GDPR in Malta
The short version. The General Data Protection Regulation (GDPR) applies in Malta as everywhere in the European Union. This page explains who is responsible for your data in Hashmark, which authority you can turn to in Malta, and how to use your rights. What we keep, why and for how long is in our privacy policy.
Who is responsible for your data
In Hashmark there are two possible controllers, depending on the information:
| Information | Controller | Who to write to first |
|---|---|---|
| Your account (email, name, sign-in), billing, the usehashmark.com website | Vantry LLC, which publishes Hashmark | Hashmark: support@usehashmark.com |
| What your team or club records about you: roster, attendance, injuries and absences, wellness, fitness tests, licence and medical certificate, dues, trips, photos and videos, messages, club emails | Your club or team. Hashmark is only its processor (section 14 of the terms). | Your club office or coaches. If you write to us, we pass your request on and help them answer. |
Vantry LLC, 2524 Van Beek Road, Green Bay, WI 54311, United States. Data protection contact: support@usehashmark.com, with "GDPR" in the subject line. We answer in English or French.
The data protection authority in Malta
If you think your rights are not respected, write to us first: most questions are settled quickly. You can also complain at any time, free of charge, to the national authority:
| Authority | Information and Data Protection Commissioner (IDPC) |
|---|---|
| Postal address | Floor 2, Airways House, Triq Il-Kbira (High Street), Tas-Sliema SLM 1549, Malta |
| Website | idpc.org.mt |
| How to complain | Complaint page |
You can also complain to the authority of the EU country where you live, where you work or where the problem happened.
National rules in Malta
The GDPR applies directly; the national law that supplements it is the Data Protection Act (Chapter 586 of the Laws of Malta), 2018.
Age of digital consent (GDPR article 8): 13. Below this age, a parent or guardian must agree before a young person uses an online service on the basis of consent.
In Hashmark there is no account before 13, and anyone aged 13 to 15 needs the agreement of a parent or guardian, which we ask for by email. The parent can take that agreement back at any time with the link in that email, which deletes the account. For photos and videos of a minor, the parent answers the club's image rights form. This is stricter than the age set in Malta.
Your federation may have its own rules on licences and medical certificates; your club office can tell you what they are.
Health data and photos
Injuries and absences, wellness check-ins and medical certificates are health data, which the GDPR protects more strongly (article 9). Your club or team decides to record them, to organise practices and games and to follow its federation's rules; only the roles that need them can see them. Hashmark keeps them only to provide the service to your club, never uses them for anything else and never shows them to other clubs. Wellness check-ins are only for adult players who agree to them themselves.
The club only shows and shares photos and videos of you if you (or your parent, for a minor) said yes in its image rights form. You can change your mind and ask the club to remove a picture of you.
Your rights and how to use them
| Right | What it means | How to use it |
|---|---|---|
| Access | Know what information we have about you and get a copy | Write to us. For your team's or club's data, also ask the club office. |
| Rectification | Have wrong or incomplete information corrected | Your name: in Hashmark, Settings, Account settings. The rest: your coaches, the club office, or us. |
| Erasure | Have your information deleted | Delete your account yourself in Hashmark (Settings, Account settings, Delete my account). Data the club must keep (for example its accounts) stays with the club, no longer linked to your account. |
| Restriction | Have the use of your data put on hold while something is checked | Write to us. |
| Portability | Get your data in a reusable format | A coach can export a full copy of the playbook at any time. For your other data, write to us. |
| Objection | Refuse a use based on our legitimate interest | Write to us. Website visits are only measured if you agreed ("Cookie settings" button at the bottom of the website). |
| Withdrawing consent | Take back an agreement you gave | Image rights: change your answer in the club's form. Parent's agreement: the link in the email the parent received. Notifications: your phone's settings. Shared plays: stop sharing the play. |
We answer within one month, free of charge. We may ask you to confirm who you are, for example by writing from your account's email address. We make no automated decisions that significantly affect you, and we do no advertising profiling.
Where your data goes, and security
Hashmark's database is hosted in Ireland (European Union); clubs' photos are stored in the European Union and their videos in Slovenia (European Union). Some providers (email sending, payment, notifications) may process data in the United States; these transfers are covered by the European Commission's standard contractual clauses or the EU-US Data Privacy Framework. The full list of providers is in the privacy policy. We never sell or rent personal data.
Everything travels encrypted (HTTPS), and everyone sees only their own teams and, within a team, only what their role allows. If a data breach puts you at risk, we notify the competent authority within 72 hours and inform you and your club, as the law requires.
Other countries: GDPR by country. In France, see our RGPD page.