Privacy policy

1. Who we are

Jobs Classified Malta™ is a trading name of Future Computers Limited, a company registered in Malta.

Our registered office is:

Future Computers Limited
Future Computers
Triq L-Akwedott
Fleur-De-Lys
Santa Venera
Malta

In this Privacy Policy:

• “Jobs Classified Malta™” means the Jobs Classified Malta job portal and related services;

• “Platform” means the Jobs Classified Malta™ website, systems, features and services;

• “we”, “us” and “our” mean Future Computers Limited;

• “Candidate” means a person searching or applying for employment opportunities;

• “Employer” means a company, organisation, recruitment agency, sole trader or individual advertising or recruiting through the Platform; and

• “personal data” means information relating to an identified or identifiable natural person.

Questions about this Privacy Policy or our processing of personal data should be submitted through the Contact page at /contact.

2. Scope of this Privacy Policy

This Privacy Policy explains how we collect, use, disclose, retain and protect personal data when you:

• visit or browse the Platform;

• create a Candidate account;

• create an Employer account;

• search for vacancies;

• save vacancies or searches;

• subscribe to job alerts;

• submit a job application;

• upload a CV or supporting document;

• publish or manage a vacancy;

• purchase job-posting Credits or other services;

• contact us; or

• otherwise use Jobs Classified Malta™.

This Privacy Policy applies to personal data processed by Future Computers Limited.

Employers and recruiters receiving applications through the Platform may process Candidate information independently for their own recruitment purposes. Their processing is governed by their own privacy notices and legal obligations.

3. Our role under data-protection law

Future Computers Limited generally acts as a data controller when processing personal data to:

• operate and secure the Platform;

• create and manage accounts;

• provide job alerts;

• process purchases and invoices;

• administer Employer services;

• prevent fraud and misuse;

• respond to enquiries;

• comply with legal obligations; and

• improve the Platform.

When a Candidate applies for a vacancy, the Employer or recruiter responsible for that vacancy will generally act as an independent data controller for the application.

The relevant Employer normally determines:

• how the application is assessed;

• who may access it;

• whether the Candidate is contacted;

• whether the Candidate is shortlisted or interviewed;

• whether information is verified;

• whether the Candidate is offered employment; and

• how long the application is retained.

Where we merely host, store or transmit application information on an Employer’s documented instructions, we may act as a data processor for that specific processing activity.

4. Personal data we collect

The information we collect depends on how you use the Platform.

4.1 Information collected when you browse

When you access the Platform, we may collect:

• Internet Protocol address;

• browser type and version;

• device type;

• operating system;

• language and regional settings;

• date and time of access;

• pages and vacancies viewed;

• navigation and interaction information;

• referral source;

• campaign parameters;

• cookie identifiers;

• session identifiers;

• server logs;

• security logs;

• diagnostic information; and

• error reports.

We use this information to deliver the Platform, maintain security, diagnose faults, prevent misuse, measure performance and understand general usage.

4.2 Candidate account information

When you create or use a Candidate account, we may collect:

• name;

• email address;

• telephone number;

• account credentials;

• authentication information;

• account preferences;

• preferred job categories;

• preferred locations;

• saved searches;

• saved vacancies;

• CVs and résumés;

• cover letters;

• employment history;

• education history;

• qualifications;

• licences;

• certifications;

• professional skills;

• portfolio links;

• professional-profile links;

• account activity;

• application history; and

• communications with us.

4.3 Job-application information

When you apply for a vacancy, we may collect:

• name;

• email address;

• telephone number;

• postal address, where supplied;

• CV or résumé;

• cover letter;

• employment history;

• educational information;

• qualifications;

• professional skills;

• licences and certifications;

• portfolio or professional links;

• answers to Employer screening questions;

• availability;

• notice period;

• preferred working arrangements;

• work-authorisation information;

• uploaded supporting documents;

• the vacancy applied for;

• submission date and time;

• technical information relating to the submission; and

• application-related communications made through the Platform.

Application information is made available to the Employer, recruiter or organisation identified in the relevant vacancy.

4.4 Job alerts and newsletters

When you subscribe to job alerts or similar communications, we may collect:

• email address;

• preferred job categories;

• preferred locations;

• search keywords;

• preferred alert frequency;

• subscription date;

• confirmation records;

• consent records;

• delivery information;

• interaction information, where legally permitted; and

• unsubscribe records.

4.5 Employer and recruiter information

When you create or use an Employer account, we may collect:

• name;

• job title;

• work email address;

• work telephone number;

• account credentials;

• authentication information;

• organisation name;

• company-registration details;

• registered address;

• business address;

• website;

• VAT information;

• business-sector information;

• company-profile content;

• organisation-verification documents;

• information confirming authority to represent the organisation;

• authorised-user information;

• account permissions;

• vacancy content;

• logos, images and media;

• posting history;

• account activity;

• package and subscription information;

• payment and invoice information;

• support communications; and

• information concerning suspected fraud, misuse or policy breaches.

4.6 Payments and billing

Where paid services are offered, we may collect:

• purchaser name;

• company name;

• billing address;

• VAT or tax information;

• order details;

• invoice details;

• transaction amount;

• transaction status;

• payment-provider reference; and

• refund or dispute information.

Payments may be processed by an external payment-services provider.

Unless expressly stated otherwise, we do not store full payment-card numbers or card security codes.

4.7 Enquiries and support

When you contact us, we may collect:

• name;

• contact details;

• account information;

• organisation information;

• message content;

• documents or screenshots;

• technical information;

• correspondence history; and

• internal notes concerning the enquiry.

4.8 Information received from third parties

We may receive personal data from:

• Employers and recruiters;

• authorised Employer-account users;

• payment providers;

• authentication providers;

• company-verification providers;

• fraud-prevention providers;

• analytics or referral providers, where legally permitted;

• publicly available registers;

• professional advisers;

• regulators;

• courts; and

• law-enforcement authorities.

5. Sensitive and special-category data

The Platform is not intended to collect sensitive or special-category personal data unless such information is genuinely necessary for a lawful recruitment process.

This includes information concerning:

• racial or ethnic origin;

• political opinions;

• religious or philosophical beliefs;

• trade-union membership;

• genetic information;

• biometric information;

• health;

• disability;

• sex life; and

• sexual orientation.

Candidates should avoid placing unnecessary sensitive information in CVs, cover letters or application responses.

Employers must not request sensitive information unless the request is lawful, necessary, proportionate and supported by an appropriate legal basis.

Information concerning criminal convictions or offences must also be processed only where legally authorised.

6. Why we process personal data

We may process personal data to:

• provide and operate the Platform;

• create and administer accounts;

• authenticate Users;

• publish and manage vacancies;

• enable Candidates to apply;

• transmit applications to Employers;

• maintain application histories;

• provide saved searches and saved vacancies;

• provide requested job alerts;

• administer Employer services;

• process orders and payments;

• allocate job-posting Credits;

• issue invoices;

• verify Employer accounts;

• provide customer support;

• respond to complaints;

• answer privacy requests;

• send service communications;

• send marketing where permitted;

• monitor Platform performance;

• diagnose technical faults;

• improve Platform functionality;

• detect and prevent fraud;

• prevent spam and malicious activity;

• enforce our Terms and Conditions;

• protect our rights and systems;

• establish, exercise or defend legal claims;

• comply with legal and regulatory requirements; and

• create aggregated or anonymised statistics.

7. Legal bases for processing

Depending on the circumstances, we rely on one or more of the following legal bases.

7.1 Contract

We process personal data where necessary to:

• provide a service requested by you;

• create or administer an account;

• enable a job application;

• publish a vacancy;

• allocate Credits;

• process a purchase; or

• take steps at your request before entering into a contract.

7.2 Legitimate interests

We may process personal data where necessary for legitimate interests, including:

• operating a reliable jobs Platform;

• connecting Candidates and Employers;

• maintaining Platform security;

• preventing fraud and abuse;

• improving Platform performance;

• managing customer relationships;

• maintaining business records;

• protecting legal rights; and

• enforcing agreements.

We consider whether those interests are overridden by the rights and freedoms of affected individuals.

7.3 Consent

We rely on consent where required, including for:

• certain marketing communications;

• non-essential cookies;

• certain analytics technologies;

• advertising technologies; and

• optional processing expressly presented as consent-based.

Consent may be withdrawn at any time.

Withdrawal does not affect processing carried out lawfully before withdrawal.

7.4 Legal obligations

We process personal data where necessary to comply with obligations concerning:

• accounting;

• taxation;

• VAT;

• company records;

• regulatory requirements;

• court orders;

• law-enforcement requests; and

• other applicable legal duties.

7.5 Legal claims and public interests

We may process personal data where legally permitted and necessary to:

• establish, exercise or defend legal claims;

• prevent unlawful activity;

• protect individuals or systems;

• respond to security incidents; or

• comply with substantial public-interest obligations.

8. Whether personal data must be provided

You may browse certain parts of the Platform without creating an account.

However, personal data may be required to:

• create an account;

• apply for a vacancy;

• upload a CV;

• publish a Job Advertisement;

• purchase Credits;

• receive job alerts;

• process a payment; or

• respond to a legal or verification requirement.

Where required information is not provided, we may be unable to provide the relevant service.

9. Who receives personal data

9.1 Employers and recruiters

When a Candidate submits an application, the application is disclosed to the Employer, recruiter or organisation identified in the vacancy.

That organisation may use the information to:

• assess the application;

• contact the Candidate;

• conduct interviews;

• verify information;

• obtain references;

• make recruitment decisions;

• maintain recruitment records; and

• consider the Candidate for other roles where legally permitted.

The Employer’s independent processing is subject to its own privacy notice.

9.2 Service providers

We may use providers of:

• hosting;

• cloud infrastructure;

• databases;

• backups;

• content delivery;

• email delivery;

• job-alert distribution;

• customer-support systems;

• authentication;

• payment processing;

• invoicing and accounting;

• analytics;

• performance monitoring;

• fraud prevention;

• cybersecurity;

• technical maintenance;

• software development;

• legal services;

• auditing; and

• professional consultancy.

Providers acting as processors may process personal data only under appropriate contractual and legal safeguards.

9.3 Corporate transactions

Personal data may be disclosed in connection with a merger, acquisition, restructuring, financing, sale of assets or transfer of the Platform, subject to appropriate safeguards.

9.4 Authorities and legal recipients

We may disclose personal data where required or authorised by law to:

• courts;

• regulators;

• law-enforcement authorities;

• government departments;

• tax authorities; or

• other competent public bodies.

10. Public information

Job Advertisements and Employer-profile information may be publicly accessible.

Public information may be:

• indexed by search engines;

• cached;

• shared;

• copied;

• included in job alerts; or

• distributed through approved promotional or syndication channels.

Employers should not include unnecessary personal data in public advertisements.

Candidate applications and CVs are not intended to be publicly displayed unless an optional public-profile feature is clearly offered and activated by the Candidate.

11. International data transfers

We aim to process personal data in Malta, the European Economic Area or jurisdictions recognised as providing an adequate level of protection.

Some service providers may process or permit access to personal data outside the European Economic Area.

Where required, we will use safeguards such as:

• an adequacy decision;

• European Commission-approved Standard Contractual Clauses;

• Binding Corporate Rules;

• approved certification or contractual mechanisms; or

• another legally permitted transfer mechanism.

Information about applicable transfer safeguards may be requested through the Contact page at /contact.

12. Data retention

We retain personal data only for as long as reasonably necessary for the relevant purpose or as required by law.

Retention depends on:

• the type of data;

• the service concerned;

• Employer instructions;

• legal obligations;

• security considerations;

• disputes;

• complaints; and

• ongoing investigations.

12.1 Candidate accounts

Candidate-account information is generally retained while the account remains active.

Following closure, information may be deleted or anonymised after a reasonable administrative and security period, unless continued retention is legally necessary.

12.2 Applications and CVs

Applications and CVs are retained for the period configured for the relevant vacancy, Employer account or Platform service.

They may be deleted or anonymised after the vacancy closes or the applicable retention period expires.

An Employer may retain an independent copy under its own recruitment-retention policy.

Deleting an application from the Platform does not necessarily delete copies already held by the Employer.

12.3 Job alerts

Job-alert information is retained until you unsubscribe, delete the alert, close the account or the service is discontinued.

A limited suppression record may be retained to ensure that unwanted messages are not sent.

12.4 Employer accounts

Employer-account and job-posting records are generally retained while the account remains active and for a reasonable period afterwards for administration, accounting, security, dispute resolution and legal compliance.

12.5 Billing records

Invoices, transaction records and supporting accounting information are retained for the periods required by applicable Maltese tax, VAT, accounting and company law.

12.6 Support and complaints

Enquiries and complaints are retained for as long as needed to resolve the matter and for a reasonable period afterwards.

12.7 Logs

Technical, server and security logs are retained for a limited operational period, unless longer retention is needed for incident investigation, fraud prevention or legal claims.

12.8 Backups

Deleted personal data may remain temporarily in protected backups until those backups are overwritten or deleted according to the applicable backup cycle.

13. Cookies and similar technologies

The Platform may use:

• cookies;

• local storage;

• pixels;

• tracking tags;

• software development kits; and

• similar technologies.

These may be used to:

• provide essential functions;

• maintain sessions;

• authenticate Users;

• remember preferences;

• secure accounts;

• detect fraud;

• diagnose faults;

• measure performance;

• understand usage;

• measure campaigns; and

• provide advertising where legally permitted.

Strictly necessary technologies may be used without consent where legally permitted.

Non-essential technologies will be used only where permitted and, where required, after consent has been provided.

Cookie choices may be managed through the Platform’s cookie controls.

14. Job alerts and marketing

We may send job alerts specifically requested by you.

We may send marketing communications where:

• you have consented; or

• another lawful basis permits the communication.

You may unsubscribe through the mechanism contained in the communication or through available account settings.

Unsubscribing from marketing does not prevent essential service communications concerning accounts, applications, purchases, security or legal matters.

15. Automated decision-making and artificial intelligence

Jobs Classified Malta™ does not use solely automated systems to make recruitment decisions that legally or similarly significantly affect Candidates.

Recruitment decisions are made by the relevant Employer or recruiter.

The Platform may use automated tools to:

• help Employers draft or improve vacancy content;

• format Job Advertisements;

• suggest classifications or categories;

• support search and filtering;

• detect spam or fraud;

• identify prohibited content;

• maintain security; and

• support technical or customer-service operations.

Artificial-intelligence assistance used for vacancy content is not intended to assess Candidate CVs or make hiring decisions.

If Candidate-ranking, profiling, automated assessment or matching features are introduced, this Privacy Policy and the relevant User notices must be updated before those features are used.

16. Security

We use technical and organisational measures intended to protect personal data against:

• unauthorised access;

• unlawful disclosure;

• loss;

• alteration;

• destruction;

• misuse; and

• other unlawful processing.

Measures may include:

• authentication controls;

• role-based access;

• encryption;

• monitoring and logging;

• secure development practices;

• malware and abuse controls;

• backup procedures;

• provider due diligence;

• confidentiality obligations; and

• incident-response procedures.

No internet-based service can be guaranteed to be completely secure.

Suspected account compromise or security incidents should be reported through the Contact page at /contact.

17. Personal-data breaches

We maintain procedures for assessing and responding to suspected personal-data breaches.

Where required by law, we will notify the competent supervisory authority and affected individuals within the applicable legal time limits.

18. Children and young persons

The Platform is intended primarily for persons seeking or offering employment and is not directed at children.

Persons under 16 should not create an account or submit personal data without the involvement and authorisation of a parent or legal guardian, unless applicable law allows otherwise.

Employers advertising lawful opportunities for minors remain responsible for compliance with employment, safeguarding and data-protection requirements.

19. Third-party websites

The Platform may link to Employer websites, external application systems, payment services, social networks or other third-party services.

We do not control and are not responsible for their:

• privacy practices;

• security;

• content;

• terms; or

• data retention.

Users should review the third party’s privacy information before providing personal data.

20. Your data-protection rights

Subject to applicable legal conditions and exemptions, you may have the right to:

• receive information about processing;

• access your personal data;

• correct inaccurate information;

• complete incomplete information;

• request erasure;

• request restriction;

• receive certain data in a portable format;

• object to processing based on legitimate interests;

• object to direct marketing;

• withdraw consent;

• challenge qualifying automated decisions; and

• lodge a complaint with a supervisory authority.

These rights are not absolute and may be restricted where processing is required for legal obligations, fraud prevention, security or legal claims.

21. Exercising your rights

Requests must be submitted through the Contact page at /contact.

Please include:

• the right you wish to exercise;

• the account or application concerned;

• the email address associated with the relevant account;

• enough information to identify the relevant records; and

• any supporting information reasonably required.

We may request proof of identity or authority.

We will normally respond within one month after receiving a valid request.

Where legally permitted, that period may be extended by up to two further months because of complexity or the number of requests.

Requests are generally handled free of charge. A reasonable fee may be charged, or a request may be refused, where it is manifestly unfounded or excessive.

Where the request concerns information controlled independently by an Employer, you may need to contact that Employer directly.

22. Complaints

We encourage you to contact us first through /contact so that we may address your concern.

You may also complain to Malta’s supervisory authority:

Office of the Information and Data Protection Commissioner
Floor 2, Airways House
High Street
Sliema SLM 1549
Malta

23. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in:

• the Platform;

• our processing activities;

• service providers;

• technology;

• applicable law;

• regulatory guidance; or

• business operations.

The revised version will be published with an updated date.

Where a change materially affects individuals, we may provide additional notice through the Platform, an account notification or email.

24. Applicable legal framework

This Privacy Policy is intended to reflect:

• the General Data Protection Regulation, Regulation (EU) 2016/679;

• Malta’s Data Protection Act, Chapter 586 of the Laws of Malta;

• applicable Maltese electronic-communications and cookie requirements; and

• other applicable Maltese and European data-protection legislation.

Where this Privacy Policy conflicts with a mandatory legal requirement, the mandatory requirement prevails.