DATA PROTECTION NOTICE
Purpose
In our dealings with you, we, Mon Tresor Smart City Management Ltd , (hereinafter referred to as “we” or “our” or “us’’) are called upon to process the personal data of your legal representatives and/or authorised signatories (hereinafter referred to as “personal data” or “your personal data”). The purpose of this Data Protection Notice is to explain:
1. Who we are and how we may be contacted;
2. The types of personal data we collect;
3. The purpose for which we collect your personal data and the lawful basis for such collection;
4. The intended recipients of the personal data;
5. Whether the supply of personal data is voluntary or mandatory;
6. Your rights relating to your personal data being processed by us;
7. The period for which we will store your personal data;
8. Whether, and in what circumstances, we may transfer your personal information to another country, and the safeguards we have put in place in relation to such transfer; and
9. How we conduct direct marketing.
Application
This Data Protection Notice applies to any processing of your personal information by us, whether such information is provided to us by email, through the filling of forms, through the exchange of contractual documents, by letter or fax, verbally, or through any other means.
By entering into a business relationship with us, or by providing your personal data to us, you confirm that you are agreeable to the processing of your personal data in accordance with the terms of this Data Protection Notice.
1. Who we are and how we may be contacted
Details about us and how we may be contacted are set out in the table found in the Schedule to this Data Protection Notice (the “Information Table”).
2. The types of personal data we collect
The types of personal data we collect are set out in the Information Table.
While we have attempted to make the list as exhaustive as possible, there is a possibility we may have omitted come types due to the complexity of our organisation and the intricacies of our operations.
We encourage you to get in touch with our Data Protection Officer if you find that any of your personal data which we collect is not listed in this Data Protection Notice. We will then endeavour to promptly amend this Data Protection Notice accordingly.
3. The purpose for which we collect personal data and the lawful basis for such collection
3.1. Purpose
We collect personal data for a number of purposes, including:
(a) to perform the contractual relationship we have with you;
(b) to keep a database of clients and potential clients to communicate advertising and marketing materials
(c) to comply with our legal obligations towards authorities, including the Mauritius Revenue Authority, the Registrar of Companies and the regulators;
(d) to generate statistics and reports on different aspects of our business; and
(e) for such other purposes as may be related, directly or indirectly, to our business activities.
3.2. Lawful basis
The law (a) provides that we cannot process personal data unless we have a lawful basis for such processing; and (b) lists a number of lawful bases for the processing of data.
The lawful bases which apply to our processing of your personal data are as follows:
(a) for the performance of a contract to which you are a party or in order to take steps at your request before entering into a contract with you; and/or
(b) for compliance with any legal obligation to which we are subject.
4. The intended recipients of the personal data
In connection with our business relationship with you, we may have to disclose your personal information to our collaborators, including our employees, consultants, advisors, directors.
However, we may also be required to disclose your personal data to third parties to comply with our legal obligations. Such third parties may include the Registrar of Companies, the Mauritius Revenue Authority, and any other government authorities.
As you are aware, we form part of the Omnicane Group. In this context, we may, from time to time, disclose your personal information to other companies forming part of the Omnicane Group (a list of such companies is set out at Annex B). The objective of this disclosure is to develop a centralised database of clients, which would help the Omnicane Group better identify your needs and provide tailor-made packages and services to you. If you do not wish that your personal data be communicated to other companies within the Omnicane Group, we encourage you to notify our Data Protection Officer as soon as possible.
5. Whether the supply of personal data is voluntary or mandatory
The provision of personal data is of course entirely voluntary. You are free to choose whether to provide your personal data to us or not. Please note however that if you choose not to provide your personal data to us, we may not be able to provide certain services to you or enter into a contractual relationship with you.
6. Your rights relating to your personal data being processed by us
The law confers upon you a number of rights relating to the personal data being processed by us. These rights are set out below. If you wish to exercise any of the said rights, we encourage you to contact our Data Protection Officer.
6.1. Right to withdraw consent at any time
Where we process your personal data on the basis of your consent, you may withdraw such consent at any time. The withdrawal of your consent will not affect the lawfulness of any processing done by us prior to such withdrawal.
Please note that withdrawing your consent may result in us not being able to provide certain services to you or enter into a contractual relationship with you.
6.2. Right of access
You may request a copy of the personal data we hold about you. Kindly ensure that such request is made in writing to our Data Protection Officer.
Please note that if, in our opinion, your request is manifestly excessive, we may either not attend to your request or charge a fee for attending to same.
6.3. Rectification, erasure or restriction of processing
You may also, at any time, request:
(a) to have any inaccurate personal data we hold on you corrected. This includes the right to supplement and/or update existing personal data provided to us;
(b) that we erase any personal data we hold on you where (i) such data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (ii) you have withdrawn your consent to us holding and processing such data and there are no overriding legitimate grounds for the continued processing; or (iii) your personal data has been unlawfully processed.
You will understand that this right is not absolute and that it will not be applicable where the exceptions provided for by law apply, including where our processing of your personal data is necessary for the purpose of historical, statistical or scientific research or for compliance with a legal obligation or for the establishment, exercise or defence of a legal claim;
(c) us to restrict processing of your personal data where (i) the accuracy of your personal data is contested by you. This restriction will apply for such period as may be necessary to enable us to verify the accuracy of the data; (ii) we no longer need the personal data for the purpose of processing; (iii) you deem the processing of your personal data to be unlawful, but do not wish us to erase it; or (iv) you have objected to the processing of your data. Such restriction will apply pending verification as to our legitimate grounds to keep processing the personal data, despite your objection.
6.4. Right to object
You have the right to object to our processing of your personal data at any time. Upon receiving such objection, we will stop processing your personal data, except where there are compelling legitimate grounds to continue such processing;
6.5. Right to lodge a complaint
If you feel that we have not processed your personal data lawfully, please do feel free to contact us through our Data Protection Officer.
If you remain unsatisfied, you may lodge a complaint with the Data Protection Commissioner in Mauritius. Her contact details are as follows:
Address: 5th Floor, SICOM Tower, Wall Street, Ebène
Email address: dpo@govmu.org
Phone number: + (230) 460-0253
Fax: + (230) 489-7346
7. The period for which we will store your personal data
The law provides that where the purpose for keeping any personal data has lapsed, we should destroy the data as soon as reasonably practicable.
We will keep storing your data for as long as is necessary:
(a) for us to fulfil the purposes we collected it for;
(b) for the performance of any contract which may exist between us;
(c) for us to share with you the latest news regarding our organisation and our services;
(d) for us to satisfy any legal requirement, including statutory reporting obligations;
(e) for us to defend or enforce our rights.
8. Whether, and in what circumstances, we may transfer your personal information to another country, and the safeguards we have put in place in relation to such transfer
Please refer to the Information Table.
9. How we conduct direct marketing
You may from time to time receive communication of advertising or marketing material from us if you have given your consent to receive such communication.
You have the right, at any time, to object to the processing of your personal data for direct marketing purposes. Where we receive such an objection from you, we will stop processing your data for direct marketing purposes.
Queries
If you have any queries on this Data Protection Notice, we encourage you to get in touch with us through our Data Protection Officer.
Schedule
Information Table
| Who we are | [*] Mon Tresor Smart City Management Ltd |
| Our contact details |
Address: [*] Omnicane House Mon Trésor Business Gateway New Airport Access Road Plaine Magnien 51521, Mauritius Telephone number: [*] 6600600 Fax number: [*] N/A Email address: [*] info@montresor.mu |
| Our Data Protection Officer |
Group Compliance Manager dataprotection@omnicane.com |
| The categories of personal data we collect (including the special categories of personal data) | Please refer to Annex A below. |
| Our services | Please refer to Annex B below for the list of our entities and their corresponding activities. |
| Transfer of personal data to another country | We endeavour to ensure that whenever we transfer personal data to other countries, the recipients of such personal data comply with all applicable data protection laws and principles. |
Annex A: Types of Personal Data we hold on you
Categories of personal data
Identity
Examples
- First name
- Maiden name
- Last name
- Username or similar identifier
- Job title
- Date of birth
- Gender
- Signature
Contact details
- Email Address
- Telephone numbers
- Fax numbers
- Address