WEBSITE PRIVACY POLICY
  

1. PURPOSE OF THIS POLICY 
   
   

Mont Choisy Smart City Ltd (the “Company” or “we”) is registered with the Data Protection Commissioner (the “Commissioner”) as Controller. The Company is the Controller of your personal data and is responsible for it. The Company respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This website is not intended for children of less than 16 years old and we do not knowingly collect data relating to children.

2. QUERIES AND COMPLAINTS
   
   

If you have any questions about this privacy policy and our privacy practices, including any requests to exercise your legal rights (refer to Section 12 below), please contact our Data Protection Officer by email at lareserve@montchoisy.com or telephone +230 269 4242.

The Company’s address is CheminVingtPieds, 30527, Grand Baie, Mauritius.

You have the right to make a complaint relating to the handling by us of your personal data at any time to the Commissioner, the supervisory authority for data protection issues. We would, however, appreciate to be given the opportunity to deal with your concerns before you approach the Commissioner - so please contact us in the first instance.

3. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES 
    

It is important that the personal data we hold about you is accurate and current. It is your responsibility to inform us promptly of any change in your personal data. We may amend this privacy policy. This privacy policy was last updated on the 30^th of November 2019.
 

4. 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 as follows:

• Identity Data includes first name and last name.
• Contact Data includes physical address, email address and telephone numbers.
• Financial Data includes information relating to your bank account and payment card details.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

5. 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 concluded or are trying to conclude with you. In this case, we may have to cancel our contract and we shall not be liable to you in respect of this cancellation.

6. 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.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
  
  

7. 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 we are about to enter into or 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 obligation.

See Section 8 below to find out more about the types of lawful basis that we will rely on to process your personal data. 

8. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  
   
   

We have set out below, in a table format, a description of all the ways we plan to use your personal data, the legal bases which we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity	Type of Data	Lawful basis for processing
To register you as a customer	Identity Contact Details	Performance of a contract with you
To process and deliver the services	Identity Contact Details Financial Information	Performance of a contract with you Necessary for our legitimate interests (recover debts due to us)
To manage our relationship with you, which will include: (a) Notifying you about changes to our terms or privacy policy (b) To administer and protect our business and this website	Identity Contact Details Technical Information	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Details Technical Information	Necessary for our legitimate interests (for running our business, provision of administration and IT services) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you	Identity Contact Details Technical Information Marketing	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests
To make suggestions and recommendations to you about products that may be of interest to you	Identity Contact Details Technical Information Profile Marketing	Necessary for our legitimate interests (to develop our services and grow our business)

 

9. MARKETING
   
   

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have opted in to receiving that marketing. You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time. Where you request us to stop sending your marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

10. DISCLOSURES OF YOUR PERSONAL DATA
      

We may share your personal data with the parties set out below for the purposes set out in the table at Section 8 above.

• Internal third parties, namely other companies in the Company Group acting as joint controllers or processors and who are based in Mauritius and provide support services to us.
• External third parties, namely (i) service providers based in Mauritius acting as processors who provide IT and system administration services, (ii) professional advisers based in Mauritius acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, and (iii) the Mauritius Revenue Authority, regulators and other authorities based in Mauritius acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
• 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 policy.

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.

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.

11. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  
    
    

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.  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, regulatory, tax, accounting or other requirements. In some circumstances we may anonymise your personal data (so that it 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.

12. YOUR LEGAL RIGHTS  
    
    

Under certain circumstances, you have rights under data protection laws in relation to your personal data which includes:

• Access to your personal data: this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Correction of your personal data: 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 we will notify you of, 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 (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) 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; (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
• Right to withdraw consent: 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.
  
  

13. 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 could refuse to comply with your request in these circumstances.

14. 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. 

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