Privacy Policy

Effective Date: 3rd October 2023


Welcome to the Apsyofrelief internet portal, also referred to as “the Site”. This platform is an initiative by John Tabone, conducting business under the Apsyofrelief name, henceforth collectively known as ‘the Company’, ‘the Service’ or the Data Controller, along with references of ourselves, we, and our. We extend a comprehensive guide through these regulations and stipulations, known as “Terms”, which are designed to govern your interaction with the Site and its affiliated services. Engaging with the Site signifies your agreement to adhere to these Terms. In cases of disagreement, we advise against the usage of the Site. Upholding the confidentiality of all our clients and potential clients is a top priority, and we are committed to safeguarding the personal information we are entrusted with. This document aims to provide a clear understanding of our practices regarding your personal data usage and protection, including detailing your entitlements.

By accessing or using the Service, you are consenting to the collection, use, and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service.

Data Protection Legislative Framework

The legislative framework encompassing Data Protection includes the General Data Protection Regulation ((EU) 2016/679), along with any national laws, regulations, and secondary legislation in Malta as amended or updated periodically, until the General Data Protection Regulation ceases to be directly applicable therein, followed by any subsequent law to GDPR or the Data Protection Act (Ch. 586 of the Laws of Malta).

Contact Information

Should you need to reach out, our detailed contact information is as follows:

Data Collection Specifics

Personal Information Gathering: We may accumulate personal information from you owing to legal obligations or with your explicit consent for specific objectives. The type of information you might impart to us during our interaction ranges widely, including:

  • Identity Information: Details like names, dates of birth, gender, identification numbers, or passport numbers, particularly when making a reservation or communicating via the Site or email. It may involve your name, email address, telephone number, and other relevant contact information.
  • Contact Information: Details such as billing addresses, email addresses, and telephone numbers are gathered, along with emergency contact details, encompassing names, relationships, and residential and contact numbers.
  • Health Information: Includes your general practitioner’s contact details and any medical, physical, or mental conditions, especially concerning your care requirements.
  • Lifestyle Information: Relating to your preferences, dislikes, and likes as they pertain to providing support (which comprise your spiritual convictions or other analogous ideologies, heritage or ethnic background, medical status, and sexual identity to the extent that these are relevant to delivering appropriate assistance to you).
  • Feedback: Including contributions to surveys and questionnaires about our service, as well as any complaints, compliments, or concerns about the service we offer.
  • Marketing and Communications Preferences: Involving your preferences in receiving marketing from us and your communication preferences.
  • Automated Information Collection: As you navigate the Site, information about your device and interactions with the Site, such as your IP address, browser type, and device type may be gathered. We may use cookies and other tracking technologies to collect this data.
  • Information from Third Parties: We might receive information about you from third parties, like social media platforms, if you have allowed them to share your information with us.

Methods of Providing Information: You might provide us with information through various methods, including completing a form, sending an email, or during telephone conversations or messages, requesting a quotation for a service, during assessment meetings, while receiving our service, and when visiting our offices.

In instances where you fail to provide necessary personal data, which we require by law or under contract terms, we may be unable to fulfil our contractual obligations. In such cases, we might have to cancel a service you have with us, and we will inform you if this is the case at the time.

Usage of Personal Data

We will use your personal data in a lawful manner. Commonly, we use personal data in the following scenarios to fulfil contracts we are about to enter into or have already entered into with you, when necessary for our legitimate interests or those of a third party, provided your interests and fundamental rights do not override those interests, and to comply with legal or regulatory obligations.

Data Minimization and Limitation: We are committed to ensuring that the data collected is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. We will not retain personal data longer than necessary and ensure that personal data is securely disposed of when no longer needed.

International Data Transfers: Currently, we do not transfer your personal data outside the European Economic Area. If in the future we need to transfer personal information outside the EEA, we will ensure that there are adequate protections in place as required by data protection laws, including standard contractual clauses, adequacy decisions or other appropriate safeguards.

Specificity in Third-Party Sharing: We may share your personal data with various parties, including third-party service providers such as website hosting and analytics providers who assist us in the operation of the Site and services. We will ensure that all third parties are bound by contractual obligations to process the personal data provided to them only for the provision of the specified services to us and subject to commitments relating to confidentiality and security.

Incident Response and Notification: In the event of a personal data breach, we will promptly investigate the matter and notify the competent data protection authorities and you as required by law. We will also take necessary measures to mitigate any harm and prevent future breaches.

Consent and Marketing Communications: Generally, we do not depend on consent as a legal basis for processing your personal data, except in relation to sending direct marketing communications via email, text message, or post. You have the right to withdraw your consent to marketing at any time by unsubscribing from our mailing list or contacting us at

Processing Purposes: We process your data for various purposes, including quoting and following up through assessment meetings for our services, providing services post your opt-in, preparing, reviewing, and updating a suitable therapy plan under a contract with us, describing the nature and level of therapy and support services you have requested, communicating with you, your representatives, and any relevant external social or healthcare professionals regarding your individual needs to personalise the service delivered to you, responding to changes in your care needs to ensure your and our employees’ safety, invoicing you for therapy and support services, conducting quality assurance procedures, service reviews, and customer experience improvements, notifying you about relevant service changes, monitoring the effectiveness of our services to ensure they meet your needs, and complying with legal requirements.

Marketing Considerations: We may use your Identity Data, Contact Data, Transaction, and Marketing and Communication Data to determine what services or offers might interest you. You will receive marketing communications from us if you have requested information from us or are receiving services from us, and in each case, you have consented to receive such information. You can withdraw consent to marketing anytime by unsubscribing from our mailing list or contacting us at

Data Use Modifications: We will use your personal data only for the purposes for which we collected it unless we need to use it for another purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis allowing us to do so. Note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Sharing Personal Data: We might need to share your personal data with various parties, including third-party service providers such as Google and payment providers based in the EU who provide website hosting and payment solutions, professional advisers including accountants, lawyers, bankers, auditors, and insurers based in the EU who offer consultancy, banking, legal, insurance, and accounting services, third parties involved in business transactions.

We mandate 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.

Data Security: We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Moreover, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Retention Periods: We retain your personal data only for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your Rights: You have several rights concerning your personal data including the right to be informed through this Privacy Notice. You can request access to the personal data we hold about you by contacting us at If you believe any personal data we hold about you is inaccurate or incomplete, you have the right to ask for corrections. Under certain circumstances, you may ask for your personal data to be deleted or for the processing of your data to be restricted. If you wish to transfer your personal data to another party, you can request data portability. You have the right to object to the processing of your personal data in certain situations. If you have given consent to the processing of your data, you can withdraw it at any time. Lastly, if you are unhappy with how we have used your personal data, you have the right to lodge a complaint with the local data protection authority.

Amendments to Privacy Policy: We may modify this Privacy Policy at any time without any prior notice to you and will post the revised Privacy Policy on the Service. The revised Policy will be effective 180 days from when the revised Policy is posted on the Service and your continued access or use of the Service after such time will constitute your acceptance of the revised Privacy Policy. We therefore recommend that you periodically review this page. We will notify data subjects of any changes through their preferred means of communication.