General rules of collecting, processing, distributing, use and storage of AUTOMATA users personal data will be set forth. This policy will also cover disputes concerning privacy under the General Data Protection Regulation (GDPR), in accordance with the data protection regulations applicable to AUTOMATA. By accessing the Website and its services, or clicking the “REGISTER” button, it is presumed that the user consents that they have fully read, understood and accepted this policy. If the policy terms are not agreed with, the AUTOMATA site and services should not be used.
Consent of the data subject is any intelligent, knowledgeable and informed consent of the data subject's wishes by which he or she, by a tangible or otherwise observable action, constitutes agreement to the processing of personal data relating to them.
b) Controller or controller responsible for the processing The controller or controller responsible for the processing of this information is the natural or legal person, public authority, agency or other registered entity which, alone or in conjunction with other individuals or groups, determines the purposes and means or methods of the processing of personal data; where the purposes and means of such processing are determined by current Maltese legislation.
A cookie is a digitised file possessing an identifiable digital component (a string of letters and numbers) that is transferred by a web server to a internet browser and is then stored by said browser. This identifiable component is then relayed back to the web server on each and every occasion that the internet browser requests a page from the web server.
Cookies can be categorized into two differing sections, "continuous" cookies or "one-time" cookies. A continuous cookie will be stored by an internet browser and it will remain valid until its predetermined expiry date, unless deleted by the user before said expiry date. A one-time cookie on the other hand, will expire at the end of the user’s singular session, when the web browser is closed and the individual session has ended. Cookies of these two natures do not generally possess any data that can personally identify a specific user, but personal data that we may store about you may be traced to the information stored in and obtained from these cookies. For more information on cookies, their uses and how you can manage them please go to www.allaboutcookies.org.
d) Data subject
A data subject can be defined as an identifiable natural person, whose personal data is processed by the controller or automated electronic system that is under the purview of the designated controller responsible for the processing of such information.
e) Personal data
Personal data can be defined as any information relating to an identifiable sovereign person (defined above as the data subject). An identifiable sovereign individual is a naturalised individual that can be distinguished, directly or indirectly, by analysing a unique combination of recognisable content such as a given name, residential address, browsing history or other information that could be collated and used for identification, such as occupation or education status.
Processing is any method or set of methods which are performed on personal information or on sets of personal information, whether or not by automated means, such as collection, collation, organisation, storage, editing or retrieval, consultation, notification by transmission to our other platforms, release or otherwise making ready, alignment or combination, constraint, removal or outright destruction.
A processor is a legally sovereign person, public authority such as government or other registered body which processes user’s personal information on behalf of the controller, under the conditions previously defined by the controller. These processors may also take the form of automated systems that performs processing acts pre-defined by the controller.
Profiling ascertains to any form of automated processing of personal information consisting of the use of personal data to analysis specific personalised and unique aspects relating to a natural person, in particular to analyse or estimate aspects concerning that natural person's performance at work, financial situation, health status, personal or sexual preferences, interests, personal reliability, behavior patterns, location or repeated movements.
Pseudonymisation is the processing of personal information in a specialised method so that personal data can no longer be attributed to any specific data subject, without the utilisation of alternative information, provided that such additional information is kept separate from other collated data and is subject to technical and structural measures to make sure that the personal data cannot be attributed to an identified or identifiable natural person.
Recipient is a natural or legal person, public authority such as government, profit or non-profit agency or another organised and registered body, to which the personal information was given access to, whether a third party or not. However, public authorities which may gain access to this personal data if it is within the structural framework of a particular investigation in accordance with enforceable Union or Member State legislation shall not be considered as recipients; the processing of this data by those public governmental authorities shall be in compliance with the applicable data protection rules according to the intentions of the processing.
k) Restriction of processing
Restriction of processing is the designation of held personal information with the intention of constraining or otherwise limiting their processing in the future.
l) Sensitive personal information
Any information about an individual that reveals their racial background, ethnic origin, political tendencies, affiliate or activity, religious or social beliefs and activism pertaining to this potential involvement, or public group membership, genetic markers or other health related information, biometric information for the purpose of uniquely identifying an individual, information concerning health or data pertaining to a natural person’s sexual activities, interests or sexual orientation. AUTOMATA does not collect, collate, access or store such information.
5. The data controller of this Website is Zaied Al-Sultani. Contact details for him can be gained by contacting : firstname.lastname@example.org
m) Third party
Third party is a natural or legal person, registered public authority, profit or non-profit agency or recognisable body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal information gained from the data subject by legal means.
A group of interrelated website platforms owned and operated by AUTOMATA, available for access on the Internet via address: www.automata.live.
All personal information belonging to the data subject is processed with goal of compliance with a legal obligation under Art. 6(1) of GDPR under which the data controller is required to acquire consent of the data subject for specific processing methods with personal data.
6. The Website of AUTOMATA acquires a set of generalised data and information when a data subject or automated system ‘dials up’ the website. This general data and information is stored in the designated server log files.
7. The following data might be collected, gathered or otherwise collated for generalised means only:
(1) the internet browser brand, platform and its version;
(2) the user’s operating system used by the platform accessing our webpage and associated pages.
(3) the specific internet website from which an accessing network or individual system gains access to the website or associated pages.;
(4) the sub-websites that are controlled, in part or whole by AUTOMATA or its associated and approved partners.
(5) the date and time of access to the Internet site;
(6) an Internet protocol address (IP address);
(7) the Internet service provider of the accessing system; and
(8) any other similar data and information that may be used in the event of attacks on our information technology systems. Naturally this is needed in the event of an attempted security incursion.
8. When using general data and information, AUTOMATA does not make any assumptions about the data subject. In essence this information is required by us to (1) For our website content to be delivered quickly and in the manner in which is was designed, (2) to further streamline the content and delivery of our website and its advertising features, (3) ensure and provide for the long-term viability and security of our information technology systems, structures and procedures, as well as our native website technology, and (4) provide the relevant law enforcement bodies with any data necessary for criminal prosecution in case of a cyber-attack or other attempted incursion by a malevolent actor on any of our data systems, structures and platforms. Therefore, AUTOMATA analyzes anonymously collated data and information unbiasedly, with the intent of raising the data protection and data security of our company and its associated platforms, and to ensure an optimal level of protection for the personal information we process during our standard business operation. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
9. The following information can be collected for service purposes:
(1) Contact information, such as name, phone number, home address, and email address;
(2) Account information, such as username and password;
(3) Information related to your virtual wallets public addresses;
(4) Financial information, such as basic bank account information, bank statements, and historical trading information;
(5) Identity verification information, such as images of your government issued ID, passport, national ID card, or driving license.
(6) Residence verification information, such as Utility bill details or similar information that suffices with current legislative requirements.
|Purpose||Description||Type & Expiry|
|Performance (i.e., User's Browser)||Our website platforms are constructed using commonplace internet frameworks and system infrastructure. These features, platforms and interfaces may have built-in cookies which help us solve compatibility problems and improve performance via the quicker loading of content.||Session Deleted upon closing the browser|
|Security (e.g. Asp .NET) Cookies||If you attempt to access a restricted area, our native cookies ensure that your respective device is logged on for the complete duration of your visit. For understandable security reasons, you will need your username and password to access these restricted areas throughout your time using our platforms.||Session Deleted upon closing the browser|
|Site Preferences||Our cookies may also remember your site preferences (e.g., language, screen zoom, landing page) in an attempt to enhance your user experience through personalisation. This will additionally apply to fields where you have registered in order to access our services or create an account (eg. log in pages).||Session Deleted upon closing the browser|
|Analytical||We use several third-party analytics tools to help us understand how site visitors use our web site and therefore optimise their experience. By using these analytical tools we can improve the quality and content on Website for our visitors. Only basic information is collected such as aggregated statistical data cover items such as total visits or page views, and referrers to our web sites.||Persistent, but will delete automatically after two years if you no longer visit Website.|
|Site visitor feedback||We utilise a survey tool (operated by a trusted third party) to invite a small percentage of our web page visitors to provide their feedback for optimisation purposes. Cookies are used in this circumstance to ensure visitors are not invited multiple times or on repeated occasions. The initial cookie (1) is set if the visitor is not invited to participate in the survey, and is used to ensure visitors are not invited after their first page view and further experience. The second cookie (2) is set if the platform visitor is voluntarily invited to participate in the basic feedback survey, and is used to ensure that these particular visitors are not invited again to participate for a time period of 90 days.||1 Session Deleted upon closing the browser
2 Persistent Deleted automatically after 90 days or presenting survey invite.
|Social sharing||We use third party ‘widgets’ or buttons that allow us to link our web platform to our various social media channels. They additionally provide users with additional functionality, in order to share content from our web pages to social media platforms and email lists if they so wish to do so. Use of these widgets or buttons may involve placing a cookie on your device to make our service infrastructure, our platform and our various user features easier to use, to count your visit against our ongoing visitor number tally and log generalised data about your activities across the Internet and on our web platforms. We encourage you to review each individual provider's privacy information before using any such service.||Persistent, but will be deleted automatically after two years if you no longer visit Website.|
11. The data subject may, as stated numerous times above, prevent the setting of cookies through our website platform at any time if they choose to do so. They can achieve this by completing a simple settings adjustment of the web browser they have used and thus permanently denying the setting of cookies, both one-time and continuous. For example, most browsers allow you to refuse to accept cookies and/or to fully delete cookie caches at any opportunity. The methods for doing so vary from each browser, and from version to version of these particular browsers. You can however obtain up-to-date information about blocking, deleting or discontinuing cookies via the following links:
(1) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox)
(2) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(3) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(4) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(5) https://support.apple.com/kb/PH21411 (Safari); and
(6) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12. You also have act in the ways listed below:
As part of AUTOMATA’s ongoing commitment to responsible and legal data collection and processing best practice, AUTOMATA allows you to opt out of the use of information about your activities on other websites that, in turn, provides you with advertising that is specifically tailored to your particular individual interests. You can opt out of Google Analytics by installing Google’s opt-out browser add-on, and by opting out of Google Ads by navigating to the correct option under Google’s Ads Settings in your browser. Even if you choose to opt out, you may still receive AUTOMATA advertising via other means, such as social media or email listings. By opting out of Google Ads, it just results in advertising that you receive will not be customised for you.
(2) Refusing Cookies
We honor Do Not Track signals and Do Not Track, do not plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place on a user’s device. You can limit the collection, acquirement or collation of your information by disabling cookies on your respective browser. You may also be able to change your platform settings to require your permission each time a site attempts to set a cookie, either persistent or one-time in nature. However, our website(s) (and many other websites) rely on cookies to enable certain functionality and a streamlined process. If you choose to disable cookies, some of the services available on our website may not work properly or may be somewhat delayed.
(3) Non-AUTOMATA Websites and Associated Links
4) Caution regarding automatic Cookie Functionality
Browsers such as Google Chrome and Microsoft Internet Explorer provide an option allowing you to store various user passwords and log-on identification details so you do not need to re-enter this information each time you access a web site or service platform. AUTOMATA strongly encourages you NOT to use this feature in any circumstance, at any time, as to prevent unauthorized use of your online banking access codes or other private personal information.
14. The data subject has the possible opportunity to register on the website platform of the controller with reference to the collection, storage and use of personal data. Which personal information is transmitted to the controller is decided by the respective input mask utilised on a user’s web platform for the registration process. The personal data entered by the data subject is then collated and stored exclusively for private internal use by the controller, and for his own purposes while complying with relevant data privacy laws that AUTOMATA happily complies with. The controller may request that some user information is moved to one or more processors (e.g. a courier service or postal agency) that also utilises personal information for an internal purpose which is directly attributable to the controller.
15. By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are additionally stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses against the website or AUTOMATA. The storage of this data is vital and absolutely necessary to secure the controller and the controller’s designated platform infrastructure, as well as its individual features. This data is not passed on to third parties unless there is a binding legal obligation to pass on the data, or if the transfer of data is required as part of criminal prosecution under jurisdictional framework that AUTOMATA operates under.
16. The registration of the data subject, with the voluntary consent to allow access to personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question and for no alternative or additional purposes. Registered persons are free to change the personal data or access to such data specified during the registration at any time, or to have them completely deleted from the database of the controller. This may however, affect AUTOMATA’S ability to provide the aforementioned service.
17. On the website of AUTOMATA, users are given the chance to subscribe to newsletter service for an indefinite period. The utilised input mask used for this purpose determines what personal data are disseminated, as well as when the newsletter is sent from the controller. Subsequently this newsletter will only be sent to, and received by the data subject under the following conditions (1) the data subject has given AUTOMATA a valid e-mail address upon registration and it maintains its viability (2) the data subject submits to any costs pertained by the newsletter’s shipping and the associated costs that come with that. A confirmation e-mail will be sent to the e-mail address registered by the data subject on the first occasion for newsletter shipping. This will be done for legal reasons, and is related to double opt-in procedures.This confirmation e-mail is used specifically to prove whether email addresses owner is the data subject, as well as ensuring that the data subject is authorised to receive our newsletter. Additionally, our website will also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of said registration. The personal data collected as part of registration for our newsletter will only be used to send our newsletter, optimise our internal processes in regards to the email service and will serve or be utilised for no additional purpose.
18. The website contains information that enables optimised electronic contact to AUTOMATA. If a data subject contacts the controller by e-mail or via a contact form or any other recognised electronic means, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject (as contacting us implies), is stored for the purpose of contacting the data subject or processing their desired claim. This is completed in order to optimise our customer service ability now, and in the future. AUTOMATA commits to their being no transfer of this personal data to third parties for advertising or other additional purposes.
19. The data controller processes and stores the personal data of the data subject only for the period absolutely necessary and vital to achieve the purpose of storage. If the storage purpose is not applicable, or if a storage period expires, the personal data is alternatively blocked or erased.
20. Subject to certain restrictions on certain legal rights, you have the following rights in relation to your information, which you can exercise by contacting AUTOMATA, sending an email to email@example.com x:
1) to request access to your own personal information, as well as to request information as to the nature of how we have processed such information. This may include:
a) reasoning behind our need to process such information;
b) the type of personal information that has been collected;
c) the recipients or categories of recipients of any of the aforementioned personal information. These already have been or will be disclosed to recipients in third-world countries, registered and reputable international organisations or governmental bodies;
d) where available, the potential period of time in which the personal information of that particular user will be stored by us, or, if not ascertainable, the criteria utilised to calculate that period of time;
e) the existence of the right to request from the controller modification or erasure of personal data, or restriction of processing of personal data concerning the data subject on any level, or to object to such processing;
f) the existence of the right to lodge a complaint with a supervisory authority about the processing or storage of aforementioned data;
g) where the personal data are not collected from the data subject, any available information as to the data source;
h) the existence of automated processing platforms, including those capable of profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the reasoning involved, as well as the significance and potential consequences of such processing for the data subject. AUTOMATA strives to remain compliant with this new legislation.
i) to obtain information as to whether personal data are transferred to a third country or to an international organisation for any reason. Where this is the case, the data subject shall have the right to be notified of the safeguards utilised relating to the transfer.
(2) To request and to gain possession from the controller the confirmation as to whether or not personal data concerning him/her/it is being processed currently.
(3) to request the correction or deletion of your information from our servers. Data subject can request to delete his personal information (the right to be forgotten) in case:
a) if personal information is no longer needed to fulfill the original means for which it was collected, collated, transferred or otherwise processed.
b) the data subject desires to remove their consent, directly or implied on which our processing is based in accordance to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no additional, nor alternative legal ground on which this data may be processed.
c) the data subject refuses or wishes to withdraw from processing under Article 21(1) of the GDPR and there are no counteracting nor overarching legal grounds for processing of user information to continue, or the data subject refuses to processing in line with Article 21(2) of the GDPR.
d) the personal data has been unlawfully processed or obtained.
e) the personal data must be erased for compliance with legal obligations in Malta.
f) the personal information has been collected, collated, processed or transferred in accordance with the offer of providing information-society services as outlined in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the deletion, removal or pause in the processing of personal data collected, received and stored by AUTOMATA, they may, at any moment, contact any employee of the controller or the controller directly and request for this action to be taken. An employee of AUTOMATA or the designated controller of such data storage and processing activities shall immediately make sure that the deletion request is fulfilled to the fullest extent of the law.
(4) to request that the company restrict the processing of your personal or identifiable information in cases when:
a) the accuracy or authenticity of the personal information being stored or processed is disputed by the data subject, with the necessary period of time being afforded to the controller to gauge the claim as well as the personal data being referred to.
b) the data processing is found to be unlawful under the legal framework AUTOMATA operates under, with the data subject additionally rejecting the deletion of personal data and instead alternatively requests the restraint of its use and storage.
c) the controller does not further require the specific personal data outlined for the purposes of processing, but are required by the data subject to store such data for the defence of existing or upcoming legal claims that involve either Automata or the data subject.
d) the data subject has officially protested against processing of information in line with Article 21(1) of the GDPR depending on the assertion of whether this access to this information can be overridden on legitimate legal grounds by the controller.
If one of the aforementioned conditions are met, and a data subject knowingly wishes to request the restriction of the processing of personal data stored by AUTOMATA, he or she may at any time contact any employee of the controller. The employee of the AUTOMATA will arrange the immediate restriction of the processing.
(5) to receive information which the data subject has provided to us or provided implied consent to collect or receive said data in a structured, commonly used and automated format and the right to have that information transferred to an additional, alternate data controller (including a third party data controller that Automata has designated);
(6) to object to the processing of your information for specific purposes; and
(7) to withdraw your data protection consent to our use of your personal data at any time where data controller relies on your consent to use or process that information.
21. In accordance with Article 77 of the General Data Protection Regulation, data subject have the right to lodge a complaint with a supervisory authority or other relevant governmental body, in particular in the Member State of his/her/its habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
22. We may disclose any information we collect, collate or acquire about you, regardless of whether you are a current or former customer, this includes personal information that is non-public in nature and any additional data we collect, to AUTOMATA- linked companies and services and to non-affiliated third parties, which may include non-financial companies, such as platforms providing email services, bounty program affiliates and services that help us fulfill our KYC/AML requirements, and others, such as other AUTOMATA users with which you engage in transactions on our platform. Additionally we reserve the right to make such disclosures:
(1) to service providers that enact marketing services on our behalf; and
(2) for common, everyday business purposes, such as to process and make record of transactions, ensure account security, react appropriately to relevant court orders and legal investigations pertaining to AUTOMATA or its users, or report to credit bureaus in line with current KYC/AML requirements or our indigenous business best practices.
(3) if we are under an obligation to disclose or share your information to comply with our legal obligations.
23. Other than in connection with a potential merger, sale of AUTOMATA assets or AUTOMATA as a whole, financing or other investment means, we will not sell, lease, lend or gift any of your personal information to third-party companies or other registered bodies for their own respective marketing or sales purposes.
24. Please note that third parties that support our user recognition and anti-fraud controls (KYC-AML requirements) may gather, store and utilise data about you to perform services on our behalf, and additionally to enhance their own respective platform features. By using our services, regardless of the method, medium or mode, you directly imply consent to the collection, storage and use of such information by these associated providers to improve their services.
25. We may also collect, gather and transmit metadata that is de-identifiable to any of our customers to some of our affiliated or partnering companies or non-partnered third parties, which cannot reasonably be used to identify you via any recognised method or collection of data points. This is done to enhance our services ability, as well as the services of the aforementioned bodies.
27. Unfortunately, the transmission of information via the internet is never completely secure. Although we will do our utmost to protect your personal data, we cannot guarantee the security of your data transmitted to our site, and any transmission is at your own risk. In the process of receiving, processing and storing your individual data we will use the strictest procedures and security features available to us, in an effort to prevent unauthorised access.
28. We will also transmit electronically or in hard copy your information outside the EEA or to an appropriate international organisation only in the improbable occurrence that we are constrained to complying with. This is reliant upon the legal obligations to which we are subject, and the jurisdiction in which we operate under, which may be subject to change in the future. In the unlikely chance that we are required to comply with such legal obligations (such as court orders), we will ensure that advanced safeguards and multi-layered protections are in place to guard against the possibility of security incursion..
29. The Website and any products or Services available on Website are not intended to solicit information of any kind from persons under 18 years of age, in line with legal requirements.
30. Data controller does not use automatic decision-making or profiling to process and utilise a data subject’s personal data.
31. AUTOMATA uses relevant electronic and structural procedures to ensure the safeguarding of information the user provides to AUTOMATA from misplacement, illegal transfer, editing, modification and complete deletion. Please note that transmission of data or information (including communications by e-mail or via other recognised mediums of electronic or traditional communication) over the Internet or other widely accessible networks is not completely secure. Please note that AUTOMATA are not legally liable for any breaches of security, whether limited or catastrophic, of any data users are transmitting over the Internet, or additionally any third-party content.