Thomas Smith & Co Ltd, TC Smith Agencies Ltd, TS Container Agencies Ltd, (registered office 1, War Victims Square, Luqa LQA 1010, Malta), (together ‘Thomas Smith’, ‘Us’ or ‘We’) acknowledge the importance of privacy to you and are fully committed to respecting your privacy as well as protecting your personal data. The scope of this Privacy Notice (‘Privacy Notice’) is to clearly describe how We, on receipt of your enquiry, process your information for service provision in a safe manner. All information received is utilised for the sole purposes outlined in this notice.
The above companies in the Thomas Smith Group provide shipping (freight forwarding, logistics & project cargo, container liner and port agency) & other related services.
Access to personal data is limited to authorised personnel within the Thomas Smith Group, who are in turn required to maintain data confidentiality.
Our Personal Data Protection Policy governs the use and storage of your data. Please read our Personal Data Protection Policy to find out how we protect and process your personal information.
Collection of Personal Data
Thomas Smith is a Controller of the personal data you provide us. We may collect, store and process the following types of personal data from you:
- Basic personal details such as your name, surname, address, e-mail address, telephone number, mobile number, ID Card Number and Signature;
- IP addresses when visiting our webpage without disabling Cookies including related location data;
- Bank Account Details;
- Passport and bank details, gender and nationality, employment contracts and lease or residential agreements and police conduct certificates for port agency and consulate services.
If you deem inappropriate to provide the requested information, we may not be able to execute a contract we have entered with you.
Use of Personal Data
We collect and use personal data given to Us by you to:
- Prepare quotations for freight forwarding, port agency, container liner and other shipping services;
- Execute the services offered;
- Maintain an effective communication channel from enquiry to post-delivery activities such as invoicing and customer feedback;
- Provide you with updates on industry related aspects, upcoming events and products or services for you, in accordance with our legitimate interests;
- Protect our legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation).
Sharing of Data
Your personal data is processed in our central office located in Luqa. Internally, we may share your information within the specific business units (e.g. Freight Forwarding, Port Agency, Container Liner Agency, Insurance) to facilitate the service provision.
Due to the nature of our work, we are obliged to share your personal data with:
- Authorities (e.g. Transport Malta, Port Security, Immigration Office, Customs);
- Freight forwarding companies and agents;
- Carriers and Transport companies;
- Other sub-contractors and service providers.
Hosting and storage of your data takes place in secure databases supported by professional IT management and software companies, all of whom are bound to comply with all applicable data protection regulations including GDPR.
We may, as a matter of law, and without requiring notice or consent, use your information for crime and fraud prevention to enforce our compliance with any regulatory requirements. This may require disclosing your personal information with regulatory bodies in Malta or overseas, Police and other organisations to undertake credit or fraud searches.
Retention of Personal Data
Under Maltese law, we are required to keep your documents according to our Data Retention Policy. After this period, your personal data will be irreversibly destroyed.
We will not retain your data for longer than is necessary to fulfill the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
Where you are a customer, we will keep your information for the length of any contractual relationship you have with us and after that for a period of 10 years due to fiscal laws that impinge on Thomas Smith. In cases of legal issues, these are retained until the relevant court case is resolved.
Where you are a prospective customer, we will only retain your data in line with our Data Retention Policy until you unsubscribe from our communications.
Storage of Personal Data
Appropriate measures are taken by Us to ensure that all personal data is securely kept internally. Access to personal data is also limited to authorised personnel within the Thomas Smith Group, who are bound by a duty of confidentiality.
We aim to ensure that personal data held about you is accurate and up to date. In this respect you also have the right to:
- Request access to your personal data;
- Request that We correct any mistakes in information held about you by Us;
- Request that We delete personal data held about you by Us.
If you want to exercise any of these rights you can contact Us on [email protected].
Requests have to be done in writing and proof of your identity will be required for any amendments and/or deletions of Personal Data.
In the event that you wish to complain about how we have handled your personal data, please contact the Data Protection Officer at [email protected] or in writing at 1, War Victims Square, Luqa, LQA 1010. Our Data Protection Officer will then look into your complaint and work with you to resolve the matter.
It is important that you include your name, email address and purpose of your request when contacting us. Please note, however, that certain Personal Information and Sensitive Personal Information may be exempt from such access, correction and erasure requests pursuant to applicable data protection laws or other laws and regulations.
If you still feel that your personal data has not been handled appropriately according to the law, you can contact the Information and Data Protection Commission located in Sliema and file a complaint with them.
Any queries about this Privacy Notice or about information which we hold about you are to be sent to: [email protected].