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Privacy Policy

Introduction and key points

Whether you are our customer or not, we understand the importance of your personal data and of your right to privacy.  The purpose of this document is to reassure you that we are committed to continuing to do our utmost to keep your personal data as safe as possible.  We invite you to read on and learn about the types of personal data we collect, when we collect it, why we do so, what we do with it – including who we may have to share it with and why – and how long we keep it for and why.

We hope and trust that this will give you a clear picture of how we handle your personal data and on how you can better manage and control it.  However, if you have any questions or need any clarifications whatsoever, our Data Protection Officer will be more than glad to help you.  Please send any such requests to info@sensinnovation.com or call on (+356) 2148 2143.  You may also write to The Data Protection Officer, Sens Innovation Ltd. UB 5B Industrial Estate, San Gwann SGN3000 Malta.

Throughout the document, when we make use of the word ‘services’, we take this to also include complimentary services such as our customer care unit, our website and any other means that assist or improve your ease of access to or your experience of our core products.

SENS processes all personal data lawfully and in a proportionate, fair and justified manner and in a manner which recognises, respects and protects your rights.  These rights include your right to access, rectify and port out your personal data. Where circumstances allow this, you can also erase the data we hold on you or suspend, withdraw your consent or object to how we collect, use and save your personal information.

We process your information solely for the purpose of providing you with the service you requested and to ensure that you and others may continue to enjoy this service.  In order to do this, we also require the services of other companies and may, therefore, need to share your information with them.  However, we will always do this in a safe way which is consistent with your rights and in accordance with our legal obligations.

The main reasons we process your information is for us to deliver and maintain the services we offer, for the payment of our services, to improve and develop our products and services and, if you have consented to it, for marketing purposes.

Unless you misuse our products or services or do not abide by your obligations in our Terms and Conditions, none of the ways in which we process your personal information will have any legal effects on you.

If you are not a SENS customer but still want to know what data we have access to, how we process it and for how long, you too should also read the relevant section on Information we collect about you and how we use and share it if you are not our customer.

Information we collect about you and how we use and share it if you are not our customer

If you are not our customer, we have access to the data you provide us with when you contact us via email, ordinary mail, our website or any applications of ours which you download, social media platforms such as Facebook or over the phone or when you visit us at one of our outlets to make enquiries or fill out application forms, to fix appointments for services, or to sign new service contracts.  In all these cases, we only use this data in order to process your request.  If you become our customer, we would then store and use your data as described in all the other sections of this Privacy Policy.

We also receive information about you when you enter into any competition organised by us, whether this is at an event, online or via any social media platforms and other electronic or digital media or when you participate in an event organised or sponsored by us.  In such a case, we do not use your data for any other purposes and we delete all information provided within a month from when you shared it with us or a month after the event you shared it with us for (such as competition) took place.  If we take any photographs or videos of you in relation to these competitions, these will only be published with your consent.

There are instances when calls may be recorded and stored.  If you ring our offices, your call may be recorded for quality assurance and training purposes.  Live calls and call recordings may also be used for internal and external audits and investigations, including by law enforcement agencies.  If we save a recording of your call for training purposes, we will delete anything that can identify the call with you and we shall never share any of your personal data with the employees we train.  Otherwise, all recordings containing any personal data, such as your phone number, are automatically deleted after one year if they are no longer required for crime prevention, crime investigation and/or crime detection purposes and crime reporting, for the resolution of any complaints, for the protection of our business and/or legal interests and the protection of our employees.

Similarly, all calls that originate from our technical support team, telesales agents, call centre agents, customer experience team, fraud prevention unit and credit control unit are recorded.  We will not remind you of this recording when we call you if we are legally prevented from doing so.

All our outlets and office reception areas are monitored with 24/7 CCTV surveillance cameras and this is clearly indicated with appropriate signage once you enter any of our premises.  This is mainly intended to help you and our staff feel safer and the footage recorded is only shared with authorised enforcement agencies for the purpose of crime prevention, investigation and reporting.  However, we may also use this data to observe and understand how to run our outlets more efficiently.  Unless required for longer for legal and investigative purposes, all footage is automatically overwritten after thirty days.

We will also have any personal data you may provide us with in order for you to give feedback.  We will only keep such data until we have noted this feedback. If you receive information relating to our services, we will only keep your personal data until you inform us that you no longer wish to receive such information and news from us.  You will need to allow us 24 hours to action your request.  You can do this by responding directly to the electronic or digital communication you receive from

If you have filed an insurance-related or any other legal claim with/against us, we will keep your personal data and collect any further data which we may be legally authorised or obliged to collect from third parties until such claim is finally and permanently settled and, where applicable, until any payment due is fully paid or received by us.  The same shall apply if we have filed such a claim with/against you ourselves.  However, if you do not give us access to personal information which is relevant to help us (or others acting in our interest) to assess our responsibility if any, then we may either use whatever legal means we have available to obtain such information or we may not accept responsibility.  So long as we are assured that your information shall remain as safe, we may share your personal information with others in order to verify your identity or the identity of others involved in your claim, with the lawyers or other consultants we engage and with our insurance company.  We shall only use and share any personal information we have access to for the purposes of the insurance or legal claim.

In the case of enquiries made by phone, we will only make your phone number known to the enquiring person.  In the case of automated online enquiries, only your phone number will be provided unless you have consented to reverse searches.  In all cases, we will only have access to any such data and pass it on to those who have requested it until your consent to make your data available to others for directory purposes remains valid with your telephone service-provider of choice.

Each time you visit our website, we use cookies and other tracking technologies to provide functionality and to recognise you across different services and devices.  Please see our Cookies Policy to find out more about what these cookies and tracking technologies are, how and why we use them and how you can opt-out or limit these cookies and tracking technologies.

Information we collect about you if you are our customer

Once you are our customer, we collect your information (i) when you provide information to us, (ii) when you use any of our services and (iii) when we obtain it from others, as described below.

(i) Information we collect when you provide information to us

You provide personal data and information to us when you sign a contract for any of our services.  You also provide us with your personal information when you register for a REACH account.  We also collect your information whenever you modify your data and we keep track of your preferences when you select settings within the platform.

When you make use of any of our customer support channels such as, for example, when you submit information to us regarding a problem you may be having with any of our services, we will also ask for your personal details.

The type of information we collect directly from you in these situations usually relates to your contact details, therefore your name, surname, title, address, email address, phone number/s and I.D card or Passport number. 

When signing a contract and authorising us to debit your bank account for payment by direct debit, we will also have access to your banking details.

We do not keep any information relating to your payment details when you purchase anything from our website or download any of our applications.  This is handled entirely by a separate online payment system which we have no connection with.

To learn how the above-mentioned data is used by us, please refer to the section on How we use your information.

To learn about how we store your information and how long for, please refer to the section on How we store your information and keep it safe.

(ii) Information we collect when you use any of our services

When you are a registered customer and make use of any of our services, we collect data on the way you are using our services.  For example, when using REACH we will know things like the duration of your browsing sessions, what IP address you were assigned while browsing, the amount of data you uploaded.

For any of the services you subscribe to, we will know your monthly or yearly spend.

When you browse our website or visit your REACH account, we use cookies and other tracking technologies.

Whenever you give us your feedback together with your personal details, we also use this data.

To learn how the above-mentioned data is used by us, please refer to the section on How we use your information.

To learn about how we store your information and how long for, please refer to the section on How we store your information and keep it safe.

(iii) Information we obtain from others

We use other entities which are completely independent from us, known as credit rating agencies, and other publicly accessible sources, to provide us with information about you only when we need to carry out credit ratings or when we are trying to collect or enforce payment for outstanding bills you or the company you represent may have with us.

However, we also have access to publicly available information about you and to information about you which appears on your public profile on online social media platforms when you decide to contact us via these channels.

If you have filed an insurance-related or any other legal claim with/against us, we will collect any further data which we may be legally authorised or obliged to collect from third parties. The same shall apply if we have filed such a claim with/against you ourselves. If you do not give us access to personal information which is relevant to help us (or others acting in our interest) to assess our responsibility, if any, then we may either use whatever legal means we have available to obtain such information or we may not accept responsibility. To learn how the above-mentioned data is used by us, please refer to the section on How we use your information.

To learn how the above-mentioned data is used by us, please refer to the section on How we use your information.

To learn about how we store your information and how long for, please refer to the section on How we store your information and keep it safe.

How we use your information

We only collect, use and store the information about you which you or others provide us with in a lawful manner.  In this section, we aim to explain as clearly as possible when and where your information is used by us and the grounds upon which we collect and use that information.

Current data protection law provides for specific reasons and circumstances when we can collect, use and store your information.  In our case, it is one of the following four reasons that will justify why we process your information:

  1. The information is needed for you or us to fulfil our contractual obligations;
  2. The information is needed for you or us to fulfil a legal requirement;
  3. You have provided us with your consent to collect, use and store such information;
  4. There is a legitimate interest to collect, use and store such information.

When you have given us your consent to process your information, you are free to withdraw this consent at any time.  When we state that there is a legitimate interest to process your information, this refers to our interest or the interest of others and can be commercial interests, individual interests or broader societal benefits.  Nonetheless, you may object to the use of your data on this basis at any time.  For more information on how to withdraw your consent or object to the legitimate interest, please refer to the section on How you can access and control your information.

The type of information we use can be categorised broadly as follows: your contact information; information and records of your usage of our services; your fault history; and your bank details and billing history.

The contact information you provide us with in your contract/order form, via our customer care and sales channels or via social media platforms such as Facebook, is used for us to communicate with you and in order to:

  1. provide you with and deliver the services that you signed a contract for, including installation and maintenance of the services;
  2. respond to you and any comments, questions and requests and provide customer and/or technical support;
  3. inform you about service-related matters such as sending you technical notices, updates, security and usage alerts, informing you about benefits on your existing services and sending you messages of an administrative nature such as that you are getting a temporary upgrade of services free of charge or that your service is about to expire;
  4. verify your identity when you report a fault, ask for information and make use of our core products;
  5. bill, process and receive payments including receiving payment from your bank and sending reminders for you to renew or alter your direct debit mandate to us;
  6. get your feedback on our services;
  7. defend ourselves and safeguard our legal interests and rights.

We process this information on the basis of your and our legal and contractual obligations and also because we consider that there is a legitimate interest to do so.

Where you have specifically consented to doing so, your contact information is also used by us to communicate with you to market and promote our services. In this case, we will contact you by any of the following means: SMS, mobile phone, telephone, ordinary mail, email and other electronic and digital means. We may also contact you within the service itself or when we send your bill. We will inform you about any offers related to any of our products or services, and for any products or services we may be offering jointly or together with any other companies. However, we will never share any of your information with any other company for their own marketing purposes unless you have specifically consented to receive marketing from other companies via our website or any applications you make use of.

Any data generated as a result of your use of our services is used by us for billing purposes (including itemisation and refunds) and collecting payment and outstanding dues from you, for internal accounting and auditing purposes, to address any technical issues you or we may be experiencing and to monitor your use of our services and network to make sure you use them in a fair manner which doesn’t go against the law.  We do this in line with your and our legal or contractual obligations.

For our legitimate interest, we use your usage data, as well as any feedback you consented to provide us with, to understand your preferences, consider the suitability of products that may interest you, to improve and develop our products and services (including forecasting) and to personalise services and our communications to you.  In order for us to use your data for the purposes listed in this paragraph, we need to use automated processing.  This means that information on how you use our services will be gathered and analysed by tools which will also draw conclusions to help us understand how the core products and services we offer could be used, improved or developed to provide you or others with a better experience.  You will only be affected by the conclusions of this automated processing to the extent that we may contact you directly to make suggestions to change the package of services you are currently subscribed to.  However, you will be under no obligation whatsoever to take up such a suggestion.

The cookies and tracking technologies found on our website and when you log in to REACH are used to provide functionality and to recognise you across different services and devices.  Please see our Cookies Policy to find out more about what these cookies are, how and why we use them and how you can opt-out or limit these cookies.

We retain your fault history in order to solve problems you may be experiencing with our service, identify issues we may be experiencing with our network, monitor the performance of our network and to improve our services to you and others.  We do this in line with our contractual obligations to you and also because there is a legitimate interest for us to do so in order to continue providing you and our other customers with the best possible service.

Recordings of the calls you make to our call centre are kept to ensure that, insofar as this is possible, we are following your instructions to the letter.  Your calls to our call centre will also be recorded for quality assurance purposes.  We do this in order to fulfil our contractual obligations to you and ensure you are satisfied with the level of service we offer you.

We may also use live calls and call recordings for training purposes.  If we save a recording of your call for training purposes, we will delete anything that can identify the call with you and we shall never share any of your personal data with the employees we train.  Live calls and call recordings may also be used for internal and external audits and investigations including by law enforcement agencies.  We consider that there is a legitimate interest to justify our use of live calls and call recordings.

The use of 24/7 CCTV surveillance cameras is mainly intended to help you and our staff feel safer and the footage recorded is only shared with authorised enforcement agencies for the purpose of crime prevention, investigation and reporting because there is a legitimate interest to do so.  However, because there is a legitimate interest, we may also use this data to observe and understand how to run our outlets more efficiently.  Unless required for legal and investigative purposes, this footage is automatically overwritten after 30 days when.

Your monthly/yearly spend, which is generated as a result of your usage, as well as any credit worthiness information we get from third parties, are used so as to ensure that you can and will comply with your contractual obligation to settle bills relating to your use of our core products.

How we share your information

In order to provide, improve, customise, support and market our services, we engage the services or use the products of other companies with whom we have a contractual relationship.  As much as possible, we limit their access to any of your data.  However, if aspects of your personal data need to be shared by us with them or can be accessed by them for them to be able to assist us with our operations, they will only use or access that information under our instruction, and in accordance with policies and procedures designed to protect your information.

We use such companies or their products for the following purposes:

  • to install, deliver, provide, maintain and repair our services;
  • to offer customer care services;
  • to store, cross-check, verify and update your personal details;
  • to store, calculate, verify and update information on your use of our services;
  • to get feedback on how we are doing and whether you are satisfied with our services;
  • to follow up on debt collection through agencies or other debt recovery organisations;
  • to get professional advice or consultancy services;
  • to build, maintain, provide support services and troubleshoot matters relating to our various services;
  • to communicate with you on our behalf.

If any of the companies perform the functions listed above on our behalf outside of the EU or EEA or in a country which the EU Commission has not declared safe, then we will take all appropriate measures, in line with our own legal obligations, to ensure that the companies we engage adhere to the same high standards that are required of all companies operating and processing data within the EU.

We will never share your personal information with other companies which are not processing your information upon our instructions and we shall never share your personal information for marketing purposes unless you have specifically consented to it.

We may also be obliged to share any of your personal information which we have access to with competent authorities upon a lawful request.  This may include enforcement agencies such as the Police and courts of law and public authorities.  We may challenge any request to share such information if we do not consider it justified but we do not consider ourselves under an obligation to do so.  Unless we are prevented from doing so, we will always try to inform you that we have received such a request and which data we have shared with the requesting public entity.

It may become necessary for us to pass on all relevant personal information we may hold on you in the case of a complaint or suspicion of your abusive, fraudulent or illegal use of our network.  Recordings of your calls and CCTV footage may also be passed on to local enforcement agencies for the reporting, prevention, investigation and detection of crime.  However, we will also share your data with other companies, including with companies facing similar threats, for the purpose of protecting the security or integrity of any of our services or network.

We share financial information of defaulting customers and of dishonoured cheques with local credit reference agencies.

If you have filed an insurance-related or any other legal claim with/against us, or if we have had to file one against or with you, we may share your personal information with others in order to verify your identity or the identity of others involved in your claim, with the lawyers or other consultants we engage and with our insurance company. We shall only use and share any personal information we have access to for the purposes of the insurance or legal claim.

Where you have consented to sharing personal information with others for directory enquiries purposes, we will share such information with enquiring persons.  We will not share your information unless the enquiring persons themselves have already provided us with details, such as your name and surname and the locality you live in, that will help us identify you and give them the correct directory-related information they requested.  In the case of enquiries made by phone, we will only make your phone number known to the enquiring person.  In the case of automated online enquiries, only your phone number will be provided unless you have consented to reverse searches.

How we store your information and keep it safe

Our systems and networks use industry standard technology to protect all the personal information we hold and the processes we use are similarly geared.  While we implement safety measures designed to protect your information, no security system is impenetrable and, due to the inherent nature of the internet and technology, we cannot certify that data, while in transmission through the internet or while stored on our systems or otherwise in our care, is absolutely safe from any interference by others.

The length of time we keep your personal information for depends on the type of information.

Your personal contact details and your contract are kept for a period of five (5) years from your termination of services.  We have a legal right and obligation to do this.  This information may be kept for a longer period if there is an ongoing dispute between us.  In such a case, your information shall be kept until such a dispute is finally and effectively resolved and any outstanding dues and expenses are fully settled by you.

We have a legal obligation to keep your usage data for up to one (1) year and invoices for ten (10) years.

Beyond this time, we will delete or depersonalise any personal information we may have and use it for research and statistical purposes.  If, for some reason, this may not be possible (such as, for example, because the information was stored in backup archives), we will store it securely and not use it any further until deletion is possible.

If your personal details are being used with your consent for marketing or directory purposes, we will only keep that information and use it until your consent for us to do so remains valid.

Any recordings of calls are only kept for a maximum period of one year, after which they are automatically overwritten, so long as they are no longer required for crime prevention, crime investigation and/or crime detection purposes and crime reporting, for the resolution of any complaints, for the protection of our business and/or legal interests and the protection of our employees.

If you have filed an insurance-related or any other legal claim with/against us, we will keep your personal data and any further data which we may have been legally authorised or obliged to collect from others until such claim is finally and permanently settled and, where applicable, until any payment due is fully paid or received by us. The same shall apply if we have filed such a claim with/against you ourselves.

How you can access and control your information

Since we process your personal information, data protection law gives you specific rights which may be used under certain circumstances. In accordance with law, you have a right to:

Request access to your personal data:

This means that you have a right to ask, at no cost to you, for a copy of the personal information we hold about you.  You may do so by filling out and submitting a request in writing to info@sensinnovation.com or by mail addressed to the Data Protection officer at  Sens –  UB 5B Industrial Estate, San Gwann SGN3000 Malta.  This right can only be exercised by you to the extent that it will not affect others. 

Request the correction of your personal data:

This means that if any personal information we hold about you is incomplete or incorrect, you have a right to have this corrected.  In order to allow your request, you may need to provide us with evidence and documentation (such as your ID, passport or proof of address).  In order for us to process this request, you need to vist in person one of our offices.

Request the erasure of your personal data (aka the right to be forgotten):

This means that you may request the erasure of your personal data where we no longer have a legitimate reason to continue using or retaining it.  We will not be able to fulfil your request while you are still our customer and for a further period of five years thereafter as well as if we are under a legal obligation to retain this information, or where the retention of your information is necessary for us to defend ourselves in a legal dispute or to execute a legal title against you.  You must contact the Data Protection Officer in order for us to process this request.  You may do so in writing by email to info@sensinnovation.com or by mail addressed to the Data Protection officer at  Sens –  UB 5B Industrial Estate, San Gwann SGN3000 Malta.

Object to the processing of your data

You may object to the collection, use and/or sharing of your personal data if we rely on our legitimate interests (or those of a third party) to do so and you feel that our processing of your data in such a manner impacts your fundamental rights and freedoms. However, in some cases, we may be able to demonstrate that we have a compelling legitimate ground to process your data which may override your rights and freedoms. You may submit your objections to processing of your personal data on the grounds of the above-mentioned legitimate company interests by contacting our Data Protection Officer.  You may do so in writing by email to info@sensinnovation.com or by mail addressed to the Data Protection officer at  Sens –  UB 5B Industrial Estate, San Gwann SGN3000 Malta.

Request the restriction of the processing of your personal data

You may ask us to temporarily suspend the processing of your personal data in one of the following scenarios: (a) where you want us to establish the accuracy of the data, (b) where our use of the data is unlawful but you do not wish for us to delete it, (c) where you need us to retain your data even when we no longer need it in order for you to establish, exercise, or defend legal claims, or (d) where you have objected the use of your data but we need to verify whether we have overriding legitimate grounds to use it.  You must contact the Data Protection Officer in order for us to process this request.  You may do so in writing by email to info@sensinnovation.com or by mail addressed to the Data Protection officer at  Sens –  UB 5B Industrial Estate, San Gwann SGN3000 Malta.

Request the transfer of your personal data (aka data portability)

This means you may ask us to transfer certain data we process about you to you or others. This right only applies to data which you provided us with and consented us to use and which were necessary for us both to honour our mutual contractual obligations so long as such data is processed by us in an automated manner.  In order for us to process this request, you must contact the Data Protection Officer in order for us to process this request.  You may do so in writing by email to info@sensinnovation.com or by mail addressed to the Data Protection officer at  Sens –  UB 5B Industrial Estate, San Gwann SGN3000 Malta.

Withdrawal of your consent to processing your personal data

‘Opting out’ or withdrawing your consent will not affect the lawfulness of the processing carried out by us up until the time you withdrew your consent. Withdrawing your consent means that, SENSing forward, you no longer wish for us to process your data in such a manner. This means that you may no longer consent for us to provide you with certain services (such as marketing).  You will need to allow us 24 hours to action your request.  You may do so in writing by email to info@sensinnovation.com or by mail addressed to the Data Protection officer at  Sens –  UB 5B Industrial Estate, San Gwann SGN3000 Malta. You will automatically exclude yourself from further communication via all the various channels we use.

However, if you withdraw your consent, we may still have other lawful grounds or legal obligations to continue to use your information.  If there are, we shall inform you accordingly.

File a complaint with a supervisory authority

We hope to be able to resolve any difficulties or complaints you may have by bringing them to the attention of any of our customer support services or by forwarding whatever query, request or issue you may have to our Data Protection Officer.  You may do so in writing by email to info@sensinnovation.com or by mail addressed to the Data Protection officer at  Sens –  UB 5B Industrial Estate, San Gwann SGN3000 Malta.

However, should you consider at any time that we are handling your personal information in a manner that leaves you dissatisfied or at a disadvantage, you may at any time file a complaint with Office of the Information and Data Protection Commissioner by email on idpc.info@idpc.org.mt, by ordinary mail at Information and Data Protection Commissioner, Level 2, Airways House, High Street, Sliema, SLM 1549, Malta or by calling (+356) 2328 7100.

Except for your right to file a complaint with a supervisory authority, for us to be able to action any of your requests made in accordance with your rights described above, we may need to request specific information about you to help us verify your identity. This is a security measure to ensure that we are certain that the person to whom we disclose your personal data is really you.

We will do our utmost to respond to all legitimate requests within one month from when we receive a request. If your request is particularly complex, or if you have made multiple requests in a certain time period, it may take us a little longer. In such a case, we will notify you of this extension.

Other important information

Notice to Business Customers

We understand that any information your organisation shares with us on your employees, is done with their full knowledge.

We understand further that you have an interest in knowing how your employees may be making use of the services we offer and which you pay for.  We shall provide you with the information we are legally and contractually bound to.

If we consider that any request for further information may put you and/or us in breach of applicable data protection legislation, we will not provide such information to you.  We may need to contact you and your employees directly in order to make a considered decision on the matter.

Children’s personal information

Our systems do not allow us to assess the age of the users of our services.  We understand that our services may also be used by minors but we will not intentionally use, store or share their data unless this is done with the written consent of those who are legally responsible for their care.  The responsibility of a child’s use of our services shall remain with the consenting adult.

Changes to our Privacy Policy

We may change this privacy policy from time to time.  We will post any privacy policy changes on this page and, if the changes are significant, we will provide more prominent notice on our website and/or by sending you a notification within the service or via your contact information.  We will also keep prior versions of this policy in an archive which you can access.  We encourage you to review our privacy policy whenever you use our services to stay informed about our information practices and the ways you can help protect your privacy.

Contact us

Your information is controlled by SENS Innovation Group Ltd. or any of its subsidiaries. If you have any questions or concerns about how your information is handled, please do so in writing by email to info@sensinnovation.com or by mail addressed to the Data Protection officer at  Sens –  UB 5B Industrial Estate, San Gwann SGN3000 Malta.