1. Data Controller
The data controller responsible for the processing of your personal data through this website is:
[TO BE COMPLETED: Full Name]
Freelance Estate Agent — Estate Agent Warrant No. [TO BE COMPLETED]
Email: marsipropertiesmalta@gmail.com
Tel: +356 7962 8570
For any questions regarding the processing of your personal data, you may contact the data controller directly at marsipropertiesmalta@gmail.com.
2. What Data We Collect
We collect the following categories of personal data:
2.1 Data you provide voluntarily (contact form)
- Full name
- Email address
- Phone number
- Message content (including any property preferences you describe)
2.2 Data collected automatically
- IP address and approximate geolocation
- Browser type and version
- Pages visited and time spent on the website
- Referring URL
Automatically collected data is processed by our infrastructure provider (see Section 5) for security and operational purposes only. We do not use any analytics, advertising, or tracking tools.
3. Purposes and Legal Basis
| Purpose | Legal Basis (GDPR Art. 6) |
|---|---|
| Responding to your property enquiry or contact form submission | Art. 6(1)(b) — pre-contractual measures at your request; and/or Art. 6(1)(a) — your explicit consent |
| Matching your requirements with available properties | Art. 6(1)(b) — performance of a contract / pre-contractual steps |
| Compliance with anti-money laundering obligations (PMLA, Cap. 373) | Art. 6(1)(c) — legal obligation |
| Security and protection of the website from abuse | Art. 6(1)(f) — legitimate interest |
4. Data Retention
- Contact enquiries: retained for 24 months from the date of last contact, unless a contractual relationship has been established.
- AML-related records: retained for the period required by Maltese law (currently 5 years from the end of the business relationship).
- Server logs (automatic data): retained for up to 90 days for security purposes.
After the retention period expires, data is permanently deleted.
5. Data Processors and Third Parties
We use the following third-party services that may process personal data on our behalf. All processors are bound by appropriate data processing agreements.
| Processor | Purpose | Location | Safeguard |
|---|---|---|---|
| Supabase Inc. | Database hosting and backend infrastructure (stores contact form submissions) | EU (AWS eu-west-1, Ireland) | Standard Contractual Clauses (SCCs); GDPR-compliant DPA |
| Vercel Inc. | Website hosting and content delivery | EU edge nodes; HQ: USA | Standard Contractual Clauses (SCCs); GDPR-compliant DPA |
We do not sell, rent, or share your personal data with any third parties for marketing or advertising purposes.
6. International Transfers
Your data is stored on servers located within the European Union. Where any processor operates infrastructure outside the EEA (e.g. for global CDN delivery), appropriate safeguards are in place through Standard Contractual Clauses adopted pursuant to Art. 46 GDPR.
7. Your Rights
Under the General Data Protection Regulation (GDPR) and the Maltese Data Protection Act (Cap. 586), you have the following rights:
- Right of access (Art. 15): you may request a copy of the personal data we hold about you.
- Right to rectification (Art. 16): you may request correction of inaccurate data.
- Right to erasure (Art. 17): you may request deletion of your data, subject to any legal retention obligations.
- Right to restriction (Art. 18): you may request that we limit the processing of your data in certain circumstances.
- Right to data portability (Art. 20): you may request your data in a structured, machine-readable format.
- Right to object (Art. 21): you may object to processing based on legitimate interest.
- Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at marsipropertiesmalta@gmail.com. We will respond within 30 days of receipt of your request.
8. Cookies
This website uses strictly necessary technical cookies only, required for its secure operation. No tracking, analytics, or advertising cookies are used. For full details, please read our Cookie Policy.
9. Automated Decision-Making
We do not carry out any automated decision-making or profiling that produces legal or similarly significant effects on you.
10. Supervisory Authority
You have the right to lodge a complaint with the Maltese data protection supervisory authority:
- Name: Office of the Information and Data Protection Commissioner (IDPC)
- Address: 2nd Floor, Airways House, High Street, Sliema SLM 1549, Malta
- Tel: +356 2328 7100
- Email: idpc.info@idpc.org.mt
- Website: https://idpc.org.mt
11. Changes to this Policy
We may update this Privacy Policy from time to time. The date of the latest revision is shown at the top of this page. We encourage you to review this page periodically.