VOCA Privacy Policy
Introduction
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR). By means of this data protection declaration, our choir would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
Data Controller
The Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
The Vice President
VOCA
c/o Villa Maria Dolores
96, Brared Street
Birkirkara BKR1253
Malta.
What data do we collect and why do we store and process your Personal Data?
VOCA collects a series of general data and information when a data subject either becomes a member of the choir, subscribes through our website or makes contact with the choir through other communication channels. The choir also collects date of its clients when booking a private event. This data and information is stored securely by the choir’s committee members on their personal computers. Generally, when a data subject becomes a member or requests a private event we collect the following: Name & Surname, Address, Telephone and Mobile numbers, email addresses and emergency contact numbers.
The data collected is never used by Voca choir to draw any conclusions about the data subject. We use this data to be able to contact our members and clients and to liaise on the logistics of the services we provide.
Where we are obliged to process your personal data in fulfilment of a legal requirement to which we are subject, or in pursuance of performing an obligation under a contract which we have with you, and you fail to provide us with that data, we may not be able to perform the Services as agreed upon.
Who collects personal data?
Data is collected by
Retention Period
We usually retain the personal data of our members for the period during which they are considered as members. As a policy, VOCA retains all personal data for two years from the date of the last contact. After this period, the data subject is no longer considered a member or client and their data is erased unless asked to do otherwise by the data subject.
In the case of marketing communications we ask for specific permission from the data subject to retain their email address and/or phone number indefinitely. The data subject is reminded continuously in every mail shot that they may opt out of this communication.
Who we share your data with
VOCA does not share any data of the data subject with any third party unless required in order to fulfil a contractual obligation through the services we offer. Any such sharing of data would be performed after the consent of the data subject. In such cases we purposely share only the data that is required to fulfil that obligation rather than all the personal data about a data subject.
VOCA may, disclose and divulge your personal data, where disclosure is requested by public authorities in accordance with a legal obligation, such as law enforcement, tax and customs authorities, provided that the personal data which is requested is necessary by the said public authority to carry out a particular inquiry in the general interest, in accordance with European Union or Member State law. We may also disclose your data if we are under a legal obligation to do so, in pursuance of a judgment or court order, in order to enforce our Terms of Use or protect our rights.
Transferring of data outside of the European Union, particularly to countries which might not have appropriate data protection safeguards in place, will be based on your consent.
Subscription to our mailing list
On our website, users are given the opportunity to subscribe to our mailing list. VOCA uses this mailing list to inform its clients and audience about upcoming events. These emails may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers to join the mailing list and (3) if the data subject Opts in to receive such correspondance. A confirmation e-mail will be sent to the e-mail address when a user subscribes. A double opt-in procedure is employed. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive such correspondance.
The personal data collected as part of the registration process for our mailing list will only be used to send our newsletters and related correspondance.
Cookie Policy on our website
VOCA’s website uses cookies, which are small text files that are placed on users’ secondary storage to assist in enhancing your browsing experience by displaying content that is more relevant and applicable to you and your preferences. Furthermore, cookies are used for the proper functioning of the website. Our website will request your acceptance for the use of these cookies. VOCA does not use data acquired through cookies to draw any conclusions about the data subject.
Data Security
The processing of your data will be in accordance with the provision of the GDPR. VOCA takes appropriate precautions to preserve your rights and prevent any corruption, loss, damage or destruction of your personal data. The choir has appropriate security arrangements, including, where appropriate, limited physical access, administrative, procedural, and information ICT measures to prevent unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal or destruction of personal data. In case our systems are compromised and suffer a data breach where the personal data of our members is exposed, VOCA will promptly inform the data subject and the Office of the Data Protection Commissioner.
VOCA’s committee members may access personal data strictly on a “need to use” basis for the performance of their duties. Committee members are aware of the confidential nature of personal data and how they should handle it in strictest confidence.
How to contact us
You can contact us as follows:
VOCA
c/o Villa Maria Dolores
96, Brared Street
Birkirkara BKR1253
Malta.
Phone Number: +(356) 99869922
Email: [email protected]
Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is erased in accordance with legal requirements.
You rights as a data subject
As a data subject GDPR provides you with extensive rights as follows:
Right of confirmation
Each data subject has the right to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes that his data is no longer processed they may contact the company at any time.
Right of access
Each data subject shall have the right to obtain free information about his or her personal data stored at any time as well as a copy of this information, the purpose of processing, with whom this data has been disclosed if any, the length of time the data will be retained, the existence of the right to request erasure of personal data, the existence of the right to lodge a complaint with the Data Protection authority. Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third parties and have the right to be informed of the appropriate safeguards relating to the transfer.
Right to rectification
Each data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact the company.
Right to erasure (Right to be forgotten)
Each data subject shall have the right to request the erasure of personal data concerning them without undue delay. The controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
If one of the above reasons applies, and a data subject wishes to request the erasure of personal data stored by VOCA, he or she may, at any time, contact any member of the committee who shall promptly ensure that the erasure request is complied with immediately.
Right of restriction of processing
Each data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
If one of the above conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by VOCA, he or she may, at any time, contact any member of the committee who will arrange the restriction of the processing.
Right to data portability
Each data subject shall have the right to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit this data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent.
Furthermore, in exercising his or her right to data portability the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any committee member of VOCA.
Right to object
Each data subject shall have the right to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her. VOCA shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If VOCA processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to VOCA to the processing for direct marketing purposes, then VOCA will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by VOCA for scientific or historical research purposes, or for statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the data subject may contact any committee member of VOCA.
Automated individual decision-making, including profiling
Each data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, VOCA shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any committee member of VOCA.
Right to withdraw data protection consent
Each data subject shall have the right to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any committee member of VOCA.
Data protection for applications and the application procedures
The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller.
Last revision 23rd January 2023
Introduction
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR). By means of this data protection declaration, our choir would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
Data Controller
The Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
The Vice President
VOCA
c/o Villa Maria Dolores
96, Brared Street
Birkirkara BKR1253
Malta.
What data do we collect and why do we store and process your Personal Data?
VOCA collects a series of general data and information when a data subject either becomes a member of the choir, subscribes through our website or makes contact with the choir through other communication channels. The choir also collects date of its clients when booking a private event. This data and information is stored securely by the choir’s committee members on their personal computers. Generally, when a data subject becomes a member or requests a private event we collect the following: Name & Surname, Address, Telephone and Mobile numbers, email addresses and emergency contact numbers.
The data collected is never used by Voca choir to draw any conclusions about the data subject. We use this data to be able to contact our members and clients and to liaise on the logistics of the services we provide.
Where we are obliged to process your personal data in fulfilment of a legal requirement to which we are subject, or in pursuance of performing an obligation under a contract which we have with you, and you fail to provide us with that data, we may not be able to perform the Services as agreed upon.
Who collects personal data?
Data is collected by
- By the choir committee members through physical contact;
- Through our website and social media pages;
- Through emails opened and actioned by our committee members;
- Through phone calls;
- Through postal mail;
Retention Period
We usually retain the personal data of our members for the period during which they are considered as members. As a policy, VOCA retains all personal data for two years from the date of the last contact. After this period, the data subject is no longer considered a member or client and their data is erased unless asked to do otherwise by the data subject.
In the case of marketing communications we ask for specific permission from the data subject to retain their email address and/or phone number indefinitely. The data subject is reminded continuously in every mail shot that they may opt out of this communication.
Who we share your data with
VOCA does not share any data of the data subject with any third party unless required in order to fulfil a contractual obligation through the services we offer. Any such sharing of data would be performed after the consent of the data subject. In such cases we purposely share only the data that is required to fulfil that obligation rather than all the personal data about a data subject.
VOCA may, disclose and divulge your personal data, where disclosure is requested by public authorities in accordance with a legal obligation, such as law enforcement, tax and customs authorities, provided that the personal data which is requested is necessary by the said public authority to carry out a particular inquiry in the general interest, in accordance with European Union or Member State law. We may also disclose your data if we are under a legal obligation to do so, in pursuance of a judgment or court order, in order to enforce our Terms of Use or protect our rights.
Transferring of data outside of the European Union, particularly to countries which might not have appropriate data protection safeguards in place, will be based on your consent.
Subscription to our mailing list
On our website, users are given the opportunity to subscribe to our mailing list. VOCA uses this mailing list to inform its clients and audience about upcoming events. These emails may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers to join the mailing list and (3) if the data subject Opts in to receive such correspondance. A confirmation e-mail will be sent to the e-mail address when a user subscribes. A double opt-in procedure is employed. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive such correspondance.
The personal data collected as part of the registration process for our mailing list will only be used to send our newsletters and related correspondance.
Cookie Policy on our website
VOCA’s website uses cookies, which are small text files that are placed on users’ secondary storage to assist in enhancing your browsing experience by displaying content that is more relevant and applicable to you and your preferences. Furthermore, cookies are used for the proper functioning of the website. Our website will request your acceptance for the use of these cookies. VOCA does not use data acquired through cookies to draw any conclusions about the data subject.
Data Security
The processing of your data will be in accordance with the provision of the GDPR. VOCA takes appropriate precautions to preserve your rights and prevent any corruption, loss, damage or destruction of your personal data. The choir has appropriate security arrangements, including, where appropriate, limited physical access, administrative, procedural, and information ICT measures to prevent unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal or destruction of personal data. In case our systems are compromised and suffer a data breach where the personal data of our members is exposed, VOCA will promptly inform the data subject and the Office of the Data Protection Commissioner.
VOCA’s committee members may access personal data strictly on a “need to use” basis for the performance of their duties. Committee members are aware of the confidential nature of personal data and how they should handle it in strictest confidence.
How to contact us
You can contact us as follows:
VOCA
c/o Villa Maria Dolores
96, Brared Street
Birkirkara BKR1253
Malta.
Phone Number: +(356) 99869922
Email: [email protected]
Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is erased in accordance with legal requirements.
You rights as a data subject
As a data subject GDPR provides you with extensive rights as follows:
Right of confirmation
Each data subject has the right to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes that his data is no longer processed they may contact the company at any time.
Right of access
Each data subject shall have the right to obtain free information about his or her personal data stored at any time as well as a copy of this information, the purpose of processing, with whom this data has been disclosed if any, the length of time the data will be retained, the existence of the right to request erasure of personal data, the existence of the right to lodge a complaint with the Data Protection authority. Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third parties and have the right to be informed of the appropriate safeguards relating to the transfer.
Right to rectification
Each data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact the company.
Right to erasure (Right to be forgotten)
Each data subject shall have the right to request the erasure of personal data concerning them without undue delay. The controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent.
- The data subject objects to the processing and there are no overriding legitimate grounds for the processing.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with other legal obligations.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the above reasons applies, and a data subject wishes to request the erasure of personal data stored by VOCA, he or she may, at any time, contact any member of the committee who shall promptly ensure that the erasure request is complied with immediately.
Right of restriction of processing
Each data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the above conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by VOCA, he or she may, at any time, contact any member of the committee who will arrange the restriction of the processing.
Right to data portability
Each data subject shall have the right to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit this data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent.
Furthermore, in exercising his or her right to data portability the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any committee member of VOCA.
Right to object
Each data subject shall have the right to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her. VOCA shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If VOCA processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to VOCA to the processing for direct marketing purposes, then VOCA will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by VOCA for scientific or historical research purposes, or for statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the data subject may contact any committee member of VOCA.
Automated individual decision-making, including profiling
Each data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, VOCA shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any committee member of VOCA.
Right to withdraw data protection consent
Each data subject shall have the right to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any committee member of VOCA.
Data protection for applications and the application procedures
The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller.
Last revision 23rd January 2023