Privacy Policy

At Eunoia we strongly believe in protecting the privacy of customers and users. This privacy policy describes Eunoia’s current policies and practices relating to the personal data of customers who visit (“Eunoia’s Website”) and make use of our online facilities. Eunoia employs its best endeavours to protect the privacy of visitors to its website and of customers who provide personal information through such means. Eunoia assures you that it will only use and disclose any personal data collected from you in accordance with the manner set out in this policy. This privacy policy is independent from Eunoia’s offline personal data collection practices.

1. Changes to our privacy policy

Eunoia’s Website is continually improving – new functions and features are periodically added and improved to interface, thus changes to our privacy policy may be required from time to time. We therefore encourage you to check our privacy policy frequently to be aware of such changes but rest assured that any changes will not apply retroactively and personal data previously collected will not be affected by such changes.

2. Information we collect

We only collect personal information through Eunoia’s Website that is voluntarily submitted by you, for instance first and last names, e-mail address and contact numbers. Such personal information may be requested when filling in a ‘Sign up for our newsletter’, ‘Let’s keep in touch’, ‘Leave us a message' forms with your questions and comments or any other form or application downloaded through or from Eunoia’s Website.

No one is obliged to provide personal information, however failure to do so will not enable us to update you with relevant information about our activities.

3. Use of the information collected by us

We use the personal data information you provide predominantly to answer queries previously submitted by you through Eunoia’s Website. Eunoia and related entities and subsidiaries also use the information collected to help us improve the content and functionality of our websites; to better understand our customers and markets; and to improve our products and services.

Eunoia, together with related entities and subsidiaries, may also use the information collected to contact you in the future for the purpose of updating you about our new products and services. If we do so, each communication we send you will contain instructions allowing you to “opt-out” of receiving future communications.

Similarly, we may provide you with the option of subscribing to our email services, either directly or through our related entities or subsidiaries, which will enable you to receive current news about Eunoia and our business. For all such services, we will provide you with the opportunity to “opt-out” of, or cancel, the subscription.

4. Requirements and criteria for processing personal data

Eunoia ensures all its customers that personal data will be collected, processed and stored strictly in accordance with the Data Protection Act (Chapter 440 of the Laws of Malta). Eunoia will only disclose your personal details if and when it is required to do so under any applicable law.

5. Passive information collected through Eunoia’s Website

Apart from the information you provide us with when using Eunoia’s Website, other information is passively collected from you (without you actively furnishing such information) when you navigate through the website. We use various technologies and navigational data collection methods to gather such passive information for various reasons, for example to track how many visitors access our website, the date and time of their visit, the length of their stay and which pages they view. The passive information also aids us to determine which web browsers our visitors use and the address from which they accessed our website – for instance if they connect to Eunoia’s Website through clicking on one of our banner ads. This technology does not identify you personally.

Such passively collected information may be used and combined to improve our services to website visitors, customise the website based on your preferences, compile and analyse statistics and trends of our visitors and their use of the sites operated by us and our related entities or subsidiaries. Together with our related entities and subsidiaries we will use this information and share it with third parties to improve the content, functionality and administration of our websites, to better understand our customers and markets, and to improve our products and services. We assure you that, unless you have consented, such passive information shall not be combined with personally identifiable information collected elsewhere on the  Eunoia’s Website or respective sites operated by our related entities or subsidiaries.

6. Disclosure of your Personal Data

We may share some or all of your personal data collected through the Eunoia Website with our related entities and subsidiaries located in Malta, the European Economic Area (“EEA”) as well as outside the EEA but rest assured that any use of your personal data by such related entities and subsidiaries will be in compliance with this privacy policy. By submitting your personal data to us, you agree to this transfer, storing or processing by such related entities and subsidiaries.

Other companies may be engaged by Eunoia or our related entities or subsidiaries to perform particular functions such as support services, data processing services as well as marketing services for the products and services offered by us. These third party companies may need information about you in order to perform their functions and may therefore have access to your personal information. Such companies may not use the information we share with them for any other purpose other than that for performing their functions.

Eunoia and our related entities or subsidiaries reserve the right to use or transfer your personal data in other limited circumstances, for example, to comply with legal requirements and satisfy any legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our subsidiaries and related entities.

While no method of data transmission is guaranteed against unlawful third party interception or other misuse, we use commercially reasonable efforts to ensure protection of your data including industry-standard encryption and offline security methods in our physical facilities.

7. Link to other sites

This privacy policy only applies to Eunoia’s Website. Our related entities and subsidiaries operate other websites for different purposes and in different countries that may be subject to different local customs, practices or laws.

Eunoia’s Website may contain links to websites that are not operated by Eunoia or by one of our related entities and subsidiaries. These links are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators – we do not control these websites and are not responsible for their data practices. Note that upon linking to another site, you are no longer on Eunoia’s Website and you therefore become subject to the privacy policy of the new site. We advise you to review the privacy policy posted on any site you visit which collects personal data.

8. Modification and Deletion of Personal Data

You have the right to request the rectification, blocking or erasure of your personal data that has not been processed in accordance with the Data Protection Act or any regulation thereunder. We shall act upon such requests immediately.

It is our responsibility to notify any third party to whom the data has been disclosed about any measures taken as mentioned above. Provided however that we will not provide such notification if it is shown to be impossible or it will involve a disproportionate effect.

9. Subject Access Policy

We will provide you with information in response to any reasonable access request made by you as the data subject (being the person to whom the personal data refers). We shall ensure data is kept in an accessible form to facilitate access thereto. Upon request by the data subject, we shall provide without excessive delay and without expense, written information as to whether personal data concerning the data subject is processed, provided such request is made by the data subject at reasonable intervals. Any such request application shall be made in writing to  Eunoia and is to be signed by the data subject and delivered at the postal address indicated in clause 13 below.

If such information is processed by us, we shall provide the data subject with written information in an intelligible form about:

1. The actual information that has been processed;

2. Where this information has been collected from;

3. The purpose of such processing;

4. To which recipients or categories of recipients the information is disclosed; and

5. Knowledge of the logic involved in any automatic processing of data concerning the data subject.

10. Cookies

Cookies are pieces of information which are transferred from a website onto your computer’s hard disk and stored. Cookies in themselves do not personally identify the individual user, but merely the user’s browser.  Eunoia may use cookies to enable us to obtain information about your use of our Website, such as whether you have visited our site more than once, how you found us and also records how many people are using the different parts of the website. This information allows us to make the site easier to use.

11. Governing Law

This privacy policy is governed by and construed in accordance with the laws of the Republic of Malta, particularly the Data Protection Act, and other relevant EU legislation.

12. How to contact us

If you have any questions about this Privacy Policy, or if you wish to make a complaint about how we have handled your personal information, please contact us at:



Nineteen Twenty Three,

Valletta Road,

Marsa, Malta MRS 3000