PRIVACY POLICY

 Effective as of September 2021

IMPORTANT: Please read this Privacy Policy together with any other privacy notice we may provide on social media or in the context of our Fidelity Program when we process your Personal Data so that you are fully aware of how and the purpose for which we are using your Personal Data.

A. INTRODUCTION

1. Société Desvaux De Marigny Cie Ltée (“SDDM”, »us« , « we« , or « our« ) is a long standing distributor and wholesaler of branded healthcare and cosmetic products (the “Products”) in Mauritius. In this connection, SDDM interacts with you (as customer(s)) when you subscribe to its Fidelity Programme, or promotional offers relating to the Products on its Facebook page, other social media, landing pages for newsletters, or its website: www.sddm.mu website (“Website” and “Social Media Pages”).

2. SDDM respects your privacy and we are committed to safeguarding it. This policy explains the way we process your Personal Data. It applies each time you subscribe to the Fidelity Programme, or use our Website and Social Media Pages.

3. Consenting to our use of cookies in accordance with the terms of this policy when you first visit our Website permits us to use cookies every time you visit our Website.

B. TYPES OF PERSONAL DATA WE COLLECT.

1. The following types of Personal Data are collected, stored and used by us:

 a. Information about your computer including your IP address, geographical location, browser type and version and operating system, login data, frequency of usage.

 b. Information about your visits to and use of our Website including the referral source, length of visit, page views and website navigation paths.

 c. Information that you enter when you register with our Website, or Social Media Pages, or to our Fidelity Program namely: your first name, last name, age, title and gender, registered address, date of birth, mobile or phone number, username or similar identifier email address, password, credit card details, bank account number, preferences in receiving newsletters, promotional offers or newsletters from us and our third parties. Such third parties include public authorities, public websites and social media, suppliers, and authorised resellers such as pharmacies.

2. In limited cases, we may collect ‘sensitive personal data’ also known as Special Categories of Personal Data in particular, information about your health. We will do so in accordance with data privacy law requirements and/or ask for your explicit consent.

C. WHY WE PROCESS YOUR PERSONAL DATA

1. Personal Data submitted to us will be used for the following purposes:

 a. Administering our Website.

 b. Creating a page that will be personal to you on our Website.

 c. Managing our Fidelity Program.

 d. Suppling samples and/or gifts following your participation in games with our social media pages.

 e. Attending to any request you may make on our Facebook page or other social media.

 f. Enabling your use of our Website.

 g. Sending the Product(s) you purchased through our Website.

 h. Sending statements, invoices and payment reminders to you and collecting payments from you.

 i. Dealing with inquiries and complaints made by or about you relating to our Website, our social media pages or our fidelity programme.

 j. Verifying compliance with the terms and conditions governing the use of our Website.

2. We will not use your Personal Data for purposes that are incompatible with the purposes for which we collected it, and of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

3. We will not, without your expressed consent, supply your Personal Data to any third party for their direct marketing.

D. USE OF PERSONAL DATA FOR MARKETING PURPOSES

1. We may also use your Personal Data for marketing purposes:

   a. when you have specifically requested to receive our marketing communications, newsletters or samples via social media, E-mail, SMS, WhatsApp, and phone call; or

   b. if you have purchased our Products with our authorised resellers.

2. You can exercise your right to prevent us from using your Personal Data for direct marketing in respect of our promotional offers, by ticking certain boxes on the forms we use to collect your Personal Data, or by utilizing opt-out mechanisms in e-mails we send to you.

3. Your explicit consent will be required if you do not wish to receive any of our promotional offers and marketing communications from us. In each case, you have not opted out of receiving that marketing, you will receive marketing communications or promotional offers from us. We may then use your identity, technical, usage and profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide, which services and offers may be relevant for you.

4. You can exercise the right to discontinue marketing communications to you, or to have your Personal Data removed from our database at any time by contacting us. In such cases, we will retain minimum Personal Data (for example, your identity contact to note that you opted out in order to avoid contacting you again.

E. DISCLOSING PERSONAL DATA

1. We may disclose your Personal Data to any of our employees, officers, accountants, insurers, professional and legal advisers, banker.
2. We may disclose your Personal Data to our preferred Service Providers (such as IT systems suppliers and support, and other service providers who facilitate the promotion of the Products, and to provide the services on our behalf, or to perform certain activities relating to our services, or to assist us in analysing how our services are used). We require from these Service Providers (i) to respect the security of your Personal Data, and to treat it in accordance with law, and(ii) not to use your Personal Data for their own purposes, and (ii) only to process your Personal Data for specified purposes and in accordance with our instructions

3. We may disclose your Personal Data:

 a. To the extent that we are required to do so by any public or enforcement authority in Mauritius or elsewhere, or in case of a court, administrative or governmental order to do so;

b. In connection with any ongoing or prospective legal proceedings;

c. In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention);

d. To a purchaser (or prospective purchaser) of any business or asset that we may be (or may be contemplating) selling; and

e. To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

4. Except as provided in this policy, we will not provide your Personal Data to third parties.

F. RETAINING PERSONAL INFORMATION

1. This paragraph F sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information.

2. Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 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 requirements.

3. Without prejudice to paragraph F-2, we will usually delete Personal Data falling within the categories set out below at the date / time set out below:

 a. If you are not a customer, we will keep your personal data for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirement.

b. If you are a customer as long as we stay in touch with you through our promotional activities.

c. Unless you object when you receive one of our prospecting messages.

4. Notwithstanding the other provisions of this Section G, we will retain documents (including electronic documents) containing personal data:

a. To the extent that we are required to do so by law;

b. If we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

c. In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

G. SECURITY OF YOUR PERSONAL DATA

1. We will take reasonable technical and organizational measures to prevent the loss, misuse or alteration of your Personal Data.
2. We will store all the Personal Data you provide on our secure (password – and firewall – protected) servers.
3. You acknowledge that the transmission of Personal Data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

 H. AMENDMENTS

We may update this Privacy Policy from time to time by publishing a new version on our Website.  You should check this page occasionally to ensure you understand any changes to this policy.  We may notify you of changes to this policy by email or through the private messaging system on our Website.

I. WHAT YOUR RIGHTS ARE

As Data Subject, you have the right:

a. to access your Personal Data, for example by requesting a copy thereof from us;

b. to request correction of incomplete or inaccurate Personal Data;

c. to request deletion or removal of your Personal Data for a valid reason. However, we may not always be able to comply with a request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

d. to object to processing for a valid reason;

e. to request restriction of processing, for example, to request that we suspend the processing of Personal Data for a valid reason;

f. to withdraw consent at any time;

g. to lodge a complaint at any time with the Data Protection Commissioner of Mauritius (“DPC”).

IMPORTANT: If you wish to exercise any of the rights set out above or needs any clarification thereon, please contact us. We would appreciate the chance to deal with any of your concerns before you approach the Data Protection Commission, so please contact us in the first instance. We will try to respond to all legitimate requests within 1 month. It may take us longer than 1 month, if the request is particularly complex or if you made a number of requests. In this case, we will notify you and keep you updated.

J. THIRD PARTY WEBSITE

Our Website includes hyperlinks to, and details of, third party websites.  We have no control over, and are not responsible for, the privacy policies and practices of third parties.

K. COOKIES

1. Our Website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser.  The identifier is then sent back to the server each time the browser requests a page from the server.  Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.  Cookies do not typically contain any information that personally identifies a user, but Personal Data that we store about you may be linked to the information stored in and obtained from cookies.   We use only  on our Website”.

2. The name of the cookies that we use on our Website, and the purposes for which they are used, are set out below:

 a. We use Google Analytics, Google AdWords and Facebook on our Website to recognize a computer when a user “INCLUDE ALL USES THAT COOKIES ARE USED FOR ON YOUR SITE visits the website / track users as they navigate the website / enable the use of a shopping cart on the website / improve the Website’s usability / analyse the use of the Website / administer the Website / prevent fraud and improve the security of the Website / personalize the website for each user / target advertisements which may be of particular interest to specific users / describe purpose (s)”;

3. Most browsers allow you to refuse to accept cookies – for example;

a. you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;

b. you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop – down menu and unticking “Accept cookies from sites” and

c. you can block all cookies by accessing the “Customize and control” menu and clicking “Settings”, “Show advanced settings” and “Content settings” and then selecting “Block sites from setting any data” under the “Cookies” heading.

4. Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

5. You can delete cookies already stored on your computer – for example:

a. In Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at

(http://support.microsoft.com/kb/278835);

 b. In Firefox (version 24), you can delete cookies by clicking “Tools”, “Options”, and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and

 c. In Chrome (version 29), you can delete all cookies by accessing the “Customize and control” menu and clicking “Settings”, “Show advanced settings”, and “Clear browsing data”, and then selecting “Delete cookies and other site and plug – in data” before clicking “Clear browsing data”.

6. Deleting cookies will have a negative impact on the usability of many websites.

L. CHILDREN’S PRIVACY

We do not knowingly collect Personal Data from anyone under the age of 18.  If you are a parent or guardian and you are aware that your children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

M. APPLICABLE LAW & COMPETENT COURTS

1. This Privacy Policy is subject to Mauritian Law.

2. Any dispute arising in connection with the present policy shall be settled under the Mediation Rules of the Arbitration and Mediation Center of the Mauritius Chamber of Commerce and Industry (MARC).

3. In the absence of any settlement pursuant to paragraph M.2 above, the dispute shall be referred to the competent Mauritian Courts.

 N. CONTACT US

• If you have any questions about this Privacy Policy, please contact us:
  • Contact person : Ida Kurmoo
  • Title: Responsable Formation et Réseaux Sociaux
  • Phone number: 58476804
  • By email: beauty@sddm.mu