1. INFORMATION ON VUNA
Vuna is the controller and responsible for this website. When processing personal data of data subjects who are in the European Union (EU) in connection with Vuna’s services, Vuna acts as a data controller and as a data processor. When Vuna determines the purpose and the manner of processing of your personal data, Vuna is deemed to be a data controller. We apply a similar approach to protecting your data whether acting as a data processor or a data controller.
Vunagroup.com is committed to adequately protecting your personal data regardless of where it is processed and regardless of your location. We are committed to providing appropriate protection for your personal data when it is transferred outside of the European Economic Area (“EEA”).
2. OUR CONTACT DETAILS INFORMATION
Vuna is registered with the Financial Service Commission, in Mauritius under Company Number C07071653, with its registered office address at Level 10, NexTeracom Tower 1, Cybercity, Ebene, Mauritius 72201. Vuna is authorised and regulated as a management company.
Email address: firstname.lastname@example.org
Postal Address: Data Protection Officer
C/o Vuna Capital Trustees (Mauritius) Ltd
Level 10, NeXteracom Tower 1,
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), however, please consider contacting us in the first instance so that we may address your concerns directly.
3. PERSONAL DATA THAT WE COLLECT
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which the identity of the individual cannot be discerned (anonymous data).
We use different methods to collect data from and about you. Data is collected through the following:
Our WebsiteWhen you use our website, we may collect, use, store and transfer the following data:
- Information you give us while using our website. We may ask you to provide us with personally identifiable information while you use our website. This includes your full name, e-mail address, phone number and your website.
Our ServicesWhen you use our services, we may collect, use, store and transfer the following personal data:
Information you give us. We may collect personal data directly from you, as set out below:
- Personal data collected from our clients. We will ask you to provide us with personal data when you apply to become our client (an application form will be sent to you via our Business Development Manager). We may require you to provide us with additional personal data as you use our services and we will collect, store and process personal data relating to you and other individuals associated with you, such as full name, email address, date of birth, home address, proof of address, photocopy of a personal identification card or passport and other information as required to on-board you and meet applicable legal requirements.
Information provided by third parties. We may collect personal data about you from third parties, as set out below:
- When required for compliance with applicable laws (including specifically anti-money laundering and counter-terrorism financing laws and regulations), we may verify your information and collect information from publicly available sources, credit reference or fraud prevention agencies or check data against government sanction lists, either directly, or using identity verification providers or due diligence and screening information providers.
- When securing our website and services, we may collect details about your device, your transaction, your computer’s internet protocol and other technical information, through our data security and firewall providers.
- When marketing our services, we may collect identity and contact data from publicly available sources.
4. HOW IS YOUR PERSONAL DATA USED?
We will process 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 as our client;
- 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, such as mitigating financial loss or other harm to our clients, you and us;
- Where we need to comply with legal or regulatory obligations, such as detecting and preventing fraud; and
- Where we need to improve and analyse our products, website, systems and tools.
5. DISCLOSURES OF YOUR PERSONAL DATA
We share your personal data with trusted third parties for the purpose of providing our services and promoting our business, as follows:
- Third-party service providers. We may also use third-party service providers acting on our behalf. These service providers help us with data and cloud services, website hosting, data analysis, application services, advertising networks, information technology and related infrastructure, customer service, communications and auditing.
- Advertising and remarketing networks. Our website uses remarketing and conversion tracking technologies provided by Google Analytics. This technology allows us to display targeted advertising to users who have already visited our website when they use the websites of the partner networks of Google across the internet. We may add similar providers to those mentioned here in the future.
- Other third parties. We will share your personal data with third parties in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.
- Safety, Legal Purposes and Law Enforcement. We may share your personal data with third parties to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of vunagroup.com, our users, customers, employees or the public or as otherwise required by law. We also use and disclose your personal data as we believe necessary (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions, or our Service Agreement and other agreements, as applicable; (iii) to protect our rights, privacy safety or property, and/or that of our affiliates, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
- We do not allow our third-party service providers to use your personal data for their own purposes.
- We only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. TRANSFER OF YOUR PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
When possible, the data we collect from you is stored and processed at data centres in the EEA.
vunagroup.com will take all reasonable legal, technical, and organisational measures to ensure that if your data is transferred outside of the EEA, it will be treated securely and with an adequate level of protection compared to the level of protection offered within the EEA.
We have taken specific steps, in accordance with EEA data protection law, to protect your personal data. In particular, we will strive to restrict the transfer of your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For the transfer of your personal data within vunagroup.com, we rely on Standard Contractual Clauses approved by the European Commission which give personal data the same protection it has in Europe. Other transfers of personal data outside of the EEA will take place only where the organisation receiving the personal data has provided us with adequate safeguards.
If you transact with parties outside the EEA, for example by: (i) transacting with an individual or entity based outside the EEA; (ii) using a payment method based or commonly used outside of the EEA; or (iii) using a non-EEA currency; we may be required to transfer your personal data to those parties in order to provide the services you requested.
7. SECURITY OF YOUR PERSONAL DATA
Protecting your information and your privacy is extremely important to us. Being entrusted with some of your most valuable data, we have set high standards for data security. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed, altered or disclosed in an unauthorised manner.
We limit access to your personal information to those employees and third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
8. RETENTION OF YOUR INFORMATIONWe retain your personal data in an identifiable format for the least amount of time necessary to fulfil our legal or regulatory obligations and for our business purposes. We may retain your personal data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law.
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.
In some circumstances you can ask us to delete your data: see below for further information about your rights in the Data Protection Act 2017.
9. YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- 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 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, 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 for your personal data where we are relying on a legitimate interest (or those of a third party) and you object to the processing of your personal data 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 overrides 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.
- 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.
The information contained in this Site is for general guidance on matters of interest only. The application and impact of laws can vary widely based on the specific facts involved. Given the changing nature of laws, rules and regulations, and the inherent hazards of electronic communication, there may be delays, omissions or inaccuracies in information contained in this Site. Accordingly, the information on this Site is provided with the understanding that the authors and publishers are not herein engaged in rendering legal, accounting, tax, or other professional advice and services. As such, it should not be used as a substitute for consultation with professional accounting, tax, legal or other competent advisers.
While we have made every attempt to ensure that the information contained in this Site has been obtained from reliable sources, Vuna Capital Trustees (Mauritius) Ltd (“Vuna”) is not responsible for any errors or omissions, or for the results obtained from the use of this information. All information in this Site is provided "as is", with no guarantee of completeness, accuracy, timeliness or of the results obtained from the use of this information, and without warranty of any kind, express or implied, including, but not limited to warranties of performance, merchantability and fitness for a particular purpose. In no event will Vuna, its related partnerships or corporations, or the partners, agents or employees thereof be liable to you or anyone else for any decision made or action taken in reliance on the information in this Site or for any consequential, special or similar damages, even if advised of the possibility of such damages.
Certain links in this Site connect to other web sites maintained by third parties and such other web sites may or may not be presented within a frame of this Site. Vuna has not verified the contents of such third- party web sites and does not endorse, warrant, promote, or recommend any services or products, which may be provided or accessible through them or any person or body which may provide them. Vuna has not issued or caused to be issued any advertisements which may appear on these web sites.