Privacy Policy

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

This Policy has been last updated: September 2023.

Disclaimer: This website may contain links and references to third parties websites (such as LinkedIn, Facebook, YouTube) and this Privacy Policy does not apply to information collected by third parties applications / websites that you click on and / or visit and we are not responsible for their data processing and privacy. Kindly review the Privacy Policy and Data Processing Policies of third-party websites and links before you click on them, engage with them and / or disclose your personal data to them.

While we take all due care in ensuring the privacy and integrity of the information that you provide to us, we recognise that no data transmission over the internet can be 100% guaranteed as secure. The possibility exists that this information could be unlawfully observed by a third party while in transit over the internet. We accept no liability should this occur.

Controller details

The data controller of your personal data is Sivenorem Limited (A Company Registered in Malta with registration number C100979 ) and our website is www.sivenorem.eu We are committed to respecting your privacy. If you wish to contact us about our privacy practices, please feel free to do so by e-mail at info@sivenorem.eu with the subject line “Privacy Policy”.

What data do we collect?

1. Website Usage Data When you use and / or visit our website, to ensure technical administration, management, and security of this website, we may collect Usage Date ( IP address, location, time of visit, browser details) .

2. Your personal information that you provide to us, either by filling out our form to be kept informed of our services and launch date, corresponding with us, visiting our website, contacting us directly via e-mail, our website, telephone, post or other means where you initiate contact with us. The personal information your provide us through the means above include, but not limited to (depending on what you disclose to us and / or further information required by us to provide you with our services): Your name, Contact Details ( such as telephone number, address) and Email Address, Corporate Website, Job Title, Industry Specialisation, Country of Residence, links to your professional/ social profiles, CV , Corporate Business Information ( such as registration number, VAT and Income Tax number).

How we collect this data ?

The information we collect about you will be provided by you, either by visiting our website, filling out the waitlist / subscribe forms, emailing us directly or by corresponding with us by phone, e-mail or otherwise and / or engaging with our services.

It will also include information you provide when you register to use our website, subscribe to our services, contact us, attend our events, participate in discussion boards or other social media functions on our website, enter a competition, promotion, or survey, and when you report a problem with our site.

In case of website usage data, this is collected when visiting our website.

Our legal basis for processing data:

The information you provide to us is used by us to:

(a) to provide you with our services

(b) keep you informed of the progress of our launch so you can discuss our services with you

(d) answer your enquiry and communicate with you

(e) provide other services related to or supplementary to the above; services directly to you to your professional, personal or business email address;

and

(f) where we have a bona fide requirement by law to process it, including by disclosing the data to third parties, for example, to comply with any applicable law and regulations, legislation, compliance requirements, detection of crime, the collection of taxes or duties, and /or in order to comply with our legal obligations and/ or to comply with any applicable law, regulations and court order.

This list is not exhaustive, and we may seek to process, use or disclose your information for any other purpose which has not been listed above always with your explicit consent.

The more information we have about you the more bespoke we can make our service.

Where appropriate, we will seek your consent to undertake some of these activities.

We may also use the information you send to us via the websites and/or services, to communicate with you via email and, possibly, other means, or to send you our newsletter, if this is in accordance with your marketing preferences.

However, you will always be able to opt out of such communications at any time.

Automated Decision-Making and Profiling

Your Personal Data will not be used for any automated decision-making or profiling which produces legal effects concerning you or similarly significantly affects you.

How do we share your personal data?

Internally within Sivenorem Limited to provide you with our services;

Service providers that may have access to your personal data when providing us with their support services, including, but not limited to IT and website management, CRM and accounting service providers;

Third parties to whom disclosure may be required because of legal obligations imposed on the business;

Legal advisors to protect and defend the rights or property of the Company, where necessary;

In the event of a sale, merger, receivership or transfer of all assets of our company, we reserve the right to assign or share your personal information with such third parties and their advisers, you will be sent notice of such an event should it occur with the ability to opt-out of such a transfer.

We do not sale or share your data with anyone for any marketing, direct selling, or advertising purposes.

International Transfers

Internally, Sivenorem Limited, is based in Malta, EU and adopts strict security and privacy policy measures, both internally and externally, and we have implemented combined security measures for data access, including, but not limited to : two-factor authentication, biometric access, encryption, to name but a few.

Given the global footprint of hosting, technical , service and e-mail service providers, your data may be processed outside EU. Should this be the case, we have taken appropriate steps to ensure appropriate safeguards are in place to protect such and that our providers are fully compliant with GDPR and utilize strict security measures, to protect the data, such as data transfer and data processing agreements and/or contractual clauses and / or any such other mechanism that is approved by the European Commission for transfer and processing of personal date to third countries.

How long we keep your data for

We retain different types of data for differing periods of time.

The criteria we use to determine whether we should retain your personal data and how long for include:

• The nature of the personal data

• Its perceived accuracy of your data

• Your engagement levels with our services

• Our legal obligations

• Our rights to defend any legal claims

We may archive part or all of your personal data, or retain it on our financial systems but delete all or part of it from systems. On removal, we may anonymise parts of your data – particularly following a request for suppression or deletion of your data – to ensure we do not re-enter your personal data to our database, unless you have requested us to do so.

Our current retention period for data of individuals who are no longer showing any signs of engagement with our services, is 12 months.

Processing Requirement

The processing of your Personal Data is not carried out to fulfil a statutory requirement. The processing of your personal data by us is required for us to carry out our services.

Your rights The GDPR provides you with the following rights:

• The right to be informed about the personal data we process on you

• The right of access to the personal data we process on you

• The right to rectification of your personal data

• The right to erasure of your personal data in certain circumstances

• The right to restrict processing of your personal data

• The right to data portability in certain circumstances

• The right to object to the processing of your personal data

• The right to be informed of the source from where your personal data originated

• The right to withdraw your consent

• The right not to be subjected to automated decision-making and profiling

Please note that your rights in relation to your personal data are not absolute and we may not be able to entertain such a request if we are prevented from doing so in term of an applicable law.

Right to lodge a complaint with a supervisory authority:

If you have any complaints regarding our processing of your personal data, we kindly ask that you please attempt to resolve any issues you may have with us first by contacting us at the contact details included above.

However, please note that you always have a right to lodge a complaint with the Office of the Information and Data Protection Commissioner in Malta (www.idpc.gov.mt).

The above list is not an exhaustive list of your rights, further information can be found at https://ec.europa.eu/info/law/law-topic/data-protection_en

Changes to our privacy notice

Any changes we make to our privacy notice in future will be posted on this page and, where appropriate, you will be notified by e-mail.

Please check back frequently to view any updates or changes to our privacy notice and your continued use of our services constitutes your agreement to our Privacy Policy.