Privacy Policy

1. Introduction

Average Joe Technology ("we", "our", or "us") respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, and protect your information when you visit our website or use our services.

We are based in Mosta, Malta, and operate under EU GDPR regulations.

2. Data Controller

3. Data We Collect

3.1 Information You Provide

• Contact Information: Name, email address, phone number
• Communications: Messages sent through our contact form
• Service Inquiries: Details about your technology needs and requirements

3.2 Information Automatically Collected

• Technical Data: IP address, browser type, device information
• Usage Data: Pages visited, time spent on site, interaction patterns
• Analytics Data: Collected through OpenReplay for website improvement
• Cookies: Session and preference cookies (see our Cookie Policy)

4. Legal Basis for Processing

We process your personal data under the following legal bases:

• Legitimate Interests: To respond to your inquiries and provide our services
• Consent: For marketing communications and non-essential cookies
• Contract Performance: To fulfill agreed-upon services
• Legal Obligation: To comply with applicable laws and regulations

5. How We Use Your Data

• Respond to your inquiries and provide customer support
• Deliver our technology consulting services
• Improve our website and services through analytics
• Send service-related communications
• Comply with legal obligations
• Protect against fraud and security threats

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your information only in these limited circumstances:

• Service Providers: Trusted third parties who assist with our operations (email hosting, analytics)
• Legal Requirements: When required by law or to protect our rights
• Business Transfers: In the event of a merger or acquisition
• With Your Consent: When you explicitly agree to sharing

7. Data Retention

We retain your personal data only as long as necessary:

• Contact Inquiries: 3 years from last contact
• Client Records: 7 years after service completion (tax requirements)
• Analytics Data: 26 months (anonymized)
• Marketing Data: Until you opt out or 3 years of inactivity

8. Your Rights

Under GDPR, you have the following rights:

• Access: Request copies of your personal data
• Rectification: Correct inaccurate personal data
• Erasure: Request deletion of your personal data
• Restriction: Limit how we process your data
• Portability: Transfer your data to another service
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Revoke consent for processing

To exercise these rights, contact us at [email protected]

9. Data Security

We implement appropriate security measures:

• SSL/TLS encryption for data transmission
• Secure email protocols for sensitive communications
• Regular security assessments and updates
• Access controls and authentication procedures
• Data backup and recovery procedures

10. International Transfers

We primarily process data within the EU. Any transfers outside the EU are protected by appropriate safeguards, such as Standard Contractual Clauses or adequacy decisions.

11. Children's Privacy

Our services are not directed to children under 16. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately.

12. Changes to This Policy

We may update this privacy policy to reflect changes in our practices or applicable laws. We will notify you of significant changes by posting the updated policy on our website.

13. Contact Us

If you have questions about this privacy policy or our data practices, please contact us:

You also have the right to lodge a complaint with the Malta Information and Data Protection Commissioner if you believe we have violated your privacy rights.