ADEONA MOBILITY LTD WEBSITE PRIVACY POLICY
The purpose of this Privacy Policy is to inform you of the manner in which Adeona Mobility Ltd (“we”/ “us”) collect, process, and share your personal data when you visit and/or make a booking on Adeona Mobility Ltd website at https://adeonamobility.futurebuzz.mu.
By using the Website, you consent to the Processing of your Personal Data as described in this Privacy Policy.
Unless otherwise provided for, terms and expressions used with capitalized initials shall have in this Privacy Policy (a) the meanings ascribed to them in this Privacy Policy or (b) when they are not defined herein, the one ascribed to them in the Terms and Conditions of Service – Adeona.
- OUR PRIVACY STATEMENT
We respect your privacy and are committed to protecting your Personal Data, as defined in the data protection laws in force in Mauritius, that is the Data Protection Act, 2017 (the “Act”), as amended from time to time.
- DEFINITIONS
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- 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 Protection Officer: means the officer designated by us as responsible for data protection compliance issues
- 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.
- Encryption: means the process of transforming data into coded form;
- Personal Data: means any information relating to a data subject.
- 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.
- Pseudonymisation: means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information and the additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable individual
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- PERSONAL DATA THAT WE COLLECT ABOUT YOU
We only collect the information that we actually need. Providing your personal data is necessary for the purposes specified in this Privacy Policy. Failure to provide such data may prevent us from providing certain services to you. We collect and process your personal data mainly upon registration to provide you with access to your Account and to support our contractual relationship with you. When you visit the Website, we automatically collect some information about your device, including information about your web browser, your IP address, your time zone and some cookies that are installed on your device. In addition, when you browse the Website, we collect information about the web pages or individual products that you are viewing, websites or search terms that have allowed you to arrive on the Website, as well as information on how you interact with the Website. This information automatically collected is referred to as the “Device Information”.
We collect Device Information using the following technologies:
Cookies are data files that are placed on your device or computer and often include an anonymous unique identifier.
Log files track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
In addition, when you make or attempt to make a booking through the Website, we collect some information about you, including your name, billing address, payment information (including, but not limited to, your credit card number), your e-mail address and your phone number. This information automatically collected is referred to as “Booking Information”. We ensure that any payment information is processed securely in compliance with applicable data protection and any applicable payment security standards.
When we use the term “Personal Data” in this Privacy Policy, we are referring to both the Device Information and the Booking Information.
We do not collect any Special Categories of Personal Data about you (this includes details about race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about sexual orientation, practices or preferences, health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
You may manage or disable these technologies through your browser or device settings, in compliance with your rights under the applicable law.
- HOW WE USE YOUR PERSONAL DATA
We will only use your Personal Data when the law allows us to, (i) on contractual necessity, (ii) on legitimate grounds not overridden by your data protection interests and/or (iii) with your Consent.
We use the Booking Information that we collect generally to fulfil any services requested through the Website (including processing your payment information and providing you with invoices and/or booking confirmations). We will not process your Personal Data for purposes incompatible with the ones described in this policy unless required and authorised by law.
Additionally, we use this Booking Information to:
- Communicate with you;
- Screen our bookings for potential risk or fraud;
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services;
- 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.
We use the Device Information (especially your IP address) that we collect to evaluate potential fraud or risks and, more generally, to improve and optimize the Website (for example, by generating analyses on how our users navigate and interact with the Website, and to evaluate the success of our advertising and marketing campaigns).
- DISCLOSURES OF YOUR PERSONAL DATA
We do not share your Personal Data with any third parties. Your Personal Data may be used for marketing purposes, but should this be the case, we will get your express opt-in consent before we proceed.
We may require to share your Personal Data to external third parties such as (i) our employees (ii) our professional advisors who may include our accountants, auditors, lawyers, insurers and bankers,
(iii) our preferred service providers (such as IT systems suppliers and support) and (iv) any public or enforcement authority in Mauritius or elsewhere, or in case of a court, administrative or governmental order to do so.
- HOW WE PROTECT YOUR PERSONAL DATA
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 particular, our preventive and protective measures include:
- the pseudonymisation and encryption of Personal Data; and
- the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services through our disaster recovery management procedure.
In addition, we limit access to your Personal Data to those persons 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.
The security of your Personal Data is important to us. We implement reasonable and appropriate technical and organizational measures to ensure a level of security appropriate to the risks associated with the processing of your Personal Data in line with our legal obligations. However, it is important to note that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
- YOUR LEGAL RIGHTS
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- You have the right to:
- Request 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.
- 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.
- 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. However please note 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 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:
- You have the right to:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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. 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. We will try to respond to all legitimate requests within one month. Occasionally it could take us longer than one 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.
- Lodge a complaint at any time with the Data Protection Commissioner of Mauritius (“DPC”). You may obtain further information in this respect on: https://dataprotection.govmu.org/Pages/Home%20-%20Pages/Take%20Action/To-report-your-Complaint.aspx
- If you wish to exercise any of the rights set out above or need any clarification thereon, please contact us. We would appreciate the chance to deal with any of your concerns before you approach the Data Protection Commission, so please contact us in the first instance. We will try to respond to all legitimate requests within [1 (one) month]. It may take us longer than [1 (one) month] if the request is particularly complex or if you made a number of requests. In this case, we will notify you and keep you updated.
- DATA RETENTION
We keep your Personal Data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless otherwise required by law or regulatory obligations.
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.
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 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.
Where you have consented to receive updates and similar materials from us, any Personal Data held by us for that purpose will be kept by us until such time that you notify us that you no longer wish to.
- THIRD-PARTY LINKS
The 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 the Website, we encourage you to read the privacy policy of every website you visit and application you use.
- COOKIES
We use cookies and/or similar technologies to analyse customer behaviour, administer the Website, track users’ movements around the Website, and to collect relevant information about users to assist with current or future transactions. This is done to personalise and enhance your experience of using the Website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.
- CHILDREN
The Website does not target anyone under the age of 18 (“Children”) with our services. We do not intend to collect or knowingly collect Personal Data from Children.
- TRANSFER OF YOUR PERSONAL DATA
If you are located outside Mauritius and choose to provide your Personal Data to us, please note that we will protect your Personal Data in accordance with the applicable laws in Mauritius.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We may transfer your personal data outside Mauritius, for example for storage purposes, in such cases, we will ensure that appropriate safeguards with respect to the protection of your Personal Data are in place in the foreign country.
- OUR CONTACT INFORMATION
If you have any questions about our Privacy Policy, including any requests to exercise your legal rights, please contact our Data Protection Officer, Xavier Harel, on the following:
Phone: 58575944
Email: info@adeonamobility.com
Address: Co Turbine Incubator, Les Kocottes, St Pierre
- GOVERNING LAW AND JURISDICTION
This Privacy Policy shall be construed, interpreted and applied in accordance with, and shall be governed by the laws applicable in the Republic of Mauritius.
The formation, interpretation and performance of the present Privacy Policy shall be governed by the laws of Mauritius. Any disputes, controversy or claim arising out of or relating to these Privacy Policy, or the breach, or invalidity thereof shall be resolved by an appropriate court of law in Mauritius. The Parties hereto expressly agree to the jurisdiction and venue of such courts in Mauritius.
- CHANGES TO THIS PRIVACY POLICY
We reserve the right to update this Privacy Policy from time to time.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on the Website.