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, we will be more than glad to help you. Please send any such requests to [email protected] or call on (+356) 8000 2750. You may also write to Data Protection Office, Klikk p.l.c., GO, Tarxien Road, Zejtun, ZTN 3000, 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, warranty-related repairs and replacements, loyalty schemes and any other means that assist or improve your ease of access to or your experience of our core products.

Whether you are a new or existing customer, you should read this policy in full and better get to know how we work but, if you choose not to, these are the key points we would like for you to take away:

• Your information is controlled by Klikk p.l.c.. If you have any questions or concerns about how your information is handled, please fill out a Complaints Form and direct your inquiry to the Data Protection Office by email on [email protected], by ordinary mail at Data Protection Office, Klikk p.l.c., GO, Tarxien Road, Zejtun, ZTN 3000, Malta, or by calling (+356) 8000 2750.


• Klikk 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 and to rectify 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 goods and services 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 the goods and maintain the services we offer, for the payment of our products, 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 legal obligations, none of the ways in which we process your personal information will have any legal effects on you.

Information we collect about you if you are our customer

Once you purchase any goods from us and become are our customer, we collect your information when you (i) provide it to us in person or via our website; (ii) when you access any of our customer care 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 register your details voluntarily in order for us to create a customer account for you.  You also provide us with your personal information when you register on our website. 

When you make use of any of our digital or phone 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 to be able to log into your customer account.

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, residency card or Passport number. We may also ask for your age in order to determine whether we are legally required to get the consent of your parents or guardians.

When signing a contract that allows you to pay for your purchases by instalments and when you authorise 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. We currently use the services of APCO Systems Limited and more information on how they process your data can be obtained on their own website: https://www.apcopay.eu/

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 customer care services

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

We automatically record all calls you make to our customer care services on (+356) 8000 2750. Similarly, all calls which you receive and which originate from our technical support team, telesales agents, call centre agents, customer experience team and fraud prevention unit are recorded. We will not remind you of this recording when we call you if we are legally prevented from doing so.

When you visit any of our outlets and office reception areas, these premises are monitored with 24/7 CCTV surveillance cameras and this is clearly indicated with appropriate signage once you enter any of our premises.

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:

• The information is needed for you or us to fulfil our legal obligations;


• The information is needed for you or us to fulfil a legal requirement;


• You have provided us with your consent to collect, use and store such information;


• 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 purchases; your fault history; and, if you have a payment plan with us, 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:

• provide you with and deliver the goods that you signed a sales contract for, including installation and possible fault repair maintenance of the goods;


• respond to you and any comments, questions and requests and provide customer and/or technical support;


• inform you about matters relating to purchased products such as sending you technical notices or updates;


• verify your identity when you report a fault in your product or ask for information;


• 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 if you signed a monthly payment plan to pay for any of our products;


• get your feedback on our products and how we served you;


• defend ourselves and safeguard our legal interests and rights.

We process this information on the basis of your and our legal and, where applicable, 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 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, usually within the GO Group of 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.

For our legitimate interest, we use 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 customer care services (including forecasting) and to personalise customer care 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 goods and customer care services will be gathered and analysed by tools which will also draw conclusions to help us understand how the products and services we offer could be used, improved or developed to provide you or others with a better experience.  You and your rights will not be affected by the conclusions of this automated processing as it is conducted in an anonymised manner.

We may also use your data to thank and reward you for your loyalty as our customer.  We consider that there is a legitimate interest to do so. 

The cookies and tracking technologies found on our website are used to provide functionality and to recognise you across different devices.  Please see our Cookie 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 warranty history in order to solve problems you may be experiencing with our products, identify similar issues other customers may also be experiencing with our products and to improve the goods and the customer care service we offer for you and others.  We do this 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 customer experience.

Recordings of the calls you make to our call centre and of WhatsApp chats 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 legal 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.

Any credit worthiness information we get from third parties, are used so as to ensure that you can and will comply with any contractual obligation to settle any monthly instalment plan you may have signed up for.

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 personal 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 digital and over-the phone 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 priducts;


• 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 service and IT networks;


• to provide you with offers relating to your purchased products;


• 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 such as the Malta Competition and Consumer Affairs Authority.  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.

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 are kept for a period of five (5) years from the date of your last purchase.  The products you purchased are kept for five (5) years. We have a legitimate interest and after-sales contractual obligation to do this as we need to keep track of the commercial warranty periods of all our products, many of which are offered for five (5) years .  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 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 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 the following Data Subject Access Request Form (Forms to be uploaded soon, in the meantime you can email us at [email protected] for a copy).  This right can only be exercised by you to the extent that it will not affect others.  The form is also available at our outlets and can be submitted there, sent to by email the Data Protection Office on [email protected], or by ordinary mail at The Data Protection Office, Klikk p.l.c., ‘GO’, Tarxien Road, Zejtun, ZTN 3000, Malta.

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 go to any of our outlets;

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 on [email protected] or by ordinary mail at The Data Protection Office, Klikk p.l.c., ‘GO’, Tarxien Road, Zejtun, ZTN 3000, 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 on [email protected] or by ordinary mail at The Data Protection Office, Klikk p.l.c., ‘GO’, Tarxien Road, Zejtun, ZTN 3000, 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 on [email protected], or by ordinary mail at The Data Protection Office, Klikk p.l.c., ‘GO’, Tarxien Road, Zejtun, ZTN 3000, 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, going 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 need to fill out the Change in Consent Form (Forms to be uploaded soon, in the meantime you can email us at [email protected] for a copy) which is also available at our outlets and submit it at our outlets or send it to us by post at Customer Experience Section, Klikk p.l.c., ‘GO’, Tarxien Road, Zejtun, ZTN 3000, 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 can do so by submitting a Complaints Form, which is also available at our outlets, which can be submitted by email on [email protected], or by ordinary mail at The Data Protection Office, Klikk p.l.c., ‘GO’, Tarxien Road, Zejtun, ZTN 3000, Malta. You may also submit it at any of our outlets.

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 [email protected], 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

Children’s personal information

Our customer care systems which are not customer facing do not allow us to assess the age of the purchasers of our products. We understand that our products may also be purchased 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 products 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 Klikk p.l.c..  If you have any questions or concerns about how your information is handled, please fill out a Complaints Form and direct this or any inquiry to the Data Protection Office by email on [email protected], by ordinary mail at The Data Protection Office, Klikk p.l.c., ‘GO’, Tarxien Road, Zejtun, ZTN 3000, Malta or by calling (+356) 8000 2750.