Last updated on the 20th June 2023.

Any capitalized terms used in this privacy notice (hereafter referred to as the “Notice” or “Privacy Notice”) are to be attributed the same meaning provided under the Prima Loyalty Scheme Terms and Conditions (T&Cs), unless otherwise defined herein.

Arkadia Retail Ltd, a company registered in Malta, bearing company registration number C103188 and having its registered address at “Mizzi Organisation Corporate Office”, Testaferrata Street, Ta’ Xbiex XBX 1407, Malta (thereafter referred to as the “Data Controller”, “Company”, “We”, “Us”, “Our”) is committed to protecting the privacy and security of personal data in accordance with the General Data Protection Regulation EU 2016/679 (“GDPR”, “Regulation”), the Data Protection Act (Chapter 586 of the Laws of Malta – “the DPA”) and any laws implementing or supplementing the GDPR as may be amended from time to time, collectively called “Applicable Data Protection Law”.

Scope

This privacy notice applies to the members of the Prima Loyalty Scheme (thereafter referred to as the “Scheme”) and sets out how We collect, process, protect your personal data in relation to the Scheme and what are your rights under the Applicable Data Protection Law.

Definitions

The definition of “automated decision”, “data controller”, “data processor”, “personal data”, “purpose”, “profiling”, “processing” have the same meaning as set out under the GDPR.

Personal Data Collected

We collect the personal data that you provide to Us when you apply to become a member of the Scheme. Personal Data collected includes your name, surname, email address, phone number and date of birth. Failure to provide your personal data will make it impossible to participate in the Scheme.

Purposes and Legal Basis of Processing

• We process your personal data for the following purposes and legal basis:
• Based on the performance of a contract or in order to take steps prior to entering into a contract: We use your personal data to manage your participation in the Scheme, including issuing rewards and benefits, verifying your eligibility to participate, communicating with you about the Scheme, and providing customer support.
• Based on Our legitimate interests or compliance with legal obligations: We process your personal data for the purpose of establishing, exercising, or defending legal proceedings, as well as complying with legal requirements such as accounting and taxation obligations.
• With your consent: We may use your personal data to send you marketing communications by mail about our products, services, promotions, and special offers.

You can always change your mind and withdraw your consent at any time by using the opt out links, clicking the unsubscribe button located at the bottom of any email communication received from Us or by contacting Us directly at: This email address is being protected from spambots. You need JavaScript enabled to view it.. Please note that withdrawing your consent does not impact the lawfulness of the processing that was carried out based on your consent prior to its withdrawal.

Sharing of data

We may share your personal information with Our service providers who assist Us with managing and administering the Scheme, including IT/clouds providers and database storage providers and entities forming part of Mizzi Organisation. We might also share your data with regulatory authorities or law enforcement agencies, where We are required to do so by law or in connection with legal proceedings.

Retention period

Your personal data shall be held throughout the period of your membership and for five (5) years following the termination of your membership on the basis of our legitimate interests to protect ourselves from cases which you might institute against Us in regard to the Scheme. Thereafter, your personal data shall be immediately and irrevocably erased unless We need to keep your personal data to comply with a legal obligation, or to exercise or defend any legal claim.

Security of data

The Company has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, We limit access to your personal data to authorized personnel on a need-to-know basis. They will only process your personal data on the Company’s strict instructions or where the task or job at hand demands such access in order to be able to carry out a certain function or perform a certain job.

Automated Decision-Making and Profiling

Your personal data will not be used for any automated decision-making or profiling.

Transfer of data Outside the EU

Your personal data shall not be transferred outside the EU. In the event that such a situation arises, we will ensure the implementation of appropriate safeguards and provide you with relevant notification.

Your Rights

You have the right to request access to your personal data, rectification of inaccuracies, erasure of data, the ability to object to the processing of your personal data (where applicable), the right to request the provision of your personal data in a structured, commonly used, and machine-readable format, the right to request the restriction of processing of your personal information, and the right to request the direct transmission of your personal data to yourself or to another controller specified by you.

For more information about your rights as a data subject including the conditions and limitations applicable to such rights, please contact Us directly at This email address is being protected from spambots. You need JavaScript enabled to view it..

Contact of Data Controller

If you have any questions or concerns about Our use of your personal data, or if you wish to exercise any of your rights in relation to your information, please contact Us at:

Arkadia Retail Ltd.
Address: Testaferrata Street, Ta' Xbiex, XBX 1407, Malta
Email This email address is being protected from spambots. You need JavaScript enabled to view it.

Contact of the DPO

The contact detail of Our Data Protection Officer is This email address is being protected from spambots. You need JavaScript enabled to view it..

Complaints

If you have any complaints regarding Our processing of your personal data, please note that you may contact Us at the details indicated above. You also have a right to lodge a complaint with the Office of the Information and Data Protection Commissioner in Malta (www.idpc.gov.mt).

Changes to This Privacy Notice

We may update this privacy notice from time to time, and We will notify you of any material changes to the notice by email or through Our website.