PRIVACY NOTICE

GWS Technologies Ltd (“GWS“, “we”, “us”, “our”, “the Company”) respects your privacy, and is committed to protecting the privacy, confidentiality and security of the personal data provided to us when we act as Controller (for example when you use our website, when you contact our office, or when you otherwise interact with us) and when we act as Processor (for example when we process your data on behalf of our clients who subscribes to our services). 

As your trust is prime to the success of our business, we are committed to protect your personal data in compliance with applicable data protection laws. 

Please read this privacy notice carefully as it contains important information on how GWS, as a registered data controller and data processor with the Mauritian Data Protection Office, treats the personal data that you provide us including how and why we collect, store, use and share your personal data, your rights in relation to your personal data and on how to contact us and the regulatory authorities in the event you have a complaint. 

Except as described in this privacy notice, we will not, without your express consent, sell or rent to any third party any of your personal data.

1. Who are we?

GWS is a private company incorporated in Mauritius offering various services related to website development, cloud hosting, and digital marketing, data driven communication. Our registered office and principal place of business is situated at:

Silicon Avenue 

Suite 102, 

Catalyst Building 

72201 Ebene Cybercity 

MAURITIUS

2. What personal information do we collect from the people that visit our blog, social media pages, website or app?

When you place an order, register on our site, interact with us, respond to a survey, fill out a form, use Live Chat, Open a Support Ticket or enter information on our site, provide us with feedback on our products or services, as appropriate, we may collect the following personal data for the purposes of our business activities: 

• your name,
• email address,
• mailing address,
• phone number,
• CV when you apply to a job,
• Any other personal data necessary to fulfill your special requests; and
• Any other personal data that you choose to provide to us.

Also, when you choose to receive our marketing communications (including newsletters, promotional and special offers), we ask that you provide us with your email address. The provision of this information is purely voluntary, and you may opt out of receiving our marketing communications at any time by unsubscribing to these communications. 

3. What personal information do we collect on behalf of our clients using our services?

As an end-user of the services offered to our clients, we may process on their behalf, your name, surname, email address, phone number, home address, cookie related information, conversion tracking tags, or any other information that you choose to provide on their website. Our clients’ websites are governed by their privacy policy.

4. How and why do we use your personal data?

We use your personal data in the course of our business activities (detailed in section 3 and 4) and interaction with you for the following purposes: 

• To perform our agreement with you (as a client);
• To deliver our services to our clients and where we act as processor of end-users’ data;
• To do conversion modeling and measurement data for statistical and advertising purposes;
• To promote eventual business relationships; 
• To assist you with your queries or concerns;

• To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
• To improve our website in order to better serve you;
• To allow us to better service you in responding to your customer service requests;
• To administer a contest, promotion, survey or other site feature;
• To quickly process your transactions;
• To ask for ratings and reviews of services or products;
• To follow up with them after correspondence (live chat, email or phone inquiries).
• To send you emails about our special offers, products and services, and other communications from time to time.
• To comply with any legal or regulatory obligations imposed on us;
• To fulfill our legitimate commercial interests; and 
• To treat your applications for specific job vacancies or on a spontaneous basis;

5. To whom do we disclose personal data?

Your personal data may be shared as follows:

• between and among subsidiaries and affiliates of GWS as may be relevant for the purposes set out in section 4 above and to facilitate our business activities or relationship, but we shall only do so on a strictly need to know basis;
• with our employees for purposes of fulfilling our business activities, treating job applications or conducting internal analysis with a view to improving our company and services;
• with our agents, advisers, accountants, auditors, lawyers, other professional advisors, contractors or third-party service providers for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;

We will ensure that your personal data is kept safely. Only designated persons will have access to your personal data on a strictly need-to-know basis for the purposes of fulfilling our agreement or promoting our business relationship with you. In addition, third parties with whom we share your personal data will be contractually obliged to safeguard all personal data to which they have access. 

Some disclosures do not require your consent. This happens when we share your personal data with (i) law enforcement bodies/agencies and other statutory authorities, if required by law and (ii) If required or authorized by law or if we suspect any unlawful activities on your part.

Where we have collected your personal data on behalf of another party, the use of your personal data by that party is governed by their privacy policy for which we are not responsible. We may also disclose aggregate or de-identified/anonymized/encrypted data that is not personally identifiable with third parties, including our commercial and strategic partners.

Our trusted third parties and processors

For our business activities, we have selected several processors/ trusted third parties (listed below) to provide the necessary services for the functioning of our clients’ website, conducting our business, or servicing our clients. Such trusted parties may have access to personally identifiable information on a need-to-know basis and will be contractually obliged to keep your information confidential. These may include, in particular, data centers that store websites and databases, IT service providers that maintain our systems, consent management companies for website cookies, or emailing services. 

If we pass on data to processors, they may only use the data to fulfill their tasks. The processors have been carefully selected and the clients remain responsible for all non-GWS products and third-party licenses selected, as per the Acceptable Use Policy & Terms and Conditions.

Processor	Function	Data processing	Location	Privacy Policy of processor for further information
Google Partner	Communication, filling, hosting of websites, advertising, statistics and analytics	Storing and sharing of data, hosting websites, collecting data for advertising, use of cookies and collection of 1st party data for conversion tracking and attribution, collection of website usage statistics within Google Analytics	Various – worldwide	https://policies.google.com/privacy
Kinsta	website hosting	Website hosting and back up	London	https://kinsta.com/legal/privacy-policy/
WordPress	website creator	Not applicable	–	https://automattic.com/privacy-notice/
Cloudflare	FirewallCDN	Content Delivery Network and Firewall	USAEurope	https://www.cloudflare.com/privacypolicy/
WooCommerce	e-commerce website creator	Not applicable	–	https://automattic.com/privacy-notice/
Cookiebot	Cookies management consent	Cookies Consent	USAEurope	https://www.cookiebot.com/en/privacy-policy
Blogvault	Backup and security	Website backup and malware scanning	GermanyEurope	https://blogvault.net/privacy
Mailchimp	Emailing platform	Automation  of emailing system	USA	https://www.intuit.com/privacy/statement/
Jira Service Management	Help desk	contact details when you log a ticket	EuropeUSA	https://www.atlassian.com/legal/privacy-policy#what-this-policy-covers
DigitalOcean Partner	Server Backup Disaster Recovery	Backup of website files and database	Frankfurt, Germany	https://www.digitalocean.com/legal/privacy-policy
Facebook	social media	Conversion modeling and measurement data for statistical and advertising	Worldwide	https://www.facebook.com/privacy/policy/?section_id=0-WhatIsThePrivacy

6. Overseas Transfers of Your Personal Data 

In some cases, we may need to transfer your personal data with organisations located in countries outside our territorial limits in order to provide our services to you. We will take appropriate safeguards in order to secure the personal data being transferred.

Refer to section 5 for additional information on overseas transfers of personal data taken place with our processors or trusted third parties.

7. Direct Marketing 

From time to time, we could use your name and contact information to send you either via emails, post, or social media information that we think may be of interest to you, including stories, events, products and services offered by GWS as well as special offers and promotions and surveys but we can only do so with your consent. 

You may opt-out from receiving marketing communications at any time, free of charge, by following the unsubscribe instructions contained in each of our marketing communications or by contacting us in accordance with the section “Contact Us” below.

8. How long do we keep your information?

Your personal data will be stored for as long as required to fulfill our business purposes and for the period of time required by law. To the extent required by law, we will take reasonable steps to destroy or anonymise personal data in a secure manner when we no longer need it for the purposes for which it was collected (as set out in section 4 of this notice) and retention is no longer necessary for legal or business purposes.

9. Processing of personal data must be justified

We will only process your personal data where we are satisfied that we have an appropriate legal basis to do so, such as (i) for the performance of a contract between us; (ii) where you have provided us with your express consent to process your personal data for a specific purpose; (iii) our use of your personal data is necessary to fulfill our statutory obligations with relevant authorities (regulators, tax officials, law enforcement bodies) or otherwise meet our legal responsibilities; (iv) our use of your personal data is in our legitimate interest as a commercial organization.

10. Security of personal data

GWS has in place reasonable technical and organisational measures to prevent unauthorised or accidental access, processing, erasure, loss or use of your personal data and to keep your personal data confidential.  These measures are subject to ongoing review and monitoring.  To protect your personal data, we also require our third-party service providers to take reasonable precautions to keep your personal data confidential and to prevent unauthorised or accidental access, processing, erasure, loss or use of personal data, and to act at all times in compliance with applicable data protection laws. 

We cannot guarantee that the website (including but not limited to WordPress and WooCommerce) will function without disruptions. We shall not be liable for damages that may result from the use of electronic means of communication, including, but not limited to, damages resulting from the failure or delay in delivery of electronic communications, interception or manipulation of electronic communications by third parties or by computer programs used for electronic communications and transmission of viruses.

11. Links to other websites 

Our website may contain links to other websites, apps, content, services or resources on the internet which are operated third parties. If you access other websites, apps, content, services or resources using the links provided, please be aware they may have their own privacy policy, and we do not accept any responsibility or liability for these policies or for any personal data which may be collected through these sites. Please check these policies before you submit any personal information to these other websites.

Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

12. What are your rights over your personal data?

1. Right to Access to your personal data 

You have the right to request a copy of the personal data we hold about you. To do this, simply contact our Data Protection Officer and specify what data you would like. We will take all reasonable steps to confirm your identity before providing details of your personal data. 

You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

2. Right to ask for correction of your personal data 

You have the right to ask us to update, correct or delete your personal data. We will take all reasonable steps to confirm your identity before making changes to personal data we may hold about you. We would appreciate it if you would take the necessary steps to keep your personal data accurate and up-to-date by notifying us of any changes we need to be aware of. 

3. Right to withdrawal of consent and request for deletion of your personal data

You may also withdraw your consent to receiving direct marketing communications, or more generally to our processing of your personal data, at any time, and you may in certain circumstances ask us to delete your personal data. However, we may not be able to fulfill our contractual obligations to you if you entirely withdraw your consent or ask us to delete your personal data entirely. To protect your personal data, we shall require that you first prove your identity to us at the time the request is made, for instance by providing a copy of your national identification card, contact details or answering some other security questions to satisfy ourselves of your identity before we may proceed with your request(s).

Whenever reasonably possible and required, we will strive to grant these rights within 30 days, but our response time will depend on the complexity of your requests. We will generally respond to your requests free of charge unless if your request involves processing or retrieving a significant volume of data, or if we consider that your request is unfounded, excessive or repetitive in which case we reserve the right to charge a fee (as mentioned above regarding access).

There may be circumstances where we are not able to comply with your requests, typically in relation to a request to erase your personal data or where you object to the processing of your personal data for a specific purpose or where you request that we restrict the use of your personal data where we need to keep your personal data to comply with a legal obligation or where we need to use such information to establish, exercise or defend a legal claim. To make these requests, or if you have any questions or complaints about how we handle your personal data or would like us to update the data we maintain about you and your preferences, please contact our Data Protection Officer at the address set out under section 22 below.

13. Cookies policy

Our website uses cookies.

1. What is a cookie?

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

2. Why do we use cookies?

We use cookies for instance to:

• Help remember and process the items in the shopping cart.
• Understand and save user’s preferences for future visits.
• Keep track of advertisements.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. 

We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browsers are a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.

3. If users disable cookies in their browser:

If you turn cookies off, Some of the features that make your site experience more efficient may not function properly. Some of the features that make your site experience more efficient and may not function properly.

4. How are third party cookies used?

For some of the functions within our websites we use third party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third party suppliers) may contain third party cookies and you may wish to consult the policies of these third party websites for data regarding their use of cookies. For further details on the third party cookies that we use, please read our page on cookie types.

5. How do I reject and delete cookies?

We will not use cookies to collect personally identifiable data about you. However, should you wish to do so, you can choose to reject or block the cookies set by the websites of any third party suppliers by changing your browser settings – see the Help function within your browser for further details. Please note that most browsers automatically accept cookies so if you do not wish cookies to be used you may need to actively delete or block the cookies.

You can also visit www.allaboutcookies.org for details on how to delete or reject cookies and for further data on cookies generally. For data on the use of cookies in mobile phone browsers and for details on how to reject or delete such cookies, please refer to your handset manual. Note, however, that if you reject the use of cookies you will still be able to visit our websites but some of the functions may not work correctly.

6. Which cookies are used on this website?

The cookies used on this website are managed by a cookie consent management tool. Kindly click on the cookie sign on the bottom left hand side of your screen for more information on the cookies used on this website. You may update your consent at any time.

14. California Online Privacy Protection Act

We at GWS value your privacy, that is why we have taken the necessary precautions to be in compliance with the California Consumer Privacy Act (CCPA). For visitors coming from California, the CCPA applies. You can opt out of the processing of your data any time with effect for the future. Additionally, you can make use of your rights under the CCPA by:

• contacting us at support@gws-technologies.com, 
• by logging in to your account 
• by chatting with us or 
• by sending us a support ticket.

15. How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

16. Does our site allow third-party behavioral tracking?

It’s also important to note that we allow third-party behavioral tracking.

See GWS Cookie Declaration for information on the cookies we use.

17. Minors

Except where required by local laws, we do not knowingly collect personal data from minors.  If you are a minor, you may only use our website and services with the permission of your parent or guardian. 

Our online services are not directed at children under the age of 13. If you believe we have collected information about a child under the age of 13, please contact our Data Protection Officer so that we may take appropriate steps to delete such information. 

If you are at least 13 but under the age of 16, please get the consent of your parent or legal guardian before giving us any personal data about yourself. 

If you are a parent of a child below the age limit and you learn that your child has provided GWS with personal information without your consent, please contact us at support@gws-technologies.com and insist on exercising your rights of access, correction, cancellation and / or opposition.

If you are resident in California and are under 18 years of age and wish to erase publicly available content, please contact us at support@gws-technologies.com.

18. CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions
• Process orders and to send information and updates pertaining to orders.
• Send you additional information related to your product and/or service
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to the following:

• Not use false or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us or follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

19. Online presence in social networks

We maintain online presences in social networks in order to communicate there with customers and interested parties, among others, and to provide information about our products and services.

The users’ data is usually processed by the social networks concerned for market research and advertising purposes. In this way, usage profiles can be created based on the interests of the users. For this purpose, cookies and other identifiers are stored on the users’ computers. On the basis of these usage profiles, advertisements, for example, are then placed within the social networks but also on third-party websites.

As part of the operation of our online presences, it is possible that we can access information such as statistics on the use of our online presences, which are provided by the social networks. These statistics are aggregated and may include, in particular, demographic information and data on interaction with our online presences and the posts and content distributed via them. 

The legal basis for data processing is in order to stay in contact with and inform our customers and to carry out pre-contractual measures with future customers and interested parties.

For the legal basis of the data processing carried out by the social networks on their own responsibility, please refer to the data protection information of the respective social network. 

We may also use data-driven conversion tracking methods. Data-driven attribution gives credit for conversions based on how people engage with your various ads and decide to become your customers. It uses data from your account to determine which keywords, ads, and campaigns have the greatest impact on your business goals.

20. Amendments to this Privacy Notice

We may amend this privacy notice from time to time. Any amendment will be posted on our website so that you are always informed of the way we collect and use your personal data. Updated versions of this privacy notice will include the date of the revision at the end of this privacy notice so that you are able to check when the privacy notice was last amended. Any changes to this privacy notice will become effective upon posting of the revised privacy notice on the website. Use of our website following such changes constitutes your acceptance of the revised privacy notice then in effect but, to the extent such changes have a material effect on your rights or obligations as regards our handling of your personal data, such changes will only apply to personal data after the changes are applied.  

21. Miscellaneous 

This privacy notice is governed by and shall be construed in accordance with the laws of the Republic of Mauritius. This privacy notice is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this privacy notice, the English version shall prevail. 

22. How to contact us?

We have appointed a Data Protection Officer to oversee compliance with and questions in relation to this notice. If you have any questions about this notice, including any requests to exercise your legal rights, please contact our Data Protection Officer using the details set out below: 

The Data Protection Officer

GWS Technologies LTD

Suite 101, Catalyst Building

Ebene Cybercity, 

Ebene 72201

Mauritius

support@gws-technologies.com

or dpo@gws-technologies.com

Tel: +230 465 03 00

23. Complaints

If you believe we have not handled your request in an appropriate manner, you may lodge a complaint with the Data Protection Commissioner (DPC) (The Data Protection Office, 5th floor, SICOM Tower, Wall Street Ebène, Mauritius). However we ask that you please try to resolve any issues with us first before referring your complaint to the DPC.

24. Terms and Conditions and Data Processing Agreement

Please also visit our Acceptable Use Policy and Terms and Conditions section establishing the use, disclaimers and limitations of liability governing the use of our website and services and our Data Processing Agreement.

This version is dated 24 March 2023