Terms of Service

We, the team at Hili Ventures, strongly value privacy and are committed to protect your personal data (i.e. information that identifies you).

If you have any questions about how we protect your privacy, get in touch here: [email protected]

This privacy policy describes our practices relating to the personal data of visitors of www.hiliventures.com and the use of our online facilities. For the data collected through and the maintenance of our website, the data controller is Hili Ventures Ltd with its address at Hili Ventures, Nineteen Twenty Three, Valletta Road, Marsa, MRS 3000.

We assure you that we will only use and disclose any personal data collected from you in accordance with the manner set out in this policy.

Most of the personal information which we may collect about you through this website is given to us only if you choose to give it to us. Such personal information may be requested from you when you fill in a field, e.g. to fill in our contact form with your questions and comments on the Hili Ventures Ltd’s Website. If you send us emails, then the personal data we process will depend on what you send us in the email.

The information we collect from you normally includes the following:

1. Information about your device (phone or laptop) with which how used our website;

2. If you reach out through us through our contact form, we will also collect your name and email address;

The next sections will outline how and why we use this information.

Some other information is given to us because you accessed this website (e.g. logs, recorded through cookies). This is explained in the Cookies section below.

We use your information in a number of different ways — what we do with it then depends on the information and the purpose for which we collected.

The tables below set this out in detail, showing what we do, and why we do it.

Your name and contact details

Your contact history with us

What you’ve said to us — for example, over email or contact forms.

Information about your device (phone or laptop)

Information you give us when you browse our site, including your IP address and device type as well as how you use our website.

• You don’t have to give us any of this personal information but if you don’t, you may not be able to use our site or all of the services we offer on the site, and you are unlikely to receive an optimal customer experience.
• We also anonymise and aggregate personal information (so that it does not identify you) and use it for purposes including testing our IT systems, research, data analysis and improving our site. We also share this anonymised information with third parties – but don’t worry, they cannot identify you.

For all of the uses of your personal data (as described above), we ensure that there is a legal basis under applicable data protection laws for us to use such personal data.

This includes, for example, where it is necessary for us to use the information to perform a contract with you or take steps at your request prior to entering into a contract with you. We also use consent as a legal basis in order to process your query when you contact us, provide customer-care and support services to you.

It also includes circumstances (such as we have described below) where we have a legitimate interest to use your data, provided that proper care is taken in relation to your rights and interests:

• to carry out research and analysis of your data as this helps us understand our clients better, who they are and how they interact with us.
• to improve and ensure the security of the website (for example, for statistical, testing and analytical purposes, troubleshooting).

• We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data.
• We may also keep hold of some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
• As a guide: – we will keep personal data until such time as you ask us to stop communications with you, unless we need to keep the data for longer;– we may keep certain categories of personal data for longer in order to meet any legal or regulatory requirements, or to resolve a legal dispute.

We may keep different types of personal data for different lengths of time if required by law (for instance, we may need to keep certain personal data relating to payments for about 10 years in order to comply with tax/VAT reporting requirements).

You may obtain more information as to the retention periods or the criteria used by us to determine the retention periods by contacting us here [email protected].

If you are aged 13 or under, please get your parent/guardian’s permission before you provide any personal information to us.

We will need to process personal data relating to parents or guardians in that case – and we may also need to request for verification documentation to ensure that consent is given or authorised by the holder of parental responsibility.

We do not, and will not, sell any of your personal data to any third party – including your name, email address or any other information you provide to us. It is not our business to do so – and we want to earn your trust and confidence.

However, we share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out below:

1. Companies in the group to which Hili Ventures belongs, as sometimes different entities within our group are responsible for different activities (especially licensed ones). This includes Hili Ventures – related entities and members of the Hili Ventures Group (any of our subsidiaries). Related entities and subsidiaries use the information collected to help us improve the content and functionality of our websites; to better understand our customers and markets; and to improve our services. Members of the group vary from time to time.
2. Professional service providers, such as marketing agencies, advertising partners and website hosts who service us in turn to operate our business.
3. Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud.

• In most circumstances we will not disclose personal data without consent. However there may be occasions where we might have to – e.g. with a court order, to comply with legal requirements and satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our subsidiaries and related entities.
• When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended.
• We may also provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you. Anonymous information means it is anonymous and you will not be identified through this data.
• If we ever have to share data with entities that are outside of the EEA, we will be sure to do so in a manner that complies with the requirements established by the GDPR.

What are cookies?

A cookie is a small text file (typically numbers and letters) that is downloaded onto ‘terminal equipment’ (e.g. your computer or smartphone) when you (or someone else) access a website using that device. Cookies are then sent back to originating website on each subsequent visit – and they are useful because they allow a website to recognize a user’s device and store some information about your preferences or past actions.

Some cookies are needed for the sole purpose of carrying out the transmission of a communication over an electronic communications network – others may be necessary for the provision of a service over the internet, in which case they have to be used.

Other cookies may be desirable to improve your experience, in which case we will ask you for your consent to use them.

Should you wish to amend your cookie preferences, you may click on the banner at the bottom of this page.

What cookies do we use?

The cookies we use are the following:

How do you change your cookie settings?

Should you wish to amend your cookie preferences, you may click on the banner at the bottom of this page.

Other Passive Information which we collect

Apart from the information you provide us with when using our Website, other information is passively collected from you (without you actively furnishing such information) when you navigate through the website. We use various technologies and navigational data collection methods to gather such passive information for various reasons, for example to track how many visitors access our website, the date and time of their visit, the length of their stay and which pages they view. The passive information also aids us to determine which web browsers our visitors use and the address from which they accessed our website – for instance if they connect to our Website through clicking on one of our banner ads. This technology does not identify you personally.

We assure you that, unless you have consented, such passive information shall not be combined with personally identifiable information collected elsewhere by our website or respective sites operated by our related entities or subsidiaries.

You enjoy several rights relating to your personal information:

• The right to be informed about how your personal information is being used;
• The right to access the personal information we hold about you; 

You can access the personal data we hold on you by filling this form and sending to Hili Ventures Limited by email: [email protected] or deliver to Data Protection Officer at Hili Ventures Limited , Nineteen Twenty Three, Valetta Road, Marsa MRS 3000 Malta.

• The right to request the correction of inaccurate personal information we hold about you;

We appreciate feedback from you to ensure our records are accurate and up-to-date. If you think that the information we hold about you is inaccurate or incomplete please fill this form and send to Hili Ventures Limited by email: [email protected] or deliver to Data Protection Officer at Hili Ventures Limited , Nineteen Twenty Three, Valetta Road, Marsa MRS 3000 Malta.

• The right to request that we delete your data, or stop processing it or collecting it;

You can ask us to delete your personal data; however, this is not an absolute right.

In spite of a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation (for instance, we are required by personal data for VAT reporting purposes); and (ii) in relation to the exercise or defence of any legal claims.

When you ask us to delete your personal data, we assume that you do not want to hear from us again.

If you would like to exercise your right to be forgotten, please fill this form and send to Hili Ventures Limited by email: [email protected] or deliver to Data Protection Officer at Hili Ventures Limited , Nineteen Twenty Three, Valetta Road, Marsa MRS 3000 Malta.

Other than as described above, we will always comply with your request and do so promptly. We would carry out our best efforts to notify any third parties with whom we have shared your personal data about your request so that they could also comply.

• The right to object to certain processing based on legitimate interest;

You have a right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling using automated means.

• The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;
• The right to withdraw consent for other consent-based processing at any time;
• The right to request that we transfer or port elements of your data either to you or another service provider;

You have the right to move, copy or transfer your personal data from one organisation to another. If you do wish to transfer your personal data we would be happy to help. If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation.

When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.In order to request the transfer of your data, please fill in this form and send it to Hili Ventures Limited by email: [email protected] or deliver to Data Protection Officer at Hili Ventures Limited, Nineteen Twenty Three, Valetta Road, Marsa MRS 3000 Malta.

• The right to complain to your data protection regulator — in Malta – the Information and Data Protection Commissioner (IDPC)

If you want to exercise your rights, have a complaint, or just have questions, please contact us here [email protected].

Security of your personal data is very important to us.

Where it’s appropriate, our website uses HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.

We do our best to keep the information you disclose to us secure. Security measures which have implemented to secure information transmitted over our website or stored on our systems include the following:

1. Use of secure servers;
2. Use of firewalls;
3. Use of encryption;
4. Physical access controls at data centres;
5. Information access controls;
6. Use of back-up systems;

Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.

Our website is continually under review – new functions and features are periodically added and improved to interface, thus changes to our privacy policy may be required from time to time.

We therefore encourage you to check our privacy policy on a frequent basis.

This privacy notice does not cover the links within this site linking to other websites which are not controlled by us. We are not responsible for the collection or use of your personal information from these third-party websites.

Therefore, we encourage you to read the privacy statements on the other websites you visit.

We are always happy to hear from you, whether to make a suggestion but especially if you feel we can do better.

If you have any questions about this Privacy Policy, or if you wish to make a complaint about how we have handled your personal information, please contact us at: [email protected]

Hili Ventures, Nineteen Twenty Three, Valletta Road, Marsa, Malta MRS 3000

To view the CCTV policy, please visit: https://hiliventures.com/cctv-policy

Hili Ventures may hold conferences and events from time to time. At such events, we may take pictures or videos of attendees. The legal basis for such processing is the Company’s legitimate interest to build a community and promote its programs and activities. To this end, we have completed a legitimate interest assessment, a copy of which is available upon request.

You have the right to object to such processing at any time by contacting the event organisers or getting in touch with us [email protected]. The photos and videos may be shared with other

group companies. The photos and videos will be stored by the Company for a period of five (5) years from the date of the event. With respect to your personal details collected in order to note your attendance to the event, we will delete this personal data immediately following the event, unless you have a direct working relationship with Hili Ventures, or one of its subsidiaries.

You will always be informed in advance of such processing and should contact the event organizers should you prefer not to feature in photos and videos taken at an event. Should you wish to exercise any of your rights in relation to your personal data, please refer to the section above entitled “Your Rights”. Should you have any queries about how we process your data, please contact us on [email protected].

If you choose to use the facilities available at the 1923 offices, we may collect your name, email address and phone number in order to be able to confirm any bookings you make and to contact you in case of any changes. We will hold on to this data for a six-month period after which we will delete your personal data and booking information. For further information on how we process your personal data, please refer to the above sections of our privacy policy or contact our Data Protection Officer on [email protected].

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Our website includes a section whereby candidates may submit applications to any vacancies we may have.

We are the data controller for the information you provide during this process unless otherwise stated. For example, if you apply for a job at a different entity within the Hili Ventures group, then the entity you are applying to will be the data controller of your personal data. If you have any queries about the process or how we handle your information please contact us at [email protected].

§  What will we do with the information you provide to us?

All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details (such as your contact number) you provide to us to contact you to progress your application.

We will use the other information you provide to assess your suitability for the role you have applied for.

§  What information do we ask for, and why?

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. The information we ask for is used to assess your suitability for employment.

You don’t have to provide all the information requested but it might affect your application if you don’t – as your application will be incomplete.

§  Application stage & Short Listing

If you use our online application system, this will be collected by our Human Resources Department.

We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.

§  Assessments

We might ask you to participate in further recruitment tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us and if so, this information is held by us for the recruitment exercise and perhaps after if you are selected.

If we make a conditional offer of employment we may ask you for information so that we can carry out pre-employment checks – which may be required to seek assurance as to trustworthiness, integrity and reliability and the possibility to work in Malta. Further processing of your information would be required if we are to apply for a work permit.

Depending on the job requirements, you may be required to provide: Proof of your identity and/or proof of your qualifications. We might also ask you to show us your police conduct certificate.

§  We will contact your referees, using the details you provide in your application, directly to obtain references.

§  We may also ask you to provide a certificate issued by a medical professional in order to ensure that you are fit for work in advance.

Final recruitment decisions are made by hiring managers and members of our recruitment team. All of the information gathered during the application process is taken into account. Once an offer is formally accepted and a contract is entered into by both parties, the Employee Privacy Policy will apply.

§  Retention Periods

We may ask if you would like your details to be retained in our talent pool for a period of six (6) months. If you say yes, we may proactively contact you should any further suitable vacancies arise within that period. You may ask us to cancel this at any time – however we normally keep information about your application until we decide whether or not to continue with your application. Once it has been decided that your application has been unsuccessful, we will promptly delete your application documents.

If you are employed, we will keep your personal data throughout the employment and for a period after that in accordance with our HR privacy policy.