the server that placed them, and will not plant viruses or harvest your personal data. Cookies will not be used for any other purpose other than those stated in this section.

To provide you with the Services, we use first-party session and persistent cookies as well as third-party persistent cookies. Session cookies are automatically erased from your web browser once you close it. Persistent cookies last until they automatically expire after a period of time, or until you choose to delete them from your browser.

 

What are the types of cookies we use?

We use first-party session cookies which automatically log generic information about your computer’s connection to the Internet, called “session data”. Session cookies are temporary and are deleted as soon as you close your internet browser. We use session cookies so that you do not have to stay re-inserting your information and so that our Website remembers your preferences. Session data consists of your IP address, operating system and type of browser software being used and your activities while using our Website. We collect session data because it helps us administer our Website, track correlative information and to collate statistics in relation to visitor traffic. We may use your IP address to help us diagnose problems with our server.

We use first-party persistent cookies which remain on your device for a pre-defined period after you’ve visited the Website.

Personal data that you provide us with such as your name and address is neither gathered, nor stored in the cookies placed by our Website and, as a result, your information will not be passed on to any third parties, unless specifically mentioned below.

In certain instances, we use third party cookies, which are cookies provided by parties other than Us/Website. We always ensure that these parties are reputable and will respect your privacy.

In particular, Pacific makes use of third-party persistent cookies which are cookies set by Google Analytics. These help us measure how users interact with our Website by collecting information on clicks, time spent on the Website, and pages visited on the Website, the frequency a User visits the Website, what browser a visitor to the Website is using. We also collect information on how long a User remains on our Website and whether the User visits a third party site. This information is passed on to Google Analytics and the information we get back from Google Analytics is solely used to improve the Website. Statistics and analytical data are very useful tools for us to provide a better and more engaging product for our users and to make our business predictions more accurate. The cookie set by Google Analytics which will identify you as a unique User on the Pacific Website can only be used by Google. For further information please visit the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to stop Google Analytics from recognising you when return to our Website by disabling cookies on your browser (further information on how this can be done, may be found below). The cookies Google Analytics places on Users’ devices may last up to 2 years.

We may place social media buttons and/or plugins on the Website that allow you to connect with your chosen social network. In order to work, the social network (such as Facebook, LinkedIn or Twitter) will set cookies through our Website which may then be used to enhance your profile on the social networking site or otherwise contribute to the data they hold for the purposes outlined in their respective privacy policies.

 

How to control cookies

Most web browsers automatically accept cookies but it is possible to change the options on your web browser or use certain software programs, which will enable you to control how and whether cookies will be accepted by your browser. You can disable cookies or set your browser to alert you when cookies are being sent. The Website supports your right to block any unwanted Internet activity, especially that of unscrupulous Websites, but if you choose to block our cookies, this may disable certain features on the Website. It is possible however to block cookie activity from certain Websites while permitting cookies from sites you trust.

You can control and/or delete cookies as you wish – for more information, see AllAboutCookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.