Privacy Notice
Wealth International Financial Planning – Privacy Policy
Wealth International Financial Planning (Mauritius) Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Wealth International Financial Planning (Mauritius) Limited collects and processes your personal data, including any data you may provide through our website, our client portal and when you purchase a product or service from us.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions, when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Wealth International Financial Planning (Mauritius) Limited is the controller and responsible for your personal data (collectively referred to as “Wealth Mauritius” "we", "us" or "our" in this privacy notice).
We have appointed a Data Protection Officer as required under the Data Protection Act 2017 of Mauritius, who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact the data privacy manager using the details set out below.
Contact details
Our full details are as follows:
Full name of legal entity: Wealth International Financial Planning (Mauritius) Limited
Name of Data Protection Officer: Mokshana Poorun
Email address: [email protected]
Postal address: Office B.1.3 (Corner Office), 1st Floor, Block B, Ruisseau Creole Complex La Mivoie 1909-07, Black River, Republic of Mauritius
Phone Number: (230) 460 0388/89
You have the right to make a complaint at any time to the Mauritius Data Protection Commissioner's Office, the Mauritian supervisory authority for data protection issues (www.dataprotection.govmu.org). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commissioner. So please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
What kind of personal data do we collect?
· names and contact information;
· general demographic information (such as gender, age, date of birth, marital status, nationality, employment details, residence, utility bills, etc.);
· Financial arrangements, savings, investments and financial protection plan details;
· personal identification documentation and related information such as passport numbers, national ID Card, driver’s licence and employee identification numbers;
· source of wealth;
· financial and payment data such as bank account numbers, bank statements and transaction information;
· tax residency; and
· information related to the provision of the services performed under the contract for services to our clients.
The list above is not exhaustive and Wealth Mauritius may also collect and process personal data to the extent that this is useful or necessary for the provision of our services.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Financial Planning Services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our products or services;
· create an account on our client portal;
· subscribe to our service or publications;
· request marketing to be sent to you;
· or give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below
Technical Data from the following parties:
· analytics providers such as Google based outside the EU and Mauritius;
· search information providers inside OR outside the EU or Mauritius.
· Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU or in Mauritius.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract of financial planning services we have entered into with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will always ask you to make certain decisions about your personal data use before proceeding to provide services
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside Wealth Mauritius for marketing purposes.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please 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.
Disclosures of your personal data
Wealth Mauritius may disclose or transfer personal data collected by Wealth Mauritius to other companies insofar as reasonably necessary for the purposes of our service offering, or for bona fide compliance purposes, as well as on the legal basis as set out in this Privacy Notice.
Except as described in this paragraph, Wealth Mauritius will not disclose, transfer or sell your personal data to any third party unless you have consented to this.
The following is a list of potential recipients of data (in each case including respective employees, directors and officers):
· Other providers of services (legal, governance or otherwise, including any bank or financial institution providing services in relation to any matter on which Wealth Mauritius is instructed) where disclosure to that provider of services is considered necessary to fulfil the purposes set out above;
· Any sub-contractors, agents or service providers of Wealth Mauritius;
· Courts or tribunals;
· Law enforcement agencies where considered necessary for Wealth Mauritius to fulfil legal obligations applicable to it;
· Regulators or other governmental or supervisory bodies with a legal right to the material or a legitimate interest in any material;
· Any registrar of a public register where the data is to be included in a public registry;
· Potential parties with whom Wealth Mauritius intends to merge or sell Wealth Mauritius; and
· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require 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.
International transfers
Many of our external third parties are based outside of Mauritius so their processing of your personal data will involve a transfer of data out of Mauritius.
Whenever we transfer your personal data out of Mauritius, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal in line with international data protection standards.
Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in Mauritius.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Mauritius.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, 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.
Data retention
How long will you use my personal data for?
We will only retain your personal data 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 for personal data, 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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
· [Request access to your personal data].
· [Request correction of your personal data].
· [Request erasure of your personal data].
· [Object to processing of your personal data].
· [Request restriction of processing your personal data].
· [Request transfer of your personal data].
· [Right to withdraw consent].
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
Service providers acting as processors based in The Channel Islands, The United Kingdom or The Republic of Ireland or Mauritius who provide IT, Web based operational and accounting systems, administrative support and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, compliance consultancy providers and insurers based The Channel Islands, The UK or The Republic of Ireland or Mauritius who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in The Channel Islands, The United Kingdom or The Republic of Ireland or Mauritius who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.