Privacy Policy

1. Who we are

110 Analytics Ltd (“110 Analytics”, “we”, “us”) is a company registered in Malta.

• Registered name: 110 Analytics Ltd

• Company registration number: C 113879

• Registered office: 81, Triq il-Falkunier, Fgura FGR 1934, Malta

• Telephone: +356 7998 0821

• Privacy contact: admin@110analytics.io

For the personal data described in this policy, 110 Analytics Ltd is the controller under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Maltese Data Protection Act (Chapter 586 of the Laws of Malta).

We have not appointed a Data Protection Officer. We are not a public authority, our core activities do not consist of large-scale processing of special category data, and we do not carry out large-scale systematic monitoring of individuals. We keep that assessment under review and will appoint a DPO if it changes.

2. What this policy covers

This policy applies to personal data we process when you:

• visit 110analytics.io or go.110analytics.io, including any campaign or landing page on those domains;

• complete a form, book a call, or otherwise contact us;

• interact with our pages on LinkedIn, Facebook or Instagram;

• view a publicly accessible dashboard we publish, including the Malta Media Battle dashboard;

• receive business communications from us.

  
  

What this policy does not cover

Where we deliver services to a client, we process data inside that client’s systems on the client’s instructions. In that work the client is the controller and we act as a processor under a written data processing agreement. The client owns that data, the client’s own privacy notice governs it, and this policy does not apply to it. If you believe your data sits inside a client system we work on, please contact that organisation.

Our websites link to third-party sites we do not control. This policy does not cover them.

3. The personal data we process

We do not ask for special category data and we ask that you do not send it to us. We do not knowingly collect data from anyone under 16.

3.1 Data collected automatically

IP address, approximate location derived from it, device and browser type, operating system, referring page, pages viewed, time on page, clicks and scroll depth, and cookie or similar identifiers. On non-essential collection, see section 6, nothing beyond what is strictly necessary is collected before you agree to it.

3.2 Data from other sources

• Business contact details from public and professional sources, including LinkedIn, company websites and business directories, where we identify an organisation that may be a fit for our services. We use the individual’s name, role, employer and business contact details for business-to-business outreach on the basis of our legitimate interests (section 4). We do not buy consumer marketing lists.

• Referrals, where an existing contact passes on your details. We will tell you who referred you if you ask.

• Our booking and CRM system, where a booking or form submission generates a record.

  
  

4. Why we process it, and our lawful basis

Where we rely on legitimate interests we have weighed our interest against your rights and freedoms. Our outreach is limited to business contact details, in a business context, about services relevant to the recipient’s role; every message identifies us and offers a simple way to stop hearing from us. You can object at any time (section 9) and we will stop.

Where we rely on consent, you can withdraw it at any time, use the unsubscribe link in any marketing email, change your cookie choices using the “Cookie settings” link in our footer, or email admin@110analytics.io. Withdrawing consent does not affect processing already carried out.

5. Who we share it with

We do not sell personal data. We share it with the following categories of recipient, each under a written contract that limits them to processing it on our instructions.

We will also disclose personal data where we are required to by law, by a court, or by a competent authority, and to a buyer or successor if our business is sold or reorganised.

A note on our social media pages. When you interact with our pages on Facebook, Instagram or LinkedIn, the platform gives us aggregated audience statistics (Page Insights or their equivalent). For that statistical processing we and the platform act as joint controllers. We do not receive data identifying individual visitors through it, and we have no control over the platform’s own processing of your account data, that is governed by the platform’s own terms and privacy notice.

6. Cookies and similar technologies

We use three groups of cookies and similar technologies.

Strictly necessary. Needed for the site to work — security, load balancing, remembering your cookie choices. These are set without consent because the site cannot function without them. Examples include our consent-preference cookie, which lasts up to 12 months.

Analytics. Tell us how the site is used so we can improve it. Examples: Google Analytics 4 _ga (up to 24 months) and _ga_<container-id> (up to 24 months).

Advertising. Let us show relevant advertising and measure whether it works. Examples: Google Ads _gcl_au (up to 90 days), the Meta pixel _fbp (up to 90 days), and LinkedIn’s li_sugr and bcookie (up to 12 months).

Nothing in the analytics or advertising groups is set, and no analytics or advertising tag fires, before you accept it. Our cookie banner gives Accept, Reject and Settings equal prominence; rejecting is a single click and carries no penalty. Where Google’s Consent Mode is in use, your choice is passed to Google’s tags and they behave accordingly.

You can change your mind at any time using the Cookie settings link in our website footer, and you can block or delete cookies in your browser, though strictly necessary cookies cannot be turned off without affecting how the site works.

7. Transfers outside the EEA

Some of our providers are established outside the European Economic Area, or process data outside it. Where personal data is transferred outside the EEA, we rely on one of the following:

• an adequacy decision by the European Commission, including the EU–US Data Privacy Framework where the recipient is certified under it; or

• the European Commission’s Standard Contractual Clauses, together with a transfer risk assessment and, where needed, additional technical and organisational safeguards.

To ask which mechanism applies to a specific provider, or for a copy of the safeguards in place, email admin@110analytics.io.

8. How long we keep it

Where a longer period is needed for a legal claim, we keep only what is relevant to that claim, for as long as it is live.

9. Your rights

Under the GDPR you have the right to:

• be informed about how we use your data, this policy;

• access the personal data we hold about you, and receive a copy;

• have inaccurate data corrected, and incomplete data completed;

• have your data erased, where one of the grounds in Article 17 applies;

• restrict our processing while a dispute about accuracy or lawfulness is resolved;

• receive your data in a portable format, where we process it by automated means on consent or contract;

• object to processing based on our legitimate interests, and — with no need to give a reason — to direct marketing, which we will always honour; and

• withdraw consent at any time, where consent is the basis.

We do not carry out automated decision-making that produces legal effects for you, and we do not profile individuals in a way that has a significant effect on them.

To exercise any of these rights, email admin@110analytics.io or write to us at the registered office above. We will respond within one month. If your request is complex, or if you have made several, we may extend that by up to two further months and will tell you why. There is no charge unless a request is manifestly unfounded or excessive. We may ask for enough information to confirm your identity before we act.

If you are not satisfied, you can complain to the Maltese supervisory authority:

Information and Data Protection Commissioner (IDPC) Level 2, Airways House, High Street, Sliema SLM 1549, Malta +356 2328 7100 · idpc.info@idpc.org.mt · idpc.org.mt

You may also bring a claim before the Maltese courts. We would rather hear from you first, so please give us the chance to put it right.

10. Security

We hold personal data in access-controlled cloud services with encryption in transit, and we limit access to the people who need it for the purpose it was collected for. No system is perfectly secure, and we cannot guarantee the security of data while it travels to us over the internet. If a breach occurs that is likely to result in a risk to your rights, we will notify the IDPC within 72 hours and tell you directly where the law requires it.

11. Changes to this policy

We may update this policy as our processing changes. The version and date at the top always show the current one. Where a change materially affects how we use your data, we will say so on our website and, where we hold your contact details for that purpose, tell you directly.

12. Contact

Questions about this policy, or about how we handle your data:

110 Analytics Ltd · 81, Triq il-Falkunier, Fgura FGR 1934, Malta admin@110analytics.io · +356 7998 0821