Data Protection Statement – v.1.0 – 08.12.2014
1. – Glossary;
2. – Introduction;
3. – Data protection Principles,
4. – Use of information;
5. – Web Sites & e-mail marketing,
6. – Opt-in Policy;
7. – Cookies;
8. – Contact Information;
9. – Security, Data Security Breaches;
10. – Updating, Verifying and Deleting Personal Data;
11. – Right of Access
12. – Website usage terms and conditions
1. – Glossary
Data: means automated and manual data
Data Protection: is the safeguarding of the privacy rights of individuals in relation to the processing of personal data, in both paper and electronic format.
Data Protection Acts: the Principal Act means the Data Protection Act 1988 the Act of 2003 means the Data Protection (Amendment) Act,2003;
Personal Data: means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller;
Data Controllers: means a person who, either alone or with others, controls the contents and use of personal data;
Processing: Processing, of or in relation to information or data, means performing any operation or set of operations on the information or data, whether or not by automatic means, including: (a). obtaining, recording or keeping the information, or (b) collecting, recording, organising, storing, altering or adapting the information or data, (c) retrieving, consulting or using the nformation or data (d) disclosing the information or data by transmitting, disseminating or otherwise making it available, or (e) aligning, combining, blocking, erasing or destroying the information or data.
Sensitive Personal Data: means personal data as to –(a) the racial or ethnic origin, the political opinions or the religious or philosophical beliefs of the data subject, (b) whether the data subject is a member of a trade union (c) the physical or mental health or condition or sexual life of the data subject (d) the commission or alleged commission of any offence by the data subject, or(e) any proceedings for an offence committed or alleged to have been committed by the data subject, the disposal of such proceedings or the sentence of a ny court in such proceedings.
Session Cookies: “Session” cookies help users to navigate across VJ Agency Online pages. They are deleted once your leave our website. Session cookies do not contain anything other than a session identification number which allows the webserver to “remember” where you are online.
2. – Introduction.
VJ Agency respects each individual’s privacy and data protection rights and complies with its obligations under the Data Protection Acts 1988 and 2003. The Data Protection Acts 1988 and 2003 (the “Data Protection Acts”) lay down strict rules about the way in which personal data and sensitive personal data are collected, accessed, used and disclosed. It is VJ Agency’s Policy to protect the rights and privacy of individuals in accordance with the Data Protection Acts.
The Data Protection Acts also permit individuals to access their personal data on request, and confer on individuals the right to have their personal data amended if found to be incorrect.
This document outlines VJ Agency’s Policy for compliance with the Data Protection Acts. This Policy is a statement of VJ Agency’s commitment to protect the rights and privacy of individuals in accordance with the Data Protection Acts.
This Policy applies to all employees (including contractors and temporary personnel) of VJ Agency and any subsidiaries who process personal data/sensitive personal data of individuals including clients.
VJ Agency staff members and contractors of VJ Agency who separately collect, control or process the content and us e of personal data are individually responsible for compliance with the Data Protection Acts and this Policy and any related procedures. The Compliance Department co-ordinates the provision of support, assistance, advice, and training throughout VJ Agency and its subsidiaries to ensure compliance with the Data Protection Acts, this Policy and related procedures.
In the event that any change is made to Data Protection legislation or regulation, this Policy will be reviewed, updated and ratified. Adherence to this Policy is the responsibility of line management and will be subject to review by VJ Agency
3. – Data Protection Principles.
VJ Agency performs its responsibilities under the Data Protection Acts in accordance with the following eight Data Protection principles:
a. Obtain and process information fairly – VJ Agency obtains and process personal data fairly and in accordance with statutory and other legal obligations.
b. Keep it only for one or more specified, explicit and lawful purposes. – VJ Agency retains personal data for purposes that are specific, lawful and clearly stated. Personal data is only processed in a manner compatible with these purposes.
c. – Use and disclose only in ways compatible with these purposes. – VJ Agency discloses personal data only in circumstances that are necessary for the purposes for which the data is collected. Where personal data is used for marketing purposes, appropriate consents must be obtained from the clients/potential clients. Where prior notification and/or consent where required is provided by the data subject, VJ Agency may disclose information to our service providers and contractors for the following: – processing and assessing the application(s); – verifying personal data, including contacting the employers or professional advisers of the applicants; – meeting VJ Agency’s legal and compliance obligations; – quality control and Group reporting and management; and – marketing purposes , if appropriate consent is received.
d. – Keep it safe and secure. – VJ Agency takes appropriate security measures against unauthorised access to, or alteration, disclosure or destruction of personal data and against its accidental loss or destruction. This includes adopting enhanced security measures where personal data is being stored or processed outside of a secure VJ Agency office location (e.g. encryption of laptops etc).
e. – Keep it accurate, complete and up-to-date. – VJ Agency adopts procedures that ensure high levels of data accuracy, completeness and ensure that personal data is up-to-date. Where there has been a contravention in relation to Section 2(1) of the Data Protection Acts, VJ Agency acknowledges the right of the data subject, to having his/her personal data rectified, blocked or erased.
f. – Ensure it is adequate, relevant and not excessive. – VJ Agency only requests and retains personal data to the extent that it is adequate, relevant and not excessive.
g. – Retain for no longer than is necessary. – VJ Agency maintains retention schedules which document the retention period for all data (including personal data) . Retention schedules are reviewed on an annual basis and signed by line management.
h. – Give a copy of his/ her personal data to that individual, on request. VJ Agency also adopts procedures to ensure that data subjects can exercise their rights under the Data Protection Acts to access their data. VJ Agency also adopts procedures to ensure that where requested in writing, data subjects will be informed of the data that is processed on his/her behalf, a description of the data and the reason for processing.
4. – Use of information.
The Data Protection Acts impose obligations on Data Controllers (including VJ Agency), to process personal data entrusted to us in a manner that respects the rights of data subjects.
We collect and use information to provide the following services: (a). – to undertake advertising, marketing, direct marketing and public relation exercises; (b). – to perform accounting and other record-keeping functions; (c). – to provide personnel, payroll and pension administration services. (d). – to provide clients with online services. (e). – to comply with our legal obligations; (f). – Prevent or detect crime.
Sensitive personal data will be held, only where necessary, in order to process applications and VJ Agency staff members sensitive personal data may also be held for employment purposes. Except in the narrow exceptional cases set out in the Data Protection Acts, explicit consent is obtained from clients in line with the Data Protection Acts in order to process such data. We don not collect customers sensitive personal data.
5. – Web Sites & e-mail Marketing.
VJ Agency has created this specific privacy statement to demonstrate our firm commitment to privacy. A user can access our sites and utilise it without providing any information at all. However, all users who register for VJ Agency services may provide an e-mail address, for direct marketing purposes, or basic contact and demographic information. This site contains links to other sites. VJ Agency is not responsible for the privacy practices or the content of such websites.
VJ Agency will not disclose a user’s personally identifiable information to any third party without the user’s express permission except where applicable for the purpose of supplying the service for which the user has registered. We do not follow a user’s browsing path outside of our websites.
We collect any information you voluntarily provide through any correspondence with VJ Agency through email or optional sign ups. This information is not disclosed to any third party without your prior consent. For example, if you contact our privacy staff via email, we collect your email address, name and any additional information you include in your email message.
Information such as your email address and name may also be collected when you sign up to E-mail marketing services offered by VJ Agency and our partner services. These services currently include the following: e-mail marketing.
VJ Agency offers users the ability to change certain personal identifiable information (e.g. email address) collected during the signup process for specific services.
6. – Opt-in Policy.
Our sites provides users with the opportunity to opt-in to receive promotional/marketing information from VJ Agency and select advertisers via email.
This means that only with your explicit consent, we may contact you via the contact details provided by you for marketing, advertising and opinion research purposes, this includes for example information related to products of the product you are interested in, e-commerce activities, special offers, promotions as well as information on store openings, store activities or events.
All email correspondence from VJ Agency will include an opt-out / unsubscribe button, so you can unsubscribe from these emails at any time by following the ‘unsubscribe’ link at the footer of the email page. You may also send an express request to at any time, should you wish to request removal from our files.
7. – Cookies
Cookies are small pieces of information, stored in simple text files, placed on your computer by a website. Cookies can be read by the website on your subsequent visits so that you can access information in a faster and more efficient way. The information stored in a cookie may relate to your browsing habits on the web page, or a unique identification number so that the website can “remember” you on your return visit. Generally speaking, cookies do not contain personal information from which you can be identified, unless you have separately furnished such information to the website.
You can at any time set your browser or your mobile device settings to reject cookies. However if you reject our session cookies, this may affect your ability to use our website.
For more information on how to manage cookies, including including how to disable cookies please visit: www.aboutcookies.org.
We log your IP address, browser’s user agent and referring address to help diagnose problems with our server, to administer our website and to identify unique users. Your IP address is also used to gather broad demographic information.
VJ Agency may perform statistical analyses of user behaviour in order to measure interest in the various areas of our site (for product development purposes) and to inform advertisers as to how many consumers have seen or ‘clicked’ their advertising banners.
For the purposes of statistical analysis and advertisement targeting, we will disclose information to third parties only in aggregate form. Personal information about you as an individual subscriber will not be provided to any third party without your consent.
8. – Contact Information.
If you have any questions regarding this privacy statement or the security practices of VJ Agency, please send them to VJ Agency or to VJ Agency St. Teodor Keko, Ales building, Tirana, Albania.
9. – Security Data Security Breaches.
This site has security measures in place to protect the loss, misuse and alteration of the information under our control. Unfortunately, no data transmission over the internet can be guaranteed to be 100 per cent secure. As a result, while we strive to protect your personal information, VJ Agency cannot ensure or warrant the security of any information you transmit to us or from our online products or services – you do so at your own risk. Once we receive your transmission, we make our best effort to ensure its security on our systems.
The Data Protection Commissioner has approved a Personal Data Security Breach Code of Practice to help organisations react appropriately when they become aware of breaches of security involving customer personal information.
The Code of Practice addresses “security breaches” i.e. personal data which has been put at risk of unauthorised: • disclosure, • loss, • destruction or • alteration
In the event of a security breach, VJ Agency may be obliged to make initial contact with the Data Protection Commissioner outlining circumstances surrounding the incident, the number of data subjects affected, noting where appropriate any additional controls that have been put in place and confirming that the information has subsequently been secured which was inappropriately disclosed.
- – Updating, Verifying and Deleting Personal Data
If VJ Agency hold incorrect information about you, you have the right to have the data amended. Further you have the right to have any information you have sent to us erased if we have failed to comply with our obligations under the Data Protection Acts. To request your right to rectification and/or erasure please send your request to us in writing at or to VJ Agency, St: Teodor Keko,Ales Building , Tirana, Albania, with: 1. Your name and address. 2. A description of the specific personal data you wish rectified.
If you request an erasure of your personal data, all your data will be erased subject to the following important notice. You agree that you will notify us of any relevant change in your personal circumstances to enable us to comply with our obligations to keep your information up to date.
- – Right of Access
Where you have provided us with your personal data you have a right to be given a copy of your personal data in accordance with section 4 of the Data Protection Acts subject to certain exceptions. To request a copy of your personal data please visit our Access Request Procedure at www.vj.agency where you can download our Access Request Form for completion before sending it to us at together with the prescribed fee of €6.35.
Please note the following important points: 1. we reserve the right not to process an access request that is not made in our Access Request Form format or which does not contain sufficient detail to enable us to comply with our obligations. We will however notify you of any decision not to process a request for these reasons. 2. we shall not process an access request unless the prescribed fee of €6.35 is received by cheque or postal money order; and 3. we are only obliged to process access requests received in writing and do not accept access requests via telephone or text message.
Website usage terms and conditions
The term ‘VJ Agency’ or ‘us’ or ‘we’ refers to the owner of the website whose registered office is [address]. Our company registration number is [company registration number and place of registration]. The term ‘you’ refers to the user or viewer of our website.
The content of the pages of this website is for your general information and use only. It is subject to change without notice.
Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the website.
Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.
From time to time, this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
Your use of this website and any dispute arising out of such use of the website is subject to the laws of Italy