3. Personal data
Personal data, or personal information, means any information about an individual from which that person can be identified. The personal information collected and processed by HSL (in paper and electronically) includes:
- Contact details such as phone number
- Email address
- Site plan
- ID number
- Medical Health Information
- Fulfilling contractual obligations, or
- Our legal duty
In any event, HSL is committed to ensuring that the information it collects and processes is appropriate for the purpose for which it was collected.
HSL reassures its customers that any disclosure or transfer of personal data to third parties and/or to different countries will only be done if it fits under any of the above purposes.
5. Use of personal data
Lawful basis for processing including basis of legitimate interest
Purchase of products from our physical stores, online store, direct sales, service centre or any other means of purchase
· Performance of a contract (To be able to proceed with the sale and provide you with the service)
Loyalty and Promotional Offers
· Performance of a contract (To be able to provide you with your loyalty benefits)
· To protect your interest (To contact you prior to the expiry of your loyalty benefits so that you can benefit from same)
· Performance of a contract (To be able to contact you and to provide you with the services)
Transfer of personal data to supplier/service providers within or outside Mauritius with your consent
· Necessary for our legitimate interest (for the running of our business, to recover our claims, etc)
· Necessary to comply with the contractual terms and conditions imposed by our suppliers/service providers to maintain our position as authorised partners/distributors
Follow-up calls to client for a quotation, to conclude a sale/delivery or aftersales service
· Performance of a contract (To collect your feedback on the sale, delivery or repair of your product)
To effect payment to an individual supplier through cheques, transfers or any other means of payment
To follow up and recover money owed to us
· Performance of a contract (To be able to proceed with your payment)
· Necessary for our legitimate interests (to recover debts due to us by customers)
To administer and protect our business (including maintenance of our customer database, accounting records, employee and candidate data, analysis of financial results, external and internal audit requirements and legal obligations)
· Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation exercise)
· Necessary to comply with a legal obligation
6. Marketing Purposes
HSL may use your personal data to inform you about relevant products and offers. The personal data we have about you is made up of what you voluntarily gave to us and the data we collect under circumstances mentioned in section 5 above.
We can use your personal data to send you marketing correspondences if we have your consent. You may request us to stop sending you such correspondences by notifying HSL in writing at any time.
We may also ask you to confirm or update your personal data and/or your choices (e.g. your preferred channel of communication) in the future.
When you connect to our websites, we collect information automatically via cookies and other similar technologies, such as web beacons. Cookies are small text files that are automatically placed on your computer or mobile device when you visit a website. They are stored by your internet browser. Cookies contain basic information about your use of the internet. This information includes internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp and clickstream data. Your browser sends these cookies back to our website every time you visit it, so it can recognise your computer or mobile device and personalise and enhance your browsing experience. You can opt-out or revoke your consent to cookies by blocking same through your browser settings.
8. Sharing Personal Data
HSL may share your personal data either with your consent or by operation of law with external third parties within or outside the territory of Mauritius only if doing so fulfils any of the duties and responsibilities as mentioned in section 4 above.
They include amongst others:
- service providers based in Mauritius acting as processors who provide IT and system administration services, payroll services, etc.
- professional advisers based in Mauritius acting as lawyers, bankers and auditors amongst others
- the Mauritius Revenue Authority, regulators and other authorities based in Mauritius who require reporting of processing activities in certain circumstances.
- our suppliers outside Mauritius to fulfil our contractual obligation we have entered into with you
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. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
HSL will keep your personal data for:
- the period required for the purpose for which it is initially collected, or
- the period as may be necessary for HSL's compliance with legal obligations.
10. Acceptance of the use of Personal Data
You acknowledge, understand and agree that HSL will, for the purpose of providing its services to you during the usual course of its business operations, collect and, where necessary required, process the personal data voluntarily communicated by you.
You may withdraw your consent as regards the disclosure and processing of your personal data for any particular purpose(s) at any time. Should you wish to do so, you will need to notify HSL in writing.
If you withdraw your consent, we will not be able to provide you with certain products or services and you will be informed accordingly.
However, notwithstanding the withdrawal of your consent, your personal data may still be processed by HSL in the performance of its statutory duties.
11. Security and confidentiality
We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf. We have several security measures in place to prevent the loss, misuse or alteration of your information. All staff working for HSL have a legal duty to keep information about you confidential. HSL has strict information security policies and procedures in place to ensure that your information (whether held in paper or electronic format) is safe.
12. Customer's rights
You have the following rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights, please contact us on firstname.lastname@example.org.
- Request access to your personal data. This includes details of what information we hold about you and a copy of that information. The information will be provided free of charge and, unless there are grounds for extending the statutory deadline, the information will be provided to you within one month of receipt of your request.
- Request rectification of the personal data that 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. You may request to delete or remove personal data where:
- there is no good reason for us continuing to hold or process it
- you have successfully exercised your right to object to processing (see below),
- you deem the processing of your personal data to be unlawful, or
- we are required to erase your personal data to comply with the law.
Note, however, that we may not always be able to comply with such a request where it is necessary to keep your information for the purposes of establishing, making or defending legal claims.
- Request objection to the processing of your personal data. You have the right to object to the processing of your personal data on the ground that it affects 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, HSL 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. You have the right to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where you deem the processing of your personal data to be 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
- 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
The information will be provided free of charge. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may decide, subject to our legal obligations, to delete your personal data in case we consider that you are making an abuse of your right to have access to your personal data in our possession. You will consequently bear the consequences of such erasure and we shall in no way be liable should we be unable to provide any services and/or comply with our contractual obligations to you following such erasure.
Please note we will generally also ask for confirmation of your identity and may need further information from you in order to locate the information, in which case the time period starts from the date we have that detail. Please note that in some cases we may not be able to comply fully with your request, such as where your request also involves information about someone else and where confidentiality needs to be maintained.
13. Links to other websites of interest
Our website may contain links to other websites of interest. However, once you have used these links to leave our website, kindly note that we do not have any control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and which are not governed by our privacy statement. You should exercise caution and look at the privacy statement applicable to the websites in question.
14. Queries and complaints
You have the right to make a complaint relating to HSL's handling of your personal data at any time to the Data Commissioner. We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner. Kindly contact us in the first instance (see contact details at no.12).
15. Modifications and updates