Privacy Policy

Data protection information 

Our data protection information is structured as follows:

You are visiting our website or the Property Search 

You are concluding a search or marketing agreement with us

You are contacting us by phone or internet, visiting our shop or attending one of our marketing events

You are sending us an unsolicited application, or an application based on a job advertisement 

Data protection information for visiting the website 

This data protection information applies to the use of the website www.saragrech.com (hereinafter referred to as "website"). 

The following information applies to the website unless expressly stated otherwise.

Sara Grech Ltd in its function of responsible authority (hereinafter also referred to as “Sara Grech" informs its users that by using the website, personal data about them will be processed, in particular:

• Personal data (e.g., e-mail address, first name, surname, title, address, telephone number – in the following “data” or “personal data”) provided by users at the time of registration on the website (e.g., in connection with contact requests).
• Personal data transferred from the user’s internet browser each time the user accesses the website and stored within log files, also known as server logs. This data comprises: IP address (Internet protocol address) of the accessing computer; name of the accessed site; date and time of access; related URL from which the user accesses the site; number of transferred data items; status report of successful access; session ID number.

Purpose of processing

Sara Grech Ltd as a responsible authority, processes the personal data of website and users for the following purposes:

• Fulfilment of user’s requests (legal basis is contract performance and the legitimate interest of Sara Grech Ltd in transferring contact requests within departments).  
• The forwarding of e-mail newsletters (website only) on the company’s own offers and advertising by the company or third parties to the legally permissible extent or based on consent. (Legal basis is either the consent or the legitimate interest of Sara Grech in direct marketing, providing this is in accordance with the data protection and competition rules).
• For the functionality and optimization of the website. (Legal basis is the legitimate interest of Sara Grech Ltd in continuously improving the quality of the website and ensuring its ease of use).
• Analysis of the website for determining user behaviour and for interest-based advertising. (Legal basis is the consent.).
• Identification and possible blocking of users who have installed a so-called adblocker and who thereby block advertising. (Legal basis is the legitimate interest of Sara Grech Ltd of providing users who do not block advertising with wholly or partially web-financed offers).
• In order to prevent fraudulent activities or misuse on the website or in connection with the website and to observe the legal stipulations for secure websites. (Legal basis is the legitimate interest of Sara Grech Ltd in eliminating faults, ensuring system security, and identifying unauthorized access attempts or accesses.)

The legal basis for the processing of personal data is GDPR Article 6(1)(a), if the processing is based on consent, Article 6(1)(b) if the basis for processing is a contractual relationship and Article 6(1)(f) if the basis is the legitimate interests of Sara Grech Ltd.

If the legal basis is your consent, you are entitled to revoke your consent at any time without affecting the lawfulness of the processing carried out based on the consent until revocation. If the legal basis is a legitimate interest, you are also entitled in principle to object to the processing of your personal data at any time for reasons arising from your situation. Article 21 GDPR applies in this respect.

Nature of supply of personal data and consequences of objection

The provision of personal data by users is voluntary. They may freely decide whether to make personal data available to Sara Grech Ltd and may subsequently revoke their consent to the processing of personal data which have already been made available. Revocation may mean that the Sara Grech Ltd website is no longer usable.

Access to data

The personal data is processed by Sara Grech Ltd and (in respect of individual items) particularly by

• Employees (permanent employees such as jobholders and independent property consultants) and consultants authorised to administer the website and provide the associated services.
• ●    Third-party supplier companies (e.g., IT service providers, hosting providers, etc.) to which Sara Grech Ltd has outsourced processing services as part of a job processing agreement. 

Information about the data

As the responsible authority we can provide information about your personal data. However, this information may only be given for the following reasons:

• In the case of fulfilment of legal obligations or obligations arising from regulations and guidelines under national or European laws.
• For defence in court in the case of a legal dispute.

Saving and deleting of data

Sara Grech Ltd saves personal data for the time necessary for achieving the purposes for which the data was collected and processed, including any retention period stipulated under the applicable legislation (e.g., retention of accounting records) and in any case for a maximum of 24 months after the personal data was collected.

Use of cookies and other tracking technologies

Use of cookies on the website

In addition to the above-mentioned processing of personal data, cookies and other tracking technologies are stored on your end device during or after your visit to Sara Grech Ltd. To provide you with a better experience, we make use of 3rd party services such as Google Analytics and Google ReCaptcha, which store information we share about your use of our site outside of the EU.

Cookies are small text files that are sent when visiting our website or property app and stored in the user's browser. If the corresponding website is called up again, the user's browser sends the contents of the cookies back and thus enables the user to be identified. Third party technologies such as scripts, pixels, and tags, which Sara Grech Ltd integrates for advertising purposes, also set cookies on your end device. Certain cookies are automatically deleted at the end of the browser session (so-called session cookies), others are stored in the user's browser for a specified time or permanently and then delete themselves automatically (so-called temporary or permanent cookies).

Which cookies does Sara Grech Ltd use in general?

Depending on their function and purpose, cookies are divided into various categories by Sara Grech Ltd. "Essential" and "functional" cookies are required to enable Sara Grech Ltd to provide the online offering in a secure and user-friendly manner. This category includes, for example, these cookies enable you to navigate through the Sara Grech Ltd online offers and use the functions as desired. Without these cookies, essential services of Sara Grech ltd cannot be provided. They are only used when you visit our online offers and are usually deleted after closing your browser. They are also used to retrieve the optimised website display when accessed with a mobile device, so that your data volume is not unnecessarily depleted.

The legal basis for setting these cookies is the legitimate interest of Sara Grech Ltd that the online services can be used securely and easily and that the quality of the online services and content is constantly improved. No consent is required for the use of "essential" and "functional" cookies. They cannot be deactivated. Sara Grech Ltd also uses cookies for analytical ("analytical cookies") and advertising purposes ("advertising" cookies). Sara Grech Ltd uses the profiles created with the help of these cookies for statistical information on the use of Sara Grech Ltd online services and to display advertising or offers which are tailored to your interests ("interest-based advertising"). The legal basis for the use of these cookies is your consent.

How can you manage and prevent the use of cookies or delete cookies?

You can use Sara Grech Ltd without "analytical" cookies, "advertising" cookies and other web tracking mechanisms. We use Cookiebot as our GDPR Compliancy engine; you may change your cookie permission preferences at any time by clicking on the floating Cookiebot icon at the bottom-left of the website, indicating that you would like to change your consent, and providing Cookiebot with your updated permission selection by enabling/disabling the relevant cookie type toggles.

You can also deactivate the storage of cookies via your browser settings and delete previously stored cookies in your browser at any time. Please note, however, that this online offer may not function or may only function to a limited extent without cookies. We also recommend that you visit the website of www.YourOnlineChoices.com, where you can obtain information and assistance in connection with web tracking mechanisms. A central opt-out option for various tools, from US American providers, is also available at the following link: optout.networkadvertising.org.

Links to social media pages

This website contains links to the main social media network sites (e.g., Facebook, LinkedIn and Instagram). These are not embedded social media plug-ins, but a link through which no personal data is transmitted to the social media operators.

Rights of data subjects

You have the right to information on the processing of your personal data (for example, the origin of this data, the processing purpose, the modalities of the data processing). Under certain conditions, you are also entitled to object to data processing in the future, to restrict it or to request that the data be deleted. Finally, you can prevent the sending of advertising material or the implementation of market research or commercial communications at any time.

In summary, you have a right to 

• information,
• correction,
• deletion (or to be forgotten),
• limitation of processing,
• data portability,
• objection to the processing of your personal data,
• complaint to the supervisory authorities.

Please note that your right to deletion is subject to certain restrictions. For instance, we need not or may not delete any data which we need to retain for a further period under a statutory retention period. Data needed by us for the establishment, exercise or defence of legal claims are also excepted from your right to deletion.

To exercise the above rights and to request information, users may write to the following e-mail address hello@saragrech.com or postal address Sara Grech Ltd, LEK Business Centre, Triq L-Esportaturi, Malta. Similarly, users may at any time revoke consent to correct and delete the processing of their data.

Contacts

The responsible authority for processing of data is Sara Grech Ltd, LEK Business Centre, Triq L-Esportaturi, Malta.  In the event of questions regarding our data processors, we are happy to make a current list of these available to you.

If you have questions about this data protection declaration or about data protection, please contact the data protection officer, Ms Sara Grech, Sara Grech Ltd, LEK Business Centre, Triq L-Esportaturi, Malta. Email: sara.grech@saragrech.com

If you have a complaint regarding the way that we process your data, you can submit a complaint to the supervisory authority. This is: Office of the Information and Data Protection Commissioner Malta
https://idpc.org.mt/en/Pages/contact/complaints.aspx

Data protection information in connection with a search or marketing agreement

Sara Grech Ltd in its function of responsible authority (also "Sara Grech" in the following) informs its customers and stakeholders about the personal data regularly gathered in connection with a contractual relationship or pre-contractual relationships. These specifically include:

• first name, surname, title, address, phone number, information regarding desired property (in the case of property search) or (in the case of property marketing) information about the property.
• hello@saragrech.com if you have consented to receiving promotional information, particularly the offer of properties.
• as well as (if there is a purchase/sale or rental of property) bank details, information on identity, copy of ID (when buying a property) as well as land register, electricity, water/gas bills, general direct cost statements, purchase contract (when selling a property) or (if there is a rental of a property) bank details, information on identity, CV, proof of address, rental contract.

In the following, this data is referred to as “data” or “personal data”.

Purpose of processing

Sara Grech Ltd, as a responsible authority, processes the personal data for the following purposes:

• Fulfilment of a contractual relationship by independent property consultants, including invoicing and credit checks (the legal basis is GDPR Articles 6(1)(b) and also 6(1)(f); Sara Grech Ltd legitimate interest in connection with the disclosure of data to independent property consultants stems from the freedom to fulfil contractual obligations by means of independent brokers or sub-brokers. The legitimate interest in the performance of credit checks follows from the legitimate interest in protection from bad debts).
• Promotional information about property marketed by Sara Grech Ltd (legal basis is GDPR Article 6 (1) (f); Sara Grech Ltd’ legitimate interest arises from the processing of personal data for the purposes of direct advertising). 

Access to data

The personal data is processed by Sara Grech Ltd and (in respect of individual items) particularly by

• Employees (permanent employees and independent property consultants) and consultants that make the offered services available.
• Third-party supplier companies (e.g., IT service providers, hosting providers or shipping companies) to which Sara Grech Ltd has outsourced services for processing operations as part of a job processing agreement.

Saving and deleting of data

Sara Grech Ltd saves personal data in connection with a contractual relationship for the duration of the retention period arising from the legal provisions. Furthermore, Sara Grech Ltd saves its data in connection with the receipt of commercial information until the withdrawal of your consent from Sara Grech Ltd.

Rights of data subjects

You have the right to information on the processing of your personal data (for example, the origin of this data, the processing purpose, the modalities of the data processing). Under certain conditions, you are also entitled to revoke your consent to data processing in the future, to restrict it or to request that the data be deleted. Finally, you can prevent the sending of advertising material or the implementation of market research or commercial communications at any time.

In summary, you have a right to 

• information,
• correction,
• deletion (or to be forgotten),
• limitation of processing,
• data portability,
• objection to the processing of your personal data,
• complaint to the supervisory authorities.

Please note that your right to deletion is subject to certain restrictions. For instance, we need not or may not delete any data which we need to retain for a further period under a statutory retention period. Data needed by us for the establishment, exercise or defence of legal claims are also excepted from your right to deletion.

To exercise the above rights and to request information, you may write to the following e-mail address hello@saragrech.com or postal address Sara Grech Ltd, LEK Business Centre, Triq L-Esportaturi, Mriehel. 

Contacts

The responsible authority for processing of data is Sara Grech Ltd, LEK Business Centre, Triq L-Esportaturi, Mriehel. In the event of questions regarding our data processors, we are happy to make a current list of these available to you.

If you have questions about this data protection declaration or about data protection, please contact the data protection officer:

Ms Sara Grech

LEK Business Centre,
Triq L-Esportaturi
Mriehel
 Sara.Grech@saragrech.com If you have a complaint regarding the way that we process your data, you can submit a complaint to the supervisory authority. This is: 

Data protection information in connection with telephone contact, contact via the Internet or at marketing events 

Sara Grech Ltd in its function of responsible authority (also "Sara Grech" in the following) informs its customers and stakeholders about the personal data that is regularly collected when making contact. These specifically include:

●      first name, surname, title, address, phone number, information regarding desired property (in the case of property search) or (in the case of property marketing) information about the property.

●      hello@saragrech.com if you have consented to receiving promotional information, particularly the offer of properties.

In the following, this data is referred to as “data” or “personal data”.

Purpose of processing

Sara Grech Ltd, as a responsible authority, processes the personal data for the following purposes:

●      Fulfilment of a pre-contractual relationship by independent property consultants (the legal basis is GDPR Articles 6(1)(b) and 6(1)(f); Sara Grech Ltd legitimate interest in connection with the disclosure of data to independent property consultants stems from the freedom to fulfil contractual obligations by means of independent brokers or sub-brokers.

●      Promotional information about property marketed by Sara Grech Ltd or licensees in the Sara Grech Ltd network (legal basis is GDPR Article 6 (1) (f); Sara Grech Ltd legitimate interest arises from the processing of personal data for the purposes of direct advertising).  

Access to data

The personal data is processed by Sara Grech Ltd and (in respect of individual items) particularly by

●      Employees (permanent employees such as job holders and independent property consultants) and consultants that make the offered services available.

●      Third-party supplier companies (e.g., IT service providers, hosting providers or shipping companies) to which Sara Grech Ltd has outsourced services for processing operations as part of a job processing agreement.

Saving and deleting of data

Sara Grech Ltd stores personal data in connection with a pre-contractual relationship for the duration necessary for the fulfilment of the pre-contractual relationship, for the duration of any retention period arising from the legal provisions, or for the duration required to pursue legal claims. Furthermore, Sara Grech Ltd saves its data in connection with the receipt of commercial information until the withdrawal of your consent from Sara Grech Ltd.

Rights of data subjects

You have the right to information on the processing of your personal data (for example, the origin of this data, the processing purpose, the modalities of the data processing). Under certain conditions, you are also entitled to revoke your consent to data processing in the future, to restrict it or to request that the data be deleted. Finally, you can prevent the sending of advertising material or the implementation of market research or commercial communications at any time.

In summary, you have a right to 

-       information,

-       correction,

-       deletion (or to be forgotten),

-       limitation of processing,

-       data portability,

-       objection to the processing of your personal data,

-       complaint to the supervisory authorities.

Please note that your right to deletion is subject to certain restrictions. For instance, we need not or may not delete any data which we need to retain for a further period under a statutory retention period. Data needed by us for the establishment, exercise or defence of legal claims are also excepted from your right to deletion.

To exercise the above rights and to request information, you may write to the following e-mail address hello@saragrech.com or postal address Sara Grech Ltd, LEK Business Centre, Triq L-Esportaturi, Mriehel. 

Contacts

The responsible authority for processing of data is Sara Grech Ltd at LEK Business Centre, Triq L-Esportaturi, Mriehel.  In the event of questions regarding our data processors, we are happy to make a current list of these available to you.

If you have questions about this data protection declaration or about data protection, please contact the data protection officer: 

Ms Sara Grech

LEK Business Centre
Triq L-Esportaturi
Mriehel
sara.grech@saragrech.com

If you have a complaint regarding the way that we process your data, you can submit a complaint to the supervisory authority. This is: Office of the Information and Data Protection Commissioner
Malta https://idpc.org.mt/en/Pages/contact/complaints.aspx

To exercise the above rights and to request information, you may write to the following e-mail address hello@saragrech.com or postal address Sara Grech Ltd, LEK Business Centre, Triq L-Esportaturi, Mriehel.