IP Address and Cookie Policy

IP ADDRESS AND COOKIE POLICY

Last Updated: 08/Jul/2020

1. INTRODUCTION

Welcome to the Ministry for Economy, Government of Malta’s IP Address and Cookie Policy (the “Policy”).

We, the Ministry for Economy (“we”; “us”; “our” or the “Ministry”) have appointed MALTA INVESTMENT MANAGEMENT COMPANY LIMITED incorporated and registered in Malta Company registration Number C 9588, whose registered office is at CLOCK TOWER, LEVEL 1, TIGNE POINT, SLIEMA, MALTA (“MIMCOL”) to project manage the issuance of vouchers (the “Vouchers”) to be used at eligible establishments  within the territory of Malta which were forced to close due to the Covid-19 pandemic, a list of establishments is available from the following website: [insert website] (the “Website” and/or the “Site”), (the “Eligible Establishments”), which vouchers will be issued by the Government of Malta through the Ministry (the “Project”).

The Ministry has appointed MIMCOL as its data processor and therefore, the Website and the related app, called ‘[INSERT]’ (the “App”) are owned by the Ministry who is the data controller for these purposes. A data processing agreement between MIMCOL and Ministry has been signed.

Whenever you use our online services, including our app, cookies and other tracking technologies can be used in various ways, such as to make our Website work, to analyse traffic, or for advertisement purposes. These technologies are either used by us directly, or by our business partners, including third party service providers and advertisers whom we work with.

This may also involve collecting and using your user Internet Protocol Address (an “IP Address”).

Please read the following carefully to understand how and why we use cookies and other tracking technology, and also collect your IP Address! If you do not accept or agree to the practices described in this Policy, you must exit the Website and our App immediately! By continuing to use either of them, it shall be deemed to signify your full acceptance and consent to the practices set out in this Policy, including the way in which we will track your activities through the use of cookies.

2. IP ADDRESS

• WHAT HAPPENS WHEN YOU VISIT THE SITE

Every time you connect to the internet or, if you use an always-on connection, such as broadband or ADSL, when you boot up or restart your computer, you are automatically assigned a unique identifying number known as an IP Address. This IP Address, which contains, amongst others, information regarding the location of your computer on the internet (your country of origin) and the name of your internet service provider (“ISP”), is automatically logged by our Website.

• What is an IP Address?

When you first started your internet session (i.e. your computer connected to the internet), your computer was automatically assigned a unique number (normally in the region of 9 or 10 decimal numbers), known as an IP Address. This is your computer’s unique address on the internet. Without an IP Address, websites would not be able to deliver their respective content to you, given that they would not be able find your computer on the internet. Since each time you disconnect and reconnect to the internet a new IP Address is automatically assigned to your computer, IP Addresses are not inherently capable of identifying you as an individual (at least, by themselves and not combined with other identifiers).

An IP Address does, however, contain information regarding the location of your computer on the internet (your country of origin), and the name of your ISP. Such information, when combined with other available information, may then potentially lead to, or otherwise allow for, your identification. For these reasons, EU Data Protection Law treats IP Addresses as personal data with the resulting protections.

• HOW DO WE COLLECT YOUR IP ADDRESS

Each time you visit a page on our Website, your computer sends out a message asking for the requested content to be delivered. This message sent by your computer also encloses your IP Address as a form of “return address”, so that the Website may find your computer in order to send it that requested content. Our web-server automatically logs all these messages.

• WHAT DO WE DO WITH YOUR IP ADDRESS?

When we log your IP Address, the data collected is grouped up with the other logged IP Addresses in order to provide us with the statistics on the geographic location of visitors to our Website, how long they stay on the Website, which are the most viewed pages and for other statistical reasons that may be relevant to us.

We gather your IP address automatically and store it in log files. These files also contain information relating to your browser type, ISP, operating system, date/time stamp, clickstream data and the files viewed on the Website. Collecting this type of information allows us to generate aggregate information for the purposes of developing our Website, including in terms of overall user trends and activities online (such as the number of unique visitors, pages accessed and viewed most frequently or the search terms entered). It also allows us to administer the Website, diagnose any potential server problems, analyse visitor trends and statistics, and generally helps us to provide you with a better internet experience.

IP Addresses are not stored for longer than necessary for the above stated purposes.

3. COOKIES

• INFORMATION ABOUT OUR USE OF COOKIES

We have implemented and activated cookies on our App and Website to distinguish you from other users. These cookies allow us to analyse trends and administer our App and Website, to help provide you with a good experience when browsing through them and to also improve them at the same time.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or on your mobile device, if you agree to let us do so. A cookie enables the Website or App to remember users that have already visited. Without a cookie, every time you open a new web page, the server where that page is stored will treat you like a completely new visitor.

So-called “first party cookies” are cookies which are served by the entity operating the domain through which the cookie is served. Our own cookies are therefore “first party cookies”. In case we allow others to service cookies through our Website and App, these cookies are so-called “third party cookies”. In addition to the above, there is also a difference between “session cookies” and “permanent cookies”. Session cookies will only exist until you close your browser. Permanent cookies have a longer lifespan and are not automatically deleted once you close your browser.

Cookies are used for different purposes. They allow you to be recognised as the same user across the pages of a website, between websites or when you use an app. Cookies allow us to remember your custom preferences such as your language preference and allow you to complete tasks without having to re-enter your information when browsing. The types of information that we collect through cookies include IP address; device ID; viewed pages; browser type; browsing information; operating system; internet service provider; timestamp; whether you have responded to an advertisement; the referring URL; and features used or activities engaged in within the Website/App.

Our Website and App use cookies for different purposes. We use the following cookies:

• Strictly Necessary Cookies. These are cookies that are required for the operation of our Website or App. By way of illustration, they include cookies that enable you to log into secure areas of the Site.

• Analytical Cookies. They allow us to recognise and count the number of visitors and see how visitors move around the Website and App when using them and gain insight on how our visitors use them. This means we can find out what works and what doesn’t, optimize and improve our Website and App, understand the effectiveness of advertisements and communications, and ensure we continue to be interesting and relevant. The data we gather can include which web pages you have viewed, which referring/exit pages you have entered and left from, the number of clicks you make on a given page, your mouse movements and scrolling activity, the search words you use and the text you enter into various fields. This helps us to improve the manner in which our App and Website work, such as by ensuring that users are finding what they are looking in a seamless and straightforward manner.

• Functionality Cookies. These are used to recognise you when your return to our Website and App, to help you to use them efficiently and effectively. This enables us to personalise our content for you, greet you by name and remember your preferences such as, your searches. We may also use cookies to remember your registration information so that you don’t have to retype your login credentials each time you visit our site. Passwords will, however, always be encrypted. These functional cookies are not strictly necessary for the functioning of our Website and App, but they add functionality and enhance your experience as user or visitor.

• Targeting Cookies. These cookies record your visit to our Website and App, the pages you have visited and the links you have followed. We will use this information to make our Website and App, together with the advertising displayed on them, more relevant to your interests. We may also share this information with third parties for this particular purpose.

• Technical Cookies: We try to give our visitors an advanced, user-friendly website and app that adapt automatically to their needs and wishes. To achieve this, we use technical cookies to show you our Website and App, to make them function correctly, to create your user account, to sign you in and to manage your bookings. These technical cookies are absolutely necessary for our Website and App to function properly, i.e. a ‘strictly necessary cookie’.

• Third Party Cookies. These cookies allow the Website to interact with different websites.

• Commercial Cookies: We use third-party cookies as well as our own to display personalized advertisements on our websites and on other websites. This is called “retargeting,” and it is based on browsing activities, such as the Travel Services you have been searching for.

You can find more information about the individual cookies we use and the purposes which we use them in the table below:

Please note that third parties (including advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical and performance cookies or targeting cookies.

We strive to serve cookies or allow the serving of cookies with a maximum lifespan of five (5) years. Only in exceptional circumstances, such as for security purposes and where absolutely necessary, will a cookie have a longer lifespan than that.

• MANAGING COOKIES AND YOUR CHOICES

You do not have to accept cookies to use our App or Website.

You can control the use of cookies at the individual browser level, and can even block or reject all or some cookies by activating the relevant setting on your browser. However, if you choose not to accept certain technical and/or functional cookies, you may not be able to use some functions on our App or Website.

Therefore, please be aware that if you do block or reject cookies (including technical and/or functional cookies), you would still be able to access and use the App or Website, but your ability to some of their functions or features, together with the services that you connect to through the App and/or Website, may be limited or may simply not work or function properly.

To learn more about cookies and how to manage or delete them, visit www.allaboutcookies.com and the help section of your browser. Many browsers allow you to browse privately, whereby cookies are automatically erased after you visit a site. In the settings for browsers such as Internet Explorer, Safari, Firefox or Chrome, you can set which cookies to accept and which to reject. Where you find these settings depends on which browser you use. Use the “Help” function in your browser to locate the settings you need. For your guidance, the following is a list of the most common browsers and the way in which you can activate private browsing:

• Internet Explorer 8 and later versions: In Private
• Safari 2 and later versions: Private Navigation/Browsing
• Firefox 3.5 and later versions: Private Navigation/Browsing
• Google Chrome 10 and later versions: Incognito

4. OTHER INFORMATION STORED

4.1    WEB SERVER LOGS

For security and troubleshooting purposes our web server stores logs of activity on the Website. The information stored includes: date, time, IP, page visited, result, amount of data sent and browser used.

1. OTHER TECHNOLOGIES

Next to cookies, other tracking technologies are used which are similar to cookies. These can include web beacons (also known as pixel tags, web bugs or gifs), tracking URLs or software development kits (SDKs).

A web beacon is a tiny graphic image of just one pixel that can be delivered to your computer as part of a web page request, in an app, in an advertisement or in an HTML email message. Pixels can be used to retrieve information from your device, such as your device type or operating system, IP address, and time of visit. They are also used to serve and read cookies in your browser. Tracking URLs are used to understand from which referring website our App and/or Website is/are being used. SDKs are small pieces of code included in apps, which function like cookies and web beacons.

5. GOOGLE ANALYTICS

Our App and Website also use Google Analytics, a web analysis service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (“Google”).

Google Analytics employs cookies. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted to Google’s location in the US and stored there.  In using Google Analytics, our website employs the extension, “gat.anonymizeIp”. In doing so, Google abbreviates and thereby anonymizes your IP address before transferring it from Member States of the European Union or signatory states to the Agreement on the EEA.

Google uses this information to analyse your use of our App and Website, to compile reports for us on internet activity and to provide other services relating to website and internet use. Google may also transfer this information to third parties where required to do so by law or where such third parties process this data on Google’s behalf.   Google states that it will never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser software accordingly, as discussed earlier on this Policy. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our App or Website.

Furthermore, Google offers a deactivation add-on for most current browsers that provides you with more control over what data Google can collect on websites you access. The add-on tells the JavaScript (ga.js) used by Google Analytics not to transmit any information about website visits to Google Analytics. However, the browser deactivation add-on offered by Google Analytics does not prevent information from being transmitted to us or to other web analysis services we may engage. You can find additional information on how to install the browser add-on at https://tools.google.com/dlpage/gaoptout?hl=de

6. UPDATES TO THIS POLICY

We will occasionally update this Policy to reflect changes in our practices and services. When we post changes to this Policy, we will revise the “Last Updated” date at the top of this Policy.

We recommend that you check this page from time to time to inform yourself of any changes in this Policy or any of our other policies.

7. CONTACT US

If you have any questions or comments about this Policy, or privacy matters generally, please contact us via email at [email protected].