1. WHO WE ARE
www.http://sancteous.com/ (“Sancteous”) is a website designed to connect business in view of creating, fostering and facilitating business partnerships. It is operated by LeadBusiness & Networking Solutions Ltd (“LeadBusiness”), a company registered in Mauritius under the company number C18157508 and whose registered office address is at 19 Church Street, Port Louis, Mauritius. Sancteous is a registered trademark owned by LeadBusiness.
2. OUR PRIVACY STATEMENT
3. CATEGORIES OF PERSONAL DATA THAT WE COLLECT ABOUT YOU
Personal Data that we collect about you are as follows:
|Identity Data||first name, last name, company name, username or similar identifier, title and gender.|
|Contact Data||registered address, email address and telephone numbers|
|Technical Data||internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Sancteous|
|Profile Data||username and password, preferences, feedback|
|Usage Data||information about how you use Sancteous|
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 health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
- Direct interactions
We receive your Identity and Contact Data when you create an account on Sancteous. If you contact us, we may keep a record of that correspondence.
- Automated technologies or interactions
As you interact with Sancteous, we will automatically collect Technical Data about your equipment, browsing actions and patterns and patterns and traffic data. We collect this Personal Data by using cookies, server logs and other similar technologies.
5. HOW WE USE YOUR PERSONAL DATA
- We will only use your Personal Data when we are allowed to do so. Most commonly, we will use 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.
- 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.
6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as Participant Partner
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as Participant Partner||(a) Identity
|Performance of your subscription to Sancteous platform|
|(a) Performance of your subscription to Sancteous platform
(b) Necessary to comply with a legal obligation
(c) Necessary to keep our records updated and to analyse how our participant partners are using Sancteous
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for the running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
|To make our website of interest to you
To analyse the use of the website in order to improve its functionalities, and our relationship with Participants / Partners
|Necessary to develop our services and grow our business
Necessary to define the users profile, to update the website.
7. DISCLOSURES OF YOUR PERSONAL DATA
We do not share your Personal Data with any company outside other than our Participating Partners for marketing purposes, but should this be the case, we will get your express opt-in consent before we proceed.
In relation to the purposes for which we collected your Personal Data, we may have to share your Personal Data to (i) employees of LeadBusiness, and (ii) internal third parties such as our preferred service providers (such as IT systems suppliers and support).
We may require to share your Personal Data to external third parties such as (i) our professional advisors who may include our accountants, auditors, lawyers, insurers and bankers, and (ii) any public or enforcement authority in Mauritius or elsewhere, or in case of a court, administrative or governmental order to do so.
8. 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:
(i) the pseudonymisation and encryption of Personal Data; and
(ii) 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.
9. DATA RETENTION
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. 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.
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 other requirements.
10. YOUR LEGAL RIGHTS
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:
- 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.
11. THIRD-PARTY LINKS
13. TRANSFER OF YOUR PERSONAL DATA
Our servers are based in the Netherlands and are protected by EU and Mauritius Law, at no point will your data be transferred out of the two regions without prior consent of the users.