Last updated: 10th April 2018

Discus Holdings Ltd (“us”, “we”, or “our”) operates the website and is the Data Controller for the website. Discus Holdings Ltd is committed to protect the privacy of individuals who visit the website and who make use of its services.

This page informs you of our policies regarding the collection, use and disclosure of Personal Information (as defined below) in connection with your relationship with us as our clients, acting for a client or being generally interested in our services, including this website, in terms of the Data Protection Act, Cap 440 of the Laws of Malta. It also takes into consideration the General Data Protection Regulation of the European Parliament and of the Council adopted on the 27th April 2016 (“GDPR”) which became applicable on 25th May 2018.

We will not use or share your information with anyone except as described in this Privacy Policy.

We use your Personal Information for providing and improving our services. By using our services and this website, you agree to the collection and use of information in accordance with this policy.


Information Collection and Use

While using our services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your email address, name, phone number (“Personal Information”). Personal Information does not include data from which you can no longer be identified, such as anonymised aggregate data.

We will process your Personal Information if and to the extent the applicable law provides a lawful basis for us to do so and only in the following cases:

  • If you have consented to us doing so;
  • If we need it to perform the contract we have entered into with you;
  • If we need it to comply with a legal obligation;
  • If we have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms.


Log Data

We collect information that your browser sends whenever you visit our website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (IP) address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyse this type of information to increase our website’s functionality. These third-party service providers have their own privacy policies addressing how they use such information.



Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

We use cookies to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.


Behavioural Remarketing

Discus Holdings Ltd uses remarketing services to advertise via third party web sites to you after you visited our website. We, and our third-party vendors, use cookies to inform, optimise and serve ads based on your past visits to our website.


Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page.

Google also recommends installing the Google Analytics Opt-out Browser Add-on for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

Service Providers

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obliged not to disclose or use it for any other purpose.



We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.


Compliance with Laws

We will disclose your Personal Information where required to do so by law or by court order or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.



The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.


International Transfer

Your information, including Personal Information, may be transferred to, and maintained on, computers located outside of your country where the data protection laws may differ than those from your jurisdiction.

If you are located outside Malta and choose to provide information to us, please note that we transfer the information, including Personal Information, to Malta and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.


Keeping of Personal Information

Any Personal Information will be stored in our system for as long as it is being required and used, and for the purpose of satisfying any legal, regulatory, accounting or reporting requirements. We will securely destroy your Personal Information after the lapse of the applicable retention period. To determine the appropriate retention period for your Personal Information, we will consider the amount, nature, and sensitivity of the Personal information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. In this regard, Personal Information shall be deemed to have been used even for communication purposes such as using your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You are reminded that you are at all times free to opt out of receiving such communications, and from any other usage or processing of your Personal Information.

We are committed to ensure the security, confidentiality and privacy of your Personal Information. In the event that we suffer from any breach of data, we shall be notifying you of such breach without undue delay.


Your Rights as Data Subject

As an individual, you may exercise your right to access the data held about you by the Data Controller by submitting your request in writing to the Data Controller. You may request the following information relating to the data held about you:

  • The purpose of the holding and processing of data;
  • The categories of personal data held;
  • The recipients to whom data have been disclosed;
  • The envisaged period for which data will be stored;
  • If any of your data have been transferred to a third country, and if so, the appropriate measures and safeguards in place to ensure the security and privacy of the holding and processing of such data.

Although all reasonable efforts will be made to keep your information updated, you are kindly requested to inform us of any change referring to the personal data held by the Data Controller.

At any time, you may exercise your right to request from us without undue delay the rectification of your Personal Information should you consider the information about you to be inaccurate.

You also have the right to request the blocking or erasure of data, subject to certain exemptions, if:

  • The Personal Information is no longer necessary in relation to the purposes for which it was collected;
  • You no longer consent to your Personal Information being processed;
  • The Personal Information has been unlawfully processed; or if
  • Such erasure is required for compliance purposes.

We shall communicate in the shortest time possible of any rectification or erasure of data to you and to each recipient to which such data has been disclosed.

You are also reminded that you have a right to restrict the processing of your Personal Information, subject to certain exemptions, where:

  • You are contesting the accuracy of the data;
  • The processing is unlawful;
  • There is no longer need of such data for processing purposes; or where
  • You object to the processing of the data based on the lack of legitimate grounds.

You may also request the Personal Information to be provided to you in a structured and machine-readable format. You are also entitled to transmit such data to another controller without any hinderance from our end.

You are reminded that you have a right to object at any time, subject to certain conditions and exemptions, to your Personal Information from being used for direct marketing purposes, including profiling.

In case you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent at any time.

If you want to exercise any one of these rights, please contact us on office@

You also have the right to make a complaint at any time to the Information and Data Protection Officer in Malta.


Links to Other Sites

Our website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. When connecting to such other websites you will no longer be subject to this policy but to the privacy policy of the new site. We therefore strongly advise you to review the privacy policy of every site you visit.

We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party sites or services.



We will in general not charge for any reasonable exercise of your individuals rights mentioned in this Privacy Policy. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.


Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. It is therefore in your interest to check the Privacy Policy any time you access our website to be familiar with the most updated version of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.


Contact Us

If you have any questions about this Privacy Policy, please contact us. Any comments or suggestions you may have and which may contribute to a better quality of service will be welcome and greatly appreciated.



We will not sell or transfer user's data and contact info to a third party.