This Privacy Policy relates to the website https://community.esprimi.eu/ and/or any sub-website and/or associated domains (and/or sub-domains) of https://community.esprimi.eu/ (hereinafter referred to as “Esprimi.eu” and/or “this Site” interchangeably). 

PLEASE READ THESE TERMS CAREFULLY. BY ACCESSING OR USING THIS SITE AND/OR ANY OF OUR SERVICES YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY, OUR TERMS OF USE AND MEMBERSHIP, OUR COPYRIGHT NOTICE AND ALL TERMS INCORPORATED BY REFERENCE.

If You do not agree to this policy or Our Terms of Use and Membership, please do not use this Site or any of Our services.

This Site is a Maltese website owned by Business Leaders (Malta) Limited (C 57403) having its registered office at Business Leaders Hub, 160, Mdina Road, Zebbug, ZBG 9015, Malta and complies with the Maltese Data Protection Act (Chapter 440 of the Laws of Malta) relating to the personal information You supply online. In these terms, "You" and "Your" refer to the customer and/or any user of this Site and "we", "us", "our" and “Esprimi” refer to Business Leaders (Malta) Limited (C 57403) having its registered office at Business Leaders Hub, 160, Mdina Road, Zebbug, ZBG 9015, Malta.

Esprimi can be contacted at info@esprimi.eu or by writing to Business Leaders (Malta) Limited (Esprimi), Business Leaders Hub, 160, Mdina Road, Zebbug, ZBG 9015, Malta. or by phoning us using telephone number (+356) 21 354289 (during normal office hours).

At Esprimi we are committed to protecting Your privacy and the security of Your personal data. Kindly be informed that by providing us with Your personal information (as explained below), You signify that You consent to us processing such personal data in accordance with this Privacy Policy. 

Please read the following Privacy Policy carefully before making use of the Site.

We will never collect sensitive information (as defined in the Maltese Data Protection Act) about You without Your explicit consent.

1.    What information do we collect about You?

We do not obtain any personal data (as defined in the Maltese Data Protection Act), that is, information that identifies You as an individual other than that which You choose to provide to us by email and/or when completing Your profile if and when You decide to join Our community or register for any of Our services available on the Site.

We collect Your Facebook basic profile information (meaning Your name, e-mail address, gender, birthday and location) which information You consent us to process when You connect to, and/or use the Esprimi Facebook Applications within Your Facebook account (and/or when You log in to any of Esprimi’s services within Your Facebook account if and when this option is made available) after having read and accepted these Terms and our Privacy Policy.

We also collect information when You voluntarily complete any of the surveys we invite You to participate in, or You provide feedback, comments or other information on our community website.

Without prejudice to the above, we only collect information that we believe to be relevant to conduct our business, for marketing purposes and/or to monitor the improvement of our products and/or services. Any such personal data will be collected, used and kept by us strictly for the purposes indicated in this Privacy Policy and the Site in strict adherence to any and/or applicable Data Protection laws in Malta

2.    How will we use the information You provide?

We may use the information You provide to:

  • Keep a record of all Esprimi community members.
  • Send You invitations to participate in surveys that are relevant to You based on the information You provided in response to our recruitment questionnaire(s). 
  •  Append personal information about You to Your responses to any surveys You participate in, such as geographical location, occupation categories, etc. for the purpose of analysing the survey responses and producing anonymous, statistical research results. 
  •  To create anonymous, statistical profiles of community membership based on the information provided by community members. 
  • We may also send Your information to our sub-contractors who may carry out some of the work we do on our behalf, and under our control.

For more information about our community, community membership or information related to Your membership, please contact our Support Team by sending an email to: info@esprimi.eu 

Our online surveys (as well as our affiliates’ surveys) may automatically capture information from tracking technologies (see note about tracking technologies below) about the following: 

  • Usage info (e.g. visitor logs including IP address, cookies, etc.)
  • Device info (e.g. which browser used, which OS, etc.)
  • Referral source (e.g. which source or link referred respondent to survey)
  • Page tag data (e.g. clear gifs, web beacons, web bugs, etc.)

We and/or our affiliates may use this information to:

  • Ensure that the survey questionnaire is delivered in a form suited to the software Your computer is using. 
  • Assist in providing support to You should You have difficulty accessing or completing a survey.
  •  Help us send You surveys that are relevant to You (for example, You may be asked Your opinion on ads that You've actually seen), or for other research into internet usage. 

Anonymised information may also be used for research purposes - for example, to determine the percentage of our community lists in a specific country who use a certain type of browser.  

We may collect and use personal data to send direct marketing material on our products and/or services, promotions and offers that may be of interest to You, to provide You with information that You request, to respond to feedback that You submit to the Site, to allow You to participate in any of our online surveys (or surveys of our partners and/or affiliates) and competitions and generally to be able to correspond with You after we receive a request from You. However, we do not send unsolicited mail, messages or junk mail. 

You have a right to request not to receive direct marketing material by writing to us at the address above.

3.    Which Tracking technologies are used in our surveys?

  • Cookies

Like most other similar websites, Esprimi may choose to use “cookies” to collect data about visitors. Cookies are alphanumeric identifiers stored on Your computer’s hard drive through Your Web browser for the purpose of identifying You when You visit a site or page. The storing of information or gaining of access to information stored in the terminal equipment used by You shall only take place with Your prior consent. 

Cookies enable us to recognize Your browser when You visit and to tell us whether You and other visitors have visited the Site previously. For these purposes Your cookies are tied to personally identifiable information (like Your email address). If You have provided Your name or other contact information to Esprimi via a web form, we are able to tie that information back to the cookie.

Cookies can be either temporary session cookies that expire at the end of a user session when the browser is closed or persistent cookies that remain on Your hard drive for an extended period of time. With Your consent as indicated above, we use persistent cookies. A persistent cookie can remain on Your hard drive for an extended period of time.

We (or our affiliates) may set cookies when You visit our Site, use our application and/or the applications of third parties and take a survey. Cookies may be used to:

  • Identify whether a user is logged in, for security purposes, and to allow the use of software features;
  • Allow us to see how visitors use our site (these may be third party cookies like ‘Google Analytics’);
  • Identify a unique survey response when You are a Respondent taking a survey.

In any case, You can usually modify Your browser to prevent the above from happening. Each browser is different, but the ‘Help’ section for the browser will be able to show You how to change cookie preferences or clear Your cookies from time to time.  

The information collected in this way can be used to identify You unless You modify Your browser settings. Should You wish to browse anonymously please contact us and request a link that we can send You to exclude You from web tracking. However, please note that if You block cookies as indicated above, it may impact Your experience and You may not be able to take advantage of all features of our software. 

We strongly urge You to familiarise Yourself with all the terms and conditions and/or privacy policies of any relevant third parties as mentioned in our Terms (including but not limited to the terms and conditions and privacy policies described at www.surveygizmo.com).

Please note that in certain cases, it may not be possible to take part in certain surveys unless “cookies” are enabled.

  • Clear Gifs (Web Beacons/Web Bugs)

Our surveys sometimes include software features that will enable clear gifs (a.k.a. Web Beacons/Web Bugs) in survey distribution email campaigns to community members. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence.

Esprimi also uses clear gifs in our HTML-based emails to You our customers and users to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If You would like to opt-out of promotional emails we may send, please follow the unsubscribe instructions included in each promotional email. In any case, as stated above, You have a right to request not to receive direct marketing material by writing to us at the address indicated above.

4.    How long will we keep the information You provide?

We will keep the information You provided when You joined our community, together with any information You provided in Your profile for as long as You remain a member of the community. You can leave the community at any time You wish. We may also disable Your account in our community if You are not taking part in any surveys, are no longer eligible to be a member for any other reason, or the community is closed. Before disabling anyone from our community, we will contact them to let them know and provide details of how to remain a community member where appropriate. However, in the event we consider You breach Esprimi's rules or terms and conditions, we may disable Your account without any notice and Your access to the community list website and to Your points account will be closed.

When You leave the community, Your account is disabled, or the community is closed, we will remove all Your contact details, together with any other information that could be used to identify You, leaving only anonymous responses to surveys that You participated in.

5.    Who may we share Your personal data with?

We do not transfer any personal data that we process about You to any third party in Malta or outside the European Union unless You consent to such transfer, or such transfer is necessary in order to provide You with services that You may request (such as third parties offering surveys You may be interested in), or we are otherwise obliged or authorised to make such transfers by or under any law. You will be aware however that data sent via the Internet may be transmitted across international borders even where sender and receiver of information are located in the same country. Consequently, data relating to You may be transmitted via a country having a lower level of data protection than that existing in Your country of residence.

We may share personal information with companies within the European Union who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to You, managing and enhancing customer data, providing customer service, assessing Your interest in our products and services, and conducting customer research or satisfaction surveys. We may also disclose information about You if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

You will be duly informed of any changes to the way we process Your personal data and of anything that You are entitled to know in terms of the Data Protection Act.

Without prejudice to anything contained in this Privacy Policy, we reserve the right to disclose personal data relating to You to any third party if such disclosures are necessary inter alia for the following purposes: 

(1) For the purpose of preventing, detecting or suppressing fraud; 
(2) To protect and defend our rights and property or that of users of our Site; 
(3) To protect against abuse, misuse or unauthorised use of our Site; 
(4) To protect the personal safety or property of users of our Site (e.g. if You provide false or deceptive information about Yourself or attempt to pose as someone else, we shall disclose any information we may have about You in our possession so as to assist any type of investigation into Your actions); 
(5) For any purpose that may be necessary for the performance of any agreement You may have entered into with Us; or 
(6) As may be allowed or required by or under any law.

Relevant data will be disclosed or shared as appropriate with Our employees and with affiliated companies, associates, agents and other third parties if pertinent to any of the purposes listed in this Privacy Policy. We may make certain personal information available to strategic partners that work with us to provide products and services, or that help us market to our customers. Personal information will only be shared by us to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.

6.    How can You request information about the personal data we hold about You and/or request to correct and/or delete it?

You have the right to request information about the personal data we hold about You. All reasonable efforts are made to keep the information we hold about You up-to-date. If You require information about the personal data we hold about You, please contact the Esprimi support team at the following email:

Email sent to: info@esprimi.eu    

Please quote Your membership number (this can be found in Your account overview panel on the left hand side) in Your email.

If You find any inaccuracies we will delete or correct them.

7.    How do You ensure my personal information is secure?

We take very seriously our responsibilities to keep Your personal information secure. The personal information which we hold (and/or transfer to our affiliates/partners as the case may be) will be held securely in accordance with our internal security policy and the law. We use reasonable efforts to safeguard the confidentiality of all personal data that we process relating to You and regularly review and enhance our technical, physical and managerial procedures so as to ensure that Your personal data is protected from:

-unauthorised access
-improper use or disclosure
-unauthorised modification
-unlawful destruction or accidental loss

To this end we have implemented security policies, rules and technical measures to protect the personal data that we have under our control (these measures include appropriate physical security of our offices, controlled access to computer systems, and use of secure, encrypted internet connections when collecting personal information).

All our employees and data processors, who have access to and are associated with the processing of personal data, are further obliged to respect the confidentiality of our visitors’ personal data.

By its very nature, the Internet is not a secure medium and data sent via this medium can potentially be subject to unauthorised acts by third parties. We cannot guarantee the privacy or confidentiality of any information passing over our Site.

We shall accept no responsibility or liability whatsoever for the security of Your data while in transit through the Internet.

For more information on our security measures please contact our Customer Services department at the number above or else send us an email using the address indicated above.

Authorised third parties, including external service providers, with permitted access to Your information are specifically required to apply appropriate security measures to appropriate technical and organisational security measures that may be necessary to safeguard the personal data being processed from unauthorised or accidental disclosure, loss or destruction and from any unlawful forms of processing.

8.    Anything Else?

Links that we provide to third-party websites are clearly marked and we are not in any way responsible for the content of such websites. We suggest that users should read and familiarise themselves well with the privacy policies of such third-party websites.

We reserve the right, at our complete discretion, to change, modify, add and/or remove portions of this Privacy Policy at any time. Your continued access to or use of the Site will mean that You agree to any and all such changes.

9.    How can You contact us?

For more information about our community and/or our community membership or if You have any questions or require further information about our privacy policy, our compliance with data protection laws or information we hold about You, please contact our Support Team. They can be contacted by Email at: info@esprimi.eu 

Please quote Your membership number (this can be found in Your account overview panel on the left-hand side) in Your email.

Should You wish, You may also phone us using telephone number (+356) 21 354289 (during normal office hours).

Our privacy policy was last updated on 29.08.2014.