1. Who are we?
STRATEGIA is an independent provider of wealth and asset management solutions incorporated in Mauritius. Our registered office and principal place of business is situated at Level 2, Office 2, IconEbene, Rue De L’Institut, Ebene, 72201, Mauritius.

2. Which personal data we collect?
When interacting with you, we may collect the following personal data for the purposes of our business activities (refer to section 3 below) or when you make a job application through STRATEGIA ’s website:

• your name and surname;
• your national identity card number;
• your passport details;
• your residential address;
• your marital status;
• your contact details (phone and fax numbers, email addresses);
• CV, pictures and qualifications details when you either spontaneously apply for a job at STRATEGIA or respond to a vacancy notice;
• your photos and videos when you participate to corporate events, cocktails, sports events organised by STRATEGIA ;
• your name, surname, signature and national identity card details in our visitors’ log book when you visit us;
• any other personal data necessary to fulfil your special requests; and
• any other personal data that you choose to provide to us.

Also, when you choose to contact us, we ask that you provide us with your email address. The provision of this information is purely voluntary.

3. How and why we use your personal data?
We use your personal data in the course of our business activities and interaction with you for the following purposes:

• to better understand your needs and provide you with a better service;
• performing our agreement with you;
• promoting eventual business relationships;
• assisting you with your queries or concerns;
• treating your applications for specific job vacancies or on a spontaneous basis;
• complying with any legal or regulatory obligations imposed on us;
• fulfilling our legitimate commercial interests; and
• sending you communications if you have consented to receiving the same, and for any other purposes for which we have your consent.

4. To whom do we disclose personal data?
Where personal data of the shareholder has been provided to STRATEGIA WEALTH MANAGERS LTD, it is protected under the data protection policy of the Company, available upon request with the data protection officer at contact@strategiawealth.com The latter will ensure that the personal data is kept safely, and only designated persons will have access, with a strictly need-to-know basis (including and not limited to the registrar and transfer agent, custodian, auditor and company secretary) for the purposes of fulfilling our obligations including the operation or performance of the services of or any obligation under any agreement. STRATEGIA WEALTH MANAGERS LTD will further use the personal data to meet any legal or regulatory obligations in relation to checking identification and conducting background screening and taking steps to avoid any money laundering and terrorist financing; in relation to record keeping; and to meet disclosures under any law, regulations or court order, or under and for the purpose of any guideline issued by regulatory or other authorities.

5. Overseas transfers of your personal data
In some cases, we may need to transfer your personal data with organisations located in countries outside Mauritius in order to provide our services to you. We will take appropriate safeguards in order to secure the personal data being transferred.

6. Direct Marketing
From time to time, we could use your name and contact information to send you either via emails, post, or social media information that we think may be of interest to you, including stories, events, products and services offered by STRATEGIA , its affiliates as well as special offers and promotions and surveys but we can only do so with your consent.
You will also be able to opt-out from receiving marketing communications at any time, free of charge, by contacting us in accordance with the section “Contact Us” below.

7. How long do we keep your information?
Your personal data will be stored for as long as required to fulfil our business purposes and for the period of time required by law. To the extent required by law, we will take reasonable steps to destroy or anonymise personal data in a secure manner when we no longer need it for the purposes for which it was collected (as set out in section 3 of this notice) and retention is no longer necessary for legal or business purposes.

8. Processing of personal data must be justified
We will only process your personal data where we are satisfied that we have an appropriate legal basis to do so, such as (i) for the performance of a contract between us; (ii) where you have provided us with your express consent to process your personal data for a specific purpose; (iii) our use of your personal data is necessary to fulfill our statutory obligations with relevant authorities (regulators, tax officials, law enforcement bodies) or otherwise meet our legal responsibilities; (iv) our use of your personal data is in our legitimate interest as a commercial organisation.

9. Security of personal data
STRATEGIA has in place reasonable technical and organisational measures to prevent unauthorised or accidental access, processing, erasure, loss or use of your personal data and to keep your personal data confidential. These measures are subject to ongoing review and monitoring.
We cannot guarantee that our website will function without disruptions. We shall not be liable for damages that may result from the use of electronic means of communication, including, but not limited to, damages resulting from the failure or delay in delivery of electronic communications, interception or manipulation of electronic communications by third parties or by computer programs used for electronic communications and transmission of viruses.

10. Access to your personal data
You have the right to request a copy of the personal data we hold about you. To do this, simply contact our Data Protection Officer and specify what data you would like. We will take all reasonable steps to confirm your identity before providing details of your personal data.
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

11. Correction of your personal data
You have the right to ask us to update, correct or delete your personal data. We will take all reasonable steps to confirm your identity before making changes to personal data we may hold about you. We would appreciate it if you would take the necessary steps to keep your personal data accurate and up-to-date by notifying us of any changes we need to be aware of. If you believe that any personal data we are holding about you is incorrect or incomplete, please write to or email us as soon as possible. We will promptly correct any personal data found to be inaccurate.

12. Withdrawal of consent and request for deletion of personal data
You may also withdraw your consent to receiving direct marketing communications, or more generally to our processing of your personal data, at any time, and you may in certain circumstances ask us to delete your personal data. However, we may not be able to fulfil our contractual obligations to you if you entirely withdraw your consent or ask us to delete your personal data entirely. To protect your personal data, we shall require that you first prove your identity to us at the time the request is made, for instance by providing a copy of your national identification card, contact details or answering some other security questions to satisfy ourselves of your identity before we may proceed with your request(s).

Whenever reasonably possible and required, we will strive to grant these rights within 30 days, but our response time will depend on the complexity of your requests. We will generally respond to your requests free of charge unless if your request involves processing or retrieving a significant volume of data, or if we consider that your request is unfounded, excessive or repetitive in which case we reserve the right to charge a fee (as mentioned above regarding access).

There may be circumstances where we are not able to comply with your requests, typically in relation to a request to erase your personal data or where you object to the processing of your personal data for a specific purpose or where you request that we restrict the use of your personal data where we need to keep your personal data to comply with a legal obligation or where we need to use such information to establish, exercise or defend a legal claim. To make these requests, or if you have any questions or complaints about how we handle your personal data, or would like us to update the data we maintain about you and your preferences, please contact our Data Protection Officer at the address set out under section 18 below.

13. Cookies policy
Should you require more information about the data we collect about you while you visit our website, please read our Cookies Policy.

14. Amendments to this Privacy Notice
We may amend this privacy notice from time to time. Any amendment will be posted on our website so that you are always informed of the way we collect and use your personal data. Any changes to this privacy notice will become effective upon posting of the revised privacy notice on the website. Use of our website following such changes constitutes your acceptance of the revised privacy notice then in effect but, to the extent such changes have a material effect on your rights or obligations as regards our handling of your personal data, such changes will only apply to personal data after the changes are applied.

15. Miscellaneous
This privacy notice is governed by and shall be construed in accordance with the laws of the Republic of Mauritius. This privacy notice is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this privacy notice, the English version shall prevail.

16. How to contact us?
We have appointed a Data Protection Officer to oversee compliance with and questions in relation to this notice. If you have any questions about this notice, including any requests to exercise your legal rights, please contact our Data Protection Officer.

17. Complaints
If you believe we have not handled your request in an appropriate manner, you may lodge a complaint with the Data Protection Commissioner (DPC) (The Data Protection Office, 5th floor, SICOM Tower, Wall Street Ebène, Mauritius). However we ask that you please try to resolve any issues with us first before referring your complaint to the DPC.