Privacy Policy
Last updated: 08 July 2026
This Privacy Policy explains how TW Consulting & Trade Ltd, trading also through PUREMalta, collects, uses, stores and protects personal data when You use Our websites, online store, services, customer account, checkout, and Independent Business Owner / IBO programme.
By using Our Website or submitting information through Our forms, You acknowledge that We will process Your personal data as described in this Privacy Policy.
1. Who We Are
Company: TW Consulting & Trade Ltd
Trading name / project: PUREMalta
Address: Town’s End, Block D/9, Triq L-Izbark Tal-Francizi, Mellieħa, Malta
Websites: twctmt.com and puremalta.store
Email: support@twctmt.com
For the purpose of data protection law, TW Consulting & Trade Ltd is the data controller responsible for the personal data described in this Privacy Policy.
2. Personal Data We Collect
We may collect and process the following categories of personal data.
Customer and Account Data
When You create an account, place an order, contact Us, or use Our Website, We may collect:
- First and last name
- Email address
- Phone number
- Billing address
- Delivery address
- Account login details
- Order details
- Product purchase history
- Coupon or IBO code used at checkout
- Payment status
- Delivery information
- Messages or requests You send to Us
IBO Partner Application Data
If You apply to become a PUREMalta Independent Business Owner, business partner, or IBO Partner, We may collect additional information, including:
- First and last name
- Residential address
- Date of birth
- ID card or identification number
- Email address
- Phone number
- Online acceptance of the IBO Agreement
- Confirmation that You have read the Income Disclosure
- Full legal name used for online acceptance
- Assigned IBO number
- IBO user account details
- Sales linked to Your IBO number
- Commission calculations
- Monthly payout records
- Paid / unpaid payout status
- Payment notes, such as Revolut, bank transfer, or cash
- Internal application review status
Usage and Technical Data
When You use Our Website, some information may be collected automatically, including:
- IP address
- Browser type and version
- Device type
- Operating system
- Pages visited
- Time and date of visit
- Website interaction data
- Cookies and similar tracking technologies
3. How We Use Personal Data
We use personal data for the following purposes:
- To operate and maintain Our Website and online store
- To create and manage customer accounts
- To process orders and payments
- To arrange delivery
- To provide customer support
- To respond to Your requests and messages
- To send order confirmations, account emails and service updates
- To manage returns, refunds and complaints
- To prevent fraud, misuse and security issues
- To comply with legal, accounting and tax obligations
- To improve Our Website, products and services
- To send marketing communications where permitted by law or where You have consented
- To manage IBO applications and IBO Partner accounts
- To verify that IBO applicants are at least 18 years old
- To assign IBO numbers
- To track sales linked to IBO numbers
- To calculate IBO commissions
- To manage monthly IBO payouts
- To keep business records related to the IBO programme
4. IBO Sales Tracking and Commission Records
PUREMalta uses IBO numbers to track sales and calculate commission.
When a customer enters an IBO number at checkout, WooCommerce stores that code with the order. This allows Us to identify which IBO Partner is linked to the sale.
IBO Partners may see sales and commission information in their IBO Dashboard. For customer privacy, IBO Partners should not be given unnecessary customer personal details such as full address, phone number or payment details.
IBO commission is calculated according to the applicable PUREMalta commission rules. At the time of this policy, the standard IBO commission is 15% of product sales, excluding shipping, cancelled orders, refunded orders, failed orders and other excluded transactions.
5. Lawful Basis for Processing
We process personal data under one or more of the following lawful bases:
- Performance of a contract: to process orders, manage accounts, deliver products, manage IBO agreements and provide requested services.
- Steps before entering into a contract: to review IBO applications and customer requests.
- Legal obligation: to keep accounting, tax, payment, invoice and business records.
- Legitimate interests: to operate Our business, prevent fraud, manage customer service, protect Our Website, improve Our services, track IBO sales and manage commission records.
- Consent: where required, such as for certain marketing communications or non-essential cookies.
6. Payments
Payments may be processed by third-party payment providers. We do not store full card details on Our Website.
Payment providers may process payment information according to their own privacy policies and security procedures.
7. Delivery
Where delivery is required, We may share necessary delivery information with courier or delivery providers, including Pony Express Couriers or other delivery partners We may use.
This may include Your name, delivery address, phone number and order delivery information.
8. Sharing Personal Data
We may share personal data with:
- Website hosting providers
- WordPress, WooCommerce and related technical service providers
- Payment processors
- Courier and delivery providers
- Email service providers
- IT support providers
- Accounting, tax or legal advisers
- Fraud prevention or security service providers
- Public authorities where required by law
- Business partners only where necessary for the service or where You have agreed
We do not sell Your personal data.
9. Cookies and Similar Technologies
We use cookies and similar technologies to operate and improve Our Website.
Cookies may be used for:
- Essential website functions
- Shopping cart and checkout functions
- Login and account functions
- Remembering preferences
- Security
- Analytics
- Cookie notice acceptance
- Marketing, where applicable and permitted
You can control cookies through Your browser settings. If You disable certain cookies, parts of the Website may not work properly.
A separate Cookie Policy or cookie banner may provide more detailed information about the cookies used on Our Website.
10. Marketing Communications
We may send marketing emails or promotional information where permitted by law or where You have consented.
You can unsubscribe from marketing emails at any time by using the unsubscribe link or by contacting Us.
We may still send service-related messages, such as order confirmations, account notifications, delivery updates, IBO programme communications, or important legal notices.
11. Data Retention
We keep personal data only for as long as necessary for the purposes described in this Privacy Policy.
Order, invoice, accounting and payment records may be kept for as long as required by applicable tax, accounting and legal obligations.
Customer account data may be kept while the account remains active and for a reasonable period afterwards.
IBO application records may be kept for as long as necessary to review the application and, if approved, for the duration of the IBO relationship and for a reasonable period afterwards for legal, accounting, dispute-resolution and record-keeping purposes.
Rejected or incomplete IBO applications will be kept only for as long as reasonably necessary, unless a longer period is required to protect Our legal rights or comply with legal obligations.
Usage data may be kept for a shorter period unless needed for security, fraud prevention, analytics or legal purposes.
12. International Transfers
Some service providers may process data outside Malta or outside the European Economic Area.
Where this happens, We will take reasonable steps to ensure that appropriate safeguards are in place, as required by applicable data protection law.
13. Security
We take reasonable technical and organisational measures to protect personal data from unauthorised access, loss, misuse, alteration or disclosure.
However, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.
You are responsible for keeping Your account login details confidential.
14. Your Data Protection Rights
Depending on the circumstances, You may have the right to:
- Request access to Your personal data
- Request correction of inaccurate personal data
- Request deletion of Your personal data
- Object to certain processing
- Request restriction of processing
- Request data portability
- Withdraw consent where processing is based on consent
- Lodge a complaint with a data protection authority
These rights may be limited where We must keep information for legal, tax, accounting, contractual, fraud-prevention or dispute-resolution purposes. Data subject rights under GDPR include rights such as access, rectification, erasure, restriction, portability and objection.
To exercise Your rights, contact Us at:
We may need to verify Your identity before responding to a request.
15. Complaints
If You believe that Your data protection rights have been infringed, You may contact Us first so that We can try to resolve the matter.
You also have the right to lodge a complaint with the Office of the Information and Data Protection Commissioner in Malta. The Malta IDPC states that individuals have the right to lodge a data protection complaint where they believe their rights have been infringed.
16. Children
Our Website and services are not intended for children.
The IBO Partner programme is available only to applicants who are at least 18 years old.
If We become aware that We have collected personal data from a child without appropriate permission, We will take steps to delete it where required.
17. Links to Other Websites
Our Website may contain links to third-party websites.
We are not responsible for the privacy practices, content or security of third-party websites. You should read their privacy policies before providing personal data.
18. Changes to This Privacy Policy
We may update this Privacy Policy from time to time.
The updated version will be posted on Our Website with a new “Last updated” date.
19. Contact Us
For questions about this Privacy Policy or Your personal data, contact Us at:
TW Consulting & Trade Ltd
Town’s End, Block D/Office 2, Triq L-Izbark Tal-Francizi, Mellieħa, Malta
Email: support@twctmt.com
