Privacy Policy

DM Capital Group of Companies

DM Capital prides itself in committing to safeguard and preserve each and every individual’s privacy when visiting the following websites or communicating with it:

Hereinafter collectively above mentioned websites shall be referred to as “Websites”.

This privacy policy, together with the Web and E-mail Disclaimers, describe DM Capital’s current policies and practices with regard to any personal data collected by DM Capital through its Websites.

This privacy policy is independent from DM Capital’s offline personal data collection practice. The term “personal data” refers to personally identifiable information about you, such as your name, date of birth, e-mail address or mailing address, and any other information that is identified with you personally, including your individual health information.

Intellectual Property

All materials within Websites are the intellectual property of DM Capital. These materials may not be copied or reproduced, save to the extent necessary to view the same on-line. Notwithstanding the above you may print complete pages of Websites to hardcopy for your own personal use. We may sometimes give you the opportunity to download wallpaper, screen savers and other utilities from the website.

Notification of Changes to This Policy

DM Capital is continuously improving and adding new functionality and features to its Websites and improving and adding to its existing products, services, and programs. Because of these ongoing changes, changes in the law, and the changing nature of technology, DM Capital’s data practices will change from time to time. If and when its data practices change, DM Capital will post the changes on its Websites to notify you of the changes. DM Capital encourages you to check this page frequently. An individual’s continued use of the Websites after any updates take place denotes such individual’s agreement to the policy as updated.

Personal Data collected through its Websites

Personal data which may be collected by DM Capital through its Websites is the information you voluntarily give us when you use our sites and when you communicate with us. DM Capital may collect details of your visit to our Websites and any resources which you access, including, but not limited to any traffic or location data and weblogs.

Use of Personal Data Collected Through the Websites

DM Capital uses the personal data information you provide to answer the query you will have posted through the Websites. DM Capital and our affiliates may also use this information 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. DM Capital and our affiliates may use this information to contact you in the future to tell you about products or services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications.

Similarly, we may provide “subscription” e-mail services, either directly or through affiliates, which enable you to receive current news about DM Capital and its business. For all such services, we will provide an opportunity to “opt-out” of, or cancel, the subscription.

Requirements and Criteria for Processing

Portman International Holdings ensures that:

  • Personal data is processed fairly and lawfully;
  • Personal data is always processed in accordance with good practice;
  • Personal data is only collected for specific, explicitly stated and legitimate purposes;
  • Personal data is not processed for any purpose that is incompatible with that for which the information is collected;
  • Personal data that is processed is adequate and relevant in relation to the purposes of the processing;
  • No more personal data is processed than is necessary having regard to the purposes of the processing;
  • Personal data that is processed is correct and up to date;
  • All reasonable measures are taken to complete, correct, block or erase data to the extent that such data is incomplete or incorrect, having regard to the purposes for which they are processed;
  • Personal data is not kept for a period longer than is necessary, having regard to the purposes for which they are processed.

Anonymous Data Collected Through the Websites


While you visit our Websites and any other website, your web browser may automatically download a copy of the site you are visiting in addition to a text file called ‘Cookies’. This file is then stored on the hard drive of your personal computer. Cookies help us improve our Websites. Cookies may be declined by changing the settings to the web browser. Kindly note that should you decide to decline Cookies, you may not be able to access certain sections of our Websites.

Cookies provide us with anonymous information about how many visitors access our Websites, the date and time of their visit, the length of their stay, and which pages they view. We also use these Cookies to determine which web browsers our visitors use and the address from which they accessed our sites (for example, if they connected to a DM Capital website by clicking on one of our banner ads).

These Cookies do not identify you personally. They simply enable us to compile statistics about our visitors and their use of our sites. DM Capital and our affiliates use this anonymous data and share it with third parties to improve the content and functionality of our Websites, to better understand our customers and markets, and to improve our products and services.

Disclosure of Your Personal Data

DM Capital may share some or all of the personal data collected through the Websites with our affiliates in Malta and overseas, who will use this data in accordance with this Privacy Policy. Both DM Capital and our affiliates may share personal data collected through its Websites with third-party vendors who act for or on behalf of DM Capital or our affiliates (for example, companies that provide support services to us, including data processing services, or that help us market our products and services). These companies may need information about you in order to perform their functions. These companies are not authorised to use the information we share with them for any other purpose. In addition, there may be some other, limited circumstances in which DM Capital or our affiliates may share or transfer the personal data in our databases, for example, to comply with a legal requirement, for the administration of justice, to protect your vital interests, or in the event of a corporate sale, merger, reorganisation, dissolution, or similar event.

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

If you do not want DM Capital to share your data with other third parties, you will have the opportunity to withhold your consent to this when you provide your details to us.

Kindly also note that no identifiable individuals’ information is revealed to our advertisers and affiliates, but we may occasionally provide such third parties with aggregate statistical information about visitors to our Websites.

Links to Other sites

This privacy policy applies only to DM Capital Websites. DM Capital and our affiliates operate other websites for different purposes and in different countries where different laws may apply. If you visit a DM Capital affiliated website, please take a moment to review the privacy policy posted on that site to learn what personal data may be collected through that site and how it is processed.

DM Capital Websites may contain hyperlinks to websites that are not operated by DM Capital or one of our affiliates. These hyperlinks 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. DM Capital does not control these websites and is not responsible for their data practices. We urge you to review the privacy policy posted on any site you visit before using the site or providing any personal data about yourself.

Social Media Plug-ins

Social plug-ins of social networks e.g. Twitter, Facebook and Google+, are integrated on the Websites. You can recognize the plug-ins through the company signs. If you visit one of our Websites, that uses such social plug-ins (e.g. “like”- button by Facebook), your browser will directly connect to the server of the social network. DM Capital does not receive any knowledge about such transferred data. To ensure that during a visit to our Websites the social networks are not able to collect your data, you have to be logged out of any social network before entering our Websites. Using the social connect button of the particular provider (Facebook, Twitter, Google+) through registration on our website personal data will only be communicated with your consent. Regarding information about purposes and the amount of data collection through the social networks as well as your rights and alternative adjustments regarding the protection of your privacy please have a look at the private policy declaration of the particular social network.

Google Analytics

DM Capital measures visitors to Websites using Google Analytics. This records what pages you view within DM Capital sites, how you arrived at DM Capital’s sites and some basic information about your computer. All of that information is anonymous – so DM Capital does not know who you are; just that somebody visited the Group’s sites.

The information DM Capital collects from Google Analytics helps DM Capital to understand which parts of the Group’s sites are doing well, how people arrive at these sites and so on. Like most websites, DM Capital uses this information to make the Websites better.

You can learn more about Google Analytics or opt out if you wish.

Rectification, Deletion and Updating of personal data

DM Capital shall, at the request of the data subject, immediately rectify, block or erase such personal data that has not been processed in accordance with the Data Protection Act in Malta, the Data Protection Act 1998 in the UK and the Data Protection Act 1988 in the Republic of Ireland, including any subsequent amendments, or with any regulations made thereunder.

Subject Access Policy

DM Capital will provide information in response to any reasonable subject access request. DM Capital will ensure data are kept in an accessible form to facilitate subject access.

DM Capital, at the request of the data subject, shall provide to the data subject, without excessive delay and without expense, written information as to whether personal data concerning the data subject is processed:

  • Provided that a request by the data as aforesaid shall only be made by the data subject at reasonable intervals;
  • Any such application shall be made in writing to DM Capital and is to be signed by the data subject;
  • If such data is processed, DM Capital shall provide to the data subject written information in an intelligible form about;
  • Actual information about the data subject which is processed;
  • Where this information has been collected;
  • The purpose of the processing;
  • To which recipients or categories of recipients the information is disclosed; and
  • Knowledge of the logic involved in any automatic processing of data concerning the data subject.

Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Republic of Malta, the Republic of Ireland and the laws of England and Wales, in accordance with the relevant EU legislation.

Questions About Our Privacy Policy

If you have any questions about this privacy policy or concerns about the way DM Capital processes your personal data, please contact us.