Privacy policy

1. Introduction

This Privacy Notice explains how we collect, use, disclose, and safeguard and treat your personal information when you are seeking to become a client, and/or you are a client, whether through an ongoing business relationship or an occasional transaction (collectively, ‘Services’).

By utilising, or receiving, our services, you agree with the terms of this Privacy Notice. By providing us with your personal information, you acknowledge us to process your personal data/personal information in accordance with this Notice and the applicable EU laws and regulations.

2. What type of personal information will I hold on you and why?

We may collect, store and use the following kinds of personal information:

Personal details as per the ‘Know Your Customer’ (KYC) forms. Details will include your name, surname, address, identification details, date of birth, the service we are providing you, citizenship, nationality and similar information about you.
We will keep a copy of your identification document(s) such as ID card, driving license, residency card, passport or any other identification document available to fulfil my obligations under the 4th AML Directive.
We will keep a copy of information or documentation to proof residency of your address such as bank statement, bank reference, utility bill, fix telephone line bill or similar documentation. This is to fulfil our obligations in line with the 4th AML Directive.
We will keep a copy of name checks, google searches and passport checks on you. Such ‘name screening’ is performed to prevent fraud, money laundering, funding of terrorism, financial crime or any other type of crime. This is also in line with the 4th AML Directive and/or internal risk-based policy. Such screening services are performed when the relationship with the client or prospect has initiated and on an ongoing basis apply a risk-based approach.
We shall use your personal data to perform, in a manual or automated manner, a risk classification/profiling which would classify you as ‘low risk’, ‘medium risk’ or ‘high risk’ in order to fulfil my obligations under the 4th AML Directive. Such classification will affect the level of ongoing monitoring I perform on you and/or the level of documentation I request. You may request further information on how such risk classification is performed by contacting the info@dbsaassure.com or by calling us on +356 79271280.
We will keep a copy of your communication with me, such as emails and letters, in line with my legal obligations under the 4th AML Directive.
We shall use your personal data, especially one or more of your identification documents, to perform automated facial recognition. This is performed to avoid identity fraud and/or financial crime. We may request a video conference. Should you accept to provide us with such a call, I shall record and hold a video and sound recording of the video conference in line with my AML/CFT obligations and internal retention policy found in the Data Protection Policy. We may also take screen shots of such video conference in line to fulfil my obligations under the 4th AML Directive.
We may also process and hold information about your wealth, such as the value of your assets; details of bank accounts inheritance information; and similar related information to your global net worth. We shall use such information in line with the AML/CFT obligations.
We shall process and hold certain declarations that I may ask you to provide, in line with the legal obligations.
We may hold and process any other information or documentation we provide to you to complete, whether in physical or digital format, in line with our legal obligations.
We may also ask for a copy of your employment contract as a supporting documentation on your source of wealth or funds, on a risk-sensitive basis.

3. When do we need your consent?

We shall need your consent in the following circumstances:

When sending you marketing material or promotions regarding my services;
When sharing your personal information to third parties, unless we are required to do so by law such as providing information to police, court of law or a competent authority. Please see section 5 for more details; and
When processing your personal information without having one of the other legal basis found in section 4 below.

Please note that you can withdraw your consent at any time, unless there is another legal basis that allows us to process your data as per the below section.

4. When can we process your personal data?

Apart from the ‘consent’ noted in section three above, we may also process your data if we have the following legal basis:

Contractual obligation or necessity;
Legal obligation;
Member-state law;
Vital interest of the data subject;
When processing the data is in the best interest of the public; and
Legitimate interest.

It is the nature of our business to process your data due to a contractual or legal obligation. When neither of these apply, it is likely that we will process your data based upon your consent. That said, we may process data according to regulations listed within the General Data Protection Regulation (“GDPR”).

5. How and when can we disclose your personal information to third parties

We may disclose your personal information:

To the extent that we are required to do so by law;
In connection with any ongoing or prospective legal proceedings;
In order to establish, exercise or defend my legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information;
To any of my employees, officers, insurers, professional advisers, bankers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this notice;
If we merge, or sell, or in the event of a transfer of some, or all, of my assets or equity, we may disclose or transfer Personal Information and usage data in connection with such transaction; and
In all other circumstances where you would have given your consent.

We will not, without your express consent, supply your personal information to any third party for the purpose of their, or any other third party’s, direct marketing.

Personal information that you publish on my website /portal or submit for publication on the website may be available, via the internet, around the world. I cannot prevent the use or misuse of such information by others.

6. Where is your data stored and how is it protected?

Your data may be stored in one or more of the following locations:

Physical files in my cabinets at my office;
On Cloud (Microsoft), which is located within the European Union.

How is your personal data protected?

We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information. We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of Personal Information and other information transmitted to us.

You acknowledge that the transmission of information over the internet is inherently insecure and while we strive to protect information transmitted on or through the website/portal or services, we cannot, and do not, guarantee the security of any information you transmit on, or through, the website/portal or services, and you do so at your own risk.

That said, when information reaches us, we shall take the necessary steps to protect such information. This is done by one or more of the below:

Ensuring the data is safeguarded by the use of firewalls, encryptions, access restrictions and/or passwords;
In case of physical copies of your personal information or data, precaution shall be taken to ensure such data is accessible only to individuals connected to us that require to access your data to perform their duties and/or to provide you with a service;
We shall ensure that proper backups are taken to prevent the data from being lost; and
Without prejudice to section 6 above, your data saved in digital format on cloud shall be accessible by individuals that are required to access your data to perform their duties and/or to provide you with a service.

7. For how long shall we keep your data?

Personal data will be retained by us for as long as it is necessary for the purposes of processing such data. Thus, we will keep data for as long as it is obliged to by law, or need to keep a record of, a relationship with a client.

How shall we destroy your data after the retention period is over?

We shall destroy your data in a safe and reliable manner. Physical files shall be destroyed by means of shredding. Shredding services may be outsourced to third parties.

In the case of data stored in digital format, such data shall be permanently deleted. This would include any backups held cloud. Communication between us shall be deleted or destroyed.

8. What are your Rights?

You can obtain information regarding the processing of your personal information and access to the personal information which we hold about you by contacting me.
You may request that any personal information be rectified by sending an e-mail notification on info@dbsassure.com.
You have the right to request that we erase your personal information if it is inaccurate or incomplete. There may be circumstances where you ask us to erase your personal information, but we are legally obliged to retain it.
You may object to, and request the processing of, your personal information in certain circumstances. There might be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
You may instruct us at any time not to process your personal information for marketing purposes.
You may withdraw your consent given under this Policy at any time by sending an e-mail notification. Our details are listed hereunder.
Your personal information may only be stored unless further processing is brought about by individual consent and the necessity for the establishment of legal claims for the protection of the rights of another natural/legal person or for the public interest.
You have a right to lodge a complaint to the supervisory authority of the jurisdiction in which the personal information is being provided.
You may request one printed copy of this Privacy Notice free of charge.

9. Where can you register your complaint if you have an issue related to Data Privacy?

We value our customers’ comments and we are committed to ensure that all our clients’ data is safeguarded and in line with regulation and the internal policies. Should you feel the need to complain about, or raise your objections, to how we are handling your personal data, then you may contact us using the below contact details.

10. Can I modify this Privacy Notice?

From time to time, we may change this Privacy notice and inform you accordingly.

Note that the services are provided by Darren Bugeja as a sole practitioner, but the policy covers the related subcontractors.

This Privacy Policy is inconformity with applicable EU laws and regulations. We are liable only to the extent of the provisions set out under the applicable EU laws and regulations.

Contact details

By post, to 16, Alfier Street, Zejtun ZTN 3450, Malta.
By mobile on +356 79271280.
By sending an email to info@dbsassure.com.

We will do its utmost to ensure that complaints are handled and settled internally in an efficient and professional manner.

Contacting the Maltese Data Commissioner

You may also contact the Office of the Data Commissioner as follows:

You may file a complaint with the Maltese Data Protection Commissioner through the following link: https://idpc.org.mt/file-a-complaint/
Alternatively, you may contact the office of the Maltese Data Commissioner by phone on +356 23287100 or by post.

Last updated in January 2024.

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