TABLE OF CONTENTS

• 1. Introduction
• 2. Responsibilities
• 3. Privacy Statement
• 4. Processing of Personal Data
• 5. Data Retention
• 6. Your Rights
• 7. Security of Personal Data
• 8. Third-Party Services
• 9. Cookies Policy
• 10. Contact Information
• 11. Changes to This Privacy Policy

GENERAL PRIVACY POLICY

1. Introduction

1.1 In this General Privacy Policy, ‘KGL’ refers to KASA GROUP LTD, and all the words and expressions used in this Privacy Notice shall be interpreted and construed in line with the definitions used in KGL’s General Data Protection Policy.

1.2 This General Privacy Policy should be read and interpreted in conjunction with and subject to KGL’s General Data Protection Policy that governs all the personal data processing activities of KGL.

1.3 This General Privacy Policy is relevant to all persons (‘data subjects’) whose personal data is collected by KGL in line with the requirements of the European General Data Protection Regulation 2016 (‘GDPR’) and the Mauritius Data Protection Act 2017 (‘DPA’).

1.4 Users of KGL’s website as well as KGL’s customers and potential customers are likely to be data subjects in as much as KGL may collect their personal information whether by automated or non-automated means.

2. Responsibilities

2.1 KGL is responsible for ensuring that this General Privacy Policy is made available to data subjects prior to KGL collecting/processing their personal data.

2.2 All Employees/Staff of KGL who interact with data subjects are responsible for ensuring that:

• a. this General Privacy Policy is drawn to the data subject’s attention prior to processing the latter’s personal data; and
• b. they obtain the consent of the data subjects prior to the processing of their data wherever consent is required under either the GDPR or the DPA.

3. Privacy Statement

3.1 Who is KGL and what does KGL do?

3.1.1 KGL is a private company duly registered and validly existing under the laws of Mauritius.

3.1.2 KGL has its registered office situated at 19 Poivre Street, Port-Louis, Republic of Mauritius and its administrative headquarters situated at the same address. KGL’s other contact details are as follows:

Telephone Number(s): +230 2027500

3.1.3 More information on KGL is contained in its General Data Protection Policy.

3.1.4 Although established, based and domiciled in Mauritius, KGL has expanded its business activities beyond the jurisdiction of Mauritius including but not limited to parts of the European Union.

3.1.5 In the light of paragraph 3.1.4 above, KGL is likely to process personal data both under the GDPR and the DPA.

3.1.6 The Board of Directors of KGL has appointed a Data Protection Officer in Mauritius whose identity and contact details are as follows:

Name: Aishah Dilmohamud

Postal address: 42, Edith Cavell Street, Port-Louis, Mauritius.

Email address: adilmohamud@kasa.mu

Telephone No.: 2027500

3.1.7 The personal data KGL is likely to collect from any user of the website, whether you are a customer or a potential customer, is nothing more than the information that you wilfully provide during your client (customer) account creation process, including for instance your full name, address, and at least a valid email address. Information that is automatically collected by the website is just your IP address, to the exclusion of any other information. You are hereby informed that the website is likely to automatically track cookies which you may block, in the case that you have not signed in to the website, by changing the related parameters in your Internet browser, as set out in our cookies policy.

3.1.8 The personal data KGL collects will be used to enable the good functioning of the website and to enable the marketing team to carry out analytics in order to provide a better service.

3.1.9 KGL’s legal basis for processing your personal data:

• (a) If you are a user of our website:
• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Processing is necessary for compliance with a legal obligation.
• The data subject has given consent.
• Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.
• (b) If you are a customer or a potential customer of KGL:
• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Processing is necessary for compliance with a legal obligation.
• The data subject has given consent.
• Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.

3.1.10 In any event, KGL is committed to ensuring that the information it collects and uses is appropriate for the purpose for which it was collected, and does not constitute an invasion of your privacy.

3.1.11 In terms of being contacted for marketing purposes KGL will contact you for additional consent.

3.1.12 KGL’s aim is not to be intrusive, and KGL undertakes not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.

3.2 Consent

3.2.1 By using KGL’s website (as a user of KGL’s website) you are giving KGL permission to process your personal data specifically for the purposes identified above.

3.2.2 By placing an order for goods and/or services with KGL (as a customer) or by requesting KGL to provide you a quote (or any further information) in respect of KGL’s goods and/or services (as a potential customer), you are giving KGL permission to process your personal data specifically for the purposes identified above.

3.2.3 Subject to paragraph 3.2.7 below, further explicit and written consent will be requested from you for KGL to process any of your sensitive or special categories of data.

3.2.4 Sensitive or special categories of personal data are information about racial origin, ethnic origin, political opinion, religious belief, philosophical belief, trade union membership, genetic data, biometric data, health data, criminal record, data concerning sex life and/or sexual orientation.

3.2.5 Where asking you for sensitive or special categories of personal data KGL will always tell you why and how the information will be used.

3.2.6 When you have been requested to and do submit written explicit consent, you may withdraw consent at any time by informing KGL and/or KGL’s Data Protection Officer in writing of your wish to withdraw your consent without having to assign any reason for your decision.

3.2.7 KGL may exceptionally process sensitive or special categories of personal data without your consent if such processing is required by law and/or a Court order or where the information is already in the public domain.

3.3 Disclosure and transfer

3.3.1 KGL may pass your personal data on to third-party service providers contracted to KGL in the course of dealing with you. Any third parties that KGL may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on KGL’s behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with KGL’s procedures.

3.3.2 Basically, KGL will not pass on your personal data to third parties unless it has obtained your consent or such disclosure is necessary for the processing activities of KGL in furtherance of a contractual relationship to which you are privy as a customer or potential customer of KGL or from which you will be deriving a personal interest.

3.3.3 KGL will not transfer your personal data to a different country without having carried out an adequacy test as explained in KGL’s General Data Protection Policy and informed you about the adequacy of protection afforded to your personal data in that country.

3.4 Report of Breach

Whenever KGL is on notice that a breach of personal data has been committed or reasonably suspects that a breach of personal data is likely to be committed, KGL shall as soon as reasonably practicable inform the relevant supervisory authority about the same. You shall also be informed about the same where such a breach is likely to impact on your rights and freedoms as a data subject.

4. Processing of Personal Data

4.1 KGL processes personal data in accordance with the principles of data protection as set out under applicable laws, including the GDPR and the DPA. Processing includes the collection, storage, use, and potential sharing of personal data in the course of KGL's operations.

4.2 KGL shall ensure that personal data is:

• a. Processed lawfully, fairly, and transparently;
• b. Collected for specified, legitimate purposes and not further processed in a manner incompatible with those purposes;
• c. Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;
• d. Accurate and kept up to date;
• e. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data is processed;
• f. Processed in a manner that ensures appropriate security of the personal data.

5. Data Retention

5.1 KGL will retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

5.2 The criteria used to determine the retention period of personal data include:

• a. The length of time the personal data is needed for the purposes of processing;
• b. Any legal obligations to retain the data;
• c. Any potential for legal claims or disputes.

5.3 Once personal data is no longer necessary, it will be securely deleted or anonymized, in line with applicable legal requirements.

6. Your Rights

6.1 You have various rights regarding your personal data under applicable data protection laws, including:

• a. The right to access: You have the right to request a copy of the personal data KGL holds about you.
• b. The right to rectification: You have the right to correct any inaccuracies in the personal data KGL holds about you.
• c. The right to erasure: You have the right to request that KGL erase your personal data under certain conditions.
• d. The right to restrict processing: You have the right to restrict KGL's processing of your personal data under certain conditions.
• e. The right to object: You have the right to object to the processing of your personal data in certain circumstances.
• f. The right to data portability: You have the right to request that KGL transfer your personal data to another controller in a machine-readable format.
• g. The right to withdraw consent: If you have consented to the processing of your personal data, you have the right to withdraw that consent at any time.
• h. The right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated.

7. Security of Personal Data

7.1 KGL implements appropriate technical and organizational measures to ensure the security of personal data and to protect it from unauthorized access, disclosure, alteration, or destruction.

7.2 These measures include:

• a. Encryption of personal data where necessary;
• b. Secure storage and access controls;
• c. Regular security audits and assessments;
• d. Training and awareness programs for KGL’s staff regarding data protection and security practices.

7.3 Despite these measures, KGL cannot guarantee that unauthorized access or disclosure will never occur, but KGL will take all reasonable steps to protect your personal data.

8. Third-Party Services

8.1 KGL may use third-party service providers to process personal data on its behalf. These service providers are contractually bound to comply with applicable data protection laws and KGL’s data protection policies.

8.2 KGL is responsible for ensuring that these third-party providers implement adequate safeguards to protect your personal data, and that they process the data solely for the purposes for which it was disclosed.

8.3 KGL may also share personal data with third parties if required by law or for the protection of KGL’s rights and interests.

9. Cookies Policy

9.1 KGL’s website uses cookies to improve user experience and gather analytics. Cookies are small text files that are stored on your device when you visit the website.

9.2 The types of cookies KGL may use include:

• a. Necessary cookies: These are essential for the website to function properly and cannot be disabled.
• b. Preference cookies: These enable the website to remember your preferences and settings.
• c. Analytical cookies: These collect information about how you use the website to help KGL improve its functionality.
• d. Marketing cookies: These track your activities across websites to deliver personalized advertising.

9.3 You can manage your cookie preferences through your browser settings, including disabling cookies entirely or clearing them after each session.

10. Contact Information

10.1 If you have any questions or concerns regarding this General Privacy Policy or the processing of your personal data, please contact KGL’s Data Protection Officer:

Name: Aishah Dilmohamud

Postal address: 42, Edith Cavell Street, Port-Louis, Mauritius

Email address: adilmohamud@kasa.mu

Telephone No.: 2027500

10.2 You can also contact the relevant supervisory authority in your jurisdiction for any concerns regarding data protection issues.

11. Changes to This Privacy Policy

11.1 KGL reserves the right to modify or update this General Privacy Policy from time to time to reflect changes in its practices or legal obligations.

11.2 Any changes to this General Privacy Policy will be communicated via an updated version on KGL’s website, with the date of the most recent update clearly stated at the top of the document.