We at The Maltese National Federation of Past Pupils and Friends of Don Bosco (‘We’ / ‘Us’) are strongly committed to respecting and protecting our users’ (‘You’ / ‘Your’) privacy, and therefore are committed to protect your Personal Data (i.e. information that identifies you) as though it is our own.

This privacy policy describes our practices relating to the Personal Data of users of the Checkin Camino (the ‘App’) and make use of our online facilities. For all our services, the Data Controller — the entity that’s responsible for your privacy — is The Maltese National Federation of Past Pupils and Friends of Don Bosco with its address at marica@friendsofdonbosco.mt

If you have any questions about how we protect your privacy, get in touch here: marica@friendsofdonbosco.mt

 

The Information We Collect

Such personal information may be requested from you when you fill in a field in order to utilise the App. Certain data is also necessary in order for the App to function correctly.

If you send us emails or contact us, then the Personal Data we process will depend on what you send us in the email.

 The information we collect from you normally includes the following:

 

  1. Name + Surname;
  2. Contact Details;
  3. Email address
  4. Country of Origin
  5. Telephone Number
  6. Date of Birth;
  7. Gender
  8. Location Data;
  9. Data identifying your mobile phone or portable device.

 

How and Why We Use Your Information

When you create a  Checkin Camino account, we ask you to provide your email address, name, age, gender, nationality, and password. This information is used to calculate the route which you are undertaking and to enable you to receive a certificate of achievement. The legal ground for processing this information for these purposes is your consent. You can withdraw your consent at any point by contacting marica@friendsofdonbosco.com.

We process your email address and password because you use your email address and password to sign into your account. The legal ground for processing your email address and password for this purpose is our legitimate interest in protecting the security of your account.

We also process your email address for the purpose of sending you important information about the App, your account, and our accompanying products or services. The name you provide is associated with your account profile and is displayed when you submit queries through the App or achieve trophies or milestones.

Your email address is also processed to notify you if you have violated any terms of usage of the App. Our legal ground for this is legitimate interest in providing a quality experience and ensuring adherence to terms.

We also process your activity data, in an aggregated manner to analyse usage and trends and develop or improve features, routes, services and rewards. The legal ground for this processing is our legitimate interest in providing relevant and quality features and services.

Location Data – You can choose to upload activities and activity data and monitor your movement along routes. Your activity data is set to “Private” by default. We process your activity data, if you choose to upload it to the App, to enable you to analyse your activity data, see your location on your activity course and segment maps, track your goals, and, if you wish, share your activity data with others. The legal ground for this processing is your consent, which you can withdraw at any time within your account.

 

Analytical Data – We collect analytical data from users about their usage of the App. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the device, language settings, what information and files have been downloaded to the app, device model, hardware and operating system information, and information relating to how the app functions. We utilize this data to improve the quality and functionality of the App and other apps we are or may be developing; to develop and market products and features that best serve You and other users; and to help identify and fix App stability issues as quickly as possible. The legal ground for processing this analytical information is our legitimate interest in understanding how users interact with our product so we can enhance the user experience and functionality of our apps.

 

Retention Periods

 We will keep Personal Data while your account with us is active (if you have an account) or until such time as you ask us to stop communications with you, unless we need to keep the data for longer;

 We may keep certain categories of Personal Data for longer in order to meet any legal or regulatory requirements, or to resolve a legal dispute;

We may keep different types of Personal Data for different lengths of time if required by law (for instance, we may need to keep certain Personal Data relating to purchases for about 10 years in order to comply with tax/VAT reporting requirements);

 

Sharing Your Information 

We do not, and will not, sell any of your Personal Data to any third party – including your name, address, email address etc. It is not our business to do so – and we want to earn your trust and confidence.

Your Rights 

 

You enjoy several rights relating to your personal information:

(i) The right to be informed about how your personal information is being used;

We need to be clear with you about how we process your Personal Data. We do this through this Privacy Policy, which we will keep as up to date as possible.

 

(ii) The right to access the personal information we hold about you;

You can access the Personal Data we hold on you by contacting us on: marica@friendsofdonbosco.mt or deliver a written request to Data Protection Correspondent at louis@friendsofdonbosco.mt

To process your request, we will ask you to send us proof of identity so that we can be sure we are releasing your Personal Data to the right person.

We will carry out our best efforts to process your request within one month or, if the request is particularly complex, two months. We can provide you with a copy of your Personal Data in electronic format.

If we consider the frequency of your requests as being unreasonable, we may refuse to comply with your request. In those circumstances, if you disagree, you can complain to the data protection authority – in Malta, the Information and Data Protection Commissioner.

 

(iii) The right to request the correction of inaccurate personal information we hold about you;

We appreciate feedback from you to ensure our records are accurate and up-to-date. If you think that the information we hold about you is inaccurate or incomplete please contact us on: marica@friendsofdonbosco.mt or deliver a written request to Data Protection Correspondent at louis@friendsofdonbosco.mt

 

(iv) The right to request that we delete your data, or stop processing it or collecting it;

You can ask us to delete your Personal Data; however, this is not an absolute right.

In spite of a request for erasure, we may be justified to keep Personal Data which we need to keep, e.g. (i) to comply with a legal obligation; and (ii) in relation to the exercise or defence of any legal claims.

When you ask us to delete your Personal Data, we assume that you do not want to hear from us again.

Other than as described above, we will always comply with your request and do so promptly. We would carry out our best efforts to notify any third parties with whom we have shared your Personal Data about your request so that they could also comply.

In order to request to delete, stop processing or collecting it, contact us on: marica@friendsofdonbosco.mt or deliver a written request to Data Protection Correspondent at louis@friendsofdonbosco.mt

 

(v) The right to stop direct marketing messages;

 

(vi) The right to object to certain processing based on legitimate interest;

You have a right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling using automated means.

 

(vii) The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;

 

(viii) The right to withdraw consent for other consent-based processing at any time;

 

(ix) The right to request that we transfer or port elements of your data either to you or another service provider;

You have the right to move, copy or transfer your Personal Data from one organisation to another. If you do wish to transfer your Personal Data we would be happy to help.

If you ask for a data transfer, we will give you a copy of your Personal Data in a structured, commonly used and machine-readable form. We can provide the Personal Data to You directly or, if you request, to another organisation.

Please note that we are not required to adopt processing systems that are compatible with another organisation, so it may be that the recipient organisation cannot automatically use the Personal Data we provide. When making a transfer request, it would be helpful if You can identify exactly what Personal Data You wish us to transfer.

In order to request the transfer of your data, contact us on: marica@friendsofdonbosco.mt or deliver a written request to Data Protection Correspondent at louis@friendsofdonbosco.mt

(x) The right to complain to your data protection regulator — in Malta – the Information and Data Protection Commissioner (IDPC)

Please appreciate that the rights must be exercised within some limitation – for example, if you ask us for information we can only give you what relates to you and not what relates to other persons. When we receive requests, we may also request that you identify yourself and provide documentation or information for verification (we would not want to disclose information to the wrong person). Unreasonable requests may be subjected to a reasonable fee or refusal to respond.

 

Security of Your Personal Data 

You may complete a registration process when you sign up to use the App. This may include the creation of a username, password and/or other identification information. Any such details should be kept confidential by you and should not be disclosed to or shared with anyone. Where you do disclose any of these details, you are solely responsible for all activities undertaken where they are used. 

Whenever you create a password, in order to protect your account you should choose a strong password, meaning it should be lengthy and include a mixture of letters and numbers with mix of CAPS.

We do our best to keep the information you disclose to us secure. However, we can’t guarantee or warrant the security of any information which you send to us.

Security measures which have been implemented to secure information transmitted over our website or stored on our systems include the following:

  1. Use of secure servers;
  2. Use of firewalls;
  3. Use of encryption;
  4. Physical access controls at data centres;
  5. Information access controls;
  6. Use of back-up systems;

 

Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.

Changes to How We Protect Your Privacy 

The App is continually under review – new functions and features are periodically added and improved to interface, thus changes to our Privacy Policy may be required from time to time.

We therefore encourage you to check our Privacy Policy on a frequent basis.

 

How To Contact Us

We are always happy to hear from you, whether to make a suggestion but especially if you feel we can do better. If you have any questions about this Privacy Policy, or if you wish to make a complaint about how we have handled your personal information, please contact us at:

 

The Maltese National Federation of Past Pupils and Friends of Don Bosco

14, St John Bosco Street

Sliema

Malta

 

marica@friendsofdonbosco.mt

 

We have appointed a Data Protection Correspondent who may be contacted here: louis@friendsofdonbosco.mt