Compliance Policies

Privacy Policy

General Information

XirCammini is committed to respecting your privacy and protecting your personal data.

In this Privacy Policy (this “Policy”), “XirCammini”, “we”, “us” or “our” means XirCammini (a membership association registered by the office of the Commissioner for Voluntary Organisations, registration number VO1646  and with its registered office at 224, Triq ta’ Xmiexi, Msida MSD1807 – Malta; “you” or “your” means you, the person who provides us with personal data; and, “personal data” shall have the meaning assigned to it in Article 4 of Regulation General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council which becomes applicable as from the 25th May 2018 (“GDPR”).

All personal data obtained by us is held and used in compliance with this Policy, with the Maltese Data Protection Act (Chapter 440 of the Laws of Malta) as amended and as applicable (“DPA”), and the GDPR.  XirCammini is deemed data controller for purposes of the DPA and GDPR.

When we ask you to provide certain personal data, then you can be assured that it will only be used in accordance with this Policy.  This Policy applies to personal data about you that we collect, use and otherwise process in connection with your relationship with us as visitor to our website or XirCammini member including when you participate in any of our events or activities, use or are served by our websites and / or mobile apps, volunteers and/or third party service providers on our behalf. However, we are not responsible for third parties’ use of your personal data where such use is permitted for their own purposes and you should consult their privacy policies for further information.

This Policy is effective as of the “Effective Date” listed below.  We reserve the right, at our sole and absolute discretion, to change or modify this Policy at any time. If we decide to change our Privacy Policy, we will update the Privacy Policy modification date below and prompt you to read and accept the changes.)

Your continued access to, use or participation in of any of our services, products or activities following any change or modification to this Policy shall constitute consent to any such changes or modifications.

Please read this Policy carefully, access to, use or participation in of any of our services, products or activities constitutes your acceptance of all of the terms and practices described in this Policy, including without limitation, the collection, use, processing, and disclosure of your personal data as described in this Policy. Please do not access or use any of our services or products or purchase any of our services or products if you disagree with any part of this Policy.

If you have any questions or concerns about this Policy or its implementation, you are invited to contact via email on information@XIrCammini.org or via mail at 224, Triq ta’ Xmiexi, Msida, MSD1807 – Malta.

What types of personal data do we collect?

We collect personal data about you required in the membership and/or activity registration process including but not limited to:

  1. Your name and surname;
  2. Contact information including address of residence, email address, telephone number, and fax number;
  3. Your date of birth, nationality, and ID card or passport number;
  4. Food intolerances / allergies and dietary requirements;
  5. Medical condition (e.g. allergies or disabilities);
  6. Other information that may be required by us, to carry out obligations to serve you as a XirCammini member and/ or website user.

This personal data may include information that you provide to us directly or through volunteers and/or third party service providers on our behalf as well as information which we collect when you visit our website and/or participate in our activities.

When, and why, do we collect ‘sensitive personal data’?

Certain categories of personal data, such as that about race, ethnicity, religion or health, are considered “sensitive personal data” under the DPA and GDPR. Generally, we try to limit the circumstances where we process sensitive personal data.

By providing any personal data that is, or could be considered to be, “sensitive personal data” you explicitly agree that we may collect, use, share with third parties and transfer outside the European Economic Area this Personal Data, as described in this Policy.

If you withdraw your consent, it may mean we will not be able to provide all or parts of the products or services you have requested from us.

What do we use your personal data for?

We store, handle, send and generally process personal data to provide our members with the best service, and in particular for the following reasons:

  1. We will need to use the personal data as part of the membership enrolment or renewal process  We may also need to contact you if we have questions regarding your request;
  2. To deal with the general enquiries you raise from time to time;
  3. Carry out our necessary due diligence prior to membership enrolment;
  4. For internal record keeping and the general administration of your records by us;
  5. For statistical analysis;
  6. To improve the delivery of our service;

Without prejudice to the foregoing we will use your personal data to fulfil membership and/or activity enrolment.

When do we collect personal data about you?

We collect personal data about you when you use our services and or when you enroll as a member.

How we use cookies

In order to improve our services, to provide you with more relevant content and to analyse how visitors use our website and app, we may use technologies, such as cookies, pixels or tracking software. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies.

For example, we use software to monitor customer traffic patterns and website usage to help us develop the design and layout of the website in order to enhance the experience of the visitors to our website. This software does not enable us to collect any personal data. In addition, in order to understand how our customers interact with the emails and the content that we send, we use pixels that allow us to know if the emails we send are opened or if the content of our emails is displayed in text or html form.

We also use cookies in our website, mobile app or in our emails. Cookies are small pieces of information stored by your browser on your computer’s hard drive. They enable you to navigate on our website or app and allow us to provide features such as remembering aspects of your last flight search to make subsequent searches faster. You can delete cookies if you wish; while certain cookies are necessary for viewing and navigating on our website or app, most of the features will be still accessible without cookies.

When will we send you marketing communications?

You may receive marketing communications from us if you have opted in to receive such material.

We may use third parties to send marketing communications on our behalf. If we do ever want to allow a third party to send you direct marketing not related to XirCammini, we will first seek your permission before sharing your details with them.

If you have previously agreed to us using your information for direct marketing purposes, you may change your mind at any time by changing your preferences and opting out or by writing to us at information@XirCammini.org

Security, storage, and transfer

We are committed to ensuring that your personal data is secure at all times. We have in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect online.

Anyone with access to your personal data  that you provided to us and/or who are associated with the processing of that data are contractually obliged to respect the confidentiality of your personal data. 

Transmission of information over the internet

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access

Links to third party websites

Our websites, online services and mobile applications may, from time to time, contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services.  You are advised to please check these policies before submitting any personal data to these websites or using these services.

Telephone Calls

We may monitor or record telephone conversations to enhance your security and ours, to enable us to handle complaints efficiently, improve our client service and for staff training purposes.  If your telephone conversation with us will be recorded then you will receive a message to this effect prior to the start of your conversation with us.

Providing information about someone else

If you are providing personal data to us about someone else you confirm that they have appointed you to act for them, to consent to the processing of their personal data, and that you have informed them of our identity, of this Policy, and of the purposes (as set out in this Policy) for which their personal data will be processed.

How to access, review, transfer and delete your personal data

We will make your personal data available to you for review pursuant to a simple request from you. If you tell us that the personal data which we hold about you is incorrect or is used inappropriately, we will correct, update or delete such personal data as appropriate.  You also have other rights such as the right to request from us erasure of personal data or portability of personal data or restriction of processing or to object to processing.  For information about how to get access to your personal data and for exercising your rights, please contact us at information@XirCammini.org

Complaint, applicable law and Jurisdiction

Any dispute arising from or related to the acceptance, interpretation or observance of this Policy shall be submitted to the exclusive jurisdiction of the competent Court of Malta which shall apply the laws of Malta; provided however, that:

  1. any dispute concerning XirCammini  shall be submitted to the exclusive jurisdiction of the competent Court of Malta which shall apply the laws of Malta.; and,
  2. if this Policy is incorporated by reference into a contract having its own choice of law and jurisdiction, then any dispute arising from or related to the acceptance, interpretation or observance of this Policy shall be submitted to the jurisdiction, and shall be subject to the governing law, of that contract.

You also have the right to lodge a complaint with a superv

Further details

Further details about your rights can be accessed on the Malta Office of the Information and Data Protection Commissioner website at:  information@XirCammini.org

and on the European Commission’s website at: 

http://ec.europa.eu/justice/data-rotection/individuals/rights/index_en.htm