Toly invites you to read the present Privacy Policy, which illustrates how your personal data are processed by Toly, as well as how you can access and modify your data and preferences.
This Privacy Policy illustrates how Toly collects data, including personal data through various online channels, such as websites, apps, and social networks, and offline, such as at sales offices, customer assistance and events.
This Privacy Policy regulates primarily the collection and processing of personal data according to applicable norms, such as the EU General Data Protection Regulation (Regulation (EU) 2016/679), referred to as “GDPR” and therefore its scope over commercial data, which fall out of the scope of protection of personal data, is limited.
The Privacy Policy furthermore illustrate the use of cookies and related technologies on the Website.
Some sections may not apply you, depending on how you provide your personal data to interact with Toly. Please note that Toly associates the personal data collected through one channel (e.g. this Website) with personal data that Toly collects through other channels and Toly may combine personal data that were originally collected by different entities belonging to Toly itself.
If Toly changes the way it handles your personal data, Toly will update this Privacy Policy and notify you or seek your consent as and when appropriate, usually by placing an updated Privacy Policy on the Website. If Toly makes significant changes that materially alter Toly’s privacy practices, Toly may also notify you by other means, such as sending an email prior to the changes taking effect. Toly reserves the right to make changes to its practices and this Privacy Policy at any time. Toly invites you to check the Website from time to time for any updates or changes to this Privacy Policy.
Toly may also provide you with additional information when it collects personal data where it feels it would be helpful to provide relevant and timely information.
1. WHAT INFORMATION TOLY COLLECTS FROM YOU
Toly collects your personal data through various online and offline sources, your interaction with Toly’s social media channels and other websites, your visits to Toly’s offices, innovation centres, stands and events, Toly’s visits to you and your colleagues, Toly’s interaction with other suppliers of yours, whose services and products, such as filling, complement Toly’s offers.
Your personal data collected by third parties, like other suppliers Toly needs to work with for you will not be passed on to Toly by default and this Privacy Policy is not applicable to them. Toly collects the following personal data you provide Toly with online or offline:
- Contact details, such as your name, your phone number, your email and postal addresses;
- Age, date of birth, gender, nationality, preferred language, interests;
- Invoicing data, including delivery address and payment data. Please note that we do not store the details of your credit card, unless it is necessary for reimbursements; No credit card information is stored in the website. A third-party system (Paypal, APCO etc.) processes the payment;
- Personal preferences, such as communication and language settings;
- Your interactions with Toly, such as transactions history;
- Correspondence with you.
Toly does not knowingly collect personal data of minors.
Unless you are authorised to do so, you are not allowed to provide other people’s personal data.
From time to time Toly organises events, like private shows, presentations, participation in third parties’ fairs and similar, where it may happen that you provide other people’s personal data. You need to ensure that such people have given you their consent to disclose their personal data to Toly and, in case Toly interacts with them, it may refer to you as the source of such contact.
You are not obliged to provide personal data to access the Website.
If you send emails to the addresses indicated on the Website, you agree that, for the sake of replying to such requests, such email addresses and any other personal data in the message are acquired by Toly. Should such personal data not be provided, this may result in users’ requests not being met for lack of essential information.
In any case, you will be able to change communication settings.
1.1 PERSONAL DATA COLLECTED THROUGH THIRD PARTIES
Additionally, where allowed by the law, Toly collects some of your personal data through trusted sources, such as other suppliers, events organisers, payment and delivery service providers, social media, advertisers, analytic data providers, search engines.
Toly also receives personal data you have given to Toly’s sales offices and innovation and manufacturing teams.
In order to provide you with a smooth and enjoyable user experience on the Website and in order to verify the accuracy of your data, Toly links pieces of information gathered through different sources. This includes the linkage of data collected by different entities within Toly.
1.2 INFORMATION AUTOMATICALLY COLLECTED FROM YOUR USE OF TOLY’S WEBSITE(S) AND SOCIAL MEDIA CHANNELS OR INTERACTION WITH OUR ONLINE ADVERTS
Toly automatically collects the following information:
- technical information, including your device’s IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system, unique device identifiers and advertising identifiers;
- information about your visit, including the URL clickstream to, through and from Toly’s Website; Products you viewed or searched for, the content (and any ads) that you view or interact with, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Some of this information is collected using cookies and related technologies. Toly invites you to read the dedicated section on cookies.
2. TOLY COLLECTS AND PROCESSES YOUR PERSONAL DATA FOR THE FOLLOWING REASONS
- To answer your queries on Products;
- To provide you with a quotation, after receiving your query;
- To reply to a purchase order from you or to prepare an offer if you request one;
- To finalise a contract with you, if you and Toly eventually enter into a business relationship;
- To have your opinion on the Products;
- To provide you with customised communications, also through third parties’ help, such ad media marketing managers, advertising agencies, ICT providers etc.;
- To monitor your account, in order to prevent, investigate and/or report frauds, terrorism, misrepresentations, offences, security breaches;
- To investigate on your and others’ complaints about the Website;
- To protect the Website and all its content and to constantly improve it;
- For internal audit and reporting;
- To reimburse you;
- To comply with legal obligations and orders.
3. DISCLOSURE OF YOUR PERSONAL DATA
Toly may disclose your personal data to any of its companies, as well as, where permitted by the law, to:
- other suppliers;
- banks and credit institutions;
- social networks, internet service providers, marketing companies, advertisers etc., whose privacy policies shall apply;
- potential buyers of Toly’s shares or assets, in case of potential merger, split, business transfer, liquidation, bankruptcy proceedings;
- courts of justice and other authorities, as required by the law, or in order to defend Toly’s or third parties’ rights and interests, including those stemming from the general terms of use or contracts with you;
- Toly’s supplier who provide Toly with their services according to our instructions, such as hosting services, marketing managers, data analytics, etc.. Such third parties are not authorised to by Toly to utilise or divulge your personal data, except where necessary for the provision of their services to Toly or in observance of legal requirements.
Your data may be aggregated with those of other users to create an anonymous dataset, i.e. it is impossible to identify you as a person. Such dataset is useful for Toly to understand users’ behaviour and market trends. Toly may share the mentioned dataset with third parties, such as search engines and social media, which could utilise it to customise their ads. In such cases, third parties’ privacy policies shall apply.
4. DATA TRANSFER
If you reside in the European Economic Area (EEA), in Switzerland or in the Russian Federation, your personal data may be stored in servers located in the United States of America.
Toly may transfer your personal data to companies forming part of its group and to its service providers also outside of the EEA and Switzerland and such information may be stored and processes in jurisdictions whose data protection standards are different from those of your Country of residence.
If you reside in the EEA or in Switzerland and your data is transferred outside of these jurisdictions, Toly shall implement measures to ensure that your data is adequately protected by contractual clauses and certifications that reflect the standards of the EEA and Switzerland.
The Website may contain links to and from third parties’ websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Toly does not accept any responsibility or liability for these policies or how those third parties may use your personal data. Please check these policies before you submit any personal data to these websites.
5. DATA CONVERSATION
Your personal data will remain confidential and Toly will not keep it for longer than necessary to ensure the provision of its services, save the need for conservation for a longer period in compliance with regulations, including accounting ones, or in case a contractual relationship with you is established.
It is understood that the data will be stored and processed by Toly for the maximum time allowed by law. At the end of that period Toly will ask users to renew their consent to personal data processing, or will render them anonymous and store them only for statistical or historical purposes.
You will always enjoy the right to cancel your data in applicable situations, at any time.
Data transmitted to any service providers will be processed for the time strictly necessary for the performance of the tasks entrusted to them.
Toly reserves the right to delete accounts and all related data if illegitimate contents, or contents that are harmful to the image of Toly and / or its products or a third party.
6. DATA PROCESSING METHOD
Data processing is carried out mainly through electronic and telematics systems by Toly and third parties, carefully selected for their reliability and skills, in order to carry out operations that are essential to achieve the purposes of the Website.
7. YOUR RIGHTS
7.1. ADVERTISING, MARKETING AND CUSTOMIZATION
If you wish to receive communications and updates on Toly’s products and services, events and other news, you can indicate your communication preferences through the relevant checkboxes on the Website or on customer cards with Toly salespeople.
Some of such communications may be customised to your specific interests and preferences.
If you wish to stop receiving marketing and/or customised communications, simply follow the opt-out instructions in the relevant page or using Toly’s contact details.
7.2. COOKIES
You can set your browser to refuse all or some browser cookies or to alert you when cookies are being used or you can use the opt-out tools provided. Please visit Toly’s cookie policy.
In accordance with applicable law, you may be entitled to ask for a copy of your personal data, to amend it, erase or restrict its processing, or to ask Toly to transfer some of this personal data to other organisations. You may also have rights to object to some processing and, where Toly have asked for your consent to process your personal data, to withdraw this consent. Your rights may be limited in some situations, for instance legal requirements or contractual obligations.
8. UPDATES
This information may be updated over time to adapt legal or commercial changes. Any material change will be published at this address and users undertake to periodically monitor the Website to ensure they are up-to-date with the latest privacy policy.
9. DATA CONTROLLER
Navigation through the Website may involve processing of data belonging to persons identified or identifiable. The subject in charge of such data processing is Nick Xuereb, which may, at its sole discretion, partially or entirely delegate such tasks to external technical agencies, which will be required to treat your data confidentially. Toly undertakes not to use them for purposes other than those accepted by users through this policy. Toly reserves the right not to respond to illegitimate requests or those that are not based on lawful grounds.
10. CONTACT DETAILS OF THE DATA PROTECTION OFFICER
Nicholas Xuereb, Chief Financial Officer
Toly Group – Corporate Offices
BLB036A, Bulebel Industrial Estate, Zejtun, Malta, ZTN3000,
Tel: (+356) 21693520 – Email: [email protected]