Introduction
This Data Protection Policy sets out VFS International Ltd’s (“VFS”) commitment to safeguarding personal data in compliance with the Data Protection Act 2017 of Mauritius. It outlines how personal information collected, stored, and processed by the Company is handled in a manner that is lawful, fair, and transparent.
This policy also explains your rights regarding your personal data and our obligations in ensuring the protection of your privacy. By engaging our services, you acknowledge and agree to the terms and conditions outlined in this policy.
Scope of the Data Protection Policy
This policy applies to all employees, contractors, and third-party service providers of VFS who have access to personal data maintained by the firm. It covers the personal data of:
- Clients (policyholders and investment clients),
- Prospective clients,
- Employees and job applicants, and
- Any other data subjects whose personal data is held by the company.
Information Collection and Use
VFS collects personal information when you engage with our services, for example, when you contact us, subscribing to our newsletters, invest, or making inquiries. The type of personal data we may collect include:
- Personal identification information (e.g., name, email, residential address, phone number)
- Financial details and investment profiles, required for the provision of financial advice
- Policy or product-related information
- Risk assessment data
- Screening and ongoing monitoring results
The information is collected and processed to deliver, maintain, and improve our services. It enables us to process transactions, maintain communication, and tailor marketing efforts in line with your preferences and applicable legal and regulatory obligations.
Data Security
VFS implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or disclosure. These include:
- Password-protected systems and access controls,
- Secure storage of physical documents,
- Regular staff training on data protection,
- Confidentiality agreements with employees and third parties,
- Incident response procedures for data breaches.
Who We Share Your Data With
We will endeavor to maintain all personal data in accordance with our internal policies governing the use and disclosure of confidential information. Your data will only be used for purposes for which it was collected, or as otherwise permitted or required by law.
Where necessary, we may share your information with third parties strictly on a need-to-know basis in line with data protection requirements. These third parties may include:
- Our Service Providers and Franchisees (including their sub-contractors), in order to facilitate and maintain the provision of our services.
- Appointed Auditors, Accountants, Lawyers, Consultants or other professional advisers to the extent necessary for them to advise us appropriately;
- Regulatory and Government Authorities, including but not limited to the Mauritius Revenue Authority, Financial Services Commission, Financial Intelligence Unit, Data Protection Office as required under applicable laws and regulations;
- Any third party involved in a restructure, merger, acquisition, or sale of any entity within the VFS Group, provided that such recipient agrees to use your information for the same purposes for which it was originally collected;
- Any transferee of our rights and/or obligations under the agreement we have with you;
- Any individual or party you have expressly authorised to provide instructions or receive information for the administration of your services with us;
- Any person you request us to share your information with;
- Businesses that are legally part of the VFS Group of Companies, or that may become part of the Group in future;
- Any other party, where disclosure is required or permitted by law or regulation, or where VFS has a legal or regulatory obligation to do so.
VFS will not lend or sell your information to third parties, but we may provide access to your personally identifiable information when legally required to do so, to cooperate with police investigations or other legal proceedings, to protect against misuse or unauthorized use of our website, to limit our legal liability and protect our rights, or to protect the rights and safety of visitors to our website. In those instances, the information is provided only for that limited purpose.
International Transfers – Sharing Your Information to other jurisdictions
In accordance with the DPA 2017, VFS may share your personal information with our service providers, which may involve the transfer of such data to jurisdictions whose data protections laws may not offer the same level of protection as those applicable under this policy.
Where personal data is transferred outside of Mauritius, VFS will ensure that such transfers are carried out in compliance with the Data Protection Laws and Regulations. Appropriate safeguards will be implemented to ensure that, as far as reasonably possible, an equivalent level of data protection is maintained.
VFS may also share your information with other entities legally forming part of the VFS Group of Companies, strictly for the purpose of providing our services to you. Access to relevant investor data will be limited to authorised data controllers, and only to the extent necessary for the performance of their duties.
How We Keep Your Personal Data
VFS is committed to retaining your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable laws and regulations. This includes retaining your information for a reasonable period following the end of your investment or client relationship with us.
In the absence of specific legal, regulatory, or contractual obligations, personal data will be retained for a period of seven (7) years after the termination of the relationship. However, in certain circumstances—such as ongoing regulatory enquiries or inspections—we may be required to retain the information for a longer period.
All personal data will be destroyed / deleted after the retention period.
Data Protection Officer
The company has appointed a Data Protection Officer (“DPO”) responsible for overseeing compliance with this policy and serving as the point of contact for data subjects and regulatory authorities.
Contact: Data Protection Officer
Clement Li
info@vfsint.com
Office: +230 466 3852
Fax: +230 466 3851
10th Floor, Tower 1, NeXTeracom Building,
Cybercity Ebene,72201, Mauritius
Accuracy Of Your Personal Information
VFS endeavors to ensure that the personal information we hold about you is accurate, complete, and up to date. If you believe that any of the data we hold is incorrect or outdated, you have the right to request a correction. Upon receiving such a request, we will take all reasonable steps to rectify the information without undue delay.
Changes in use of Personal Data
Should there be any change in the way we use your personal data, we will promptly inform you. We will explain the reasons for the change, the new purposes for which we are using your data, and the legal basis for such use.
Confidentiality & Data Security
VFS is committed to maintaining the confidentiality of your personal information in accordance with our internal policies governing the use and disclosure of confidential data. We will only use your personal data for the purposes stated. We take the protection of your personal data very seriously and have implemented appropriate measures to ensure that it is stored securely and protected against unauthorized access.
We will not share your personal information with any third parties outside VFS, unless required by law.
When we engage external service providers to process personal data on our behalf in order to assist with providing, maintaining, and operating the services we offer, we ensure that appropriate data protection agreements are in place. All data transfers between VFS and external service providers are conducted through secure means to safeguard your information.
Protection of Children’s privacy
VFS recognizes the importance of safeguarding the privacy and safety of children who may use our services. As such, we do not permit children to use our services without verifiable consent from their parents or guardians. In the event that we discover that we have inadvertently collected personal information from a child without obtaining verifiable consent, we will take immediate action to delete such information without undue delay.
Marketing Communications
If you are an account holder, investor, business contact, or newsletter subscriber covered by this Policy, we may update you with information about our products and services, as well as those of other companies within the VFS Group, that we believe may be of interest to you. This could also include news and insights related to the financial markets and financial services.
Such information will be sent via email to the contact details you have provided to us. We will always seek your consent before using your personal email address or any other information for marketing purposes.
While using our services, you can specify your communication preferences or opt out of receiving any marketing updates. Should you choose to receive marketing communications, you have the right to change your preferences or withdraw consent at any time by contacting us, as outlined under ‘Contact Us’ below.
Furthermore, we will ensure that any third-party companies that assist us in marketing our products and services, or with whom we have joint marketing agreements, are bound by contractual obligations to protect the confidentiality of your personal information. These third parties will be permitted to use your personal data solely for the purpose of providing the services we have requested them to perform.
Legal grounds for processing Personal Data
Data protection laws provide organizations like VFS with several conditions under which we are permitted to process your personal data lawfully. We will only use your personal information when one or more of the following legal grounds has been satisfied:
- Consent of the data subject
- Performance of a contract with a client
- Compliance with legal obligations
- Legitimate interest pursued by the Company (e.g., risk management, fraud prevention)
Data Subject rights
In accordance with the Data Protection Act 2017 (DPA 2017), data subjects have the following rights:
- Access: You have the right to access personal information about you and to obtain a copy of it.
- Rectification: You may request the rectification or completion of any personal information that is inaccurate or incomplete.
- Restriction of Processing: You can request that we restrict the use of your personal information, such as for marketing purposes.
- Objection to Processing: You have the right to object to the processing of your personal information.
- Data Portability: In certain circumstances, you may receive your personal information in a structured, commonly used, and machine-readable format and transfer it to another data controller, where technically feasible.
- Erasure: You can request the erasure of your personal information under specific circumstances.
- Automated Decisions: You have the right to be informed about any automated decision-making processes affecting you and to obtain meaningful information about the logic, significance, and consequences of such processing.
- Prevention of Harm: You may prevent the processing of your personal data that is likely to cause unwarranted and substantial damage or distress to you or another individual.
- Complaint: You have the right to make a complaint to the Data Protection Office regarding the use of your personal data.
If you wish to exercise any of these rights, please contact our Compliance Department using the contact details below. In some cases, we may request additional information to verify your identity.
Please note that if a personal data breach occurs, we will notify you within 72 hours of its discovery.
Use of Cookies and similar Technology
When data is provided to VFS, it is used solely for the purposes for which it has been given. We may use cookies and similar technologies on our websites and in our emails.
Cookies are small text files that may be stored on your computer or mobile device when you visit our website or interact with links in our emails. These technologies serve various purposes, such as enabling efficient navigation between web pages and remembering your preferences. In emails, they help us understand whether you have opened the email and how you have interacted with its content.
What Are Cookies?
Cookies are used on nearly every website and are small text files containing information that your computer or mobile device downloads when you visit a site. Upon returning to these websites – or visiting other websites that use the same cookies – your device is recognised, enabling the website to recall certain information.
For more details about cookies, visit www.aboutcookies.org or www.allaboutcookies.org.
You can disable cookies through the ‘options’ or ‘preferences’ menu in your browser settings. However, please note that some parts of our website may not function correctly if you choose to disable cookies. If you have any questions about disabling cookies, the above websites provide guidance on how to remove cookies from your browser, or you can consult your browser’s support.
We are required to obtain your consent before placing cookies on your device. When you visit our website, we will ask for your consent to use cookies and for the terms of use. Clicking “continue” when prompted will indicate your consent.
Use of Cookies at VFS
At VFS, we use cookies to collect information on how visitors interact with our website. The data collected helps us:
- Provide you with the best experience during your visit
- Facilitate easy access for our clients to navigate the website
- Offer services that allow users to access and manage their accounts
- Ensure the security of your online account when you log in
- Provide resources such as online Fact Sheets, Brochures, Research, Quarterly Commentaries, Terms of Business, User Guides, Forms, and Videos
- Monitor site traffic and track general visitor activity (note, this data is anonymous and does not reveal your individual location, software, or services)
- Gain insights into user behavior, which helps us improve the website and better serve our visitors
The cookies collect information in an anonymous form, such as the number of visitors to the site and the pages they visit. This data allows us to compile reports and enhance your overall website experience.
Limitations of Cookies used by VFS:
Please note, our cookies do not:
- Allow us to identify individual activities or preferences specific to you, unless you’ve provided this information.
- Contain personally identifiable information such as passwords or sensitive data.
- Enable us to access other data stored on your computer, smartphone, or web-enabled device, such as family-related information or documents on your hard drive.
- Provide us with details of other websites you visit or your activities across the internet.
- Store information in a format that others could read or interpret.
- Compromise your security or store information that may be detrimental to your privacy.
Types Of Cookies used on our website
We use three main types of cookies:
- Strictly Necessary Cookies: These are essential for basic navigation on our website and features such as logging in or viewing videos. They do not collect personal information for profiling or marketing purposes.
- Performance Cookies: These collect anonymous data on how visitors use our website, helping us to enhance its functionality. The data gathered is non-personally identifiable and is used solely to improve the performance and user experience of our online services.
- Functionality Cookies: These cookies remember specific preferences or choices you make while using our website, such as saving search settings or login details. The information they collect is anonymous and cannot be used to track your activity across other websites.
Third-Party Websites
If you follow a link from our website to another website, please be aware that the owner of the other website will have their own privacy and cookie policies. We recommend that you review these policies, as we are not responsible or liable for any actions or content on external sites.
Managing Cookies
Most web browsers allow you to manage cookies through the browser settings. You can choose to delete existing cookies, block new cookies, receive notifications when new cookies are placed, or disable cookies entirely.
Please note: If you share a computer or web-enabled device, any changes you make regarding cookies will affect all users of that device.
You can control how cookies are placed on your device and remove existing cookies by adjusting your browser settings.
Our Privacy & Cookie Policy Compliance
We have adopted this Privacy & Cookie Policy in accordance with the Data Protection Act 2017 and the EU GDPR, which took effect on May 25, 2018. While no changes have been made to our personal data usage practices, we aim to provide greater transparency on how we utilize your data. We Regularly Review Our Privacy & Cookie Policy. We may update the content on our website at any time, without prior notice. Therefore, we recommend that you review our Privacy and Cookie Policy each time you use this site. Accessing or using this site indicates your agreement to the version of the Privacy and Cookie Policy in effect at the time of your visit.
Contact Us
If you have any questions or concerns with regards to this Privacy & Cookie Policy, or if you aren’t happy with the way we use your information, please contact us using the details below:
Compliance Department
VFS International Ltd
10th Floor, Tower 1, NeXTeracom Building, Cybercity Ebene,72201, Mauritius.
Email: compliance@vfsint.com