Introduction
At Buffer Boys Ltd (“we”, “us” “our” or “Bufferboys”),we are committed to protecting and preserving the privacy of our visitors when visiting our site or communicating electronically with us and protecting your personal data. This Privacy Policy (the “Policy”) sets out the basis on which your personal data is processed by us, informing you about how Buffer Boys Ltd uses and protects your personal data. This extends to the use and viewing of our website (regardless of where you visit it from). It is intended to inform 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. , and of what happens to the personal data that you choose to provide to us, or that we collect from you whilst you visit this site. Our Privacy Policy should be read in conjunction with our Terms and Conditions of website use.
We process your data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 586 of the Laws of Malta) (the “Act”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), following its application on 25th May 2018.
Please read this Privacy Policy carefully, 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 Policy supplements the other notices and is not intended to override them.
We do occasionally update this Policy so please do return and review this Policy from time to time.
Buffer Boys Ltd having its registered office at Bufferboys, Triq John Michael Testa, Tal-Handaq, Hal Qormi, QRM 4000, Malta is the controller of, and is responsible for, your personal data.
We have appointed a data protection contact point (“DPCP”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights as a data subject, please contact the DPCP using the details set out below.
You can address any comments, queries or complaints to the DPCP, using the details indicated below, with the words ‘Data Protection Matter’ in the subject line.
Contact details
Full name of legal entity: Buffer Boys Ltd
Email address: [email protected]
Postal address: Bufferboys, Triq john Michael Testa, Tal-Handaq, Hal Qormi, QRM 4000, Malta
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”) (https://idpc.org.mt/en/Pages/Home.aspx). 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.
Third Party Links
This Privacy Policy is limited to this website. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling such connections may allow third parties to collect or share data about you.
These websites should have their own privacy policies which you should check. We have no control whatsoever over such websites and if you use a link to leave the Site and access a third party website you accept and agree that we cannot be responsible for the protection and privacy of any information which you might provide, make available to or is otherwise collected by such third party website. Accordingly you should use caution and carefully examine such third party’s privacy policy.
We may collect, use, store and disclose different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregate 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 website feature. 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 privacy notice.
We do not collect Special Categories of Personal Data about you.
Generally we shall collect this personal data about you by means of the following:
A. When visiting our website
It is possible to visit our website and view the products displayed on our website without submitting any personal data. In order to provide you with the best experience when browsing our website we may need to process certain data which can identify you and can therefore be considered to be personal data. In this regard we may collect the following information about you whenever you visit our website.
Please refer to our Cookie Policy for further information as to how this website may collect certain information about your visit to our website.
B. When communicating with us over phone or email
Whenever you contact us in order to enquire about services or else book a meeting we shall require certain basic Identity and Contact Data (in particular, your name, surname and mobile number).
C. When using any of our services
In order to be able to provide the services which you request, we shall need to process personal data. Generally, this shall include your contact information, such as your name, surname, address, email, telephone number as well as your financial details.
We may provide specific privacy notices with our contracts with you or when we request the collection of your personal details which shall list the information which we require as well as other pertinent information relating to how and why we shall process your personal data. These privacy notices should be read in conjunction with this Privacy Policy.
The personal data which we request from you shall generally be restricted to the data which is strictly necessary for us to be able to provide the services which you request. In addition, we may also request certain personal data to ensure compliance with our legal obligations
D. Other data
Through our website you may also choose to subscribe to our newsletter. You can unsubscribe to any and all marketing information at any time by emailing us on [email protected] or else choosing the unsubscribe option in any communications sent to you. By subscribing to our newsletter, you shall be included in our mailing list until such time as you choose to unsubscribe to receiving any communications from us. In this regard, we shall process data relating to your preferences in receiving marketing from us to ensure that we adhere to your choices.
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.
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:
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 if 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 |
| To register you as a new customer | (a) Identity and Contact Data | Performance of a contract with you |
| To process and deliver your order including: (a) Setting up appointments for installation of our products (b) Manage payments, fees and charges (c) Collect and recover money owed to us (d) Carry out after-sales services as may be necessary | (a) Identity (b) Contact (c) Financial (d) Customer (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Compliance with a legal obligation (to carry out repairs covered by your warranty) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy and any changes to our website, including improvements, and service or product changes that may affect our website. (b) Asking you to leave a review or provide customer feedback | (a) Identity (b) Contact (c) 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/services) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, 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 and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We may use your Identity and Contact Data, Technical Data as well as your Customer Data to form a view on what we think you may want or need, or what may be of interest to you.
If you are an existing customer, we may contact you with information about goods and services similar to those that you have expressed an interest in previously via our website. You will receive marketing communications from us if you have subscribed to our newsletter or engaged us to carry out any services. This is within our legitimate interest to develop our relationship with you and ensure that you receive the best service possible.
If you are a new customer, we will only contact you only when you have provided consent and, only by those means you provided consent for.
Opting Out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time or emailing us at [email protected].
Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into on our site will be encrypted to ensure its safety. We strive to protect the security of any data which you provide to it and which we collect about you, and will update it from time to time in order to ensure that its measures are always up-to-date in accordance with our legal obligations.
We may also transfer your personal data to external third parties, namely our service providers which are necessary for us to be able to provide the Services we offer. In particular, we may transfer your personal data to our IT and software support service providers, our insurers and external legal counsel. 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 instructions.
Whenever we enter into a contract with you we shall inform you of the identity of the service providers which may be necessary for us to be able to provide the Services you engage us to carry out.
We may also disclose your personal information to third parties:
We may also disclose your personal data to regulatory or governmental agencies as well as executive and judicial authorities which may have jurisdiction over our operations. We shall only make such disclosures in accordance with the appropriate authority and to comply with our legal obligations.
We may transfer your personal data outside the European Economic Area (EEA) in the following circumstances:
6. Data Security
7. Data Retention
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Under applicable data protection laws, you are entitled to exercise the following rights:
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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, 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 also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where 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.
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.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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 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. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at [email protected]. No fee is usually required.
9. Google Analytics
So as to improve the quality and overall user experience of the Website, we are using Google Analytics Advertising Features. This includes, but is not limited to, remarketing and othr tracking tags from Google and other various social media and other platforms.
If you would like to opt-out of Google Analytics for display advertising, you may do so by using the Ads Preference Manager. In addition, there is also a Google Analytics Opt-Out browser add-on that you can download at https://tools.google.com/dlpage/gaoptout.
Variations
We reserve the right to revise and amend this Policy from time to time and any revised version will be deemed to be applicable from the first date of publication on this website.
If there are any changes to this privacy policy, we will replace this page with an updated version. It is therefore in your own interest to check the “Privacy Policy” page any time you access our web site so as to be aware of any changes which may occur from time to time.
Contacting Us
If you have any questions or queries relating to this Privacy Policy then please contact us at [email protected].
Any comments or suggestions that you may have and which may contribute to a better quality of service will be welcome and greatly appreciated.
IP Address and Cookie Policy
Last Updated: 04/07/2025
Welcome to Buffer Boys’s Ltd IP Address and Cookie Policy.
Buffer Boys Ltd having its registered office at Bufferboys, Triq John Michael Testa, Tal-Handaq, Hal Qormi, QRM 4000, Malta (“we”; “us”; or “our”) collects two types of information about you resulting from your use of our website www.bufferboys.com (the “Website” or 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 ‘cookies’ and the Internet Protocol Address (“IP Address”) pertaining to the users of the Website.
Our practices regarding the collection and processing of your personal information are set in our Privacy Policy. Correspondingly, the practices which we have in place regarding the generation of aggregate information are described here in our IP and Cookie Policy. In order to be able to access and use the Site, you must expressly agree and consent to the practices set out herein.
Please read the following carefully to understand how and why the Site uses your IP Address and cookies. If you not accept or agree to the practices described in this policy, you must exit the Site immediately.
2. IP Address
2.1 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.
2.2 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 given that they would not be able 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 and not combined with other identifiers). An IP Address does, however, contain information regarding the location of your computer on the internet (your country), and the name of your ISP.
2.3 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 to be delivered. 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.
2.4 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 the Site, how long they stay on the Site, which are the most viewed pages and for other statistical reasons.
We gather your IP address automatically and store it in log files. These files also contain information relating to your browser type, ISP, operating system, date/time stamp, clickstream data and the files viewed on the Site. Collecting this type of information allows us to generate aggregate information for the purposes of the Site, including in terms of overall user trends and activities online (such as the number of unique visitors, pages access most frequently or the search terms entered). Furthermore, 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.
3.0 Cookies
The Site uses cookies to distinguish you from other users. They allow us to analyse trends and administer the Site, to help us to provide you with a good experience when you browse the 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. A cookie enables the website to remember users that have already visited. 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. Cookies allow us to remember your custom preferences such as your language preference and allow you to complete tasks without having to re-enter your information when browsing.
We use the following cookies:
You can find more information about the individual cookies we use and the purposes which we use them in the table below:
| Name | Purpose | Duration | Domain |
| PHPSESSID | This cookie is native to PHP applications. The cookie stores and identifies a user’s unique session ID to manage user sessions on the website. The cookie is a session cookie and will be deleted when all the browser windows are closed. | session | bufferboys.com |
| __cfruid | This cookie is set by the Google recaptcha service to identify bots to protect the website against malicious spam attacks. | Session | .sibforms.com |
| rc::a | This cookie is set by the Google recaptcha service to identify bots to protect the website against malicious spam attacks. | Never Expires | google.com |
| wpEmojiSettingsSupports | WordPress sets this cookie when a user interacts with emojis on a WordPress site. It helps determine if the user’s browser can display emojis properly. | Session | Bufferboys.com |
| rc::c | This cookie is set by the Google recaptcha service to identify bots to protect the website against malicious spam attacks. | Session | Google.com |
| cookieyes-consent | CookieYes sets this cookie to remember users’ consent preferences so that their preferences are respected on subsequent visits to this site. It does not collect or store any personal information about the site visitors. | 1 year | Bufferboys.com |
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 and 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 the Site.
Furthermore, some parts of the Site, or the services that you connect to through it, may not function properly if you choose not to accept cookies.
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:
Further information on cookies can be found on various sites such as www.allaboutcookies.com
The Site includes social media features such as Facebook, Youtube and LinkedIn Widgets.These features may collect your IP address, which pages 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.
