Privacy Policy

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Introduction

1.1 In this General Privacy Policy, ‘KGL’ refers to KASA GROUP LTD, and all the words and expressions used in this Privacy Notice shall be interpreted and construed in line with the definitions used in KGL’s General Data Protection Policy.

1.2 This General Privacy Policy should be read and interpreted in conjunction with and subject to KGL’s General Data Protection Policy that governs all the personal data processing activities of KGL.

1.3 This General Privacy Policy is relevant to all persons (‘data subjects’) whose personal data is collected by KGL in line with the requirements of the European General Data Protection Regulation 2016 (‘GDPR’) and the Mauritius Data Protection Act 2017 (‘DPA’).

1.4 Users of KGL’s website as well as KGL’s customers and potential customers are likely to be data subjects in as much as KGL may collect their personal information whether by automated or non-automated means.

Responsibilities

2.1 KGL is responsible for ensuring that this General Privacy Policy is made available to data subjects prior to KGL collecting/processing their personal data.

2.2 All Employees/Staff of KGL who interact with data subjects are responsible for ensuring that:

a. this General Privacy Policy is drawn to the data subject’s attention prior to processing the latter’s personal data; and

b. they obtain the consent of the data subjects prior to the processing of their data wherever consent is required under either the GDPR or the DPA.

Privacy Statement

3.1 Who is KGL and what does KGL do?

3.1.1 KGL is a private company duly registered and validly existing under the laws of Mauritius.

3.1.2 KGL has its registered office situated at 19 Poivre Street, Port-Louis, Republic of Mauritius and its administrative headquarters situated at the same address. KGL’s other contact details are as follows:

Telephone Number(s): +230 2027500

3.1.3 More information on KGL is contained in its General Data Protection Policy.

3.1.4 Although established, based and domiciled in Mauritius, KGL has expanded its business activities beyond the jurisdiction of Mauritius including but not limited to parts of the European Union.

3.1.5 In the light of paragraph

3.1.4 above, KGL is likely to process personal data both under the GDPR and the DPA.

3.1.6 The Board of Directors of KGL has appointed a Data Protection Officer in Mauritius whose identity and contact details are as follows:
Name: Aishah Dilmohamud
Postal address: 42, Edith Cavell Street, Port-Louis, Mauritius.
Email address: adilmohamud@kasa.mu
Telephone No.: 2027500

3.1.7 The personal data KGL is likely to collect from any user of the website, whether you are a customer or a potential customer, is nothing more than that the information that you wilfully provide during your client (customer) account creation process, including for instance your full name, address and at least a valid email address. Information that is automatically collected by the website is just your IP address, to the exclusion of any other information. You are hereby informed that the website is likely to automatically track cookies which you may block, in the case that you have not signed in to the website, by changing the related parameters in your Internet browser, as set out in our cookies policy.

3.1.8 The personal data KGL collects will be used to enable the good functioning of the website and to enable the marketing team to carry out analytics in order to provide a better service.

3.1.9 KGL’s legal basis for processing your personal data:

(a) If you are a user of our website:

➢ Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
➢ Processing is necessary for compliance with a legal obligation.
➢ the data subject has given consent.
➢ processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.

(b) If you are a customer or a potential customer of KGL:

3.1.10 In any event, KGL is committed to ensuring that the information it collects and use is appropriate for the purpose for which it was collected, and does not constitute an invasion of your privacy.

3.1.11 In terms of being contacted for marketing purposes KGL will contact you for additional consent.

3.1.12 KGL’s aim is not to be intrusive, and KGL undertakes not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.

Consent

3.2.1 By using KGL’s website (as a user of KGL’s website) you are giving KGL permission to process your personal data specifically for the purposes identified above.

3.2.2 By placing an order for goods and/or services with KGL (as a customer) or by requesting KGL to provide you a quote (or any further information) in respect of KGL’s goods and/or services (as a potential customer), you are giving KGL permission to process your personal data specifically for the purposes identified above

3.2.3 Subject to paragraph

3.2.7 below, further explicit and written consent will be requested from you for KGL to process any of your sensitive or special categories data.

3.2.4 Sensitive or special categories of personal data is information about racial origin, ethnic origin, political opinion, religious belief, philosophical belief, trade union membership, genetic data, biometric data, health data, criminal record, data concerning sex life and/or sexual orientation.

3.2.5 Where asking you for sensitive or special categories of personal data KGL will always tell you why and how the information will be used.

3.2.6 When you have been requested to and do submit written explicit consent, you may withdraw consent at any time by informing KGL and/or KGL’s Data Protection Officer in writing of your wish to withdraw your consent without having to assign any reason for your decision.

3.2.7 KGL may exceptionally process sensitive or special categories personal data without your consent if such processing is required by law and/or a Court order or where the information is already in the public domain.

Disclosure and transfer

3.3.1 KGL may pass your personal data on to third-party service providers contracted to KGL in the course of dealing with you. Any third parties that KGL may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on KGL’s behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with KGL’s procedures.

3.3.2 Basically, KGL will not pass on your personal data to third parties unless it has obtained your consent or such disclosure is necessary for the processing activities of KGL in furtherance of a contractual relationship to which you are privy as a customer or potential customer of KGL or from which you will be deriving a personal interest.

3.3.3 KGL will not transfer your personal data to a different country without having carried out an adequacy test as explained in KGL’s General Data Protection Policy and informed you about the adequacy of protection afforded to your personal data in that country.

Notification de violation

Whenever KGL is on notice that a breach of personal data has been committed or reasonably suspects that a breach of personal data is likely to be committed, KGL shall as soon as reasonably practicable inform the relevant supervisory authority about the same. You shall also be informed about the same where such a breach is likely to impact on your rights and freedoms as a data subject.

Retention Period

3.5.1 Subject to paragraph

3.5.2 below, KGL will process and store your personal data for no longer that is required for the purpose for which it is initially collected.

3.5.2 Not with standing paragraph

3.4.1 above, KGL may store your personal data for such period as may be necessary for KGL’s compliance with legal obligations and for KGL’s legitimate interests such as the defense by KGL of legal claims that may be brought before it

Your rights as a data subject

At any point while KGL is in possession of or processing your personal data, you, the data subject, have the following rights:

Right of access – you have the right to request a copy of the information that KGL holds about you.
Right of rectification – you have a right to correct data that KGL holds about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data KGL holds about you to be erased from its records.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data KGL holds about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review: in the event that KGL refuses your request under rights of access, KGL will provide you with a reason as to why. You have the right to complain as outlined in clause 3.7 below.

Complaints

3.7.1 In the event that you wish to make a complaint about how your personal data is being processed by KGL, or how your requests under clause 3.6 above have been handled, you have the right to lodge a complaint directly with the relevant supervisory authority and KGL’s Data Protection Officer.

3.7.2
The supervisory authority in Mauritius is the Data Commissioner of the Mauritius Data Protection Office whose contact details are as follows:
Postal address: Data Protection Office.
5th Floor, SICOM Tower,
Ebene, Mauritius.
Telephone number(s): +230 460-0253/+230 460-0251
Email address: dpo@govmu.org

What does KGL hold about you?

3.8.1 At any point in time, you can find out the personal data that the organisation holds about you, if any.

3.8.2 Upon a written request being received, KGL can confirm what information it holds about you and how it is processed.
3.8.3 If KGL does hold personal data about you, you can request the following information:

Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the European Union.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of KGL or a third party, information about those interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
If KGL intends to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. Please note that the European Union has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, KGL will ensure there are specific measures in place to secure your information by carrying out an adequacy test as explained in KGL’s General Data Protection Policy.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the relevant supervisory authority
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

When making a written request to KGL pursuant to this clause 3.8, you will need to provide to KGL an appropriate form of ID in order to access to the information set out at paragraph

3.8.3 above. An appropriate form of ID is either you National Identity Card or your passport (provided the same has not expired).

Document Owner and Authorisation

KASA GROUP LTD is the owner of this document.
This document and all other related documents referred to herein may, from time to time, be reviewed in line with any changes in the law.
This General Data Protection Privacy Policy as well as all the other documents referred to herein have been duly approved by the Board of Directors of KGL 18 October 2024.
By order of the Board of Directors of KGL.
Made in good faith on 18 October 2024 at 42, Edith Cavell Street, Port-Louis, Republic of Mauritius.