HAREL MALLAC GROUP
COMMITTED TO ACTING FOR THE BETTER
At LINXIA LTD, (hereinafter “the Company/we/us’’), we care about your personal data and the way in which, it is used.
A. GETTING TO KNOW US AND WHAT WE DO
- The Company respects your right to privacy and is thus committed to fostering a trust-worthy environment when processing your personal data, in line with applicable statutory requirements and this Policy.
- This Policy allows you to take an informed decision before communicating your personal data to us.
- For the purpose of the Data Protection Act 2017, the Company is considered to be a Data Controller that will ensure the degree of care adopted when treating your personal data.
- The Company is found within the Harel Mallac Group of Companies (“Group” or “Harel Mallac Group”) ( https://www.harelmallac.com) and adopts the Harel Mallac Core Values (ACT- https://www.harelmallac.com/our-purpose ).
- If we are processing (in our capacity as Data Processor) personal data by and on behalf of any other entity/ies (Data Controller) within the Harel Mallac Group, this Policy shall be adhered to by that entity/those entities as well.
B. GETTING TO KNOW YOU:
- So, how do we collect from you your personal data?
When browsing our Website, we will invite you to take a moment to consult this Policy and provide to us your name and contact details and other relevant information about yourself and/or your firm.
- We collect personal data from you when, you register on our Website, subscribe to our newsletter, respond to a survey, undertake a transaction, apply for a job vacancy within the Harel Mallac Group and/or fill out any form on the Website. However, you also have the choice to simply browse this Website without providing any of your personal data to us.
C. HOW YOUR PERSONAL DATA IS USED:
- We are committed to using your personal data for the sole purpose for which, you have entrusted same to us. This purpose will be clearly provided to you upon collection of your personal data i.e. in the contact form or for any application, order and/or payment transaction (if available on the Website). Please ask to consult our retention policy regarding the periods of time during which we hold on to your personal data.
- Job Applications:
i. in a Harel Mallac Group mailbox administered by Harel Mallac & Co. Ltd (“HMCO”) and such data shall be processed by HMCO, as data controller (if the job vacancy is at HMCO or for future job opportunities) and/or as data processor, where HMCO will transmit your personal data to the Company and any relevant Group entity/data controller; and/or
ii. in the mailbox of the relevant officer of the Company.
If you are submitting your personal data for a job (a vacancy or future job opportunity) through our social media forums such as (without limitation) Facebook or LinkedIn, you will be asked to direct same to the said Harel Mallac Group mailbox or the mailbox of the relevant officer of the Company and Clause 2.1 shall apply. Such personal data submitted on our social media forums such as (without limitation) Facebook or LinkedIn, will thereafter be purged.
2.2. Once HMCO has conveyed emails and personal data received in the said Harel Mallac Group Mailbox to relevant persons as per Clause 2.1 above, those emails will be purged. Such personal data may continue to be processed by HMCO and the other entities within its Group, including the Company, where you provide your specific consent for them to keep your personal data on file for up to two (2) years for any future job possibilities in the Harel Mallac Group. After the said two (2) years, your said personal data shall be erased, unless there is another lawful ground to continue processing same.
2.3. If you submit your personal data for a job (a vacancy or future job opportunity) through the contact form (if available) on our Website, you must direct your interest through the proper channel i.e. to the mailbox of the relevant officer of the Company or through the Careers Section on www.harelmallac.com
2.4. As part of the recruitment process, your personal data will be processed and you may be requested to conduct a psychometric assessment, which involves automated processing of certain of your personal data and which may be used in the selection process. By participating in the psychometric assessment, you explicitly consent to the automated processing of your personal data and reliance thereupon for selection purposes. The retention policy in Clause 2.2 above shall also apply to this assessment and its results (subject to Clause 2.4 below).
2.5. If your candidature is successful, your personal data, including any psychometric assessments conducted during screening, shall be kept on record for the purposes of your contract of employment/traineeship etc. If your candidature is unsuccessful, your personal data shall be erased unless you provide your consent to keep your personal data on file for up to two (2) years for any future job possibilities in the Harel Mallac Group or there is another lawful ground to continue processing same.
2.6. After employment or traineeship etc. personal data shall be kept on record in order to comply with statutory requirements, for the purposes of defending and/or exercising any legal rights and/or where there is any other lawful basis to continue processing such personal data, whichever is the longer.
2.7. Any third-party data processor that has been appointed to administer our Website and/or social media forums are bound by confidentiality and the Data Protection Policy and ancillary policies of the Harel Mallac Group.
2.8. For job applications deposited at or posted to our offices, the above shall equally apply in those cases.
- Other use:
3.1. However, once making your acquaintance, we would like to keep in touch with you and use your personal data:
• To personalise your experience (your information helps us to better respond to your individual needs);
• To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you);
• To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);
• To administer a survey or other site feature;
• To send to you latest offers and promotions regarding the different products and services of the Company and any affiliate within the Harel Mallac Group.
3.2. Use of your personal data for other purposes is only a click away! Rest assured that you will be invited to tick a box, consenting to use of your personal data for other purposes such as marketing, surveys, customer satisfaction etc.
3.3. Your personal data may be processed and used by different companies within the Harel Mallac Group and/or consultants of the Company for such other purposes for which you provide your explicit consent and/or as permitted under law e.g. for defending or enforcing legal rights. We do not sell and/or trade in any personal data collected on this Website.
3.4. We implement a variety of security measures to maintain the safety of your personal data on the Website.
D. HOW WE CARE:
- You can transmit your personal data through this website securely.
- We have devised and implemented certain security policies, rules and technical measures in order to protect the personal data that you have entrusted to us, namely by the following:
• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss
• Confidentiality obligations of our data processors.
We equally care about the personal data of children i.e. those below the age of 16. Young ones may be interested in participating in one of our competitions for example. Parents or legal guardians of a child will be called upon to provide their consent to the processing of any personal data of the child.Other than information required to complete a purchase on our website, we do not knowingly collect personal data and our personal identifiable information from children under the age of 16. If a child under the age of 16 has provided us with personal information without parental or guardian consent, the parent or guardian may contact us by emailing on email@example.com. We will remove the information and unsubscribe the child from any of our marketing lists. In line with our legal obligations, we may ask the consent from the parents or guardians of a minor aged above 16 years before a purchase is allowed on our website.
- We only keep your personal data for as long as needed, that is, for as long as required under law, or for the purposes of any lawful processing, whichever is the longer.
E. LET’S CHECK:
You are free to ask us what personal data we hold on you and why. Just send us an email at firstname.lastname@example.org and our Data Protection Officer will check and let you know.
We may need to ask you a few questions in order to ensure that the request is actually coming from you!
F. KEEP US UP TO DATE:
Please do keep us up to date on any changes to your personal data
G. YOUR RIGHT TO SAY ‘NO’
- You have the opportunity to withdraw your consent and/or rectify and/or erase any personal data or put a stop to the way that your personal data is being used, provided that there is no other lawful purpose (not requiring consent) for which such data is required to be processed.
- Complaints regarding any breaches of this Policy and/or contraventions of the applicable data protection laws and regulations in force may be reported to our Group Data Protection Officer or the divisional Data Protection Officer (contact details mentioned below) or to the Data Protection Commissioner in Mauritius (email@example.com).
H. LINKING YOU TO OTHERS
- Our website may contain links to the websites of third parties, so as to broaden your experience.
- These third party websites have separate and independent privacy policies. We therefore have no control over these websites and/or liability for their content and/or products, goods, services and/or activities.
- However, we care about the users of our website and welcome any feedback about any third party websites linked from our website.
I. HOW THIS POLICY APPLIES TO YOU
- However, irrespective of the way in which, your personal data is collected, we are committed to caring for your personal data in accordance with all applicable laws and regulations in force.
J. TERMS GOVERNING OUR WEBSITE
Please also visit our Terms and Conditions section governing the use of our website at: http://www.linxia.mu/content/87-terms-and-conditions
K. KEEPING YOU UP TO DATE
L. KEEPING IN CONTACT
Name: Linxia Ltd
C/O Data Protection Officer,
Address: 18 Edith Cavell Street, PO Box 36, Port Louis 11302, Mauritius
Tel: (+230) 207 3200
Fax: (+230) 207 3232
Name: Harel Mallac,Group Data Protection Officer,
Address: 18 Edith Cavell Street, PO Box 36, Port Louis 11302, Mauritius
Tel: (+230) 207 3000
Fax: (+230) 207 3030
PRIVACY NOTICE - e-commerce
We care about your personal data. Before we collect your personal data, please be informed of the following information regarding how your data will be used:
1. The identity and contact details of the controller and, where applicable, its representative and any data protection officer;
Controller: Linxia Ltd (BRN.C10006367), (hereinafter the “Company”)
Data Protection Officer: Ms. Jennifer DEVILLE
Email address of Data Protection Officer: firstname.lastname@example.org
2. The purpose for which the data are being collected;
2.1. If you are purchasing online through our e-shop, your personal data, such as name, address, contact details and bank details will be collected and used for pre-contractual and contractual purposes, namely for processing your purchase order and/or your transaction and any after sales and warranty.
2.2. Bank and payment details being submitted on the Bank’s online platform or through a hire purchase company, will not be collected by the Company. Such personal data will be collected directly by those financial institutions. The Company will simply be informed of whether payment has been successfully effected or not.
2.3. Your personal data may also be processed for the following purposes:
i. For the purposes of complying with legal (statutory) obligations such as with respect to tax and/or for statutory record-keeping.
ii. customer surveys.
2.4. If you opt for payment by way of hire-purchase, you will be directed to the website of that hire-purchase company whereby you will enter into a contract with that third party for payment on credit terms. The hire-purchase company will in such event be required to effect full payment of the purchase price to the Company.
3. The intended recipients of the data;
3.1. Your personal data will be used by the following recipients, on a strictly need to know basis for the above purposes:
- The Company and its respective employees, agents, consultants, contractors and advisors, namely for pre-contractual and contractual purposes.
- Other entities in the Harel Mallac Group and their respective employees e.g. for direct marketing purposes where you have consented to same.
- Any third-party transport delivery service provider contracted by the Company.
- The Mauritius Commercial Bank for payment purposes.
- Hire-purchase companies listed on our website.
- ProximaWeb, the developer and administrator of the e-shop and its employees on a strictly need to know basis.
- The Company’s banks, auditors, lawyers.
- Relevant authorities where there is a legal (statutory) obligation e.g. for tax purposes.
4. Whether or not the supply of the data by that data subject is voluntary or mandatory;
The supply of such data is mandatory for the purposes of your order/purchase, where contractual obligation, legal obligation or legitimate interest are normally the lawful grounds on which your personal data is processed for the above purposes as per law.
If consent is the lawful ground for processing your personal data e.g. for direct marketing, you will be requested to provide your explicit consent.
The supply of data for direct marketing is voluntary and such consent may be withdrawn.
5. the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
If the processing is done on a lawful ground that is not consent, such as contractual obligation, legal obligation or legitimate interest, your consent is not required for such processing and thus there is no consent to be withdrawn.
If consent is the lawful ground for processing your personal data, you will be requested to provide your explicit consent. Consent if applicable may be withdrawn in accordance with the standard request form of the data controller and its Rights Management Policy found on www.harelmallac.com
6. The existence of the right to request from the controller access to and rectification, restriction or erasure of personal data concerning the data subject or to object to the processing;
A request for rectification or erasure of data must be in accordance with the standard request form of the data controller and its Rights Management Policy found on www.harelmallac.com
7. The existence of automated decision making, including profiling, and information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject;
Your data may be subject to profiling for marketing, customer care and/or future sales purposes of the Company.
8. The period for which the personal data shall be stored;
Such data shall be kept and used for the duration of the lawful processing applicable. This will probably be for the performance of a contract/transaction.
After the performance of the contract/transaction, the Company shall keep the personal data for a period of ten (10) years (this period includes the statutory period for record-keeping under the Income Tax Act and Companies Act and the limitation period under law for the establishment, exercise or defence of a legal claim).
Data is to be disposed of after the end of the period of record-keeping unless required for the establishment, exercise or defence of a legal claim or there is another lawful ground for processing such data (e.g. direct marketing) or there is an exception under the Data Protection Act which applies.
Such data shall be kept and used for direct marketing purposes, on the lawful basis of consent, where you consent to same and provided that consent has not been withdrawn.
9. The right to lodge a complaint with the Commissioner;
Yes. Please refer to the Company’s Data Protection Policy and Rights Management Policy found on www.harelmallac.com
10. where applicable, that the controller intends to transfer personal data to another country and on the level of suitable protection afforded by that country;
The hosting and back-up of data from the e-shop will be on the OVH Cloud, in France. Customer data is also stored by us on Microsoft Azure Cloud in EMEA (Europe, Middle East and Africa), namely Austria, Finland, France, Ireland, Netherlands.
Access to such personal data is access protected. OVH ensures encryption for security purposes. The EU General Data Protection Regulation offers a suitable legal framework for the protection of personal data.
11. Any further information necessary to guarantee fair processing in respect of the data subject’s personal data, having regard to the specific circumstances in which the data are collected.