Privacy Policy

1. Privacy Policy

This Policy is issued by Accresco Investment Management Ltd. References in this Policy to “Accresco” are references to Accresco Investment Management Ltd, any affiliated entities and its subsidiaries. It concerns individuals outside our organisation, including visitors to our websites, customers and suppliers with whom Accresco interacts in one way or the other.

This Policy is expected to be updated from time to time to reflect changes towards the processing of personal data or any changes as applicable with regards to the Mauritius Data Protection Act 2017 (the “Act”). Accresco highly encourages concerned users to read our Privacy Policy at regular intervals and to review any amendments Accresco might make.

Reference in this Policy to “Personal Data” means any information that identifies, or could reasonably be used to identify, a living individual, either on its own or together with other information.

2. Processing your Personal Data

Collection of Personal Data: Accresco may collect your Personal Data from different sources, namely:

  • When you contact us via email or telephone or by any other means of communications;
  • As part of our client on-boarding procedure;
  • When managing transactions for or on behalf of customers; and
  • When you visit our website.
  • Generally, you will have provided any such data to us. However, in some cases, we may collect data about you from a third-party source, such as government or other agencies, a service provider or from public records.
  • Creation of Personal Data: Accresco creates personal data about you, such as records of your interactions with Accresco, and details of your accounts, subject to applicable law.

     

Relevant Personal and Sensitive Personal Data: Accresco may process the following categories of personal data, such as:

  • Personal Details: first and last name, middle name, gender, date of birth or age, marital status, ID number, passport number, nationality, photographs
  • Family Details: names and contact details of family members
  • Contact Details: address, telephone and mobile numbers, email address
  • Employment Details: names of current and former employers, work address, work telephone number, work email address and work-related social media profile details
  • Education History: details of your education and qualifications
  • Financial Details: billing address, bank account numbers, credit card numbers, cardholder or accountholder name and details, instruction records, transaction details
  • Electronic Identifying Data: IP addresses, cookies and geolocation data


Processing your Sensitive Personal Data: Accresco does not seek to collect or otherwise process your personal data except when:

  • required by law
  • Accresco has obtained, subject to applicable law, your explicit consent prior to processing your Personal Data.


Purposes for which we may process your Personal Data, and legal bases for Processing: Whether we receive your Personal Data directly from you or from a third-party source, Accresco will only process your personal data for the purposes listed below, subject to applicable law:

  • AML and KYC
  • Client on-boarding
  • Providing Services to you
  • Marketing and/or Prospecting
  • IT and Information Security operations
  • Analytics
  • Physical Security
  • Legal matters (for e.g. investigations, legal compliance and legal proceedings)
  • Fraud prevention
  • For any purpose related to the foregoing or for any purpose for which you provided the personal data to Accresco.

3. Disclosure of Personal Data to third parties

Accresco may also need to transfer and disclose your personal data to other related companies affiliated to Accresco and/or third parties (including Sub-Processors) involved in your matters, for legitimate business purposes, in accordance with applicable laws. Where Accresco transfer or disclose your personal data, Accresco will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure its integrity and protection. Accresco shall procure that each Sub-Processor enters into a written agreement subjecting such Sub-Processor to equivalent obligations with respect to Personal Data that are imposed on Accresco under this Policy and under the Act.

4. International Transfer of Personal Data

Accresco has international customers and business ventures and Accresco may need to transfer your personal data and to other related companies within the group in connection with the purposes set out in this policy. All our data resides on private cloud in Microsoft data centres in the northern Europe.

5. Data Security

Accresco has implemented the appropriate physical, technical and organisational security measures which ensures a level of internal security designed to protect your personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing of your Personal Data, in accordance with the applicable law. You are responsible for ensuring secure sending of your personal data to Accresco.

6. Data Accuracy

Accresco takes reasonable steps designed to ensure that:

  • your personal data that we process are accurate and where necessary, kept up to date, and
  • any of your personal data that Accresco processes and are considered inaccurate are erased or rectified without further delay.

Accresco may request you to confirm the accuracy of your personal data from time to time.

7. Data Minimisation

Accresco takes reasonable steps designed to limit the collection of personal data to what is directly relevant and necessary to accomplish specific purposes set out in this policy.

8. Data Retention

Accresco takes reasonable steps to ensure your personal data, subject to any applicable law, are retained for only as long as it is necessary to fulfill the purposes set out in this policy.

9. Your Legal Rights

Subject to applicable law, you may have a number of rights regarding the processing of your personal data, including:

  • the right to request access to, or copies of, your personal data that Accresco processes or control together with information regarding the nature, processing and disclosure of those personal data.
  • the right to request rectification of any inaccuracies in your personal data that Accresco processes or controls.
  • the right to request, on legitimate grounds
  • erasure of your personal data that Accresco processes or controls
  • restriction of processing of your personal data that Accresco processes or controls.
  • the right to have your personal data that Accresco processes or controls transferred to another controller; to the extent applicable.
  • where Accresco processes your personal data on the basis of your consent, the right to withdraw that consent anytime.
  • the right to lodge complaints with a Data Protection Office of Mauritius regarding the processing of your personal data by Accresco or on Accresco’s behalf.

10. Direct Marketing

Accresco may process your personal data to contact you, primarily by email and also by telephone, so that we can provide you with information concerning services that may be of interest, provided that we have first obtained your consent, to the extent required by,  in accordance with applicable law. If you do not wish to receive marketing communications from Accresco, you can opt-out at any time by contacting your regular Accresco’s contact or by electronically unsubscribing from emails Accresco have sent you. After you have unsubscribed, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

11. Contact Details

If you have any comments, questions or concerns about any of the information in this policy, or any issues relating to the processing of personal data by Accresco, please contact your regular Accresco’s client service contact:

12. Cookie Policy and Consent

WHAT IS A COOKIE?

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. if you agree, it enables our website to remember your actions and preferences such as login, language, font size and other display preferences so you don’t have to re-enter this information every time you land on our website. Cookies contain that information that is transferred to your computer’s hard drive.

USE OF COOKIES ON OUR SITE

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We do not use targeting cookies.


Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

HOW DO YOU CHANGE YOUR COOKIE PREFERENCES?

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.