Privacy Policy

Our commitment to Data Protection

Muhabura Capital Ltd (“MCL”) as a regulated, financial services provider, is dedicated to safeguard personal information of its stakeholders. The Data Protection Act 217 (‘’DPA’’) places an obligation upon MCL, as a Data Controller, to collect and use personal data in a responsible and accountable manner. Our Policy applies to anyone[1] who interacts with us, who enquires about our products and services or who makes use of them, via any media including email, website, telephone, etc.

This commitment is powered by our Compliance Team who have an oversight on the use of personal data in our services. All our employees acknowledge the importance of data protection through our Code of Ethics which outlines the standards of appropriate conduct expected from our employees, and which accentuates on all the obligations we place on them, including that of confidentiality. 

Confidentiality is fundamental to MCL’s business, and this document illustrates how we process your personal data to give you transparency. It also informs you of your rights regarding your personal data.

[1] Prospective client, client, employee, consultant, or agent providing services to MCL or to whom MCL provides services.

What personal data do we collect?

Personal data relates to any information about a natural person that makes you identifiable.

MCL gathers and processes a range of data about everyone we directly or indirectly deal with.  Such data might include (but is not limited to):

(i) Personal details:

  • Names;
  • Date of Birth;
  • Occupation/ profession;
  • Nationality;
  • Marital Status;
  • Country of residence;
  • Tax Identification Numbers/ social security numbers;
  • Qualifications;
  • Employment history;
  • Your home and professional addresses;
  • Your work and personal contact details such as e-mail addresses, postal addresses and/or telephone number;
  • Payroll and accounting data; and
  • Bank account details.

(ii) Information about entities/ organisations or institution with which you are related such as:

  • Banking and/ or any other service providers;
  • Entities in which you hold an interest;
  • Your advisor;
  • Your intermediary/ agent; and
  • Your employer.

(iii) Identification documents such as passport, ID card, driving licence or any other documents required by the laws of the Republic of Mauritius.

(iv) Address verification documents such as utility bill, bank statement, credit card statement, bank reference letter or professional reference letter or any other Information required by the laws of the Republic of Mauritius or provided through our recruitment process such as CVs.

(v) Contact details of people with whom you are connected, including your immediate family or next of kin.

(vi) Information which you provide to us while corresponding with us.

Why we process your personal data?

MCL is licensed by the Financial Services Commission of Mauritius to offer investment banking activities. Under our licensing conditions and within the legal and regulatory framework in Mauritius, we are required to undertake “Customer Due Diligence” on our clients in their capacity as a principal of an entity to which MCL provides/shall provide services. Your personal data is essential in order to provide you with the following services:

  • an investment dealer (full-service dealer, including underwriting),
  • investment adviser (unrestricted), and
  • investment adviser (corporate finance advisory)

All information provided to us is strictly confidential and are not disclosed or revealed to any person or party whatsoever unless we are legally required to do so to a regulatory body or a court of competent jurisdiction in Mauritius or abroad. 

All personal data are processed at our registered office in Mauritius. In certain instances, MCL may be called upon to disclose and transfer personal data to certain jurisdictions which do not afford or guarantee that appropriate safeguards are in place to protect such personal data. In that connection, by providing us with your consent to such disclosure and transfer, you understand and expressly agree that there may be risks involved in such disclosure and transfer being made.

To whom we may disclose your personal data?

MCL may disclose your personal data in the following instances:

  • To authorities such as the Registrar of Companies (ROC), Financial Services Commission (FSC), Mauritius Revenue Authority (MRA) and Financial Intelligence Unit (FIU) for any legal or regulatory requirement; and
  • To third parties including but not limited to banks, financial institutions, legal professionals, auditors, IT service providers under the terms and conditions of a contractual arrangement or appropriate delegation.

The authorised third parties may however process your personal data abroad and may have to divulge it to foreign authorities for example, in cases relating to anti money laundering and combating financing of terrorism.

In such occurrences where third parties act as data processors, we shall ensure that there is a proper agreement in place and that your personal data is processed according to applicable laws.

For how long do we keep it?

Personal information held by MCL may be retained and stored for a period after the relationship with the counterparty has ended. The storage period is determined by the Data Protection Act 2017. Information held by MCL will be retained as long as the purpose for which the information was collected continues.

After the end of the regulatory retention period, MCL undertakes to securely destroy your personal data, except where it is required in litigation, or has been requested by a Supervisory Authority or other law enforcement agency, or where you have requested that your personal information be retained. (and have paid an approved fee to do so).

Limitation of Liability

 

MCL ensures that your personal data is always treated diligently and carefully by our organisation. Our aim is to retain and process your personal information in compliance with market standards.

Whilst MCL has taken every reasonable care to ensure the implementation of appropriate measures for security of your personal data, we cannot guarantee the safeguard over the internet, via email or via our website, nor do we accept, to the fullest extent permitted by law, any liability for any errors in data transmission, machine, software or operating error or any other cause. 

What are your rights as Data Subject?

Change in personal details

  • If you believe that the personal data we hold relating to you is incorrect or incomplete, you may request to see this information, rectify it or have it deleted by contacting your usual contact at MCL or send us email on the following:compliance@muhabura.com.

Complaint

  • Should you wish to make a complaint on the way we have handled your personal data, please contact your usual contact at MCL or send us an email on compliance@muhabura.com. We will get in touch with you to resolve the matter.
  • If you still feel that your personal data has not been handled appropriately according to the law, you may contact the Data Protection Office in Mauritius on the following address and file a complaint with them:

Level 5, SICOM Tower

Wall Street

Ebene Cyber City

Ebene

Republic of Mauritius

Tel: 4600251 Fax: 4897341

Email Address: dpo@govmu.org.

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