DATA PROTECTION NOTICE
We, Mon Trésor Smart City Management Ltd, bearing Business Registration Number C15133802 and having our registered address at Mon Trésor Business Gateway, 1st floor Omnicane House, New Airport Access Road, Plaine Magnien 51521, Rep. of Mauritius (“our physical address”), have updated our Data Privacy Notice (the “Notice”) so that it is in line with the Data Protection Act 2017 (the “Act”), which came into effect on 15 January 2018.
Please read this Notice carefully as it contains important information relating to your personal data (as defined below), such as what personal data we hold on you, what we do with your personal data and what are your rights as a data subject (as defined below).
Mon Trésor Smart City Management Ltd may be referred to in this Policy as “we” or “us”.
1. SCOPE AND HOW WE OBTAIN YOUR PERSONAL DATA
We will be collecting and processing your personal data for the purposes of providing the requested service to you.
We may collect your personal data:
- when you or your organisation contact us and/or retain our services;
- when you browse or interact with our websites(s) or use any of our online services (if any);
- when you email us or provide personal data to us in any other circumstances.
2. TYPES OF PERSONAL DATA WE COLLECT AND PROCESS
The personal data that we collect and process (as defined below) on you may include:
- Basic information, such as your name, your title or position, your gender and your relationship to a person;
- Contact information, such as your physical address, email address and phone number(s);
- Financial information, such as bank account details;
- Technical information (including your IP address), such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically;
- Information you provide to us for the purposes of attending meetings and events, including access and dietary requirements;
- Identification and background information provided by you or collected by us as part of our business acceptance processes;
- Your photos and video footage;
- Details of your visits to our offices; and
- Any other information relating to you which you may provide to us.
3. USE OF YOUR PERSONAL DATA
We take your privacy very seriously. We use the personal data that you provide to us for the purpose of the performance of a contract which we have with you for the provision of our products and services and to abide by legal obligations.
Should there be any other purpose for which your personal data is being processed other than for the performance of a contract, your consent (as defined below) shall be sought.
Should we make use of automated decision making, including profiling, we will let you know of the logic involved, as well as the significance and the envisaged consequences of such processing for you.
4. YOUR RIGHTS AS DATA SUBJECT
You have certain rights in respect of your personal data which are as follows:
- To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data, free of charge.
- To rectify: where you consider that your personal is inaccurate or incomplete, you can require that such personal data be modified accordingly.
- To erase: you can require the deletion of your personal data, to the extent permitted by law.
- To restrict: you can request the restriction of the processing of your personal data.
- To object: you can object to the processing of your personal data, on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
- To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal
If you require further information, or if you wish to exercise the rights listed above, please send a letter or an email to the address set out at Paragraph 11 below. Please include a scan/ copy of your identity card for identification purposes.
In accordance with the Act, in addition to your rights listed above, you are also entitled to lodge a complaint with the Data Protection Commissioner should you be of the view that we have committed a breach of the Act.
For the performance of the contract we have with you and for any other purposes for which we are processing your personal data, we may need to disclose your personal data (which may include special categories of data) to such regulatory authorities as required by law or to our service providers, which include, inter alia, companies offering services on our behalf.
6. TRANSFER OF YOUR PERSONAL DATA
We may need to transfer your information to countries outside Mauritius in order to provide our services to you. You will be informed should your personal data need to be transferred overseas. We will also inform you of the level of suitable protection afforded to your personal data by that country.
7. KEEPING YOUR PERSONAL DATA SECURE
Where we share or transfer your personal data, we will do this in accordance with the Act. We will take appropriate technical and organisational measures against unauthorised or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data in accordance with our internal security procedures covering its storage, access and destruction. Personal data may be stored on our own technology systems or those of our vendors or in paper files.
8. STORAGE LIMITATION
We retain your personal data for the longer of: (i) the period required by applicable law; or (ii) such other period necessary for us to meet our operational obligations, such as: proper account maintenance, facilitating client relationship management, and responding to legal claims or regulatory requests. Most personal data collected in relation to a specified client is kept for the duration of the contractual relationship with such client plus a specified number of years after the end of the contractual relationship or as otherwise required by applicable law.
We reserve the right to amend this Notice from time to time to reflect changing legal requirements or our processing practices.
11. HOW TO CONTACT US
If you have any questions relating to our use of your personal data under this Notice, please contact our Data Protection Officer on the following email address firstname.lastname@example.org or at our physical address.
“Consent” means any freely given specific, informed and unambiguous indication of the wishes of a data subject, either by a statement or a clear affirmative action, by which he signifies his agreement to personal data relating to him being processed;
“Data Subject” means an identified or identifiable individual, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
“Personal Data” means any information relating to a data subject. It covers all personal data in any form, including but not limited to electronic data, paper documents and disks.
“Processing ” means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
“Special categories of personal data”, in relation to a data subject, means personal data pertaining to –
(a) his racial or ethnic origin;
(b) his political opinion or adherence;
(c) his religious or philosophical beliefs;
(d) his membership of a trade union;
(e) his physical or mental health or condition;
(f) his sexual orientation, practices or preferences;
(g) his genetic data or biometric data uniquely identifying him;
(h) the commission or alleged commission of an offence by him;
(i) any proceedings for an offence committed or alleged to have been committed by him, the disposal of such proceedings or the sentence of any Court in the proceedings; or
(j) such other personal data as the Commissioner may determine to be sensitive personal data;
“Processing” means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.