Vrtron Ltd ("Vrtron", "we", "us") is the controller of personal data processed through vrtron.com. We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Malta data-protection law.
1. Who we are
Vrtron Ltd, a private limited company registered in Malta under registration number C65553, with registered office at 11 Horizon, Triq San Pawl, Mellieħa MLH 1191, Malta.
Data-protection representative: Ingo Mesche (imesche@vrtron.com). General enquiries: info@vrtron.com.
2. Data we collect
We collect personal data only when you provide it, or where strictly necessary to operate the site.
- Contact form data. Name, email, subject and message content when you submit the contact form.
- Direct correspondence. Any personal data you include when emailing us at the published addresses.
- Technical data. Standard server-log information (IP address, user agent, request path, timestamp) used for security, debugging and abuse prevention.
- Cookies and local storage. See the Cookie Policy for the full list.
3. How we use your data
- Respond to enquiries and conduct subsequent correspondence.
- Operate, secure and maintain the site.
- Comply with legal and regulatory obligations.
- Exercise or defend legal claims where necessary.
We do not use your data for automated decision-making with legal or similarly significant effects, and we do not sell personal data.
4. Lawful basis
- Consent (Art. 6(1)(a) GDPR) for non-essential cookies and any optional marketing communications.
- Legitimate interests (Art. 6(1)(f) GDPR) in operating, securing and improving the site, and in responding to enquiries that may initiate a business relationship.
- Contract (Art. 6(1)(b) GDPR) where processing is necessary to enter into or perform a contract with you.
- Legal obligation (Art. 6(1)(c) GDPR) where required by applicable law.
6. International transfers
Where a processor is located outside the European Economic Area, we put in place appropriate safeguards under Chapter V of the GDPR, typically the European Commission's Standard Contractual Clauses, plus supplementary measures where needed (for example, encryption in transit and at rest).
7. Retention
We retain personal data only for as long as necessary for the purposes set out above:
- Contact-form messages and related correspondence: up to 24 months from the last interaction, unless a longer period is required by law or by an ongoing business relationship.
- Server logs: up to 90 days.
- Records required for legal, tax or accounting purposes: for the period required by the relevant law.
8. Security
We apply organisational and technical measures appropriate to the risk, including encryption in transit, access controls, regular updates and the principle of least privilege. No method of transmission or storage is completely secure; we work to continuously improve our safeguards.
9. Your rights
Under the GDPR you have the right to:
- Access the personal data we hold about you.
- Request correction of inaccurate or incomplete data.
- Request erasure ("right to be forgotten") where applicable.
- Restrict or object to processing under certain conditions.
- Receive your data in a portable format.
- Withdraw consent at any time, without affecting processing carried out before withdrawal.
- Lodge a complaint with the Office of the Information and Data Protection Commissioner of Malta (IDPC).
To exercise any of these rights, email imesche@vrtron.com.
10. Children
The site is not directed at children under the age of 16 and we do not knowingly collect personal data from them. If you believe a child has provided us with personal data, please contact us so we can take appropriate action.
11. Changes to this policy
We may update this policy from time to time. Material changes will be indicated by an updated "Last updated" date at the top of the page. Where required, we will draw your attention to material changes more prominently.
12. Contact and complaints
For any privacy-related question or to exercise your rights, contact imesche@vrtron.com. You also have the right to lodge a complaint with the Malta supervisory authority, the IDPC, at idpc.org.mt.