Introduction

Welcome to Velvet Marketing Consultants’ privacy policy.

Purpose of this privacy policy
This privacy policy aims to give you information on how Velvet collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or simply by browsing through our website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Velvet is the controller and responsible for your personal data (collectively referred to as [“Company”], “we”, “us” or “our” in this privacy policy).
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Trading as Velvet, Operated by Mr Alexander Cutajar.
Email address: [email protected]
Postal address: Apartment 3, Rosamarina Apartments, Triq ix-Xatt, Pieta, Malta
You have the right to make a complaint at any time to the Information and Data Protection Commissioner (IDPC), the Malta regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes.
We keep our privacy policy under regular review. This version was last updated on the th of January 2024.
It is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plugins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Company Data includes Company Information, such as company name, registration address, registration number, country of incorporation, official website, company email address, contact number and billing details.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Online Contact Forms. You may give us your Identity and Contact Data by filling in forms or by corresponding with us on the Company’s Websites (including, but not limited to https://velvetinc.co).
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
o Technical Data from analytics providers and search information providers such as Google or Bitrix24.
4. How we use your personal data
We will only use your personal data in the manner the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where we need to contact you back for enquiries submitted on our website contact forms
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new Company member (a) Identity
(b) Contact
(c) Company Performance of a contract with you
To process our services:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us (a) Identity
(b) Contact
(c) Company
(d) Transaction
(e) Marketing and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to the Company)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey (a) Identity
(b) Contact
(c) Marketing and Communications (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To register you for our events and activities, such as participation of Stakeholder Engagement Meetings
(a) Identity
(b) Contact
(c) Company
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To make use of Photograpy and Videography during our events. (a) Identity
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
(b) Consent: To maintain your contact information and consent on our communications to you.

To provide you with information about our new products and services, new offers, and other and informational material (a) Identity
(b) Contact
(c) Marketing and Communications (a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
(b) Consent: To maintain your contact information and consent on our communications to you.

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have previously requested a service from us from us in accordance with the Processing of Personal Data (Electronic Communications Sector) Regulations. You will not receive marketing communications from us if you have not explicitly subscribed and provided your consent to the Company.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Cookies
When you visit any website including our website, a cookie may be sent to you. A cookie is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing our website. Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you and can customise what you see on the screen according to your registered preferences.
While browsing our Website cookies may be used in the following scenarios:
1. For statistical purposes to track how many users we have and how often they visit our websites. We collect information listing which of our pages are most frequently visited, and by which types of users and from which countries.

2. We use other organisations to collect anonymous user information.
You can turn cookies off but if you do so, you may not be able to use all services on our websites and you might see more pop-ups and other advertising. This is because we won’t be able to limit what you see by using cookies. However, you will still be able to see our editorial content.
By using this website you are agreeing to the use of cookies as described.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with third parties, such as, for example, Service Providers who provide us with I.T. and administration services, and our courier delivery providers; Professional advisers, including lawyers, bankers, auditors and insurers; and Government Authorities and Public Corporations who require reporting of processing activities in certain circumstances.
6. International transfers
We generally do not transfer your personal data outside of Malta or the European Union, however, if we transfer your personal data out of the Republic of Malta, we ensure that a similar degree of protection is afforded to it by ensuring that the country where your personal data is transferred have been deemed to provide an adequate level of protection for personal data by the EU Commission.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
9. Your legal rights
Under certain circumstances, you have various rights in relation to your personal data. In particular, you have a right to:
• obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
• ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
• ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data;
• withdraw consent to our processing of your personal data (to the extent such processing is based on consent);
• receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract;
• object to our processing of your personal data.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please email [email protected].
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.