Personal
data

01

Introduction

This page explains how CLAIR GROUP SERVICES LIMITED, a company incorporated under Maltese law and publisher of the institutional website Clair Group, collects, uses and protects the personal data of site users.

The name Clair Group is used on this site as a trade name and institutional brand. It does not designate a single legal entity and may be used by several of the group's companies, each of which retains its own legal personality, activities and respective obligations. This information is detailed in the legal notice.

Personal data processing related to the site is carried out by CLAIR GROUP SERVICES LIMITED, as data controller, unless otherwise stated, in accordance with the General Data Protection Regulation, known as the GDPR, the law applicable in Malta, and other applicable personal data protection rules.

This page also details the cookies used, in particular cookies strictly necessary for the site to function and Google Analytics audience measurement cookies, which are subject to consent.

02

Data controller

The data controller is:

Personal data contact: data-protection@clair-group.com

03

Personal data collected

When using the site, CLAIR GROUP SERVICES LIMITED may collect the following data:

• last name and first name;
• email address;
• phone number, only if voluntarily entered in a form;
• company or organisation;
• position, where applicable;
• content of the message sent via a contact form;
• technical browsing data, such as IP address, browser used, device, pages viewed, date and time of connection;
• cookie preferences.

CLAIR GROUP SERVICES LIMITED ensures that it only collects data necessary for the purposes pursued.

04

Purposes of processing

Personal data may be used for the following purposes:

• responding to requests sent via the site;
• directing requests to the relevant department or brand;
• handling institutional, commercial, press, partnership or recruitment requests;
• ensuring the operation, security and maintenance of the site;
• measuring site audience, where the user consents;
• managing cookie preferences;
• complying with applicable legal or regulatory obligations.

05

Legal bases

Depending on the case, processing is based on the following legal bases:

• the legitimate interest of CLAIR GROUP SERVICES LIMITED in responding to requests received, ensuring the security of the site and improving its services;
• the user's consent for Google Analytics audience measurement cookies;
• the performance of pre-contractual measures when the request concerns a business relationship, a job application or a service request;
• compliance with applicable legal or regulatory obligations.

06

Data recipients

The data collected is intended for the relevant departments of CLAIR GROUP SERVICES LIMITED and, where applicable, the brands or entities concerned by the request.

It may also be passed on to technical service providers acting on behalf of CLAIR GROUP SERVICES LIMITED, notably for hosting, maintenance, security, audience analysis, form management or cookie management.

CLAIR GROUP SERVICES LIMITED does not sell users' personal data.

07

Data transfers

The site is hosted in the European Union.

Wherever possible, CLAIR GROUP SERVICES LIMITED favours service providers located in the European Union or the European Economic Area.

Should any data be transferred outside the European Union or the European Economic Area, CLAIR GROUP SERVICES LIMITED would ensure that such transfers are covered by appropriate safeguards, in accordance with the GDPR.

08

Retention periods

Personal data is kept for a limited period, proportionate to the purpose of the processing.

For information:

• requests sent via the contact form are kept for as long as necessary to handle the request, then archived for a reasonable period;
• data relating to a job application is kept for as long as necessary for the recruitment process;
• technical security data is kept for a limited period;
• cookie choices are kept for a period suited to the consent management solution used.

09

Data security

CLAIR GROUP SERVICES LIMITED implements technical and organisational measures to protect personal data against unauthorised access, loss, alteration, disclosure or destruction.

These measures may include securing access, limiting authorisations, using secure protocols, maintaining systems and technically monitoring the site.

10

Your rights

In accordance with the GDPR, each user has in particular the following rights:

• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to object;
• right to data portability, where applicable;
• right to withdraw consent at any time where processing is based on consent.

These rights can be exercised by writing to data-protection@clair-group.com.

Proof of identity may be requested where necessary to verify the requester's identity.

Users also have the right to lodge a complaint with the competent supervisory authority: theInformation and Data Protection Commissioner, the Maltese data protection authority.

01

Cookies

When browsing the Clair Group site, cookies or trackers may be placed on or read from the user's device.

A cookie is a small file stored on a device when visiting a site. It may allow the site to function properly, remember certain choices or measure audience.

The Clair Group site only uses cookies strictly necessary for its operation and Google Analytics audience measurement cookies. The site does not use advertising cookies.

02

Strictly necessary cookies

These cookies are essential for the site to function. They enable in particular:

• correct page display;
• secure browsing;
• remembering cookie choices;
• technical management of the site.

These cookies do not require user consent when they are strictly necessary for the service requested.

03

Google Analytics

The site uses Google Analytics, an audience measurement service provided by Google.

Audience measurement cookies are implemented by CLAIR GROUP SERVICES LIMITED, the publisher of the Clair Group institutional website.

Google Analytics allows CLAIR GROUP SERVICES LIMITED to understand how visitors use the site: pages viewed, browsing paths, visit duration, content performance and general traffic statistics.

This data is used to improve the site's content, usability and operation.

Google Analytics cookies are only placed after the user's consent. The service is not loaded until this consent is given.

04

Embedded third-party services

At this stage, the Clair Group site does not include third-party services likely to place additional cookies, such as embedded videos, interactive maps, social sharing buttons or advertising tools.

Should such services be added later, this page would be updated and user consent requested where required.

05

Consent management

On their first visit, users can accept or refuse cookies that require consent.

Users can change their choices at any time by clicking the link Manage my cookies, accessible from the site footer.

Refusing audience measurement cookies does not prevent access to the site.

06

List of cookies used

The exact list of cookies may vary depending on the configuration of Google Analytics and the consent management tool used.

07

Cookie retention period

Cookies are kept for a limited period, suited to their purpose.

Strictly necessary cookies are kept for as long as necessary for the service to function.

Google Analytics cookies are kept according to the configuration set in the Google Analytics tool.

Consent choices are kept to avoid asking for the user's preferences again at each visit.

08

Browser settings

Users can also configure their browser to block or delete cookies. However, some settings may affect the normal functioning of the site.

Procedures vary depending on the browser used.

09

Updates

This page may be modified to reflect changes in the tools used on the site or in applicable regulations.

Last updated: 7 September 2026