Evaco Ltd, Business Registration Number C06040742, located at Rivière Citron, 20101 Arsenal, Mauritius operates most of the Group’s email and IT infrastructure.
Evaco Ltd is the holding company of the Evaco Group, a diversified group which operates through various subsidiaries, including:
The relevant subsidiary that you contact will be responsible for compliance with this policy in relation to the personal information that you provide to that subsidiary.
For ease of reference, the relevant subsidiary and/or the Group is referred to as ‘Evaco Group’,
‘Company’, ‘we’ or ‘us’, as the context dictates.
At Evaco Group, we take your privacy seriously. We have taken the steps necessary to ensure that we are compliant with the requirements of the Data Protection Act 2017 (Mauritius) (‘DPA’) and, when applicable, the General Data Protection Regulation (EU) 2016/679 (‘GDPR’).
1. How we collect your personal data
2. The personal data that we collect about you
3. Use of your personal data
4. Our legal grounds for using your personal data
5. Storage of your personal data
6. Sharing of your personal data
7. Transfer of personal data outside Mauritius
8. Your rights
10. Other websites
13. How to contact us
We may collect your personal data:
· when you register on our website, submit a query to us, request the provision of goods or services, sign a contract with us, subscribe to our newsletter, respond to a survey, undertake a transaction and/or fill out a form on the website; or
· when you engage with us, email us or provide personal data to us in any other manner.
Depending on the purpose for which you provide your personal data to us, we may be required by law to seek further personal information about you, including for the purposes of anti-money laundering and anti-terrorism financing.
The type of personal data that we collect and process on you may include (without limitation):
· information such as your name, title or position, your gender and relationship to a person;
· contact information, including email address and phone numbers;
· technical information such as your IP address and information from your visits to our websites;
· financial information such as bank account details or credit card details;
· your interests and preferences;
· information you provide to us for the purposes of attending meetings and events, including access and dietary requirements;
· details of your visits to our offices;
· other information relating to the products and services you are interested in and have sought from us; and
· information obtained as part of a due diligence including from our anti-money laundering and anti- terrorism financing enquiries that we are required to undertake, which may include your credit rating, convictions of fraud and other offences, and whether you are a politically exposed person.
If you are under 16 please do not provide us with any of your information unless you have the permission of your parent or guardian.
The most common purposes for which we will use your personal data are:
· to respond to your enquiries;
· to provide a product or service to you, including for after sales service and support;
· to comply with our legal obligations, which may require us to provide your information to law enforcement agencies, regulators or courts of law;
· to understand the products or services that you are interested in and that you may have already acquired from us;
· to undertake anti-money laundering and anti-terrorism financing enquiries where it is necessary for us to do so as part of an acquisition or proposed acquisition by you of our products or services;
· to refer you to our trusted partners (for example banks) if you ask us to do so, or if this is necessary in order for us to comply with our obligations to you following your acquisition or proposed acquisition of one of our products or services;
· for general business administration purposes; and
· for quality assurance purposes and to improve our products and services. Before any such use is undertaken your information will be de-personalised so that it cannot be directly linked back to you, or your express consent will be sought.
We may also want to keep in touch with you and use your personal data for other purposes, in which case we will ask your consent to do so, unless we already have the right to do so due to the application of some other legal basis. The other purposes for which we may ask you to provide your consent include (without limitation):
· to improve our website, response and services, including by personalising the information and offers we present to you;
· to implement a survey or seek feedback; and
· to send to you our latest offers and promotions in relation to the products and services offered by Evaco Group, including all its subsidiaries (Marketing Material).
If you have agreed to receive Marketing Material, you may always opt out at a later date.
We do not sell any personal data collected by us, and no disclosure of your personal data will be made to any third-party organisation or authorities unless the procedures imposed by law have been followed, or if we are required to do so by law.
In some circumstances, we may anonymise your personal data by pseudonymisation or encryption, such that the personal data can no longer be associated with you, for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Depending on which of the above purposes for which your personal data is used, it will be processed on one or more of the following legal grounds:
· The processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
· The processing is necessary to comply with a legal obligation to which we are subject; or
· The processing is necessary for the purposes of our legitimate interests or those of any third party that receives your personal information, except where these are overridden by your interests or fundamental rights and freedoms.
The only exception to the above is the sending of marketing materials, which we will only do with your consent, as specified above.
We have implemented a variety of security measures to maintain the safety of your personal data, including the use of firewalls and anti-virus protection, and we will endeavour to ensure that these measures remain adequate.
Depending on the purpose for which we hold your personal data and the requirements imposed by law, your personal data will be held for a certain period, after which it will be deleted.
The legal prescription period in Mauritius (i.e. the period during which one party may sue another after the happening of an event) depends on the nature of the relationship and goes to a maximum period of 10 years for some immovable property related matters. Depending on the nature of our relationship with you, we may, in this context, also choose to keep your personal data for at least the relevant legal prescription period in order to be able to defend or enforce our rights.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information that is transferred from you or to you via the internet.
We may disclose your persona data to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf.
Such third parties may include cloud services providers (such as hosting and email management), or other third parties who provide services to us. These include but are not limited to IT service providers, solicitors, banks, auditors and any agents acting on your behalf.
When we use third party service providers, we will retain control over, and we will remain fully responsible for your personal data and we will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers.
Your personal data may be shared with and used by other Evaco Group companies which may have products or services that are suitable for you.
We may also share your personal information with law enforcement and regulatory agencies.
We may engage service providers to provide back-ups and hosting services, who may be located overseas.
In these cases, we take steps to ensure that the transfer of your personal data is safeguarded and that your privacy rights are respected.
You have certain rights granted to you by law. The rights are outlined below:
The right to access – you have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – you have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – you have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – you have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – you have the right to object to us processing of your personal data, under certain conditions.
The right to data portability – you have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we will respond to you within one month. If you would like to exercise any of these rights, please contact our Data Protection Officer whose details appear at the bottom of this policy.
If used, the cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our website and the services that we provide to you.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
Our website may contain links to third party websites for your convenience.
We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party websites, or the parties that control these websites.
Data Protection Officer Evaco Group
Rivière Citron 20101 Arsenal Mauritius