GDPR is a new EU regulation, which seeks to strengthen the protection given to Personal Data. In the highly digitized world we live in today, information has become essential. We strive to ensure that any Personal Data that we have in our possession, is properly processed in terms of the law and shall strive to ensure proper protection for your Personal Data. Your Personal Data is critical for our business and for the provision of our services and thus its security and proper use is of paramount importance to us.
Personal Data is personal information about an individual, like you. We collect such information about our customers for relationship management, statistical reasons and for marketing purposes and also on our employees or potential employees or agents when they apply for a position with us. We may also collect some personal information from other individuals who are not our customers, for marketing purposes, subject to their consent.
Personal Data may also be of a general nature and of a special nature. Generic Personal Data refers to data such as names, surnames, contact details and similar data which can be used to identify a person. Special categories of Personal Data relate to more confidential kind of Personal Data such as health data. Information regarding the different kinds of Personal Data we collect can be found in section 3 of this document.
When you provide your Personal Data to a third party, you are passing such data to either a controller or a processor.
A Controller of your Personal Data is an individual or a company who has the power to determine the exact uses of the Personal Data you have supplied to him. On the other hand, a Processor is a third party who is processing and thus utilising your Personal Data on behalf of a controller.
RE/MAX Malta is a franchise set-up composed a numerous independent franchise companies, all of which have a franchise relationship with the RE/MAX Master Franchise Owner in Malta. In this document, this shall be referred to as the “RE/MAX Franchise”.
The RE/MAX Franchise generally collects Personal Data regarding our clients at the below stages of our relationship with our customers:
We also Process Personal Data on our potential and actual employees and on any other party who engages with the RE/MAX Franchise.
When any of our RE/MAX Franchise offices are approached by a client seeking to buy or rent a property, Personal Data shall be collected by that office, who shall be Controller of this Personal Data. This Personal Data will however be shared with the RE/MAX Master Franchise Owner, who shall also be a Controller of your Personal Data. Your Personal Data will be shared between the members of the RE/MAX Franchise so we can assist you in providing our services.
Similarly, to the above, when any of our RE/MAX Franchise offices are approached by a client seeking to sell or lease out a property, Personal Data shall be collected by that office, who shall be Controller of this Personal Data. This Personal Data will also be shared with the RE/MAX Master Franchise Owner, who shall also be a Controller of your Personal Data. Your Personal Data will be shared between the members of the RE/MAX Franchise so we can assist you in providing our services.
When a transaction can be concluded and thus a property sale or lease can be finalised, the RE/MAX Franchise office assisting in the transaction will require the collection of additional Personal Data from all the parties involved. Such Personal Data collected in this regard is required under law and shall be primarily held and Processed by the same office assisting the transaction and thus that RE/MAX Franchise office shall be Controller of this Personal Data. Any Personal Data collected in this regard may be in certain cases shared with the RE/MAX Master Franchise Owner, where in such a case the RE/MAX Franchise Holder would also become a separate Controller of this Personal Data, however the data will not be further shared with the other members of the RE/MAX Franchise.
Should you apply to work with the RE/MAX Franchise, your Personal Data shall be collected and processed by the RE/MAX Franchise office with who you will be engaged. Your Personal Data will also be shared with the RE/MAX Master Franchise Owner, who will be a separate Controller of your Personal Data.
During your visit of this website, we will automatically collect the following Personal Data about you:
If you are looking to sell, buy or rent a property, we may obtain Personal Data from this website or from other members of the RE/MAX Franchise. The Personal Data we process in this context is:
This information will only be obtained if you provide this information yourself to our franchise network or if you input this data in our website.
You may also provide us information when applying for a position with us. In such a case the personal information that we process is:
In cases where we ask you to provide any Personal Data, there is no obligation to do so, but if you do not, you will not be able to use all functions of our website, apply with us or to make use of our real estate services in general.
Certain Personal Data is more sensitive and is classified as special categories of Personal Data, which relates to the following:
In any case we will clearly explain the purposes for which we wish to use such Personal Data when it is being collected, and, if necessary, obtain your consent at that time. In such cases, you will be able to withdraw your consent at any time. We will never process such Personal Data without obtaining your prior written consent unless otherwise specified by law.
We will use your Personal Data to provide this website to you as a user of this website, to generate usage statistics, to improve and further develop this website, to provide real estate services to you, to respond to your requests and messages, to send you our newsletter if you have subscribed to it, to contact you about properties that may interest you, and to analyse your data in aggregate form for business intelligence purposes.
If you have applied for a position with us, we will process your data to determine your suitability for the position with us.
We shall always process your Personal Data in terms of the law and therefore we shall always have a proper legal basis to Process your Personal Data;
As far as this is necessary for the purposes set out above, we may transfer your Personal Data to third parties as follows:
We shall be providing your Personal Data to other members of our franchise.
Your Personal Data shall may be found in our internal databases which is managed by an external service provider.
Your Personal Data may be provided to our sales/rent associates as a normal part of our business.
Your Personal Data may be used in our marketing material and thus may be sent to marketing service providers.
Data on our servers, which may contain Personal Data is stored with external third parties and on the cloud through service providers.
Your Personal Data may be shared with the relevant public authorities as required under law.
Should you require a detailed list of processors, kindly contact us as indicated below and we would provide you with more detail.
Some of the recipients referred to above are located in or process Personal Data outside of your country. The level of data protection in another country may not be equivalent to that in your country. However, we only transfer your Personal Data to countries where the EU Commission has decided that they have an adequate level of data protection or we take measures to ensure that all recipients provide an adequate level of data protection. We do this for example by entering into appropriate data transfer agreements based on the Standard Contractual Clauses implemented through Commission Implementing Decision (EU) 2021/915 of 4 June 2021 on standard contractual clauses between controllers and processors under Article 28(7) of Regulation (EU) 2016/679 of the European Parliament and of the Council and Article 29(7) of Regulation (EU) 2018/1725 of the European Parliament and of the Council and the Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council as regards the introduction of an alternative set of standard contractual clauses for the transfer of Personal Data to third countries). Such agreements are accessible upon request from email@example.com
In terms of current laws, we may be required to transfer your Personal Data to certain regulatory or government authorities when subject to a proper and lawful request in terms of the law. We may be obliged to provide such data and we may also be prevented from informing you that such data has been provided.
In certain cases, as allowed by law, we may receive Personal Data about you from third parties, such as public authorities mainly relating to searches dealing with immovable property. Any Personal Data collected in this regard shall be processed and stored in terms of the law.
We will retain your data that we collect automatically when you visit this website for no longer than six months.
If you have subscribed to our newsletter, we will retain you email address until you unsubscribe from our newsletter. If you have registered on our website, we will retain your data for as long as your account exists and thereafter only for as long as there are any legal obligations to retain your data.
Moreover, we will retain your Personal Data that we receive from other members of the RE/MAX Franchise at least until the end of your business relationship with the RE/MAX Franchise unless there are statutory retention obligations or potential claims that are not yet time-barred.
In this regard we shall keep;
If you have applied for a position with us, we will delete all your Personal Data if we do not engage you after 4 months, unless you provide consent to keep the Personal Data for any longer.
We also process your personal data in the form of CCTV footage as stated previously. Such recordings shall be kept for 7 days unless the need arises to keep the recordings for a longer period of time due to legal obligations or to protect our legitimate interest.
Should in any event, we are required to keep your Personal Data for any longer period as allowed by law, your Personal Data shall be kept secure and shall be deleted when we are allowed by law to delete such Personal Data.
Under applicable data protection law, you have these rights:
When you are making such requests please note the below:
In case of any complaints, you also have the right to lodge a complaint with the competent data protection authority in Malta or in the Member state in which you work or reside.
We shall take all the necessary measures as required by law to ensure proper security and protection to your Personal Data. Such measures may include encryption, use of firewalls, anti-virus software and specialized security software, access restrictions and limitations, strict enforcement of policies and any other measures that we may enforce from time to time. Our measures shall strive to ensure that:
Despite our best efforts however, we cannot provide a 100% guarantee in relation to our system security.
We apply certain surveillance and security measures at our offices and on our systems. At our premises, measures like CCTV footage is recorded and retained in terms of our retention policy and security requirements. This Personal Data shall be stored and managed in terms of current data protection law.
We shall always send marketing material to you if authorised by law to do so and we shall never send unsolicited marketing material in this regard. If you subscribe to our website, create a MY RE/MAX account, or subscribe to our services, we shall be sending you information regarding property that would interest you, in terms of the information you would have provided us. Thus we would be relying on your consent to send you such information which you can withdraw at any time.
Our website contains hyperlinks to websites operated by other companies or businesses which are not related to us in any way. These websites are managed by companies who have their own data protection policies and procedures in place on which we have no control over. Therefore, we are not be responsible for the way the owners of these websites process your Personal Data.
Should you have any questions regarding our data protection policies or would like to make a request in relation to your Personal Data, please contact us on the below:
JK Holdings Limited
72/73,Gorg Borg Olivier Street, St Julian's, Malta
The contact email of our DPO is: