Updated: 16th April 2020
No To Poverty is dedicated to protecting the confidentiality and privacy of information entrusted to us in accordance with the provisions of Electronic Transactions Act 2000 and Data Protection Act 2004 and as per the prevailing laws of Mauritius. Please read this Privacy Notice to learn about your rights, what information we collect, how we use and protect it.
Who are we?
No To Poverty is a Non-Profit Organisation and Non-Governmental Organisation incorporated in the Republic of Mauritius (NGO Registration No: 16378), operating under the domain name www.notopoverty,org
How to contact us for your Privacy concerns?
If you have questions or comments about this Privacy Notice or how we handle personal data, please contact us by email and we will endeavour to respond within 30 days from the date we receive any privacy-related communications.
How do we collect Personal Data?
Directly. We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us with their business card(s), complete our online forms, visiting our website, subscribing as Member or Beneficiary or Donor or Supporter or Volunteer, accessing our in-house training courses, attend meetings or events we host, visit our offices or for recruitment purposes. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our appointed representative(s).
Indirectly. For training and employment, we may obtain personal data about candidates from an employment agency, and other parties including former employers, and credit reference agencies.
By using the Services you and your business entity, if applicable, are agreeing to the Policies and the terms for amending the same (see our Terms of Service for additional information).
When you use the website and the Services you are voluntarily providing us with certain information about you. Certain portions of the website and Services will require you to provide us with additional information, which may allow us to identify you as a specific user and/or an individual. If you do not want to provide such information to us, then do not use the website or the Services. To stop receiving our emails, please click the link found at the bottom of each email.
- 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 information that we store about you may be linked to the information stored in and obtained from cookies.
We do not allow third-party advertisers to advertise on our website but we may post our own ads regarding our Activities on our website. We may also use the information we collect from you to provide you more relevant ads.
How your Information is used?
By using the Services, you consent to the following described uses of your information.
User information and content
- By providing your information to us, you acknowledge that your information may be used by us to identify you. Further, the basic information on your profile (for instance, your name and photo) will be available to other users of the website. And further, if you provide any additional content on our Forums, such as photos, text and other works, such content will be available to other users of the Forum.
- We may also use your information to customize the Services for you and to enhance your experience on the website, including use of your information by our affiliates and contractors to provide the Services to you. However, we take the privacy of our users very seriously, and , except as described in the Policies. We also will not share your personally identifiable information that you share with us without your express consent. Notwithstanding the foregoing, we may share said information, and your consent to the same, when disclosure is reasonably necessary in our opinion to comply with legal process or to enforce the Policies.
- We may use your information to communicate with you using various means, including email, notices on the website, messages to you through other services, and through other means. If you provide us with information to allow us to connect with you using your mobile device, then you will be responsible for any charges that your carrier may bill to you as a result of such communications.
- If you create an account and/or activate your Forum, then other users may be able to contact you directly using the Services. Any information you share with other users in such communications will obviously be shared with them and also with us.
- If you provide us with your telephone number, then you consent and agree to: our calling you about your Support, your Account, your Training and other matters related to our programmes; our use of automated calling devices; and our recording of your phone calls so that we may have accurate records and maintain quality service.
What Personal Data do we collect?
We may obtain the following categories of personal data about individuals through direct interactions with us, or from information provided through client engagements, from applicants, our suppliers and through other situations including those described in this Privacy Notice.
Personal Data. Here is a list of personal data we commonly collect to conduct our activities.
- Contact details (e.g. name, job title, telephone number, email and postal address).
- Professional details (e.g., job, career history and educational background).
- Family and beneficiary details for insurance and pension planning services (e.g., names and dates of birth).
- Financial information (No bank details or any financial information).
- Your Photo for issuing of the Company Photo ID Card, if applicable
- CCTV at our sites may collect images of visitors. Our policy is to automatically overwrite CCTV footage within 30 days.
Sensitive Personal Data.
We typically do not collect sensitive or special categories of personal data about individuals other than our own employees. When we do need to process sensitive personal data from data subjects who are not our employees, it is either on the instructions of a third party, with the express consent of the individuals or as required by law. Examples of sensitive personal data we may obtain, or otherwise hold, include:
- Personal identification documents that may reveal race, religion or ethnic origin, possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
- Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.
- Information provided to us by our clients in the course of a professional engagement.
What lawful reasons we have for processing Personal Data?
We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:
Contract – We may process personal data in order to perform our contractual obligations owed to (or to enter into a contract with) the relevant individuals.
Consent – We may rely on your freely given consent at the time you provided your personal data to us.
Legitimate Interests – We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced.
Legal obligations – We may process personal data in order to meet our legal and regulatory obligations or mandates.
Why do we need Personal Data?
We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:
- Authenticating registered users to access our services.
- Forwarding details to our Appointed Training Partner to tailor-made a suitable training program for the personal development of our Registered Members in their career, and this may be governed by different Privacy Terms and Policies.
- Processing online requests, including responding to communications from individuals or requests for proposals and quotations.
- Travel arrangement assistance.
- Complying with legal and regulatory obligations relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime.
- Providing professional advice and delivering reports related to our tax, advisory, audit and assurance, pension scheme administration, restructuring, mergers and acquisitions and other professional services. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client.
- Promoting our professional services, products and capabilities to existing and prospective business clients.
- Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
- Administering, maintaining and ensuring the security of our information systems, applications and websites.
- Compiling health and safety data (directly or indirectly) following an incident or accident. Indirect data can take many forms including an incident report, first aider report, witness statements and CCTV footage.
Do we share personal data with third parties?
We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:
- for administrative purposes and to provide professional services
- Parties that support us as we provide our services (e.g., providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services).
- Our professional advisers, including lawyers, auditors and insurers.
- A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of our business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it.
- Payment services providers.
- Law enforcement or other government and regulatory agencies (e.g. MRA) or to other third parties as required by, and in accordance with, applicable law or regulation.
- Training services providers.
- To our clients for Training and Empowerment services
What are your data Protection rights?
- You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
- You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
- You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
- Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
- Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
- Automated Individual Decision-making – You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
- Right to Object to Direct Marketing including Profiling – You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
- Right to Withdraw Consent – You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
If you would like to exercise your Data Subject Rights, you can contact us directly. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
- the payment of a £10 admin fee and the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor plus an original copy of your current utility bill).
What about personal data security?
We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.
If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.
How long do we retain personal data?
We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these purposes, we retain such personal data for seven years.
Do we change this Privacy Notice?
We regularly review this Privacy Notice and will publish any updates on this webpage.
- Any updates posted shall be effective immediately upon publishing.
- You should check this page occasionally to ensure you are happy with any changes to this policy.