Effective Date: 08/02/2025
1. Introduction
Kollox ltd (« we, » « us, » or « our ») is committed to protecting the privacy of visitors to our website www.facturx-dll.com (the « Website »). This Privacy Policy explains how we collect, use, and disclose personal data in compliance with the General Data Protection Regulation (GDPR) and Maltese law.
2. Data Controller
The data controller responsible for the processing of your personal data is:
Kollox ltd, Greystone flat 2, Sqaq san isidoru, MGR1271, Mgarr, Malta
3. Personal Data We Collect
For visitors to our Website, we may collect the following types of personal data:
- Data You Provide Voluntarily When Contacting Us: If you choose to contact us via email through the Website, we will collect the personal data you provide in your email. This typically includes:
- Your email address
- Your name (if you include it in your email or signature)
- Any other personal data you choose to include in the body of your email, such as business inquiries related to Factur-X DLL.
- Website Usage Data (Automatically Collected): When you visit our Website, our server may automatically collect certain information, including:
- IP Address: Your Internet Protocol (IP) address.
- Browser Type and Version: The type and version of browser you are using.
- Operating System: Your operating system.
- Referring Website: The website that referred you to our Website (if any).
- Date and Time of Visit: The date and time of your visit to the Website.
- Pages Visited: Information about the pages you access on our Website.
4. Purposes of Processing Personal Data and Legal Basis
We process your personal data for the following purposes and based on the following legal bases as defined under GDPR:
- To Respond to Your Inquiries (Legal Basis: Legitimate Interests): If you contact us with business questions via email regarding Factur-X DLL, we will process your personal data to respond to your inquiries and provide you with the information or assistance you requested. Our legitimate interest in this processing is to effectively manage and respond to business inquiries related to our software, which is essential for the operation of our business.
- To Maintain and Improve Our Website (Legal Basis: Legitimate Interests): We process website usage data, including data collected by Google Analytics cookies, to administer our Website, analyze trends, track user movement, and gather broad demographic information for aggregate use. This helps us to understand how visitors use our Website, which pages are most popular, and how users navigate the site to learn more about Factur-X DLL. This information is used to ensure our Website is functioning correctly, secure, and to improve its functionality and content to provide a better user experience. Our legitimate interest is to maintain and enhance our online presence and user experience for individuals interested in Factur-X DLL.
- Compliance with Legal Obligations (Legal Basis: Legal Obligation): We may be required to process your personal data to comply with applicable laws, regulations, legal processes, or governmental requests.
5. Data Retention
We will retain your personal data only for as long as necessary for the purposes set out in this Privacy Policy and in accordance with applicable legal requirements.
- Email Inquiries: We will retain the content of your email inquiries and your contact details for as long as necessary to address your inquiry regarding Factur-X DLL and for a reasonable period thereafter for record-keeping purposes and to manage ongoing communication related to your inquiry, unless a longer retention period is required or permitted by law. Typically, we will retain email correspondence for 1 year, unless there is an ongoing business relationship or legal obligation to retain it longer.
- Website Usage Data: Website usage data (including data collected by Google Analytics) is generally retained for a limited period, typically 26 months, for website analytics purposes, security purposes, system administration, and to improve our website and understand user interest in Factur-X DLL. After this period, this data is either deleted or anonymized. You can adjust the data retention settings for Google Analytics within your Google Analytics account.
6. Data Sharing and Disclosure
We will not share your personal data with third parties except in the following limited circumstances:
- Service Providers: We may engage third-party service providers to assist us in operating our Website and providing our services, such as hosting providers and analytics providers (including Google Analytics). These service providers will have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose, particularly for purposes unrelated to promoting Factur-X DLL. We will ensure that any such service providers are GDPR compliant and have appropriate data processing agreements in place. For Google Analytics, we have accepted the Data Processing Amendment and rely on Google’s compliance with GDPR.
- Legal Requirements: We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).
- Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets related to Factur-X DLL, your personal data may be transferred as part of that transaction, subject to applicable law.
7. Data Security
We have implemented appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:
- Secure Website Hosting: We use reputable hosting providers with secure infrastructure located within the EU.
- Limited Access to Data: Access to personal data is restricted to authorized personnel who need to access it for the purposes described in this Privacy Policy.
- Regular Security Reviews: We conduct regular reviews of our security measures to ensure they remain effective.
- Google Analytics Security: We rely on the security measures implemented by Google for Google Analytics services.
However, please remember that no method of transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
8. Cookies
We use cookies, including Google Analytics cookies, on our Website. Google Analytics cookies are used to help us analyze how visitors use our Website www.facturx-dll.com. They collect information such as the number of visitors to the Website, the pages they visited, and the source of their visit. This information is aggregated and anonymized to provide us with insights into website traffic and user behaviour related to our Factur-X DLL offering, which we use to improve our Website and better understand the interests of potential customers. We have taken steps to anonymize IP addresses within Google Analytics.
You can control the use of cookies at the individual browser level. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. To control Google Analytics specifically, Google provides a browser add-on that allows you to opt-out of being tracked by Google Analytics across all websites you visit. You can download this add-on here: https://tools.google.com/dlpage/gaoptout. Please note that if you disable cookies entirely, you may still use our Website, but your browsing experience may be affected.
9. Your Rights Under GDPR
Under the GDPR, you have certain rights regarding your personal data. These include:
- Right to Access: You have the right to request access to the personal data we hold about you and to receive a copy of your personal data.
- Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
- Right to Erasure (« Right to be Forgotten »): In certain circumstances, you have the right to request that we erase your personal data.
- Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.
- Right to Data Portability: You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and have the right to transmit that data to another controller.
- Right to Object: You have the right to object to the processing of your personal data in certain circumstances, particularly for direct marketing purposes and processing based on legitimate interests.
- Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. (Note: For this simple website, we are primarily relying on legitimate interests and not consent for processing for email inquiries. For Google Analytics, depending on your setup and local interpretations, consent might be required or implied through information and opt-out).
- Right to Lodge a Complaint with a Supervisory Authority: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of your personal data infringes the GDPR. In Malta, the supervisory authority is the Information and Data Protection Commissioner (IDPC).
10. Exercising Your Rights
To exercise any of your rights described in this Privacy Policy, please contact us using the contact details provided in Section 2, specifically via email to [email address removed]. We will respond to your request in accordance with GDPR requirements. We may need to verify your identity before fulfilling your request.
11. International Data Transfers
We primarily process your personal data within the European Economic Area (EEA). We ensure that all our service providers, including our website hosting provider, are also located within the EEA, so no international transfers of your personal data outside the EEA occur.
12. Links to Other Websites
Our Website may contain links to other websites that are not operated by us. This Privacy Policy does not apply to those other websites. We encourage you to review the privacy policies of any third-party websites you visit.
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations related to www.facturx-dll.com. We will post any changes on this page and update the « Effective Date » at the top of this Privacy Policy. We encourage you to review this Privacy Policy periodically. For significant changes, we may also notify you more directly, such as by email or a prominent notice on our Website.
14. Governing Law and Jurisdiction
This Privacy Policy and any disputes arising out of or in connection with it shall be governed by and construed in accordance with the laws of Malta. The courts of Malta shall have exclusive jurisdiction to settle any disputes arising out of or in connection with this Privacy Policy.