Privacy Policy

Welcome to the Titan International Limited Privacy Policy.

TITAN INTERNATIONAL PRIVACY POLICY

Last updated: 29/01/2024

Introduction

Titan International Limited (C 1115) values your privacy and is committed to protecting the privacy and security of personal data in accordance with the General Data Protection Regulation EU 2016/679 (“GDPR” or “Regulation”), the Data Protection Act, Chapter 586 of the Laws of Malta, and subsidiary legislation as may be amended from time to time.

Purpose of this Privacy Policy

This privacy policy (referred to as the "Policy") aims to give you information on how your personal data is collected and processed when you visit our website https://titan.com.mt/ (referred to as the "Website" or the "Site") as well as when you reach out to us through any of the forms available on the Site.

It is important that you carefully review this Privacy Policy in conjunction with any additional privacy policies or privacy notices that we may provide during specific occasions when we are collecting or processing your personal data. This will ensure that you are fully aware of how and why we are using your data. It is important to note that this Privacy Policy serves as a complement to the other policies or notices and is not intended to supersede or replace them.

Please note that this Policy applies only to the use of information collected through our Website or during communications with us. It does not apply to the privacy policies of third-party websites linked to our site or to communications with other third parties.

Controller Details

The Controller of the personal data collected through the Website is Titan International Limited, a company registered in Malta bearing company registration number C 1115 and having its registered address at Mizzi Organisation Corporate Office, Testaferrata, Street, Ta’ Xbiex, XBX 1407,Malta (the "Controller”).

The Controller is part of The Mizzi Organisation (which means those companies having Mizzi Organisation Limited as their ultimate parent company). The Mizzi Organisation has established an Intra Group Data Transfer Agreement which governs any transfer of personal data within the companies.

The Organisation has appointed a Data Protection Officer (“DPO”) who is responsible for overseeing matters in relation to data protection including this Policy. If you have any queries relating to this Policy, including any requests to exercise your rights, please contact the DPO using the details given below.

Contact Details

Full name of legal entity: Titan International Limited

Company registration number: C 1115

Postal address: Titan International Ltd, The Lyric, Antonio Bosio Street, Msida

E-mail Address: info@titan.mizzi.com.mt

Data Protection Officer (DPO): dpo@mizzi.com.mt

The Data We May Collect About You

Personal data means any information about an individual from which that person can be identified, directly or indirectly. It does not include data where the identity has been removed (anonymous data). We may collect your data directly from you or automatically when you access our Website.

When collecting and utilizing your personal data, we guarantee that the processing is conducted on a lawful basis as per Article 6 of the GDPR. The table below presents transparent information regarding the processing of your personal data in relation to our website:

Activity
When you visit this Website	Technical Data such as cookies, IP address, browser type and versions, time zone setting and location, browser plug-ins types and versions, operating system and platform, unique device identifiers etc.	We collect and use your data to better understand our users’ needs, to continuously improve our website and to enable users to access the Website, for purposes of (network) security, to measure and improve the effectiveness of this Website, to help diagnose problems with our server, to administer this Website and to see where website traffic is coming from. Lawful basis: Art. 6 (1) (f) of GDPR, the process is necessary to fulfil our legitimate interests.
When you reach out to us through the Contact Us form or when you contact us via our social media pages	Identity Data such first name and last name Contact Data such as email address and phone number Third Party Data such as personal data included within your message which pertains to other individuals. Any other information available in your message.	We collect and use your data to provide you with the information requested and to provide you with our services. Lawful basis: Art. 6 (1) (b) of GDPR the process is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Lawful basis: Art. 6 (1) (f) of GDPR Processing is necessary for our legitimate interests of conducting our business and reply to queries, complaints or concerns raised within the form.
When you provide personal data through the Vacancy section.	Identity Data such as first and last name. Contact Data such as email address, phone number and email address. Any other information provided through the CV and any other documents you submit. Please refer to the Job Applicant Privacy Notice	We collect and use your data to assess all applications in order to select or reject applicants for relevant vacancies. Lawful basis: Art. 6 (1) (b) of GDPR the process is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Where we process your personal data in reliance on article 6(1)(f) GDPR, we ensure that our legitimate interest does not override your interests or fundamental rights and freedoms.

Cookies

When you visit our Website, we use cookies which allows us to automatically collect information about you as well as your device for different purposes, in order to enhance your navigation on our services, improve our services’ performance and customise your experience of our services. We also use this information to collect statistics about the usage of our services. For further information on what cookies are, which cookies we use, how and why we use cookies, and how you can control cookies, please read our Cookie Policy.

If you fail to provide personal data

The provision of personal data is not a statutory or a contractual requirement. However, if you do not provide the requested personal data, we may not be able to provide you with the requested services.

Minors

The Site is not intended for individuals under the age of 13. We do not intentionally collect personal information from children. If you are the parent or guardian and believe your child has provided us with personal information, please contact us at the address below to request deletion.

Sharing of your personal data

The personal information will be disclosed to third parties only to the extent required for the specific purpose(s), as stipulated in this Policy. We may have to share your personal data with the following categories of recipients:

Professional advisers including lawyers, bankers, auditors and insurers.
Any service providers that may have access to your personal data in rendering us with their support services, for example, marketing service providers and IT support.
We may disclose personal data processed to other companies within the Mizzi Organisation in accordance with Intra Group Data Transfer Agreement.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
Administrative, regulatory or judiciary authorities or agencies and other third parties to comply with any legal, enforcement or regulatory obligation and/or in the cases of an express and justified request or in case of an alleged violation of legal or regulatory provisions.

International Transfers

Unless otherwise required, we keep your information within the European Economic Area (“EEA”). However, in the event that we are required to transfer your personal data to a recipient and/or third party situated in a jurisdiction outside of the EU that has not received an adequacy decision issued by the European Commission (Art. 45 GDPR), the transmission of data shall be subject to appropriate safeguards within the meaning of Article 46(1) GDPR which might include the Standard Contractual Clauses (SCCs). You can obtain a copy of the Standard Contractual Clauses (SCCs) by contacting us at dpo@mizzi.com.mt.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Where your personal data is no longer required by us, we will either securely delete or anonymise the personal data in question. If you wish to know more about our retention periods, you can contact us at dpo@mizzi.com.mt.

Your Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.

Right to be informed about the processing of your personal data through this Policy.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide you, or a third party of your choice, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to be informed of the source where the personal data we hold about you was not provided to us directly by you, you may also have the right to be informed of the source from which your personal data originates.

Please note that your rights in relation to your Personal Data are not absolute and we may not be able to entertain such a request if we are prevented from doing so in terms of an applicable law.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you have any questions or wish to exercise your rights, you can directly contact our Data Protection Officer (DPO) via dpo@mizzi.com.mt.

Automated Decision-Making

We do not engage in automated decision-making activities. Should we endeavour to make any decision based on fully automated basis we shall notify you and seek your explicit consent.

You have the right to object to processing based solely on automated decision-making (which includes profiling) when that decision-making has a legal effect on you or otherwise significantly affects you.

What We May Need From You

We may need to request specific information from you to help us confirming your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Fees

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive in nature. Alternatively, we could refuse to comply with your request in these circumstances.

Right to complaint

You have the right to make a complaint at any time to the Information and Data Protection Commissioner Office (IDPC), the Maltese supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so kindly contact us in the first instance at dpo@mizzi.com.mt.. The IDPC’s contact details are as follows:

Address: Level 2, Airways House, High Street, Sliema SLM 1549, Malta

Email: idpc.info@idpc.org.mt

Website: https://idpc.org.mt/file-a-complaint/

Further processing

Where we need to further process your personal data for a purpose other than that for which your personal data have been collected, we will provide you, with any relevant information prior to the commencement of the further processing.

Changes to the Privacy Policy

We may update this Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.