Last updated: 27 January 2022.
Protection of your privacy and the security of your personal data are very important to Gobalsky Labs Limited.
If you are just browsing, we have designed our website so that you may navigate and use it without having to provide Personal Data, subject only to certain data that may be collected via the use of local storage, or data you choose to provide for marketing purposes or to access certain resources. If you do not accept these policies, you should immediately discontinue your use of our website.
By using our website, providing personal information and/or using any of our services, you agree that:
If we determine the purposes and means of processing your personal data, then we are a “controller”, and anyone who acts on our instructions in respect of such processing is a “processor”. There may be times where we act as controller and processor.
We are based in Gibraltar, which is no longer part of the European Union (“EU”). Gibraltar has its own data protection laws that apply certain EU laws, with such modifications as are necessary. This is referred to as the “Data Protection Legislation”, which includes:
If you live or work outside Gibraltar, other laws (including the EU GDPR) may be applicable to your individual circumstances.
For general web-browsing of this website, your personal data is not revealed to us, although certain statistical information is available to us via our internet service provider as well as through the use of special tracking technologies. Such information tells us about the pages you are clicking on or the hardware you are using, but not your name, age, address or anything we can use to identify you personally.
We collect your personal data in the following manner:
We always ensure we respect your privacy rights. This means we can only collect your personal data if we have a lawful basis for doing so.
In most cases, we collect personal data that you choose to provide to us. The relevant information is then used by us to communicate with you.
Your information may be used:
We may also use aggregate information and statistics for the purposes of monitoring website usage in order to help us to develop our website and our services. We may also provide such aggregate information to third parties. These statistics will not include information that can be used to identify you, as the information is anonymised and ‘de-identified’. More information is in our Cookies/Local Storage Policy.
Your information may also be used to provide you with information about the Vega software, otherwise known as ‘Direct Marketing’. To this end, we may use your information to:
If we do not have an existing relationship with you, marketing our materials, events and services (or those of others) to you shall be subject to your consent which shall be requested at the latest on our first communication to you, where you will be given the option to elect to receive such information by checking the appropriate boxes on the forms we use to collect your data or in links provided within our email communications.
You may also opt-out at any time by contacting us on the below details.
If you wish to be removed, we will retain your details in our marketing database(s) specifically for the purposes of suppressing your details from inclusion in all future marketing campaigns.
In connection with the provision of our services, personal data may also be transferred outside of Gibraltar. This may include countries or territories outside of the United Kingdom or the European Economic Area (“EEA”) where necessary. The EEA includes countries in the European Union, Iceland, Liechtenstein and Norway. Under the Data Protection Legislation, personal data can flow fairly freely from Gibraltar to the United Kingdom or to the EEA. However, certain restrictions exist where personal data is being transferred to a ‘third country’ outside the EEA or the United Kingdom and these are referred to as “restricted transfers”.
Generally, we will only perform restricted transfers where the transfer will be adequately protected by measures such as the following:
In the absence of adequate regulations or appropriate safeguards, we may also rely on derogations for specific situations as set forth in Article 49 of the Gibraltar GDPR. In particular, we may collect and transfer your personal data outside the EEA:
Communicating via the Internet and sending information to you by other means necessarily involves your personal information passing through or being handled by third-parties, but we do not sell or distribute without your permission your personal information to third parties. Any information we share with marketing companies, data analytics companies, website developers, and similar service providers and their affiliates is for the sole purpose of developing, hosting, managing, operating and supporting the content on our website. We ensure that in such cases, the information cannot be used to identify you and is anonymised and ‘de-identified’.
We are committed to taking appropriate measures designed to keep your personal data secure. Our technical, administrative and physical procedures are designed to protect personal data and non-personal data from loss, theft, misuse and accidental, unlawful or unauthorised access, disclosure, alteration, use and destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. We implement security measures across the firm to ensure our clients’ data is protected. We may also keep hard copy records of this personal information in physical storage facilities with access restricted solely to our personnel. We also take steps to monitor access to and modification of your information by our contractors, advisers, consultants and staff members, and ensure that they are aware of and properly trained in their obligations for managing your privacy.
We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information.
We use reasonable physical, electronic, and procedural safeguards to protect the personal information that we obtain from you from loss, misuse, and unauthorised access, disclosure, alteration, and destruction. Please note that we are not responsible for the security of any data you are transmitting over the Internet, or any data you are storing, posting, or providing directly to a third party’s website, which is governed by that party’s policies. Please note that no method of transmission over the Internet or method of electronic storage is 100% secure and we cannot ensure or warrant the security of any information you transmit to us. Transfer of your data via these means is therefore at your own risk.
The accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data is known as a “data breach”. The Gibraltar GDPR imposes requirements on businesses to identify, assess and report breaches in a timely manner (within 72 hours). We undertake to inform you if your personal data is compromised and there is a high risk to your rights and freedoms as a result.
As noted above, Gibraltar has its own data protection laws that apply certain EU laws, with such modifications as are necessary. Depending on your particular circumstances, you may also have additional rights if you live or work outside of Gibraltar. For example, the EU GDPR may apply to you if you are based in the EEA.
Under the Data Protection Legislation in Gibraltar, if you are a natural person (in other words, a human being and not a company), you have the right to:
You also have a right to lodge a complaint with the Information Commissioner under the DPA 2004. This is the Gibraltar Regulatory Authority, whose details are provided below. Please note different rights may apply under the EU GDPR or other relevant legislation if you are outside Gibraltar. The DPA 2004 also gives you the right to bring legal actions in the Gibraltar courts.
In addition, note that your right to information under Art. 13 and 14 of the Gibraltar GDPR is limited in certain cases. The requirements on us to give information do not apply insofar as:
There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases, we will let you know why we cannot comply with your request.
In addition, you can enforce your right to object to direct marketing as described above by contacting us or using ‘unsubscribe’ or other opt-out mechanisms we provide our marketing communications.
We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example if you change your email address or name, please let us know the correct details by contacting us on the details below. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate. Even if you do not request access to and/or correct your personal information held by us, if we are satisfied that, having regard to the reasons for which we hold your personal information, that personal information is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.
GOBALSKY LABS LIMITED
Suite 23, Portland House
If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the Information Commissioner under the Data Protection Act, which is presently the Gibraltar Regulatory Authority (“GRA”). The GRA is responsible for ensuring that your rights and obligations are respected. The GRA is also competent to hear your complaints and may prohibit or restrict the processing of your personal data in certain cases. You may contact the GRA on the below details:
Gibraltar Regulatory Authority
2nd Floor, Eurotowers 4
1 Europort Road
We do not collect or maintain information on our website from those we actually know are under the age of 16, nor is any part of our website targeted to attract anyone under 16. We request that all visitors to our website who are under 16 not disclose or provide any personal data and discontinue use of our website.
A cookie is a small file of letters and numbers that can be stored on your browser or the hard drive of your computer. Cookies contain information that can be transferred to your computer's hard drive. Local storage objects are sets of data that can be stored on your browser and/or hard drive by us. We use local storage objects to recognise you when you return to our website. It enables us to remember your preferences for: