Privacy Policy2018-11-14T15:46:39+00:00

ETVS Limited’s privacy notice (the “Notice”)

ETVS Limited (C 7632) of 66, Triq Dun Karm Sciberras, Mosta, Malta (“we”; “us”; “our” or “ETVS”) respects your privacy and is committed to protecting your personal information (or, as otherwise termed, your personal data). In that vein, ETVS has launched and offers a service for travellers who need to apply for a Visa, also called an “entry permit”, which is accessible via its website (the “Site”) and assists such travellers in obtaining their full or partial Visa to the targeted or destination country (presently, the USA, Canada or Australia). This will entail the submission of ‘applicant’ information, i.e. personal details, and ‘application’ responses by the traveller to ETVS (the “Application”), which mirrors the official application process and is reviewed internally ETVS support staff to advise the traveller on his or her eligibility to obtain the desired Visa. Once the Application has been reviewed and finalised, it is then transmitted on the traveller’s behalf to the relevant government agency of the targeted country for the approval and grant of the particular Visa that has been requested (altogether, the “Services”).

The purpose of this Notice is to set out the basis on which your personal data is processed by us, to inform you about how we will handle and look after your personal data when you visit the Site (regardless of where you visit it from) and use or receive our Services, and to tell you about (i) our obligations in regard to processing your personal data responsibly, (ii) your data protection rights as a data subject and (iii) how the law protects you. It should be read in conjunction with our Cookie Policy, which you can find below.

We process your data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 440 of the Laws of Malta) (the “Act”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR” or the “Regulation”), following its application on 25th May 2018.

This Notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Notice.

1. Important information and who we are;

2. The data we collect about you;

3. How is your personal data collected;

4. How we use your personal data;

5. Disclosures of your personal data;

6. No international transfers;

7. Data security;

8. Data retention;

9. Your legal rights;

10. Glossary;

11. External tools and providers;

1. Important information and who we are

Purpose of this privacy notice
This Notice aims to give you information on how ETVS, as defined above, collects and processes your personal data (i) when you apply for, use and receive the Services as well as (ii) through your use of the Site, including any data you may provide when you subscribe (opt-in) to our mailing list and marketing content.
Note that the Services are neither intended for children, nor offered directly to them. In fact, where the Application relates to a child, availability and use of the Service will be allowed only if and to the extent that it is completed and submitted to us by the holder of parental responsibility over that child. Confirmation of this status of parental responsibility will be expressly demanded by us from the moment that we ascertain that the eTA does pertain to a child. We will also take all reasonable steps to verify that the confirmation provided is truly accurate and correct. Failing such confirmation or verification, we will refuse to provide the Services or withdraw their availability (as the case may be).
The Site is similarly not intended for children.
It is important that you read this Notice, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Notice supplements the other notices and is not intended to override them. Moreover, certain processing activities will require your express consent to be carried out, as specifically indicated below in this Notice.
ETVS, as previously defined, is the controller and responsible for your personal data.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Notice. If you have any comments or queries about this Notice, including any requests to exercise your legal rights as a data subject, please contact the DPO using the details set out below, with the words ‘Data Protection Matter’ in the subject line.
You can address any comments, queries or complaints to the DPO, using the details indicated below, with the words ‘Data Protection Matter’ in the subject line.
Our full details are:
Full name of legal entity: ETVS Limited (C 7632)
Name of DPO: René Rautenberg
Postal address: Radlkoferstr. 2, 81373 München, Germany
Telephone number: +356 3550 5651
Email address: [email protected]
You have the right to lodge a complaint at any time to the competent supervisory authority in your jurisdiction on data protection matters. In the case of Malta, this is the Information and Data Protection Commissioner (“IDPC”) ( We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version of the Notice was lasted updated on 24.05.2018.
Historic versions can be obtained by contacting us at [email protected]
The data protection laws across the EU, including Malta, will change on 25th May, 2018, due to the GDPR. Although this Notice sets out most of your rights under the GDPR, we may not yet be able to respond to some of your requests until May, 2018 (for example, a request to have your personal data transmitted to another controller), as we are still working towards getting our systems ready for some of these changes.
It is imperative that the personal data which you provide us is accurate and current. Otherwise, this will impair the quality of the Service, amongst other potential issues. Please keep us informed if your personal data changes during the course of your relationship or transactions with us.
Third-party links
The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you (the applicant) which we have grouped together follows:

Applicant Data includes your first name, maiden name, last name, aliases, gender, date of birth, country of birth, city of birth, citizenship, nationality, any dual nationalities and names of parents (first and last).
Contact Data includes your (home) address, email address and telephone or mobile number.
Passport Data includes your country of passport, type of passport, nationality noted on passport, passport number, passport date of issue, passport date of expiry, national identification number (I.D.) and similar details about any passports or travel documents issued by other countries.
Travel Data includes your country of travel and planned dates of travel.
Application Data differs according to the country that is the subject of your Application (i.e. the country of travel) and its respective Visa requirements. This generally includes your employment information and your responses to the background questions mandated by the authorities of the country of travel. These background questions may require you to answer and confirm the following:
i. the existence of any prior criminal convictions or arrests against you;
ii. the existence of any addictions, disorders or diseases suffered by you (as specifically identified and listed in the relevant questions);
iii. any previous decisions taken against you regarding a Visa application, admission or stay in that same country of travel (refusal of entry or expulsion);
iv. prior travel or periods of stay in particular countries (as also specifically identified).
Financial Data includes your billing address, bank account and payment card details.
Transaction Data includes details about payments to and from you in relation to the Services.
Visa Data includes information about the decision taken by the authorities on your submitted Application, including, if positive, the details of the Visa granted to you and, where negative, the reasons provided.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site.
Profile data includes purchases made by you, your feedback and survey responses.
Usage Data includes information about how you use the Site and Services, and our other products.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Site. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Notice.

If you fail to provide personal data: Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (namely regarding the Service). In this case, we may have to refuse to provide you with the Services or withdraw their availability, but we will notify you if this is the case at the time.

Special Categories of Personal Data — Read Carefully

The term ‘special categories of personal data’ includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and/or biometric data. Due to their sensitive nature, these special categories are afforded added protection under the GDPR. Similarly, details about your criminal convictions and offences (if any) are also subject to such additional protection (altogether, “Sensitive Data”).

Your responses to the relevant background questions and questions about your nationality, as established by the country of travel, may result or lead to us processing Sensitive Data about you (“Screening Questions”). For instance, in terms of the Electronic System for Travel Authorisation application for the USA, one of the background questions posed is whether you (the applicant) have a physical or mental disorder, or are a drug abuser or addict. These Screening Questions are entirely set by the relevant authorities, and we neither have any control nor influence over them. Moreover, without your responses, we would not be able to provide you with the Services that you have requested from us (i.e. advising you on your eligibility and submitting a complete Visa application to the relevant authorities on your behalf).

We have no other scope for collecting and processing your responses, and any and all use thereof is strictly limited as necessary for the Services. It should also be emphasised that your potential responses are restricted to either ‘Yes’ or ‘No’, and we do not receive or process any details per se or any added information.

Nonetheless, if and to the extent such responses reveal Sensitive Data about you, we would need your express consent to be able to receive and process them for the purposes of your Application and its submission. Please note that these responses constitute a core and fundamental part of the Services. Thus, without such consent, it would not be possible for us to provide you with the Services, nor would we in any case be in a legal position to do so.

You are thus strongly advised to read this section carefully!

If you do not object to us processing your responses to these Screening Questions and wish to proceed or continue with receiving the Services, then you are kindly requested to provide us with your express consent.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Applicant, Contact, Passport, Travel, Application and Financial Data by filling in forms and submitting them to us, specifically your Application, or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
apply for and use the Services;
complete and submit your Application to us;
respond to communications from our support staff regarding:
(i) their review of your Application (including possible mistakes or errors);
(ii) finalising your Application and its onward transmission to the relevant authorities; and
(iii) communications, or notices of decisions, from the relevant authorities (including Visa approval).
Your express consent will be requested prior to receiving and processing any of your responses to the relevant Screening Questions — as outlined above.
Automated technologies or interactions. As you interact with the Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
Please see our cookie policy below for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
i. analytics providers such as Google;
ii. advertising networks and
iii. search information providers Google and Bing.
Contact, Financial and Transaction Data from third party providers of payment and technical services.
Identity and Contact Data from publicly availably sources.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you (namely, in respect of the provision of the Services).
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Upon your explicit consent, where and to the extent that your responses reveal Sensitive Data about you.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Please contact us should you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
(a) To provide the Services (as requested and contracted by you);
(b) To notify you about the decision taken on your Application by the relevant authorities;
(c) To process and manage payments, fees and charges; and
(d) To collect and recover money owed to us. (a) Applicant;
(b) Contact;
(c) Passport;
(d) Travel;
(e) Application;
(f) Financial;
(g) Transaction;
(h) Visa; and
(i) Marketing and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us).
(c) Upon your express consent in terms of Article 9(2)(a) of the GDPR, to the extent your responses to the Screening Questions reveal Sensitive Data about you.
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or this Notice
(b) To resolve any issues or queries which you may have or may have reported regarding the Services,
(c) Asking you to provide feedback and/or take part in a survey. (a) Identity;
(b) Contact;
(c) Profile; and
(d) Marketing and Communications. (a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services).
To administer and protect our business as well as the Site (including troubleshooting, data analysis, testing, system maintenance, support, safety and security testing, reporting and hosting of data). (a) Identity;
(b) Contact; and
(c) Technical. (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and prevention of hacks and other attacks, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation.
To deliver relevant website content to you and measure or understand its effectiveness.
To ensure that Site content is presented in the most effective manner for you and your computer, and in a user friendly manner. (a) Identity;
(b) Contact;
(c) Profile;
(d) Usage;
(e) Marketing and Communications; and
(f) Technical Necessary for our legitimate interests (to study trends regarding how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Site, marketing, client and investor relationships and experiences. (a) Technical; and
(b) Usage. Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Site updated and relevant, to develop our business and to inform our marketing strategy)
Direct Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around advertising and marketing campaigns and communications.

Through your Identity, Contact, Technical, Usage and Profile Data, we would be able form a view on what we think you may want or need and what may be of interest to you. This would then enable us to determine which of our other products, services and offers may be relevant for you (we call this direct marketing).

You are kindly requested to provide your express opt-in consent (at the end of this Notice) if you wish to receive marketing communications from us regarding our other products and services as well as information about our events.

This will be processed as your Marketing and Communications Data and, depending on whether you consent, your Marketing and Communications Data will either be inserted in our appropriate mailing list or not at all.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company for marketing purposes.

Opting Out

You can ask us to stop sending you marketing communications to you at any time by contacting us at [email protected] using the words ‘Marketing Communications’ in the subject line.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected]

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without the need for obtaining your consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below, strictly for the purposes set out in the table in Section 3 above. These include:

External Third Parties as specified in the Glossary;
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our documented instructions. Furthermore, these third parties process your data on the basis of strict confidentiality and subject to the appropriate (technical) security measures and safeguards.
We may also disclose your data if we are under a duty to disclose or share your personal data to comply with any legal obligation, judgment or an order from a court, tribunal or authority.
We may also disclose your data to enforce our contractual terms with you, or to protect our rights, property or safety, that of our partners or other users of the Site and Services. This includes exchanging information with other companies, organisations, immigration authorities and law enforcement agencies for the purposes of fraud protection and the detection, prevention and investigation of crime.
Moreover, once complete and finalised, we will transmit your application to the relevant official government authorities. This constitutes a core aspect of the Services that you have requested from us.

6. No International Transfers

We do not transfer your personal data outside the European Economic Area (“EEA”), except in the context of transmitting your Application to the official government authorities of the targeted or destination country.
If, however, we need to transfer your personal data out of the EEA for a different purpose, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards applies:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
In the absence of an adequacy decision, we will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, partners, service providers and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a strict and rigid duty of confidentiality.
Furthermore, we have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so, and within the timeframe prescribed at law.

8. Data retention

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the service provision as well as for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By and large, retention of most data shall not exceed the period of five (5) years from the date of termination or completion of the Services. This period of retention enables us to use the data for the defence of possible future legal claims (taking into account applicable statutes of limitation and prescriptive periods). In certain cases, we may need to retain your data for a period of up to ten (10) years from the date of termination or completion of the Services in order for us to comply with applicable accounting and tax laws (this will primarily consist of your Transaction Data).
In some circumstances you can ask us to delete your data. See Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Kindly contact our DPO for further details about the retention periods that we apply.
Data Minimisation
Whenever and to the extent possible, we anonymise the data which we hold about you when it is no longer necessary to identify you from the data which we hold about you.
In some circumstances, we may even anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected]
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties

Service providers who provide IT, hosting and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based in Malta who provide consultancy, banking, legal, insurance and accounting services.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
You may send an email to [email protected] requesting information as the personal data which we process. You shall receive one copy free of charge via email of the personal data which is undergoing processing. Any further copies of the information processed shall incur a charge of € 50.
Right to information when collecting and processing personal data about you from publicly accessible or third party sources. When this take places, we will inform you, within a reasonable timeframe, about the third party or publicly accessible source from which we have collected your personal data.
Request correction or rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected and/or updated, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where:
there is no good reason for us continuing to process it;
you have successfully exercised your right to object to processing (see below);
we may have processed your information unlawfully; or
we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Most commonly, this will be where further processing of the personal data is required by us for:
compliance with a legal obligation to which we are subject;
assertion, exercise or defence of legal claims (including possible future claims).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. We will notify you if this is the case at the time.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
if you want us to establish the data’s accuracy;
where our use of the data is unlawful, but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer (data portability) of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data, as above indicated. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Withdrawal of consent may also affect or impair the possibility of us providing you with the Services, as previously explained in the context of your responses to the Screening Questions set out in the Visa application. We will advise you if this is the case at the time you withdraw your consent.
Please note that, in spite of such withdrawal, we may continue to retain your personal data (rather than erase) if there are specific legal reasons which justify us doing so. Main instances would be a legal obligation requiring us to continue to hold onto such data or for the purposes of legal claims.

11. External tools and providers

Matomo (former Piwik) – Web analysis

We use the open source software Matomo (Piwik) for the statistical analysis of user access to information and advertising pages. Matomo uses cookies for this analysis. Cookies are small text files that are stored on your computer and allow an analysis of your use of the website. The information generated by the cookies, such as time, location and frequency of your visits to the website, together with your IP address, is transmitted to our Matomo server and stored there. Your IP address will be anonymized during this process and cannot be linked to any individual user. The information generated by the cookie about your use of this website will not be passed on to third parties. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do so you may not be able to use the full functionality of our website.

Heidelpay payment

Since we do not process your payment ourselves, the collection, processing and storage of data for the processing of electronic payment transactions is carried out exclusively by our partner, Heidelberger Payment GmbH, Vangerowstraße 18, 69115 Heidelberg (hereafter Heidelpay). Data processing is carried out on our behalf.

Within the framework of the processing of electronic payment transactions, Heidelpay receives the following data directly from yourself sent in relation to your order: Title, Gender, First name, Last name, Company, Address, Post code, City, Country, Customer Number, Email Address, Type of Payment.

For payment by credit card, the following information will also be transferred directly by you to Heidelpay: Credit Card Number, Credit Card Owner, Credit Card Validity Dates (month and year) Credit Card CVC (Card Validation Code).

Bing conversion tracking

This website uses the conversion tracking of Bing Ads (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA). When you click on a Bing advertisement, a cookie is placed on your device. This enables both Bing and the owner of the website to recognise that someone has been redirected to the website from a Bing ad and has made it to a predetermined target page (conversion page). If you do not want to take part in the tracking process outlined here, you can decline the placement of the cookie necessary for this to take place over your browser settings. The deactivation can also be carried out using the following link:

You can find further information on data protection and on the cookies used for Microsoft Bing on the Microsoft website:

Google Tag Manager

This website uses Google Tag Manager. The Tag Manager does not collect any personal data. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If deactivation has been made at the domain or cookie level, it will remain in effect for all tracking tags implemented with Google Tag Manager. Google’s privacy policy for this tool can be found here:

LiveChat Widget (LiveChat, Inc.)

The LiveChat Widget is a service for interacting with the LiveChat live chat platform provided by LiveChat, Inc.
Personal Data collected: Cookies and Usage Data.

LiveChat, Inc. participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. LiveChat, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. Place of processing: US – Privacy Policy:

12. Conclusion

Any changes that we may make in the future to this Notice will be visibly posted on the Site and, if appropriate, notified to you via email.
If you have any questions regarding our privacy policy, or if you would like to send us your comments, please contact us today or alternatively write to our Data Protection Officer using the details below.
Name of DPO: René Rautenberg
Postal address: Radlkoferstr. 2, 81373 München, Germany
Telephone number: +356 3550 5651
Email address: [email protected]

Please check back frequently to see any updates or changed to this Policy.

IP Address and Cookie Policy
Last Updated: 24.05.2018

(hereinafter, the “IP and Cookie Policy”).

ETVS Limited (C 7632) of 66, Triq Dun Karm Sciberras, Mosta, Malta (“we”; “us”; “our” or “ETVS”) collects two types of information about you resulting from your use of (the “Site”): (i) personal information, including your name and e-mail address and (ii) aggregate information which is generated from the practices that we have in place regarding ‘cookie’ and the Internet Protocol Address (“IP Address”) of the users of our Site.

Our Privacy Notice sets out and describes the practices that we have in place regarding our collection and processing of personal information:

Correspondingly, the practices that we apply regarding the generation of aggregate information, as mentioned above, are described in this IP and Cookie Policy.

1. IP Address
What happens when you visit the Site

Every time you connect to the internet or, if you use an always-on connection, such as broadband or ADSL, when you boot up or restart your computer, you are automatically assigned a unique identifying number known as an IP Address. This IP Address, which contains information regarding the location of your computer on the internet (your country of origin) and the name of your internet service provider (“ISP”), is automatically logged by the Site upon your access to it.

What is an IP Address?

When you first started your internet session (i.e. your computer connected to the internet), your computer was automatically assigned a unique number (normally in the region of 9 or 10 decimal numbers), known as an IP Address. This is your computer’s unique address on the internet. Without an IP Address, websites would not be able to deliver their content to you as they would not be able to find your computer on the internet. Since each time you disconnect and reconnect to the internet a new IP Address is automatically assigned to your computer, IP Addresses are not inherently capable of identifying you as an individual (at least, by themselves alone).

An IP Address does, however, contain information regarding the location of your computer on the internet (your country) and the name of your ISP.

How do we collect your IP Address

Each time you visit a page on the Site, your computer sends out a message to the Site asking for the content. This message sent by your computer also encloses your IP Address as a form of “return address” so that the Site may find your computer in order to send it the requested content. Our web-server automatically logs all these messages.

What do we do with your IP Address?

When we log your IP Address, the data collected is grouped up with the other logged IP Addresses in order to provide us with the statistics on the geographic location of visitors to our Site, how long they stay on the Site, which are the most viewed pages and for other statistical reasons.

Collecting this type of information allows us to generate aggregate information for the purposes of the Site, including in terms of overall user activities online (such as the number of unique visitors or the pages that are accessed most frequently.) It also allows us to administer the Site, diagnose any potential server problems, analyse visitor trends and statistics, and generally helps us to provide you with a better internet experience. IP Addresses are not stored for longer than necessary for the above stated purposes.

2. Cookies
Information about our use of Cookies

The Site uses cookies to distinguish you from other users. This helps us to provide you with a good and personalized experience when you browse our Site, and to improve it at the same time.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. Much like a key, a cookie enables the relevant website to remembers users that have already visited it. Without a cookie, every time you open a new web page, the server where that page is stored will treat you like a completely new visitor.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of the Site. Namely, by way of illustration, they include cookies that enable you to log into secure areas of the Site and make use of its check-out functionality.

Analytical/Performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when your return to the Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to the Site, the pages you have visited and the links you have followed. We will use this information to make the Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies We use and the purposes which We use them in the table below.

Cookie Name Purpose
Matomo pkses.*
pkid.* These cookies are essential to estimate our audience size and usage pattern
Payment wpwoocommercesession*
PHPSESSID These cookies allow us to process payment for our service
Bing _uetsid
MUID These cookies enable us to track the performance of our Bing Ads campaigns
Please note that third parties (including advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Site. Moreover, some parts of the Site may not function properly if you choose not to accept cookies.

Except for essential cookies, all cookies will expire after 30 days.

You can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Site, but your ability to use some features or areas of the Site, as well as the services that you connect to through it, may be limited. Many browsers allow you to browse privately whereby cookies are automatically erased after you visit a site. The following is a list of the most common browsers and the way in which you can activate private browsing:

Internet Explorer 8 and later versions: In Private

Safari 2 and later versions: Private Navigation/Browsing

Firefox 3.5 and later versions: Private Navigation/Browsing

Google Chrome 10 and later versions: Incognito

Further information on cookies can be found on various sites such as

Social Media Features and Widgets
Our Site includes social media features such as Facebook.These features may collect your IP address, which page you are visiting on the Site, and may set a cookie to enable this feature to function properly.

Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.