Local Enforcement System Agency (LESA) (“we” or “us”) are committed to protecting and respecting your privacy and will not collect any personal information about you as a visitor unless you provide it voluntarily

1.1 This policy together with the Terms of Use and our Policy and Objectives apply to your use of: a) our website at les.gov.mt including, without limitation, the eServices functionality available to registered eServices Users pursuant to the Terms of Use; b) any of the services accessible through the Site (the "Services").

1.2 This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.

We are the data controller responsible for your personal data.

You have the right to make a complaint at any time to the Office of the Information and Data Protection Commissioner (OIDPC), the Maltese supervisory authority for data protection issues (https://idpc.org.mt). We would, however, appreciate the chance to deal with your concerns before you approach the OIDPC so please contact us in the first instance. So that we're clear and there's no misunderstanding about how we handle your personal data, we will:

• Always keep your data safe and private
• Never sell your data
• Allow you to manage and review your account at any time

2.1 We use cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy.

3.1 We will collect and process the following data about you:

1. Information you give us"Submitted Information" This is information you give us about you by filling in forms on the Site, or by corresponding with us (for example, by e-mail). It includes information you provide when you subscribe to any of our services and when you report a problem through the Site. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, username, password and other registration information, identification document numbers, copies of identification documents (for example ID card, passport, driving license) and any other information you provide us with (including that of customers and third parties) in order to prove your eligibility to use our services or submitted as a requirement for that particular service.
2. Information we collect about you. Each time you visit our Site we will automatically collect the following information:
   1. technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version.
   2. information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, form parameters inputted, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information;
   3. transactions related to payment are affected through the Government Payment Gateway and LESA does not store any credit card details or financial details apart from the basic transaction information including date, time, amount, currencies used, messages sent or received in conjunction with the payment processed through the Payment Gateway and uses such information to process payment on the Local Enforcement System and for reconciliation purposes;
3. Information to help us deliver our service to you. We work closely with third parties in order to help us deliver our Service to you. These third parties are sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, fraud prevention agencies, customer service providers and developers. Please see the 'Disclosure of your Information' section for more information.

4.1 Below is a summary of the key types of data that we make use of as part of the LESA services. For more information on how these types of data are used and for which purposes then please see the table below.
We use information held about you in the following ways:

1. Submitted Information: We will use this information:
   • to carry out our obligations arising from any transactions you enter into with us or Services you make use of and to provide you with the information and services that you request from us;
   • to provide you with information about other services that are similar to those that you have already utilised or subscribed for;
   • to provide you, or permit selected third parties to provide you, with information about services we feel may interest you. Please see the section on 'Third Party Services' below for more information;
   • to notify you about changes to our service;
   • to ensure that content from our site is presented in the most effective manner for you and for your computer.
2. Device Information: We will use this information:
   • to administer our Site for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
   • to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
   • to allow you to participate in interactive features of our service, when you choose to do so;
   • as part of our efforts to keep our Site safe and secure;
   • to comply with our regulatory obligations.
3. Third Party Information: We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information:
   • to process applications for services available through us; and
   • for the purposes set out above (depending on the types of information we receive).

4.2 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

4.3 If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymised personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users.

Purposes for which we will use your personal data
4.4 We have set out below, in a table format, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

What do we mean when we say:
Legitimate Interest: this means the interest of ours as an agency in conducting and managing les.gov.mt to enable us to provide to you the Services and offer the *most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Fulfilling a Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Our Legal Obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

5.1 We want to make it crystal clear how we use your data for marketing purposes and how you can 'opt-out' from receiving any marketing communications from us whenever you want.

5.2 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US
5.3 You will receive marketing communications from us if you have signed up to and/or utilize the Services provided by LESA and, in each case, you have not opted out of receiving marketing notifications.

THIRD-PARTY MARKETING
5.4 We will obtain your express opt-in consent before we share your personal data with any company outside LESA for marketing or promotional purposes

OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by adjusting your marketing preferences via the ‘Manage Account’ option or by following the unsubscribe links on any marketing messages sent to you.

DATA PROCESSING PARTNERS
6.1 We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by LESA.

6.2 We send personal data to the following sets of data processors in order to perform the Services:

1. Fraud prevention agencies
   This is in order to verify your identity, protect against fraud and to confirm your eligibility to use our services;
2. Cloud storage providers and other hosting providers
   This is in order to safely and securely store your data with LESA;
3. Delivery companies
   For the purpose of delivering documents to you according to legal requirements or contractual obligations;
4. Advertisers and analytics providers
   If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymized personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users. In some instances we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience; We also use analytics and search engine providers that assist us in the improvement and optimization of our site;
5. Other Government Entities
   Certain information may be passed on to other Government Entities for the purpose of satisfying legal requirements and/or contractual obligations.

6.3 We may also disclose your personal information in the following circumstances:

• If LESA’s operations are transferred onto other government appointed agencies, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
• In order to:
  1. enforce or apply the Terms of Use and/or Policy and Objectives and/or any other agreements between you and us or to investigate potential breaches; or
  2. protect the rights, property or safety of LESA, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

THIRD PARTY SERVICES PARTNERS
6.4 We may share your data in order to provide certain services to you upon your request. For example, we will share your data with our delivery sub-contractors so that they may deliver the eService agreements. Your data will only be sent across in these instances once you have requested to utilise the eServices. You can withdraw your consent at any time by contacting support via our Contact us page, however please be aware that this may impact your ability to use such services going forward. Please remember that when we share your data with our sub-contractors in such instances that you will also be subject to our sub-contractors privacy policy as well.

7.1 LESA is bound to keep the personal data about you (which data you submitted directly through the website or has been obtained via Official Data Sources such as the Common Database (CDB), Electoral Register and Vehicle Administration and Registration System) for as long as necessary and for the legal and operational purposes defined above.

7.2 To comply with the requirement: not to hold information longer than usual, we will not hold the eService Agreement once you have opted-out of the particular service and this data will be removed after 6 months from termination of account provided that there is no legal requirement or legitimate use requiring the keeping of the said information. In practice this means that these agreements will be kept until all contraventions for which a Summons (Notification for Hearing) was served electronically on the specified email address by means of an e-Summons have been settled and any such notification will be deemed to remain a valid notification at law not requiring a further notification of summons by post.

7.3 With respect to documents submitted on les.gov.mt including but not limited to petitions, penalty point declarations, driver’s license and any other pertinent information submitted by the user will be kept until the purpose for which they have been submitted has been achieved and for 6 months following the settlement of the concerned contravention(s).

You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our support team via the Contact Us page.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. As a government agency LESA is under certain obligations to retain contravention and personal information and in such cases these retention requirements supersede any right to erasure requests under applicable data protection laws.

Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights. As a government agency, LESA is under certain obligations to process and retain certain data for compliance purposes. Please note that these requirements supersede any right to objection requests under applicable data protection laws.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) where our use of the data is unlawful but you do not want us to erase it; (b) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (c) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please reach out to our support team via the Contact us page.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we will not be able to provide the eServices to you and you will be informed of this at the time of withdrawal of consent.

WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.1 Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by SMS, by e-mail and/or when you next log onto the Site. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Services.

10.1 All questions relating to data and your privacy are welcomed and should be addressed to our support team. If you have any questions, comments or requests regarding this privacy policy then please:

• Take a look at our FAQs;
• Take a look at some helpful guidance on OIDPC website which can be found here and
• Contact LESA support via our Contact Us page