Privacy Policy
Background and Scope
This website is operated by Stewards Inc (herein after referred to as “Stewards ” or “we” or “us”), a company duly incorporated under the laws of Mauritius. Please see the ‘About Us’ section on our website for more information about Stewards.

Stewards takes privacy and the protection of personal data very seriously, and we implemented relevant policies, processes and procedures, including this website privacy policy (hereinafter referred to as “Privacy Policy”) to demonstrate our commitment towards this. Going through this Privacy Policy, we explain how we collect, use and disclose personal data (as applicable) as required by prevailing legislations, or as we require for performing our contractual obligations, responsibilities and/or operating our business.
Definition
Please find below some terms and expressions as used in this Privacy Policy. These shal be interpreted in accordance with prevailing Data Protection Legislations, including but not limited to the Mauritius Data Protection Act 2017 (“DPA”) and the General Data Protection Regulation 2016/679 (“GDPR”), as applicable.

“Consent” means any freely given specific, informed and unambiguous indication of the wishes of a data subject, either by a statement or a clear affirmative action, by which he signifies his agreement to personal data relating to him being processed;

“Data Subject” means an identified or identifiable individual, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual;

“Personal Data” means any information relating to a data subject;

“Restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future;
“Special Categories of Personal Data” means personal data pertaining to:
a. his racial or ethnic origin;

b. his political opinion or adherence;

c. his religious or philosophical beliefs;

d. his membership of a trade union;

e. his physical or mental health or condition;

f. his sexual orientation, practices or preferences;

g. his genetic data or biometric data uniquely identifying him;

h. the commission or alleged commission of an offence by him;

i. any proceedings for an offence committed or alleged to have been committed by him, the disposal of such proceedings or the sentence of any Court in the proceedings; or

j. such other personal data as the Commissioner may determine to be sensitive personal data;

“Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Processing” means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Processor” means a person who, or public body which, processes personal data on behalf of a controller;

“Third party” means a person or public body other than a data subject, a controller, a processor or a person who, under the direct authority of a controller or processor, who or which is authorised to process personal data.
Our Website
This Privacy Policy also relates to the use of our website, and will apply to the personal data that we collect and process about you while you are browsing same.

Note that there may be links to third party websites on our website (example Facebook, Linkedin or Youtube). We do not have any control and accept no responsibility regarding the manner into which third party websites are operated, collect or process personal data. For privacy information relating to these other third party websites, we recommend that you consult their relevant privacy policies, as appropriate.
When do we collect your personal information?
When you are enquiring or subscribing to any of our services;

When we retain services of any service provider;

When you send us emails;

During meetings, if we take notes or record meetings. To note that recording meetings is not our usual practice and we will ask your consent if we wish to do so;

When you use our website;

When you attend any event that we make;

When we provide you with funding or sponsor you.
Collection and use of your personal information
The personal data collected and stored by us include, but are not limited to information relating to your/your client:

identification details (name, contact details, national identity number, passport number);

email address;

phone number:

physical address;

professional details;

Nationality;

Country of residence;

Information provided by yourself for recruitment purposes;

Details regarding feedbacks on our services;

Technical details, including the Internet Protocol (IP) address used to browse our website, frequency of visits, or other similar details;

TIN or its equivalent;

Banking details  

Note that:

We may also collect personal data classified as Special Categories of Personal Data.

Our website is not intended for use by children [under the age of 16] and we do not knowingly collect or use personal information of children.
Purpose of processing
Kindly note that we use your personal data for the following:

For the performance of a contractual / pre-contractual agreement;

To abide by legal obligations imposed on us;

For recruitment purposes;

For collecting feedbacks and appreciations on our services; and

For the enhancement of our services and your browsing experience on our website.
Legal basis for Processing
For the processing of personal information, we are required to have a legal basis to rely on, which may vary depending on what information we process and why. The legal bases we may rely on include:

Consent

This is where you have expressly provided us with a clear consent for us to process your personal information for a specific purpose.

Contract

This is where the processing of your personal information is necessary for the performance of a contractual obligation between us, or because you requested us to take specific steps towards entering into a contract.

Legal Obligations

This is where we are legally obliged to process your personal information, in accordance with prevailing laws.

Legitimate Interest

This is where we process your personal information for our legitimate interest.
With whom is your personal data being shared?
Your personal data may be shared with specific organisations, for the sole purpose of Stewards to perform its contractual or legal duties. In effect, your personal data may be shared with:

Postal services;

Companies with which we have a joint venture or an agreement;

Regulatory authorities and/or any other relevant authority;

Companies you ask us to share your personal data with;

Service providers with which we have a contractual service agreement with;

Affiliate companies of Stewards; Auditors;

Legal Professionals;

and Any other third parties to whom your personal data is shared upon your request or consent.
How to Complain
We hope that our data protection officer can resolve any query or concern you raise about our use of your information. Do not hesitate to contact us on dataprotection@stewards.global should you require any further information or wish to complain about the processing of your personal data by Stewards.

You also have the right to complain directly to the Data Protection Office (https://dataprotection.govmu.org/SitePages/Index.aspx) Changes to this Privacy Policy.

This Privacy Policy was published to provide you with all information you should legally know about the manner into which we process your personal data. We may change this Privacy Policy from time to time without prior notice. If changes occur with regards to the specific processing of your information, we will inform you via email directly.
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