Our Privacy Notice
BEFORE WE BEGIN
The purpose of data protection legislation is to protect the rights and privacy of individuals (“Data Subjects“) in respect of the Processing of Personal Data concerning them. “Personal Data” is any information relating to an identified or identifiable natural person (known as a “data subject”). A person is “identifiable” if he or she can be identified, directly or indirectly, not only by things such as a name or an identification number, but also by things such as location data or some factor specific to (for example) the physical, physiological or social identity of that person. More common examples of Personal Data include names, identification numbers, contact information, identity documents and photographic images. “Processing” covers any activity involving Personal Data and includes such things as the collection, recording, storage, adaptation, use, disclosure and destruction of Personal Data.
Each member of the AGILEUM Group will process Personal Data in accordance with Applicable Data Protection Law.
After four years of preparation and debate the GDPR was finally approved by the EU Parliament on 14 April 2016. Enforcement date: 25 May 2018.
The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens’ data privacy and to reshape the way organizations across the region and worldwide approach data privacy
The EU General Protection regulation is considered the most important change in data privacy regulation in 20 years. Tech companies as AGILEUM routinely manage regulatory changes as part of everyday operations, but GDPR will likely have far greater impact than past mandates.
WHAT INFORMATION WE COLLECT
- Customers and customers and prospective customers;
- Suppliers and business partners;
- Potential employees;
- Visitors, and users of AGILEUM sites, including our websites on com, or social media pages, mobile applications;
- Other third parties as Governmental institutions;
- Attendees of AGILEUM events…
Information that you provide to us, e.g.:
- personal details, e.g. name, previous names, gender, date and place of birth;
- contact details, e.g. address, email address, landline and mobile numbers;
- information concerning your identity e.g. photo ID, passport information, Naurance number, National ID card and nationality;
- transactional data, including products and services ordered, financial details and payment methods;
- company data such as the name, size and location of the company you work for and your role within the company;
- data from surveys and publicly available information, such as social media posts;
- unique IDs such as your mobile device identifier or cookie ID on your browser
- IP address and information that may be derived from IP address, such as geographic location;
- information about a device you use, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, and the preferred language;
- behavioral data of the internet connected computer or device you use when interacting with the sites, such as
- advertisements clicked or viewed, sites and content areas, date and time of activities or the web search used to locate and navigate to a sit
Clients (and potential clients)
We have clients that are individuals and clients that are corporate bodies, including limited liability partnerships, government departments and agencies and other public bodies. Even where our clients are not themselves individuals, they will be represented by individuals and they may be owned by individuals and invested in by individuals. As a result, we will inevitably process Personal Data in the course of our relationships with those clients too.
As a potential client and then (if applicable) as a client, the Personal Data that we Process will include personal and/or professional contact details (addresses, telephone numbers, email addresses), copy identity documents, bank details…
Suppliers (and potential suppliers)
As a potential supplier and then (if applicable) as a supplier, the Personal Data that we Process will include personal and/or professional contact details (addresses, telephone numbers, email addresses), documents and other proofs of standing and reputation and details of bank accounts and/or other payment details.
If you are an applicant for a job with us (a potential employee), the Personal Data that we Process about you will include:
- your name, address and contact details, including telephone numbers and email addresses;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including entitlement to benefits;
- whether or not you have a disability that we may need to make adjustments for during the recruitment process;
- information about your entitlement to reside and/or work in the place where you have applied for a job; and
- equal opportunity monitoring information, including information about your ethnic origin, sexual orientation, health and religion or beliefs.
If your application for a job with us is successful, our retention of your Personal Data will be governed by our separate policy on staff Personal Data, which will be made available to you by our HR department as part of you are becoming a member of staff.
Enquirers and visitors to our website
You may give us Personal Data by filling in a contact form on our website or by corresponding with us by email. In each of the above cases, the Personal Data that we Process will include personal and/or professional contact details (addresses, telephone numbers, email addresses. We will also automatically collect certain information each time you visit our website. This includes:
- technical information including the Internet Protocol (IP) address used to connect your computing device to the Internet, your browser type and version, time zone setting, operating system and
- information about your visit which may include the pages viewed, page response times; and
- your country of location by reference to a look-up of your IP address against public sources.
If you leave a voicemail message with us, that message may be processed in a similar manner to email and postal correspondence.
HOW WE’LL USE YOUR INFORMATION
We may use personal information for the following purposes:
- to communicate;
- to market our products and services;
- to engage a Business relationship with customers, suppliers and business partners and to process orders for AGILEUM products and services;
- to analyse, develop, improve and optimize the use, function and performance of our sites and products and services;
- to manage the security of our sites, networks and systems;
- to comply with applicable laws and regulations and to operate our business;
Clients (and potential clients)
As a potential client, we will process Personal Data about you and those connected with you, for the purpose of carrying out our business and in order to:
- respond in our legitimate interests to your enquiries about our services and/or other requests;
- enter into an agreement with you regarding the provision of services;
- correspond with you concerning our present and future services and relevant news and service updates with your consent where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications.
If you become a client, we will continue to process Personal Data about you for such of the purposes described above as continue to be relevant. In addition, we will process Personal Data about you and those connected with you regarding the on-going provision of services, as described below. If you do not become a client, we will only keep Personal Data that you have made available to us if it is necessary for us to keep it for legitimate business purposes and/or as we are required to keep it by law or regulation.
If you do become a client, we will need to process Personal Data in order:
- Under the agreement entered into between you and us to:
- provide you with good and services and to administer and manage our relationship with you;
- carry out your instructions and to respond to enquiries made by you;
- conduct and verify ongoing credit worthiness and standing checks relevant to the agreement;
- recover any fees owed to us under our agreement with you;
- Under our legal obligations to:
- collect and use certain information, for example with regard to the ownership of assets and for the purpose of the automatic exchange of information concerning tax matters;
- carry out on-going due diligence or other “know-your-customer”;
- to comply with other applicable law and regulations in the various jurisdictions in which we operate;
- or in our legitimate interests:
- to manage our infrastructure and business and to further our business interests;
- to comply with policies and procedures under applicable professional regulation, guidelines or notices and/or that may have been put in place by us, including those relating to regulatory review and/or oversight, risk management, internal or external auditing, finance and accounting, billing and collections, IT systems, data and website hosting, training, testing and business continuity; and
- other purposes which we may notify you of from time to time, and obtaining your consent where necessary.
Suppliers (and potential suppliers)
As a potential supplier, we will process Personal Data about you and those connected with you, for the purpose of entering into and receiving good and services under a contract with you relevant to carrying out our business and in order to:
- respond to your enquiries about supplying goods or services to us;
- conduct checks concerning standing and reputation;
- enter into an agreement with you regarding the provision of services; and
- correspond with you concerning your present and future goods or services.
If you do become a supplier of AGILEUM Group, we will need to process Personal Data in order to:
- administer and manage our relationship with you;
- respond to enquiries made by you;
- carry out on-going checks in accordance with legal or regulatory obligations and our own risk management procedures;
- conduct and verify ongoing standing and reputation checks;
- pay for goods and services received;
- comply with legal or regulatory obligations, for example with regard to a regulator’s outsourcing policy; and
- for other purposes which we may notify you of from time to time, and obtaining your consent where necessary.
If you are an applicant for a job with us (a potential employee), we will process Personal Data about you in order, in our legitimate interests, to assess your application and to advance that application through our recruitment processes, including by making details of your application, including Personal Data, to relevant members of our management and of our HR department, and to comply with policies and procedures under applicable professional regulation, guidelines or notices and/or that may have been put in place by us, relation to staff and recruitment.
Enquirers and visitors to our website
If you have completed a form on our website, making a new business enquiry or asking a general question, indicating the services and/or jurisdictions then we will process Personal Data about you for the purpose of our legitimate interest in responding to your enquiries and/or request for information.
Likewise, if you have contacted our marketing team by email, either via the website or independently, or otherwise with a media enquiry, we will process Personal Data about you on the same grounds in order to respond to your enquiries and/or request for information.
If you or someone who works for you has given us a business card at a conference or a business meeting, we will use the contact details on the card in connection with the specific purpose it was provided. Where the card is provided for the specific purpose of requesting our promotional update communications we may first, where permitted by Applicable Data Protection Law, send an email promptly after receiving the business card, to confirm the request, clarify its scope and provide for you to complete contact preferences.
We use information about visitors to our website in our legitimate interests for internal operations, to ensure that content is presented in the most effective manner for you and your computer and to keep our website safe and secure.
Focus on Marketing and market research
We may use your information to provide you with details about AGILEUM products and services, and alsoproducts and services from our partners and other relevant third parties. We may send you marketing messages by post, email, telephone.
If you ask us not to send you marketing, it may take us a short period of time to update our systems and records to reflect your request, during which time you may continue to receive marketing messages.
WHO WE MIGHT SHARE YOUR INFORMATION WITH
As a global organisation, information about you may be shared globally throughout AGILEUM organisation.
We may also share personal information with the following third parties:
- business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any agreement we enter into with you. They may assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing IT and other support services or in other tasks, from time to time. These third parties will only use your information to the extent necessary to perform their functions.
- Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
- As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.
HOW LONG WE’LL KEEP YOUR INFORMATION
AGILEUM maintains personal information for the following retention periods:
- Information about you we collect to engage in transactions with our customers, suppliers and business partners, and to process purchases of our products and services, will be retained for the duration of the transaction or services period, or longer as necessary for record retention and legal compliance purposes.
- Contact information such as your email address or phone number collected online on our sites or offline from our interactions with you at AGILEUM events and conferences, and used for direct marketing and sales activities will be retained for as long as we have an active (customer) relationship with you. We treat you as an active contact if (i) you have interacted with AGILEUM or updated your contact details and preferences in the past 18 months; and (ii) you have not made a deletion request.
You have a number of rights in relation to the information that we hold about you. These rights include:
- the right to access information we hold about you and to obtain information about how we process it;
- in some circumstances, the right to withdraw your consent to our processing of your information, which you
can do at any time. We may continue to process your information if we have another legitimate reason for doing so;
- in some circumstances, the right to receive certain information you have provided to us in an electronic format and/or request that we transmit it to a third party;
- the right to request that we rectify your information if it’s inaccurate or incomplete;
- in some circumstances, the right to request that we erase your information. We may continue to retain your
information if we’re entitled or required to retain it;
- the right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to restrict, our processing of your information but we’re entitled to continue processing your information and/or to refuse that request.
You can exercise your rights by contacting us using the details set out in the ‘More details about your information’ section below. You also have a right to complain to the data protection regulator in the country where you live or work.
WHAT WE NEED FROM YOU
You’re responsible for making sure the information you give us is accurate and up to date, and you must tell us if anything changes as soon as possible. If you provide information for another person (e.g. a joint account holder, a beneficiary under an insurance policy or a dependant), you’ll need to direct them to this notice.
HOW WE KEEP YOUR INFORMATION SECURE
We have taken steps to apply appropriate technical and organizational measures to prevent the unauthorized or unlawful processing of Personal Data, and/or the accidental loss or destruction of, or damage to, Personal Data. This includes but is not limited to using properly configured and maintained firewalls, encryption and anti-virus/malware protection on servers and laptops/PCs with emails scanned for viruses and spam. Our staff have an obligation to ensure that appropriate security measures are implemented at all times in accordance with the guidance set out in our information security and data protection policies and procedures.
We require our third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.
MORE DETAILS ABOUT YOUR INFORMATION
P.O. Box 41, 1st Floor, The Factory Building
Vivéa Business Park, Saint Pierre 81430, Moka
This Privacy Notice may be updated from time to time and the most recent version can be found at Agileum.com\dataprivacy
AGILEUM Ltd, registered company under the BRN C06043371
AGILEUM Hospitality Ltd, registered company under the BRN C06043371
AGILEUM Pty Ltd, registered company under the BRN CO.2003/1561
Headquarter: AGILEUM Ltd P.O. Box 41, 1st Floor, The Factory Building, Vivéa Business Park, Saint Pierre 81430, Moka, Mauritius
All Rights Reserved.