1. Introduction
Big Wig Limited (“Big Wig”/ “we”/ “our”/ “us”) are committed to protecting and respecting our visitors' privacy. This privacy notice has been created to provide the website visitors (“user”/ “you”) with a clear explanation as to:
1. How we use any personal data that we receive from you or may collect about you, and
2. Your privacy rights under applicable privacy laws.
All personal data will be processed in accordance with your instructions, the EU General Data Protection Regulation (“GDPR”), other relevant Maltese and EU legislation and our professional duty of confidentiality (the “Data Protection Laws”).
For the purposes of the GDPR, the Data Controller is:
Big Wig Limited, a company incorporated under the laws of Malta with company registration number C 94049 and having its registered address at 175, Naxxar Road, Birkirkara, BKR 9045, Malta.
Should you wish to request any clarification or additional information in relation to this privacy notice, or you may wish to exercise any of your rights in relation to your personal date, please send us an email on privacy@wigwam.mt.
By using our services, you acknowledge that you have read, and agree to, the terms of this Privacy Notice and that you consent to the use by us, of your personal data for the purposes as set out in this Privacy Notice. If you do not wish to provide your personal information on the basis set out in this Privacy Notice, you should not enter the relevant information on the Website or provide your personal data to us in any other way. However, you understand that if you do not provide your personal data, we will not be able to provide you with our services.
This Privacy Notice is effective as from 26th October 2020. In the event that we modify this privacy notice, we will post a clear notice of the update in the homepage of our website.
2. Key Terms
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Data Controller
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The person that determines the purposes and means of the processing of personal data
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Data Processor
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Any individual or organisation that processes personal data on behalf of the data controller
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Personal data
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Any information relating to an identified or identifiable natural person
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Processing
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Any operation which is performed on personal data such as collection, storage, use and erasure
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Special Category Data
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Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic and biometric data and data concerning health, sex life or sexual orientation
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3. Collection and Processing of Personal Data
We are bound by data protection laws to respect and protect any personal data we collect from you and we will abide by such duty. We take all safeguards necessary to prevent unauthorised access. All data collected is processed in accordance with the data protection laws.
Most of the information we process is given to us directly by you. This includes information that you input via our website and that you provide us with over the telephone and/or via email.
We can only use your personal data if we have a lawful reason for doing so. In terms of the data protection laws, we may process personal data if you have given us your consent or it is necessary:
a) for our legitimate interests
b) to carry out our contractual obligations, or
c) to comply with a legal obligation.
We collect 2 types of data from you: (i) personal data like contact details to enable us to fulfil our service and (ii) behavioural data to better improve our service to you, which we will only collect if you Opt In to the use of cookies.
The below table sets out the types of personal data that we may process, for what we may use it and our legal bases, which are our reasons for processing:
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Activity
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Personal data we may process
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For what reasons we may use your personal data
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Our legal bases
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When you register as a partner to make use of our services as a potential employer.
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Contact details that you provide to us in order to create a profile/account.
These include:
- Company name
- Email address
- Chosen password
- Address
- Industry
- Company size
- Company contact person details (full name, position, contact number, email address)
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To provide you with our service.
To improve your experience.
Analytics and profiling
Contacting you and responding to your communications with us.
Updating and enhancing our contacts/client base.
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Performance of a contract:
Enabling us to perform the contract with you and provide you with our services.
For our legitimate interests:
Responding to your communications with us.
Processing is necessary for us to conduct our business, as long as our interests are not overridden by your interests or rights.
Performance of a legal obligation
In satisfaction of any obligation imposed on us by law.
Consent
On the basis of the consent that you have provided us, where this is required.
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When you register as a candidate to make use of our services as a job hunter.
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Contact details that you provide to us in order to create a profile/account.
These include:
- Full name
- Mobile number
- Email address
- Date of Birth
- Nationality
- Town/Village
- Level of interest
- Current employment details including current employer, previous employer current role, previous role, desired industry and desired occupation
- Current salary and desired salary
- Education details
- CV and any other documents you may provide.
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To provide you with our service.
To improve your experience.
Analytics and profiling
Contacting you and responding to your communications with us.
Updating and enhancing our contacts/client base.
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Performance of a contract:
Enabling us to perform the contract with you and provide you with our services.
For our legitimate interests:
Responding to your communications with us.
Processing is necessary for us to conduct our business, as long as our interests are not overridden by your interests or rights.
Performance of a legal obligation
In satisfaction of any obligation imposed on us by law.
Consent
On the basis of the consent that you have provided us, where this is required.
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When you visit our website
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These include;
- Your IP Address;
- Cookies;
- Date and time when you accessed the website;
- Details of the requested webpage and/or downloaded;
- Whether your request was successful or not;
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To improve the content and functionality of our website.
To better understand the categories of visitors to our website.
To improve our services.
For system administration, bug tracking and producing usage statistics. This information may be kept indefinitely and will not be disclosed to third parties.
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For our legitimate interests:
To understand the category of visitors of our website and to ensure that the visitors have the best possible experience when visiting the website.
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Making use of our website when you make a general enquiry.
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Contact details that you provide to us when you request information about our services through our “Contact” form on our website.
These include your full name, mobile number, email address and other personal data that you may provide us in your message.
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Responding to your communications with us.
Updating and enhancing our contacts/client base.
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For our legitimate interests:
Managing business communications.
Responding to your communications with us.
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When you complete and submit any of the available forms to make use of our services as a partner.
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Contact details that you provide to us, including;
- Company name
- Email address
- Chosen password
- Address
- Industry
- Company size
- Company contact person details (full name, position, contact number, email address)
- Goals and culture of your company
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To provide you with our service and to provide you with the best recruitment opportunities that are tailored to you. This will enable us to provide you with the best opportunities and should save you time in not having to search through information about job hunters that are not relevant to you.
For internal risk assessment purposes, internal management, research and statistics, systems administration and the development and improvement of our services.
To improve your experience.
Contacting you and responding to your communications with us.
Updating and enhancing our contacts/client base.
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Performance of a contract:
Enabling us to perform the contract with you and provide you with our products or services.
For our legitimate interests:
Responding to your communications with us.
Processing is necessary for us to conduct our business, as long as our interests are not overridden by your interests or rights.
Performance of a legal obligation
In satisfaction of any obligation imposed on us by law.
Consent:
On the basis of the consent that you have provided us, where this is required.
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When you complete and submit any of the available forms to make use of our services as a candidate/job hunter.
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Contact details that you provide to us, being;
- Full name
- Mobile number
- Email address
- Date of Birth
- Nationality
- Town/Village
- Level of interest
- Current employment details including current employer, previous employer current role, previous role, desired industry and desired occupation
- Current salary and desired salary
- Education details
- CV and any other documents you may provide.
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To provide you with our service and to provide you with the best possible employment opportunities that are tailored to you. This will enable us to provide you with the best opportunities and should save you time in not having to search through information about jobs that are not relevant to you.
For internal risk assessment purposes, internal management, research and statistics, systems administration and the development and improvement of our products and services.
To improve your experience.
Contacting you and responding to your communications with us.
Updating and enhancing our contacts/client base.
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Performance of a contract:
Enabling us to perform the contract with you and provide you with our products or services.
For our legitimate interests:
Responding to your communications with us.
Processing is necessary for us to conduct our business, as long as our interests are not overridden by your interests or rights.
Performance of a legal obligation
In satisfaction of any obligation imposed on us by law.
Consent:
On the basis of the consent that you have provided us, where this is required.
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Follow-up communication whether by email or phone call
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Any data you may provide us during our discussions.
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To provide you with our service.
To improve your experience.
Contacting you and responding to your communications with us.
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Performance of a contract:
Enabling us to perform the contract with you and provide you with our services.
For our legitimate interests:
Responding to your communications with us.
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Candidates shall take full responsibility for the integrity and the accuracy of the data provided.
Should you decline to provide us with any such data we may not be able to provide you with our service.
4. Cookies and Data Tracking
Big Wig uses cookies to optimise the functionality of our website. Cookies are small text files that contain certain data such as the site’s name and unique user ID and is downloaded to and stored on your device when you visit a website. We use cookies to help identify your computer so we can tailor your user experience. These cookies may obtain information about you, your device and your use of our website.
Most, but not all, of the cookies we use are automatically deleted from your computer when you leave our website or shortly afterwards. You can disable any cookies already stored on your computer, but these may stop our website from functioning properly.
Third party vendors, including Google, may show adverts for Big Wig on the internet. These vendors may use cookies to serve ads based on a user’s prior visits to Big Wig. Users can opt out of Google’s use of cookies by visiting the Google advertising opt-out page.
Opting Out:
You can set your browser to not accept cookies, but this may limit your ability to use the services.
For more information about our use of cookies and how you can change your settings to suit youplease refer to our Cookie Policy.
5. Sharing of Data and Disclosure
For us to be able to provide you with a service, whether you are a partner or a job hunter, information needs to be transferred internally.
If you are a job hunter, we will share your personal data with our partners, as your potential employers. If you are our partner, we will share your data with potential employees who may be interested in working with you.
We do not share your data with other third parties, except with the following persons and in the indicated circumstances:
i. between the affiliated entities and brands of BigWig & WigWam, which entities are also bound by the provisions of this privacy notice.
ii. service providers – where necessary to carry out our services. These include hosts of our private server where all data is stored.
iii. other third parties – where necessary to carry out your instructions.
We may also disclose your personal data in response to any requests made from law enforcement agencies, government entities or public authorities, where we have a duty to disclose or share your personal data in order to observe any legal or regulatory obligation or request.
We may also share your personal data with other parties in the event of a corporate reorganisation and/or disposition of our business, such as potential buyers of all or part of our business.
6. Transfer of Personal Data outside the EEA
As part of the services offered to you, no data will be transferred to and stored in other countries within the European Economic Area (EEA).
7. Data Retention & Use
Subject to your rights in Clause 8 hereunder, we retain your personal data included on your profile for as long as this is necessary to provide you with our services and for long as it is necessary for us to comply with our record-keeping requirements in terms of the law and to be able to respond to any questions, complaints or claims made by you or on your behalf.
We will not collect more data than we require or retain your data for longer than necessary to fulfil the purposes outlined in this notice.
8. Your Rights as a Data Subject
| Right of Access |
| The right to access and be provided with a copy of your personal data. |
| Right to Rectification |
| The right to require us to correct any inaccurate personal data about you. |
| Right to be forgotten |
| The right to require us to delete your personal data in certain circumstances. |
| Right to restriction of processing |
| The right to require us to restrict processing your personal data in certain circumstances. |
| Right to data portabilit |
| The right to receive your personal data which you provided to us, in a structured, commonly used and machine-readable format and the right to transmit that data to another data controller in certain circumstances. |
| Right to object |
| The right to object to the processing of your personal data in certain circumstances which include continued processing of your data carried out for the purpose of our legitimate interests.. |
| Right not to be subject to automated processing |
| The right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or significantly affects you. |
Should you require any further information on each of the above rights or would like to exercise any of them, please contact us on 99990102 or contact us via email on [email protected]. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you may bring forward.
9. Third Party Websites
Our site may contain links to other websites. Please note third party links are not associated with Big Wig and we do not have control over how your personal data is collected, stored or used by other websites. Hence, you are advised to refer to their privacy policies prior to providing your data.
10. Security
We are committed to take all appropriate measures to protect the confidentiality and security of the data you provide to us. Big Wig has implemented security measures to protect your personal data that we collect from being used or accessed unlawfully or accidentally lost.
11. Complaints
We would like to resolve any concern that you may have about the processing of your personal data directly with you. However, you have the right to lodge a complaint with a supervisory authority, in the EU state in which you work, reside or where the alleged infringement of data protection laws took place. The supervisory authority in Malta is the Office of the Information and Data Protection Commissioner which may be contacted at https://idpc.org.mt/en/Pages/contact/complaints.aspx .
Last updated on 26th October 2020
