Our website privacy policy considers all the data you should legally be cognizant about relating to your personal information and to the use of our website.

Background and Scope

This website is operated by Sunibel Corporate Services Ltd (“Sunibel Corporate Services” or “we” or “us”), Company duly incorporated under the Laws of Mauritius. Please see the ‘Presentation’ section on our website for more information about the Company.

Sunibel Corporate Services Ltd is a registered Data Controller and / or Data Processor with the Data Protection Office in Mauritius.

 

Mission and Vision Statement

Mission: Sunibel Corporate Services Ltd is committed to foster an environment of trust, safeguarding personal data with the utmost confidentiality, and exceeding industry standards through continuous improvement.

Vision: We envision a world where trust is paramount. Data privacy is not just an obligation, but the cornerstone of our commitment to stakeholders. We strive to set the gold standard in protecting data, ensuring every individual’s information is protected to the highest level of integrity.

Key Commitments:

  • Implement rigorous data protection measures that surpass industry standards.
  • Educate our team and partners on the importance of privacy and equip them with the necessary tools and knowledge.
  • Engage transparently with our stakeholders, keeping them informed about the way their information is used and protected.
  • Continuously evaluate and innovate our privacy practices in response to evolving and emerging challenges and technologies.

Sunibel Corporate Services Ltd takes privacy and the protection of personal data very seriously. We have implemented relevant policies, processes and procedures, including this privacy policy (hereinafter referred to as “Privacy Policy”) to explain how we collect, use and disclose personal data (as applicable) as required by prevailing legislations, or for performing our contractual obligations, responsibilities and/or operating our business.

 

Definition

Please find below some terms and expressions as used in this Privacy Policy. These shall be interpreted in accordance with prevailing Data Protection Legislations, including but not limited to the Mauritius Data Protection Act 2017 and the General Data Protection Regulation 2016/679, as applicable.

“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;

“Restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future;

“Special Categories of Personal Data” means personal data pertaining to:

  1. his racial or ethnic origin;
  2. his political opinion or adherence;
  3. his religious or philosophical beliefs;
  4. his membership of a trade union;
  5. his physical or mental health or condition;
  6. his sexual orientation, practices or preferences;
  7. his genetic data or biometric data uniquely identifying him;
  8. the commission or alleged commission of an offence by him;
  9. 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
  10. such other personal data as the Commissioner may determine to be sensitive personal data;

“Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

“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;

“Processor” means a person who, or public body which, processes personal data on behalf of a controller;

“Third party” means a person or public body other than a data subject, a controller, a processor or a person who, under the direct authority of a controller or processor, who or which is authorised to process personal data.

 

Our website

This Privacy Policy also relates to the use of our website, and will apply to the personal data that we collect and process about you while you are browsing same.

Note that there may be links to third party websites on our website (example Facebook, LinkedIn or YouTube). We do not have any control and accept no responsibility regarding the manner into which third party websites are operated, collect or process personal data. For privacy information relating to these other third-party websites, we recommend that you consult their relevant privacy policies, as appropriate.

You may also consult our Cookie policy for more information.

 

Collection and use of your personal information

Hereunder is a list of personal data, which may include but is not limited to information relating to the collection and storage by our entity identification details (name, contact details, national identity number);

  • email address;
  • phone number:
  • physical address;
  • bank account number
  • tax account number
  • business registration number
  • professional details;
  • Nationality;
  • Country of residence;
  • Information provided by yourself for recruitment purposes;
  • Details regarding feedbacks on our services or courses
  • Technical details, including the Internet Protocol (IP) address used to browse our website, frequency of visits, or other similar details (see our Cookies Policy for more information)

Note that:

  1. We may also collect personal data classified as Special Categories of Personal Data. This information will be solely used to cater for your specific dietary requirements during tea break or lunch for training courses;
  2. Our website is not intended for use by Children [under the age of 16] and we do not knowingly collect or use personal information of children.

 

Purpose of processing

The purposes for which Sunibel Corporate Services Ltd collects and processes your personal data include, but are not limited to:

  • For the performance of a contractual / pre-contractual agreement;
  • To abide by legal obligations imposed on us;
  • Recruitment purposes;
  • Collecting feedbacks and appreciations on our services;
  • For the enhancement of our services and your browsing experience.

 

Legal basis for Processing

For the processing of personal information, we are required to have a legal basis to rely on, which may vary depending on what information we process and why. The legal bases we may rely on include:

  • Consent
    This is where you have expressly provided us with a clear consent for us to process your personal information for a specific purpose.
  • Contract
    This is where the processing of your personal information is necessary for the performance of a contractual obligation between us, or because you requested us to take specific steps towards entering into a contract.
  • Legal Obligations
    This is where we are legally obliged to process your personal information, in accordance with prevailing Laws.
  • Legitimate Interest
    This is where we process your personal information for our legitimate interest.

 

With whom is your personal data being shared?

Your information may be shared with employees who have a legitimate need to access your data in necessity to process information relevant to their job functions and within their supervisory authority.

In certain situations, we may share your personal data with third-party service providers who assist us in performing our business functions. These service providers are contractually obligated to protect your data and use it only for the specific purposes we have authorised purposes via a carefully defined Service Level Agreement (SLA) and in accordance with our instructions.

For compliance to a legal obligation or performance of a contract, we may provide personal data to:

  • Regulatory bodies;
  • Other entities of the Group PROBUS PLEION Holding S.A.;
  • Services providers (including auditors);
  • Other third parties upon request or consent.

All information provided to us is strictly confidential and shall not be publicly disclosed to any person or party whatsoever unless we are legally required to do so to a regulatory body or a court of jurisdiction in Mauritius.

In certain circumstances, the Data Protection Act 2017 allows personal data to be shared among public sector agencies without the consent of the data subject.

 

Transfer of personal data outside Mauritius

Your personal data may be transferred outside Mauritius for storage purposes, or if same is necessary for the performance of a contract we have with you. Note however that in case of transfer of your personal data outside Mauritius (if applicable), we ensure that all appropriate safeguards are in place to cater for appropriate security of the data, and relevant steps are taken in accordance with provisions of the Law.

 

Cookies and similar technologies

Cookies are text files placed on the computer to collect standard internet log information and visitor behaviour information. When our websites are visited, we may collect your information automatically through cookies. We use cookies in a range of ways to improve your experience on our website.

Your browser can be configured not to accept cookies and our website shall tell you how to remove cookies from your browser. Refer to our cookie policy.

 

Marketing

We would like to send you information about our products and services that we think would be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, or telephone, as the case requires.

We will only ask whether you would like us to send you marketing messages when you tick the relevant boxes/fill in the relevant consent form when either you register/attend our training courses, or we enter into an agreement with you for the delivery of services. If you have previously agreed to being contacted this way, you can unsubscribe at any time by:

  • Contacting us at info@pleion.mu
  • Using the unsubscribe link in emails

You may also contact us on the above email address if you wish to update your marketing preferences, that is choose what marketing messages, about which specific services or products you would be interested to receive. Note that the change in preferences may take up to 5 working days to take place. For more information on your rights with regards to marketing, please see “Your Rights” below.

We store your name and email address for purposes of delivering email updates and newsletters when you explicitly subscribe to this service. We use and share these information with a third party, MailChimp, for delivery of such communications. MailChimp is a newsletter distribution platform run by the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA, for the distribution of our newsletters. Users can access the following link to view the data protection rules of the email service provider: https://mailchimp.com/legal/. The Rocket Science Group LLC d/b/a MailChimp is certified under the EU-US Privacy Shield and therefore provides a guarantee to comply with EU data protection legislation (https://www.privacyshield.gov/ps/participant?id=a2zt0000000TXVKAA4&status=Active).

MailChimp may also collect your information through third parties. Mail uses beacons and other tracking technologies to collect personal data during email campaigns.

Once given, your consent will be ongoing. You can withdraw your consent at any time by clicking on the “unsubscribe” link in the footer of all our emails, and we will remove your data from our database.

 

Your Rights

Data subjects have specific rights under the Mauritius DPA and the European General Data Protection Regulation (GDPR). In summary, those include:

  • Right of Access

You have the right request a confirmation from us as to whether or not we process your personal data and forward you a copy of same. You also have the right to certain other supplementary information that this Privacy Policy is already designed to address.

  • Right to Rectification

You have the right to have your incomplete personal data completed.

  • Right to erasure

This provides for the right to have your data erased in case the processing of your personal data is not justified.

  • Right to restrict

You have the right to restrict the processing of your personal data.

  • Right to object

You have the right to object to the processing of your personal data.

  • Withdrawal of consent

You have the right to withdraw your consent at any point in time, if your consent was required for the processing of your personal data.

  • Right to Complaint

You have the right to lodge a complaint to the Mauritius Data Protection Office regarding the processing of your personal data by us.

  • Automated processing

You have the right not to be subject to a decision based solely on an automated processing of your personal data, including profiling, which produces legal effects on you.

  • Right to data portability

You have the right to request to port your personal data to another party in terms of applicable laws. Such requests must be sent to us in writing.

If you would like to exercise any of those rights, please send an email to our Data Protection Officer on dpo@pleion.mu. Note that we may, at our discretion, verify your identity by requiring a proof of your identity before addressing your request.

 

Keeping your information secure

We take the security of your data very seriously and, as such, we have incorporated appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business requirement to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality and to our own security policies and procedures.

We also have procedures in place to deal with any suspected data security breach. In case any breach occurs, we will notify you and the Data Protection Office where we are legally obliged to do so.

 

How long do we keep your information?

At Sunibel Corporate Services Ltd, we recognise that the efficient management of data and records is essential to support our core operations. Our policy concerns all information collected and processed, irrespective of their format (electronic or paper).

We collect and keep your personal information for no longer than necessary to fulfil the purposes for which it is processed. The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws as set out in our retention schedule.

Data relating to customers, prospective customers, suppliers, employees or job applicants, which are no longer required, for which the consent has been withdrawn or for which the data subject has exercised his right of erasure, shall be securely disposed of by the data owner.

 

How to Complain

We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information. Do not hesitate to contact him on dpo@pleion.mu or on +203 460 06 10 should you require any further information or wish to complain about the processing of your personal data by our Company.

You also have the right to complain directly to the Data Protection Office (https://dataprotection.govmu.org/SitePages/Index.aspx)

 

Changes to this Privacy Policy

We may update this Privacy Policy from time to time (but at least annually) to reflect best practices in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 2017 and General Data Protection Regulation.  Any changes will be posted on our website, and the effective date will be updated accordingly.

 

How to contact us

Please contact our Data Protection Officer (contact details below) should you require any further information, exercise your right or complain about the processing of your personal data.

Email: dpo@pleion.mu

Telephone: +230 460 06 10

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