Licence MC19000231 · FS-3.1A

Privacy Policy

Compiled in compliance with the Mauritius Data Protection Act 2017.

This privacy policy has been compiled in compliance with the Mauritius Data Protection Act 2017 (the ‘DPA’) to explain how Convina Fiduciary Services Ltd (“Convina”) collects, uses, protects or otherwise handles your personal information which is received by it as part of its client service offering.

Subsequent to the coming into force of the EU General Data Protection Regulation (“GDPR”) on 25 May 2018, Mauritius implemented the DPA which aims to strengthen the control and personal autonomy of data subjects over their personal data in line with international standards established by the GDPR and the European Convention for Protection of Individuals with regard to automatic processing of personal data. The DPA also aims to align Mauritius’ data protection provisions with current technological and other advancements.

In this document, the terms “personal data” and “personal information” are used interchangeably.

Why we collect personal information

Convina is licensed by the Financial Services Commission of Mauritius as a management company. As part of our licensing conditions and in order to fulfil our legal and regulatory requirements in Mauritius, we need to undertake “Customer Due Diligence” on our clients in their capacity as principals of entities to which Convina provides services. All information provided to us is strictly confidential and is not disclosed to any person or party whatsoever, unless we are legally required to do so by a regulatory body or a court of competent jurisdiction in Mauritius or abroad, or unless we have your express consent to disclose or transfer your personal information in the context of providing services to you.

What personal information do we collect from website visitors?

When providing services to you and in complying with laws and regulations in Mauritius and internationally, Convina is required to collect information on you, your family and business associates such as (but not limited to) your names, addresses, email addresses, contact numbers, details on identification documents, employment details and information on your wealth and the funds that will be subject to our client relationship. For purposes of the DPA, Convina is a ‘Controller’ and handles your personal data accordingly.

When do we collect information?

  • When we commence our Customer Due Diligence procedures before we accept you as our client.
  • When we enter into an agreement with you to provide services.
  • When you register on our website, subscribe to a newsletter, fill out a form or enter information on our site.

How do we use your information?

  • To allow us to better service you in responding to your customer service requests.
  • To comply with local and international anti-money laundering or other legal or regulatory requirements.
  • To send periodic emails regarding your business with us or other products and services.
  • To follow up with you after correspondence (email or phone inquiries).

How do we protect your information?

We value your privacy and care about how your personal data is treated. While collecting, processing and managing all such information, including your email addresses and contact numbers, we have processes in place to ensure that such information is kept securely in compliance with the DPA. Your personal data may be stored electronically and made accessible to staff members to enable them to serve you, or for other related or regulatory compliance requirements.

Convina takes reasonable steps to keep secure any information we hold, whether electronically or in hard copy, and to keep this information accurate and up to date. We require our employees and data processors to respect the confidentiality of any personal information held by Convina. Our website is scanned on a regular basis for security holes and known vulnerabilities. Your personal information is contained behind secured networks and is only accessible by a limited number of persons with special access rights, and all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology.

What are your rights under the DPA?

Under the DPA you may enquire about and request copies of any personal information we hold on you. If you believe that information we hold is incorrect or out of date, or if you have concerns about how we are handling your personal information, please contact us and we will try to resolve your concerns promptly. If you wish to have your personal information deleted, please let us know and we will take reasonable steps to delete it (unless we need to keep it for legal, auditing or internal risk management reasons).

How long we keep your personal information

  • For as long as you are a client and contact of Convina.
  • Where the purpose for keeping personal data has lapsed, Convina shall destroy the data as soon as is reasonably practicable. Convina is required to retain client information for at least 7 years after the client relationship is terminated.
  • When a person is no longer a client, for a period not exceeding ten (10) years in line with the prevailing laws of Mauritius. After this period, such personal data will be destroyed.
  • Where you have consented to receive updates and similar materials, any personal data held for that purpose will be kept until you notify us that you no longer wish to receive them.

Third-party disclosure

We do not sell, trade, or otherwise transfer your personal information to non-affiliated parties unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information secure. We may also release information when appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property or safety. Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Contacting us

If there are any questions regarding this privacy policy, you may contact us using the information below:

Convina Fiduciary Services Ltd
Block E River Court, 6 St Denis Street
Port Louis 11328, Mauritius
dataprotectionofficer@convinagroup.com