Privacy Policy
Last updated: 7 August 2026
1. Introduction
1.1 This Privacy Policy explains how Smart Connect (the "Company", "we", "us", "our") collects, uses, shares and protects personal data when you visit or interact with our website smart-con.net (the "Website"), contact us, or apply for a role with us.
1.2 For the purposes of applicable data-protection law, the data controller is:
- Smart Connect, owned and operated by Peak CS Limited, a company incorporated under the laws of Malta with registration number C 91687 and registered office at 115B, Suite 3, Old Mint Street, Valletta VLT 1515, Malta.
- Contact for privacy matters: hr@smart-con.net
1.3 We are committed to processing personal data lawfully, fairly and transparently, in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Data Protection Act (Cap. 586 of the Laws of Malta), and any other applicable data-protection law.
2. Who This Policy Applies To
2.1 This policy applies to:
- Website visitors: anyone who browses or interacts with the Website;
- Business contacts: representatives of prospective or existing clients, partners and suppliers who contact us or whom we contact; and
- Candidates: individuals who apply for, or express interest in, a role with us, whether directly, through our careers pages, or through a recruiter (referred to in this policy as "candidates").
2.2 It does not cover the personal data we process on behalf of our clients when delivering our customer-support and business-process-outsourcing services. In those cases we normally act as a data processor on the client's instructions, and the relevant client's privacy notice applies; our role is governed by our written agreement with each client. It also does not cover data we process once you become an employee, which is dealt with in a separate staff privacy notice.
3. The Personal Data We Collect
3.1 Information you give us directly — for example when you complete a form, send an email, apply for a role, or otherwise communicate with us:
- identity and contact details: name, email address, telephone number, and postal or current-location address;
- business-contact details: your name, employer, job title, and the content of your enquiry;
- candidate and recruitment information: your CV, any covering message, and the answers in our application form, including work history, education and qualifications, and the languages you speak (relevant to our market-facing roles); notes and assessments from screening calls, interviews or exercises; and our correspondence with you;
- eligibility and relocation information: your nationality and right to work and, where you reach offer stage for a Malta-based role, the information needed to help arrange your relocation (see Section 5); and
- any other information you choose to provide.
3.2 Information we collect automatically when you use the Website:
- technical data: IP address, browser type and version, device information, operating system, and time-zone setting; and
- usage data: pages visited, links clicked, time spent, referring website and similar analytics, collected largely through cookies and similar technologies.
3.3 Information we receive from third parties, where lawful and relevant:
- referees you have named, who may confirm your previous roles, dates and performance;
- recruitment agencies or partners, where you have applied or been introduced through one;
- publicly available professional sources, such as professional networking sites, limited to information you have made public; and
- analytics and infrastructure providers.
3.4 Special category data. We do not routinely seek sensitive personal data (such as data revealing health, racial or ethnic origin, or religious beliefs). Please do not include such data in an application unless we specifically request it for a lawful purpose. Where we do process it, we rely on an appropriate lawful basis and, where required, your explicit consent (see Section 5).
4. How and Why We Use Your Data, and Our Lawful Basis
4.1 We use personal data only where we have a lawful basis under the GDPR. Our main purposes and bases are:
| Purpose | Typical data used | Lawful basis |
|---|---|---|
| Operating, securing and maintaining the Website | Technical and usage data | Legitimate interests (a secure, functional site) |
| Responding to enquiries and communicating with you | Contact details, enquiry content | Legitimate interests; or steps to enter into a contract |
| Assessing applications and managing recruitment | Candidate/recruitment information | Steps to enter a contract; legitimate interests |
| Carrying out background and reference checks (where lawful) | Recruitment and third-party data | Legitimate interests; legal obligation; consent where required |
| Confirming right to work and supporting relocation (offer stage) | Eligibility and relocation information | Legal obligation; steps to enter a contract |
| Managing client and supplier relationships | Business-contact details | Legitimate interests; performance of a contract |
| Analytics and improving the Website | Usage and cookie data | Consent (non-essential cookies); legitimate interests |
| Keeping your details on file for future roles | Candidate/recruitment information | Your consent (withdrawable at any time) |
| Complying with legal, tax and regulatory obligations | As required | Legal obligation |
| Establishing, exercising or defending legal claims | As relevant | Legitimate interests; legal obligation |
4.2 Where we rely on consent (for example, for non-essential cookies or optional marketing, or to keep your details on file), you may withdraw it at any time without affecting the lawfulness of earlier processing. Where we rely on legitimate interests, we balance those interests against your rights and freedoms, and you may object as described in Section 15. Submitting a job application does not guarantee employment; we process application data only to evaluate suitability and manage our hiring process.
5. Recruitment and Candidates
5.1 Right to work and relocation. Because many of our roles are based in Malta and open to candidates relocating from abroad, we will check that you are, or can become, eligible to work in Malta, which may involve processing your nationality, identity documents and any permit or visa information. If you accept an offer, we (and trusted partners acting for us) may process the information needed to arrange your relocation. For example travel and initial accommodation, and helping you set up local essentials such as identity registration, tax and banking. This mainly affects successful candidates, at the offer or onboarding stage. We collect relocation documents only when actually needed and share them only with the providers and authorities involved in that specific step.
5.2 Sensitive information in recruitment. We may process health or disability information only to consider reasonable adjustments to our process (for example to an assessment or interview) so that you can take part on a fair footing. Where we carry out equal-opportunity monitoring, that data is kept separate, used only in aggregate, and plays no part in any hiring decision. Your nationality and immigration status, used for right-to-work purposes, are handled as ordinary personal data, not special category data.
5.3 If you do not provide certain information. Some information is essential for us to assess your application, for example evidence of your qualifications, work history or right to work. If you choose not to provide it, we may be unable to progress your application or consider you for the role.
6. Marketing
6.1 We will only send you marketing communications where you have asked to receive them or where we are otherwise permitted by law. You can opt out at any time using the unsubscribe link in any message, or by contacting us at hr@smart-con.net.
7. Who We Share Your Data With
7.1 We do not sell your personal data, and we keep sharing to what is necessary. We may share it with:
- service providers and processors acting on our behalf (for example website hosting, IT support, analytics, applicant-tracking and email providers), under contracts requiring them to protect the data and use it only on our instructions;
- group or affiliated companies, where relevant and lawful;
- relocation, travel and administrative partners, at offer stage, only as described in Section 5;
- referees and background-check providers, where relevant to the role;
- professional advisers (such as lawyers, auditors and insurers) where necessary;
- public authorities, regulators and law-enforcement bodies, where required by law or to protect our rights; and
- a buyer or successor, in the event of a merger, acquisition or reorganisation of our business.
8. International Transfers
8.1 We are based in Malta, within the European Economic Area (EEA). Some of our service providers may process data outside the EEA. Where this happens, we ensure an appropriate safeguard is in place, such as a European Commission adequacy decision, or the Commission's Standard Contractual Clauses together with any additional measures required. You may request more information about these safeguards using the contact details below.
9. Data Retention
9.1 We keep personal data only for as long as necessary for the purposes described in this policy and to meet legal, accounting or reporting requirements. In setting retention periods, we weigh up what the law requires, how sensitive the information is, why it was collected, and what you would reasonably expect.
9.2 Candidates. If your application is unsuccessful, we keep your information for three (3) years after we tell you our decision, so that we can respond to any query or complaint, show that our process was fair and non-discriminatory if challenged, and with your consent consider you for future roles. If your application is successful, relevant information is transferred to your employee file and kept in line with our staff privacy notice.
9.3 When information is no longer needed, we securely delete, anonymise or otherwise dispose of it in accordance with our retention policies and applicable law.
10. Data Security
10.1 We apply appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, loss or destruction. Access is limited to authorised people who need it for their duties, all of whom are bound by confidentiality and must process personal data only on our instructions. We maintain procedures to deal with any suspected personal data breach and will notify you and the competent supervisory authority where the law requires.
10.2 No transmission of information over the internet can be guaranteed to be completely secure. While we take reasonable steps to protect your data, any transmission to the Website is at your own risk.
11. Automated Decision-Making
11.1 We do not make decisions producing legal or similarly significant effects, including recruitment decisions, based solely on automated processing or profiling. A person is always involved in decisions about your application. If this changes, we will update this policy and, where required, obtain your consent or provide appropriate safeguards.
12. Cookies
12.1 Cookies may be used on our Website. Cookies are small text files that are placed on your device when you access certain websites. They allow us to identify your device and enhance the way the Website works for you. At any point you can manage or remove cookies through your browser or device settings, and you can prevent them from being installed in the first place. Please note that turning cookies off may cause certain features of the Website to stop functioning correctly. If you permit cookies through your browser settings, you consent to their use and accept this Privacy Policy.
13. Children
13.1 The Website is intended for individuals aged 18 or over and is not directed at children. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.
14. Third-Party Links
14.1 The Website may link to third-party sites we do not control. This policy does not apply to those sites, and we are not responsible for their privacy practices. Please review the privacy policy of any site you visit.
15. Your Rights
15.1 Subject to the conditions and exceptions in applicable law, you have the right to:
- access the personal data we hold about you and receive a copy;
- request rectification of inaccurate or incomplete data;
- request erasure of your data where there is no longer a lawful basis to keep it;
- request restriction of processing in certain circumstances;
- object to processing based on our legitimate interests, and to direct marketing at any time;
- request data portability (receiving certain data in a structured, machine-readable format); and
- withdraw consent at any time where we rely on it.
15.2 To exercise any of these rights, contact us at hr@smart-con.net. We will respond within the time the law allows (generally one month) and may need to verify your identity first. Exercising your rights is free of charge unless a request is manifestly unfounded or excessive. You also have the right to lodge a complaint with the Office of the Information and Data Protection Commissioner (IDPC) in Malta.
16. Changes to This Policy
16.1 We may update this Privacy Policy from time to time. The current version is always the one published on the Website, with the "Last updated" date shown at the top.
17. Contact Us
17.1 For any question about this policy or about how we handle your personal data:
- Recruitment / privacy contact: hr@smart-con.net
- Registered address: 115B, Suite 3, Old Mint Street, Valletta VLT 1515, Malta