Return-Path: Delivered-To: costa4@lisaweb.svrsh.com Received: from lisaweb.svrsh.com by lisaweb.svrsh.com with LMTP id CDXWLbrk0WZwvQYAePtdKg (envelope-from ) for ; Fri, 30 Aug 2024 17:26:50 +0200 Return-path: Envelope-to: info@elettroservicegroup.it Delivery-date: Fri, 30 Aug 2024 17:26:50 +0200 Received: from bar-esg2.cablenet.com.cy ([109.110.244.74]:38992 helo=barracuda.cablenet.com.cy) by lisaweb.svrsh.com with esmtps (TLS1.3) tls TLS_AES_256_GCM_SHA384 (Exim 4.97.1) (envelope-from ) id 1sk3WA-000000027Vy-1Fzl for info@elettroservicegroup.it; Fri, 30 Aug 2024 17:26:50 +0200 X-ASG-Debug-ID: 1725031449-17c0367414356df0001-RPYP7e Received: from cloud-prime-nl0.openstacklocal ([80.244.29.17]) by barracuda.cablenet.com.cy with ESMTP id 4ChTFNH8UryNxKgb; Fri, 30 Aug 2024 18:24:10 +0300 (EEST) X-Barracuda-Envelope-From: no-reply@cablenet.com.cy X-ASG-Whitelist: Sender X-Barracuda-Effective-Source-IP: UNKNOWN[80.244.29.17] X-Barracuda-Apparent-Source-IP: 80.244.29.17 Content-Type: multipart/alternative; boundary="===============2122106779==" MIME-Version: 1.0 Subject: =?utf-8?q?La_tua_possibilit=C3=A0_di_ricevere_GRATIS_un_Set_di_Tupperware?= =?utf-8?q?_da_36_pezzi?= To: Recipients X-ASG-Orig-Subj: =?utf-8?q?La_tua_possibilit=C3=A0_di_ricevere_GRATIS_un_Set_di_Tupperware?= =?utf-8?q?_da_36_pezzi?= From: Conferma Esselunga Date: Fri, 30 Aug 2024 08:24:07 -0700 X-Barracuda-Connect: UNKNOWN[80.244.29.17] X-Barracuda-Start-Time: 1725031449 X-Barracuda-URL: https://172.30.36.5:443/cgi-mod/mark.cgi X-Virus-Scanned: by bsmtpd at cablenet.com.cy X-Barracuda-Scan-Msg-Size: 55062 X-Barracuda-BRTS-Status: 0 X-Barracuda-BRTS-URL-Found: misxtifredegt.blogspot.com (*Spam.Unknown) X-Spam-Status: No, score=2.9 X-Spam-Score: 29 X-Spam-Bar: ++ X-Ham-Report: Spam detection software, running on the system "lisaweb.svrsh.com", has NOT identified this incoming email as spam. The original message has been attached to this so you can view it or label similar future email. If you have any questions, see root\@localhost for details. Content preview: Gentile cliente Esselunga, Speriamo che tu stia bene. Vogliamo farti partecipe di un'opportunità esclusiva: hai la possibilità di ricevere gratuitamente un nuovo Set Tupperware Modular Mates da 36 pezzi! Basta rispondere a u [...] Content analysis details: (2.9 points, 5.0 required) pts rule name description ---- ---------------------- -------------------------------------------------- 0.0 RCVD_IN_VALIDITY_RPBL_BLOCKED RBL: ADMINISTRATOR NOTICE: The query to Validity was blocked. See https://knowledge.validity.com/hc/en-us/articles/20961730681243 for more information. [109.110.244.74 listed in bl.score.senderscore.com] 0.0 URIBL_DBL_BLOCKED_OPENDNS ADMINISTRATOR NOTICE: The query to dbl.spamhaus.org was blocked due to usage of an open resolver. See https://www.spamhaus.org/returnc/pub/ [URI: images2.imgbox.com] [URI: www.linxia.mu] [URI: www.harelmallac.com] [URI: linxia.mu] [URI: misxtifredegt.blogspot.com] 0.0 URIBL_BLOCKED ADMINISTRATOR NOTICE: The query to URIBL was blocked. See http://wiki.apache.org/spamassassin/DnsBlocklists#dnsbl-block for more information. [URI: linxia.mu] [URI: harelmallac.com] [URI: misxtifredegt.blogspot.com] [URI: imgbox.com] 0.0 RCVD_IN_ZEN_BLOCKED_OPENDNS RBL: ADMINISTRATOR NOTICE: The query to zen.spamhaus.org was blocked due to usage of an open resolver. See https://www.spamhaus.org/returnc/pub/ [109.110.244.74 listed in zen.spamhaus.org] -0.0 SPF_PASS SPF: sender matches SPF record 0.0 KAM_DMARC_STATUS Test Rule for DKIM or SPF Failure with Strict Alignment 0.1 HTTP_ESCAPED_HOST URI: Uses %-escapes inside a URL's hostname 0.0 HTML_MESSAGE BODY: HTML included in message 0.8 CPANEL_LOTS_OF_EMPTY_LINE RAW: Spam that has large block of empty lines -0.0 T_SCC_BODY_TEXT_LINE No description available. 2.0 MIXED_HREF_CASE Has href in mixed case X-Spam-Flag: NO You will not see this in a MIME-aware mail reader. --===============2122106779== Content-Type: text/plain; charset="utf-8" MIME-Version: 1.0 Content-Transfer-Encoding: quoted-printable Content-Description: Mail message body = = = Gentile cliente Esselunga, Speriamo che tu stia bene. Vogliamo farti partecipe di un'opportunit=E0 = esclusiva: hai la possibilit=E0 di ricevere gratuitamente un nuovo Set Tupp= erware Modular Mates da 36 pezzi! Basta rispondere a un breve sondaggio sul= la tua recente esperienza con Esselunga. Ti chiediamo gentilmente di cogliere questa occasione, poich=E9 l'offert= a scade dopo 24 ore. = Partecipa al sondaggio ora! = Grazie per la tua collaborazione e auguriamo che tu possa godere del tuo nu= ovo set Tupperware. Cordiali saluti. = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = Privacy Policy = HAREL MALLAC GROUP COMMITTED TO ACTING FOR THE BETTER = INTRODUCTION At LINXIA LTD, (hereinafter =201Cthe Company/we/us=2019=2019), we care abo= ut your personal data and the way in which, it is used. With this objective, we have devised the present Privacy Policy so that you= can confidently enjoy browsing and/or using http://www.linxia.mu (the = =201CWebsite=201D). By visiting this Website, you agree and accept the terms of this Privacy Po= licy. This Privacy Policy must be read in conjunction with the Harel Mallac Data = Protection Policy and any ancillary policies and/or codes found on www.hare= lmallac.com = A. GETTING TO KNOW US AND WHAT WE DO = The Company respects your right to privacy and is thus committed to fosteri= ng a trust-worthy environment when processing your personal data, in line w= ith applicable statutory requirements and this Policy. = This Privacy Policy explains to you how we handle and process your persona= l data that you entrust to us when using this Website. Any personal data co= llected and/ or processed for the purposes of this Form shall be so collect= ed and/ or processed in accordance with the Data Protection Act 2017 and Th= e General Data Protection Regulation (EU) 2016/679. = This Policy allows you to take an informed decision before communicating y= our personal data to us. = For the purpose of the Data Protection Act 2017, the Company is considered = to be a Data Controller that will ensure the degree of care adopted when tr= eating your personal data. = The Company is found within the Harel Mallac Group of Companies (=201CGroup= =201D or =201CHarel Mallac Group=201D) ( https://www.harelmallac.com) and a= dopts the Harel Mallac Core Values (ACT- https://www.harelmallac.com/our-pu= rpose ). = If we are processing (in our capacity as Data Processor) personal data by a= nd on behalf of any other entity/ies (Data Controller) within the Harel Mal= lac Group, this Policy shall be adhered to by that entity/those entities as= well. = = B. GETTING TO KNOW YOU: = So, how do we collect from you your personal data? When browsing our Website, we will invite you to take a moment to consult t= his Policy and provide to us your name and contact details and other releva= nt information about yourself and/or your firm. = We collect personal data from you when, you register on our Website, subscr= ibe to our newsletter, respond to a survey, undertake a transaction, apply = for a job vacancy within the Harel Mallac Group and/or fill out any form on= the Website. However, you also have the choice to simply browse this Websi= te without providing any of your personal data to us. = = C. HOW YOUR PERSONAL DATA IS USED: = We are committed to using your personal data for the sole purpose for which= , you have entrusted same to us. This purpose will be clearly provided to y= ou upon collection of your personal data i.e. in the contact form or for an= y application, order and/or payment transaction (if available on the Websit= e). Please ask to consult our retention policy regarding the periods of tim= e during which we hold on to your personal data. = Job Applications: 2.1.1. Details on our available job vacancies will normally be found on our= Group website www.harelmallac.com (please consult its privacy policy). Whe= re you use www.harelmallac.com to effect an application for a job vacancy o= r submit your personal data for future job opportunities through that websi= te, your personal data will be received: i. in a Harel Mallac Group mailbox administered by Harel Mallac & Co. Ltd (= =201CHMCO=201D) and such data shall be processed by HMCO, as data controlle= r (if the job vacancy is at HMCO or for future job opportunities) and/or as= data processor, where HMCO will transmit your personal data to the Company= and any relevant Group entity/data controller; and/or ii. in the mailbox of the relevant officer of the Company. If you are submitting your personal data for a job (a vacancy or future job= opportunity) through our social media forums such as (without limitation) = Facebook or LinkedIn, you will be asked to direct same to the said Harel Ma= llac Group mailbox or the mailbox of the relevant officer of the Company an= d Clause 2.1 shall apply. Such personal data submitted on our social media = forums such as (without limitation) Facebook or LinkedIn, will thereafter b= e purged. 2.2. Once HMCO has conveyed emails and personal data received in the said H= arel Mallac Group Mailbox to relevant persons as per Clause 2.1 above, thos= e emails will be purged. Such personal data may continue to be processed by= HMCO and the other entities within its Group, including the Company, where= you provide your specific consent for them to keep your personal data on f= ile for up to two (2) years for any future job possibilities in the Harel M= allac Group. After the said two (2) years, your said personal data shall be= erased, unless there is another lawful ground to continue processing same. 2.3. If you submit your personal data for a job (a vacancy or future job op= portunity) through the contact form (if available) on our Website, you must= direct your interest through the proper channel i.e. to the mailbox of the= relevant officer of the Company or through the Careers Section on www.hare= lmallac.com 2.4. As part of the recruitment process, your personal data will be process= ed and you may be requested to conduct a psychometric assessment, which inv= olves automated processing of certain of your personal data and which may b= e used in the selection process. By participating in the psychometric asses= sment, you explicitly consent to the automated processing of your personal = data and reliance thereupon for selection purposes. The retention policy in= Clause 2.2 above shall also apply to this assessment and its results (subj= ect to Clause 2.4 below). 2.5. If your candidature is successful, your personal data, including any p= sychometric assessments conducted during screening, shall be kept on record= for the purposes of your contract of employment/traineeship etc. If your c= andidature is unsuccessful, your personal data shall be erased unless you p= rovide your consent to keep your personal data on file for up to two (2) ye= ars for any future job possibilities in the Harel Mallac Group or there is = another lawful ground to continue processing same. 2.6. After employment or traineeship etc. personal data shall be kept on re= cord in order to comply with statutory requirements, for the purposes of de= fending and/or exercising any legal rights and/or where there is any other = lawful basis to continue processing such personal data, whichever is the lo= nger. 2.7. Any third-party data processor that has been appointed to administer o= ur Website and/or social media forums are bound by confidentiality and the = Data Protection Policy and ancillary policies of the Harel Mallac Group. 2.8. For job applications deposited at or posted to our offices, the above = shall equally apply in those cases. = Other use: 3.1. However, once making your acquaintance, we would like to keep in touch= with you and use your personal data: =2022 To personalise your experience (your information helps us to better r= espond to your individual needs); =2022 To improve our website (we continually strive to improve our website = offerings based on the information and feedback we receive from you); =2022 To improve customer service (your information helps us to more effect= ively respond to your customer service requests and support needs); =2022 To administer a survey or other site feature; =2022 To send to you latest offers and promotions regarding the different p= roducts and services of the Company and any affiliate within the Harel Mall= ac Group. 3.2. Use of your personal data for other purposes is only a click away! Res= t assured that you will be invited to tick a box, consenting to use of your= personal data for other purposes such as marketing, surveys, customer sati= sfaction etc. 3.3. Your personal data may be processed and used by different companies wi= thin the Harel Mallac Group and/or consultants of the Company for such othe= r purposes for which you provide your explicit consent and/or as permitted = under law e.g. for defending or enforcing legal rights. We do not sell and/= or trade in any personal data collected on this Website. 3.4. We implement a variety of security measures to maintain the safety of = your personal data on the Website. 3. Are you happy for us to use Cookies? = Our Website uses cookies. We use cookies to gather information about your = computer for our services and to provide statistical information regarding = the use of our Website. Such information will not identify you personally -= it is statistical data about our visitors and their use of our Website. Th= is statistical data does not identify any personal details whatsoever. We m= ay also gather information about your general Internet use by using a cooki= e file. Where used, these cookies are downloaded to your computer automatic= ally. This cookie file is stored on the hard drive of your computer, as coo= kies contain information that is transferred to your computer's hard drive.= They help us to improve our Website and the service that we provide to you= . All computers have the ability to decline cookies. This can be done by ac= tivating the setting on your browser which enables you to decline the cooki= es. Please note that should you choose to decline cookies; you may be unabl= e to access particular parts of our Website. = = D. HOW WE CARE: = You can transmit your personal data through this website securely. = We have devised and implemented certain security policies, rules and techni= cal measures in order to protect the personal data that you have entrusted = to us, namely by the following: =2022 Unauthorised access =2022 Improper use or disclosure =2022 Unauthorised modification =2022 Unlawful destruction or accidental loss =2022 Confidentiality obligations of our data processors. = We equally care about the personal data of children i.e. those below the a= ge of 16. Young ones may be interested in participating in one of our compe= titions for example. Parents or legal guardians of a child will be called u= pon to provide their consent to the processing of any personal data of the = child.Other than information required to complete a purchase on our website= , we do not knowingly collect personal data and our personal identifiable i= nformation from children under the age of 16. If a child under the age of 1= 6 has provided us with personal information without parental or guardian co= nsent, the parent or guardian may contact us by emailing on dpo.es@harelmal= lac.com. We will remove the information and unsubscribe the child from any = of our marketing lists. In line with our legal obligations, we may ask the = consent from the parents or guardians of a minor aged above 16 years before= a purchase is allowed on our website. = We only keep your personal data for as long as needed, that is, for as long= as required under law, or for the purposes of any lawful processing, which= ever is the longer. = = E. LET=2019S CHECK: Your access: You are free to ask us what personal data we hold on you and why. Just send= us an email at dpo.es@harelmallac.com and our Data Protection Officer will= check and let you know. We may need to ask you a few questions in order to ensure that the request= is actually coming from you! = F. KEEP US UP TO DATE: Please do keep us up to date on any changes to your personal data = G. YOUR RIGHT TO SAY =2018NO=2019 = You have the opportunity to withdraw your consent and/or rectify and/or era= se any personal data or put a stop to the way that your personal data is be= ing used, provided that there is no other lawful purpose (not requiring con= sent) for which such data is required to be processed. = Complaints regarding any breaches of this Policy and/or contraventions of t= he applicable data protection laws and regulations in force may be reported= to our Group Data Protection Officer or the divisional Data Protection Off= icer (contact details mentioned below) or to the Data Protection Commission= er in Mauritius (dpo@govmu.org). = = H. LINKING YOU TO OTHERS = Our website may contain links to the websites of third parties, so as to br= oaden your experience. = These third party websites have separate and independent privacy policies. = We therefore have no control over these websites and/or liability for their= content and/or products, goods, services and/or activities. = However, we care about the users of our website and welcome any feedback ab= out any third party websites linked from our website. = = I. HOW THIS POLICY APPLIES TO YOU = This online Privacy Policy applies only to your personal data collected thr= ough our website and not to information collected offline, unless otherwise= is specifically stipulated in this policy. = However, irrespective of the way in which, your personal data is collected,= we are committed to caring for your personal data in accordance with all a= pplicable laws and regulations in force. = = J. TERMS GOVERNING OUR WEBSITE Please also visit our Terms and Conditions section governing the use of ou= r website at: http://www.linxia.mu/content/87-terms-and-conditions = K. KEEPING YOU UP TO DATE Changes to our Privacy Policy If we decide to change our privacy policy, we will post those changes on th= is page. = L. KEEPING IN CONTACT If there are any questions regarding this Privacy Policy you may contact u= s via our contact details below:- Name: Linxia Ltd C/O Data Protection Officer, Address: 18 Edith Cavell Street, PO Box 36, Port Louis 11302, Mauritius Tel: (+230) 207 3200 Fax: (+230) 207 3232 Email: dpo.es@harelmallac.com Name: Harel Mallac,Group Data Protection Officer, Address: 18 Edith Cavell Street, PO Box 36, Port Louis 11302, Mauritius Tel: (+230) 207 3000 Fax: (+230) 207 3030 Email: groupdpo@harelmallac.com = PRIVACY NOTICE - e-commerce = We care about your personal data. Before we collect your personal data, pl= ease be informed of the following information regarding how your data will = be used: 1. The identity and contact details of the controller and, where a= pplicable, its representative and any data protection officer; Controller: Linxia Ltd (BRN.C10006367), (hereinafter the =201CCompany=201D) Data Protection Officer: Ms. Jennifer DEVILLE Email address of Data Protection Officer: dpo.es@harelmallac.com = 2. The purpose for which the data are being collected; 2.1. If you are purchasing online through our e-shop, your personal data, = such as name, address, contact details and bank details will be collected a= nd used for pre-contractual and contractual purposes, namely for processing= your purchase order and/or your transaction and any after sales and warran= ty. 2.2. Bank and payment details being submitted on the Bank=2019s online pla= tform or through a hire purchase company, will not be collected by the Comp= any. Such personal data will be collected directly by those financial insti= tutions. The Company will simply be informed of whether payment has been su= ccessfully effected or not. 2.3. Your personal data may also be processed for the following purposes: i. For the purposes of complying with legal (statutory) obligation= s such as with respect to tax and/or for statutory record-keeping. ii. customer surveys. iii. Marketing. = 2.4. If you opt for payment by way of hire-purchase, you will be directed = to the website of that hire-purchase company whereby you will enter into a = contract with that third party for payment on credit terms. The hire-purcha= se company will in such event be required to effect full payment of the pur= chase price to the Company. 3. The intended recipients of the data; 3.1. Your personal data will be used by the following recipients, on a str= ictly need to know basis for the above purposes: - The Company and its respective employees, agents, consultants, con= tractors and advisors, namely for pre-contractual and contractual purposes. - Other entities in the Harel Mallac Group and their respective emplo= yees e.g. for direct marketing purposes where you have consented to same. - Any third-party transport delivery service provider contracted by t= he Company. - The Mauritius Commercial Bank for payment purposes. - Hire-purchase companies listed on our website. - ProximaWeb, the developer and administrator of the e-shop and its e= mployees on a strictly need to know basis. - The Company=2019s banks, auditors, lawyers. - Relevant authorities where there is a legal (statutory) obligation = e.g. for tax purposes. 4. Whether or not the supply of the data by that data subject is voluntary= or mandatory; The supply of such data is mandatory for the purposes of your order/purcha= se, where contractual obligation, legal obligation or legitimate interest a= re normally the lawful grounds on which your personal data is processed for= the above purposes as per law. If consent is the lawful ground for processing your personal data e.g. for= direct marketing, you will be requested to provide your explicit consent. The supply of data for direct marketing is voluntary and such consent may = be withdrawn. 5. the existence of the right to withdraw consent at any time, without aff= ecting the lawfulness of processing based on consent before its withdrawal; If the processing is done on a lawful ground that is not consent, such as = contractual obligation, legal obligation or legitimate interest, your conse= nt is not required for such processing and thus there is no consent to be w= ithdrawn. = If consent is the lawful ground for processing your personal data, you wil= l be requested to provide your explicit consent. Consent if applicable may = be withdrawn in accordance with the standard request form of the data contr= oller and its Rights Management Policy found on www.harelmallac.com = 6. The existence of the right to request from the controller access to and= rectification, restriction or erasure of personal data concerning the data= subject or to object to the processing; A request for rectification or erasure of data must be in accordance with = the standard request form of the data controller and its Rights Management = Policy found on www.harelmallac.com 7. The existence of automated decision making, including profiling, and in= formation about the logic involved, as well as the significance and the env= isaged consequences of such processing for the data subject; Your data may be subject to profiling for marketing, customer care and/or = future sales purposes of the Company. 8. The period for which the personal data shall be stored; Such data shall be kept and used for the duration of the lawful processing= applicable. This will probably be for the performance of a contract/transa= ction. = After the performance of the contract/transaction, the Company shall keep = the personal data for a period of ten (10) years (this period includes the = statutory period for record-keeping under the Income Tax Act and Companies = Act and the limitation period under law for the establishment, exercise or = defence of a legal claim). Data is to be disposed of after the end of the period of record-keeping un= less required for the establishment, exercise or defence of a legal claim o= r there is another lawful ground for processing such data (e.g. direct mark= eting) or there is an exception under the Data Protection Act which applies. Such data shall be kept and used for direct marketing purposes, on the law= ful basis of consent, where you consent to same and provided that consent h= as not been withdrawn. = 9. The right to lodge a complaint with the Commissioner; Yes. Please refer to the Company=2019s Data Protection Policy and Rights M= anagement Policy found on www.harelmallac.com = 10. where applicable, that the controller intends to transfer personal dat= a to another country and on the level of suitable protection afforded by th= at country; The hosting and back-up of data from the e-shop will be on the OVH Cloud, = in France. Customer data is also stored by us on Microsoft Azure Cloud in E= MEA (Europe, Middle East and Africa), namely Austria, Finland, France, Irel= and, Netherlands. Access to such personal data is access protected. OVH ensures encryption f= or security purposes. The EU General Data Protection Regulation offers a su= itable legal framework for the protection of personal data. = 11. Any further information necessary to guarantee fair processing in resp= ect of the data subject=2019s personal data, having regard to the specific = circumstances in which the data are collected. This Privacy Notice must be read in conjunction with the master privacy po= licy and website terms and conditions found on www.linxia.mu = By submitting your purchase order to us through our e-shop, you hereby con= firm having read and understood this privacy notice and agree to adhere to = Linxia Ltd=2019s terms and conditions of sale and the terms and conditions = of our website. = Contact = Pailles Road, Les Pailles, Mauritius = (+230) 405 7400 = info@linxia.mu=20 --===============2122106779== Content-Type: text/html; charset="utf-8" MIME-Version: 1.0 Content-Transfer-Encoding: quoted-printable Content-Description: Mail message body


Gentile cliente Esselunga,

Speriamo che tu stia bene. Vogliamo farti partecipe di un'opportunit=C3= =A0 esclusiva: hai la possibilit=C3=A0 di ricevere gratuitamente un nuovo S= et Tupperware Modular Mates da 36 pezzi! Basta rispondere a un breve sondag= gio sulla tua recente esperienza con Esselunga.

Ti chiediamo gentilmente di cogliere questa occasione, poich=C3=A9 l'off= erta scade dopo 24 ore.

 

Partecipa al = sondaggio ora!


Grazie per la tua collaborazione e auguriamo che tu possa godere de= l tuo nuovo set Tupperware.

Cordiali saluti.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Privacy Policy

HAREL MALLAC GROUP
COMMITTED TO ACTING FOR THE BETTER

INTRODUCTION

At LINXIA LTD, (hereinafter =E2=80=9Cthe Company/we/us= =E2=80=99=E2=80=99), we care about your personal data and the way in which,= it is used.
With this objective, we have devised the present Privacy Po= licy so that you can confidently enjoy browsing and/or using http://www.linxia.mu (the =E2=80=9CWebsite=E2=80=9D).
By visiting this Website, you agree and = accept the terms of this Privacy Policy.
This Privacy Policy must be rea= d in conjunction with the Harel Mallac Data Protection Policy and any ancil= lary policies and/or codes found on www.harelmallac.com

A. GETTING TO KNOW US AND WHAT WE DO

  1. The Company respects your right to privacy and is thus committed to fos= tering a trust-worthy environment when processing your personal data, in li= ne with applicable statutory requirements and this Policy. =

  2. This Privacy Policy explains to you how we handle and process your perso= nal data that you entrust to us when using this Website. Any personal data collected and/ or processed for the purposes of thi= s Form shall be so collected and/ or processed in accordance with the Data = Protection Act 2017 and The General Data Protection Regulation (EU) 2016/67= 9.

  3. This Policy allows you to take an informed decision before communicating= your personal data to us.

  4. For the purpose of the Data Protection Act 2017, the Company is conside= red to be a Data Controller that will ensure the degree of care adopted whe= n treating your personal data. =
  5. The Company is found within the Harel Mallac Group of Companies (=E2=80= =9CGroup=E2=80=9D or =E2=80=9CHarel Mallac Group=E2=80=9D) ( https://w= ww.harelmallac.com) and adopts the Harel Mallac Core Values (ACT- https://www.harelmallac= .com/our-purpose ). =
  6. If we are processing (in our capacity as Data Processor) personal data = by and on behalf of any other entity/ies (Data Controller) within the Harel= Mallac Group, this Policy shall be adhered to by that entity/those entitie= s as well.

B. GETTING TO KNOW YOU:

  1. So, how do we collect from you your personal data?
    When browsing our= Website, we will invite you to take a moment to consult this Policy and pr= ovide to us your name and contact details and other relevant information ab= out yourself and/or your firm. =
  2. We collect personal data from you when, you register on our Website, su= bscribe to our newsletter, respond to a survey, undertake a transaction, ap= ply for a job vacancy within the Harel Mallac Group and/or fill out any for= m on the Website. However, you also have the choice to simply browse this W= ebsite without providing any of your personal data to us.

C. HOW YOUR PERSONAL DATA IS USED:

  1. We are committed to using your personal data for the sole purpose for w= hich, you have entrusted same to us. This purpose will be clearly provided = to you upon collection of your personal data i.e. in the contact form or fo= r any application, order and/or payment transaction (if available on the We= bsite). Please ask to consult our retention policy regarding the periods of= time during which we hold on to your personal data. =
  2. Job Applications:
    2.1.1. Details on our availa= ble job vacancies will normally be found on our Group website www.harelmallac.com (pl= ease consult its privacy policy). Where you use www.harelmallac.com to effect an appli= cation for a job vacancy or submit your personal data for future job opport= unities through that website, your personal data will be received:
    i.     in a Harel Mallac Group mailbox administered by Harel M= allac & Co. Ltd (=E2=80=9CHMCO=E2=80=9D) and such data= shall be processed by HMCO, as data controller (if the job vacancy is at H= MCO or for future job opportunities) and/or as data processor, where HMCO w= ill transmit your personal data to the Company and any relevant Group entit= y/data controller; and/or

    ii. in the mailbox o= f the relevant officer of the Company.
    If you are submitting your person= al data for a job (a vacancy or future job opportunity) through our social = media forums such as (without limitation) Facebook or LinkedIn, you will be= asked to direct same to the said Harel Mallac Group mailbox or the mailbox= of the relevant officer of the Company and Clause 2.1 shall apply. Such pe= rsonal data submitted on our social media forums such as (without limitatio= n) Facebook or LinkedIn, will thereafter be purged.

    2.2.&nbs= p;Once HMCO has conveyed emails and personal data received in the = said Harel Mallac Group Mailbox to relevant persons as per Clause 2.1 above= , those emails will be purged. Such personal data may continue to be proces= sed by HMCO and the other entities within its Group, including the Company,= where you provide your specific consent for them to keep your personal dat= a on file for up to two (2) years for any future job possibilities in the H= arel Mallac Group. After the said two (2) years, your said personal data sh= all be erased, unless there is another lawful ground to continue processing= same.

    2.3. If you submit your personal data f= or a job (a vacancy or future job opportunity) through the contact form (if= available) on our Website, you must direct your interest through the prope= r channel i.e. to the mailbox of the relevant officer of the Company or thr= ough the Careers Section on www.harelmallac.com

    2.4. As part o= f the recruitment process, your personal data will be processed and you may= be requested to conduct a psychometric assessment, which involves automate= d processing of certain of your personal data and which may be used in the = selection process. By participating in the psychometric assessment, you exp= licitly consent to the automated processing of your personal data and relia= nce thereupon for selection purposes. The retention policy in Clause 2.2 ab= ove shall also apply to this assessment and its results (subject to Clause = 2.4 below).

    2.5. If your candidature is successful,= your personal data, including any psychometric assessments conducted durin= g screening, shall be kept on record for the purposes of your contract of e= mployment/traineeship etc. If your candidature is unsuccessful, your person= al data shall be erased unless you provide your consent to keep your person= al data on file for up to two (2) years for any future job possibilities in= the Harel Mallac Group or there is another lawful ground to continue proce= ssing same.

    2.6. After employment or traineesh= ip etc. personal data shall be kept on record in order to comply with statu= tory requirements, for the purposes of defending and/or exercising any lega= l rights and/or where there is any other lawful basis to continue processin= g such personal data, whichever is the longer.

    2.7.=  Any third-party data processor that has been appointed to administer = our Website and/or social media forums are bound by confidentiality and the= Data Protection Policy and ancillary policies of the Harel Mallac Group.
    2.8. For job applications deposited at or poste= d to our offices, the above shall equally apply in those cases.
      =
  3. Other use:

    3.1. However, = once making your acquaintance, we would like to keep in touch with you and = use your personal data:
    =E2=80=A2 To personalise your experience (your i= nformation helps us to better respond to your individual needs);
    =E2=80= =A2 To improve our website (we continually strive to improve our website of= ferings based on the information and feedback we receive from you);
    =E2= =80=A2 To improve customer service (your information helps us to more effec= tively respond to your customer service requests and support needs);
    =E2= =80=A2 To administer a survey or other site feature;
    =E2=80=A2 To send t= o you latest offers and promotions regarding the different products and ser= vices of the Company and any affiliate within the Harel Mallac Group.
    3.2. Use of your personal data for other purposes i= s only a click away! Rest assured that you will be invited to tick a box, c= onsenting to use of your personal data for other purposes such as marketing= , surveys, customer satisfaction etc.

    3.3. Your personal data may be= processed and used by different companies within the Harel Mallac Group an= d/or consultants of the Company for such other purposes for which you provi= de your explicit consent and/or as permitted under law e.g. for defending o= r enforcing legal rights. We do not sell and/or trade in any personal data = collected on this Website.

    3.4. We implement a variety of security m= easures to maintain the safety of your personal data on the Website.
    3. Are you happy for us to use Cookies?

Our Website uses cookies. We use cookies to gather information about you= r computer for our services and to provide statistical information regardin= g the use of our Website. Such information will not identify you personally= - it is statistical data about our visitors and their use of our Website. = This statistical data does not identify any personal details whatsoever. We= may also gather information about your general Internet use by using a coo= kie file. Where used, these cookies are downloaded to your computer automat= ically. This cookie file is stored on the hard drive of your computer, as c= ookies contain information that is transferred to your computer's hard driv= e. They help us to improve our Website and the service that we provide to y= ou. All computers have the ability to decline cookies. This can be done by = activating the setting on your browser which enables you to decline the coo= kies. Please note that should you choose to decline cookies; you may be una= ble to access particular parts of our Website. 

D. HOW WE CARE:

  1. You can transmit your personal data through this website securely. =
  2. We have devised and implemented certain security policies, rules and te= chnical measures in order to protect the personal data that you have entrus= ted to us, namely by the following:
    =E2=80=A2 Unauthorised access
    =E2= =80=A2 Improper use or disclosure
    =E2=80=A2 Unauthorised modification=E2=80=A2 Unlawful destruction or accidental loss
    =E2=80=A2 Confidentia= lity obligations of our data processors. =

  3. We equally care about the personal data of children i.e. those below the= age of 16. Young ones may be interested in participating in one of our com= petitions for example. Parents or legal guardians of a child will be called= upon to provide their consent to the processing of any personal data of th= e child.Other than information required to complete a purchase on our websi= te, we do not knowingly collect personal data and our personal identifiable= information from children under the age of 16. If a child under the age of= 16 has provided us with personal information without parental or guardian = consent, the parent or guardian may contact us by emailing on dpo.es@harelm= allac.com. We will remove the information and unsubscribe the child from an= y of our marketing lists. In line with our legal obligations, we may ask th= e consent from the parents or guardians of a minor aged above 16 years befo= re a purchase is allowed on our website.

  4. We only keep your personal data for as long as needed, that is, for as = long as required under law, or for the purposes of any lawful processing, w= hichever is the longer.

E. LET=E2=80=99S CHECK:

Your access:
You are free to ask us what personal da= ta we hold on you and why. Just send us an email at dpo.es@harelmallac.com = and our Data Protection Officer will check and let you know.

We may need to ask you a few questions in order to ensure that the reque= st is actually coming from you!

F. KEEP US UP TO DATE:

Please do keep us up to date on any changes to your personal data


G. YOUR RIGHT TO SAY =E2=80=98NO=E2=80=99

  1. You have the opportunity to withdraw your consent and/or rectify and/or= erase any personal data or put a stop to the way that your personal data i= s being used, provided that there is no other lawful purpose (not requiring= consent) for which such data is required to be processed. =
  2. Complaints regarding any breaches of this Policy and/or contraventions = of the applicable data protection laws and regulations in force may be repo= rted to our Group Data Protection Officer or the divisional Data Protection= Officer (contact details mentioned below) or to the Data Protection Commis= sioner in Mauritius (dpo@govmu.org). <= /LI>


H. LINKING YOU TO OTHERS

  1. Our website may contain links to the websites of third parties, so as t= o broaden your experience. =
  2. These third party websites have separate and independent privacy polici= es. We therefore have no control over these websites and/or liability for t= heir content and/or products, goods, services and/or activities. =
  3. However, we care about the users of our website and welcome any feedbac= k about any third party websites linked from our website.


I. HOW THIS POLICY APPLIES TO YOU

  1. This online Privacy Policy applies only to your personal data collected= through our website and not to information collected offline, unless other= wise is specifically stipulated in this policy. =
  2. However, irrespective of the way in which, your personal data is collec= ted, we are committed to caring for your personal data in accordance with a= ll applicable laws and regulations in force.

J. TERMS GOVERNING OUR WEBSITE

Please also visit our Terms and Conditions section governing the use of = our website at: http://www.linxia.mu/content/87-terms-and-conditions

K. KEEPING YOU UP TO DATE

Changes to our Privacy Policy
If we decide to change our privacy poli= cy, we will post those changes on this page.

L. KEEPING IN CONTACT

If there are any questions regarding this Privacy Policy you may contact= us via our contact details below:-

Name: Linxia Ltd
C/O Data Protection Officer,
Address: 18 = Edith Cavell Street, PO Box 36, Port Louis 11302, Mauritius
Tel: (+230) = 207 3200
Fax: (+230) 207 3232
Email: dpo.es@harelmallac.com

Name: Harel Mallac,Group Data Protection Officer,
Address: 18= Edith Cavell Street, PO Box 36, Port Louis 11302, Mauritius
Tel: (+230)= 207 3000
Fax: (+230) 207 3030
Email: groupdpo@harelmallac.com

PRIVACY NOTICE - e-commerce

 

We care about your personal data. Before we collect your personal data,= please be informed of the following information regarding how your data wi= ll be used:

1. The identity and contact details of the controller and, where applic= able, its representative and any data protection officer;

Controller: Linxia Ltd (BRN.C10006367), (hereinaft= er the =E2=80=9CCompany=E2=80=9D)
Data Protection Officer: Ms. Jennifer DEVILLE
Email address of Data Protection O= fficer: dpo.e= s@harelmallac.com 

2. The purpose for which the data are being collected;

2.1. If you are purchasing online through our e-shop, your personal data= , such as name, address, contact details and bank details will be collected= and used for pre-contractual and contractual purposes, namely for processi= ng your purchase order and/or your transaction and any after sales and warr= anty.

2.2. Bank and payment details being submitted on the Bank=E2=80=99s onli= ne platform or through a hire purchase company, will not be collected by th= e Company. Such personal data will be collected directly by those financial= institutions. The Company will simply be informed of whether payment has b= een successfully effected or not.

2.3. Your personal data may also be processed for the following purposes= :

     i.    For the purposes of complying w= ith legal (statutory) obligations such as with respect to tax and/or for st= atutory record-keeping.
     ii.    custom= er surveys.
     iii.    Marketing. <= /P>

2.4. If you opt for payment by way of hire-purchase, you will be directe= d to the website of that hire-purchase company whereby you will enter into = a contract with that third party for payment on credit terms. The hire-purc= hase company will in such event be required to effect full payment of the p= urchase price to the Company.

3. The intended recipients of the data;

3.1. Your personal data will be used by the following recipients, on a s= trictly need to know basis for the above purposes:

   -    The Company and its respective employee= s, agents, consultants, contractors and advisors, namely for pre-contractua= l and contractual purposes.
   -    Other entit= ies in the Harel Mallac Group and their respective employees e.g. for direc= t marketing purposes where you have consented to same.
   -&nb= sp;   Any third-party transport delivery service provider contrac= ted by the Company.
   -    The Mauritius Comme= rcial Bank for payment purposes.
   -    Hire-p= urchase companies listed on our website.
   -   &nbs= p;ProximaWeb, the developer and administrator of the e-shop and its employe= es on a strictly need to know basis.
   -    Th= e Company=E2=80=99s banks, auditors, lawyers.
   -  =  Relevant authorities where there is a legal (statutory) obligation e= .g. for tax purposes.

4. Whether or not the supply of the data by that data subject is volunt= ary or mandatory;

The supply of such data is mandatory for the purposes of your order/purc= hase, where contractual obligation, legal obligation or legitimate interest= are normally the lawful grounds on which your personal data is processed f= or the above purposes as per law.

If consent is the lawful ground for processing your personal data e.g. f= or direct marketing, you will be requested to provide your explicit consent= .

The supply of data for direct marketing is voluntary and such consent ma= y be withdrawn.

5. the existence of the right to withdraw consent at any time, without = affecting the lawfulness of processing based on consent before its withdraw= al;

If the processing is done on a lawful ground that is not consent, such a= s contractual obligation, legal obligation or legitimate interest, your con= sent is not required for such processing and thus there is no consent to be= withdrawn. 

If consent is the lawful ground for processing your personal data, you w= ill be requested to provide your explicit consent. Consent if applicable ma= y be withdrawn in accordance with the standard request form of the data con= troller and its Rights Management Policy found on www.harelmallac.com 

6. The existence of the right to request from the controller acces= s to and rectification, restriction or erasure of personal data concerning = the data subject or to object to the processing;

A request for rectification or erasure of data must be in accordance wit= h the standard request form of the data controller and its Rights Managemen= t Policy found on www.harelmal= lac.com

7. The existence of automated decision making, including profiling= , and information about the logic involved, as well as the significance and= the envisaged consequences of such processing for the data subject;

Your data may be subject to profiling for marketing, customer care and/o= r future sales purposes of the Company.

8. The period for which the personal data shall be stored;

Such data shall be kept and used for the duration of the lawful processi= ng applicable. This will probably be for the performance of a contract/tran= saction. 

After the performance of the contract/transaction, the Company shall kee= p the personal data for a period of ten (10) years (this period includes th= e statutory period for record-keeping under the Income Tax Act and Companie= s Act and the limitation period under law for the establishment, exercise o= r defence of a legal claim).

Data is to be disposed of after the end of the period of record-keeping = unless required for the establishment, exercise or defence of a legal claim= or there is another lawful ground for processing such data (e.g. direct ma= rketing) or there is an exception under the Data Protection Act which appli= es.

Such data shall be kept and used for direct marketing purposes, on the l= awful basis of consent, where you consent to same and provided that consent= has not been withdrawn. 

9. The right to lodge a complaint with the Commissioner;

Yes. Please refer to the Company=E2=80=99s Data Protection Policy and Ri= ghts Management Policy found on www.harelmallac.com 

10. where applicable, that the controller intends to transfer pers= onal data to another country and on the level of suitable protection a= fforded by that country;

The hosting and back-up of data from the e-shop will be on the OVH Cloud= , in France. Customer data is also stored by us on Microsoft Azure Cloud in= EMEA (Europe, Middle East and Africa), namely Austria, Finland, France, Ir= eland, Netherlands.

Access to such personal data is access protected. OVH ensures encryption= for security purposes. The EU General Data Protection Regulation offers a = suitable legal framework for the protection of personal data.  

11. Any further information necessary to guarantee fair processing in r= espect of the data subject=E2=80=99s personal data, having regard to t= he specific circumstances in which the data are collected.

This Privacy Notice must be read in conjunction with the master privacy = policy and website terms and conditions found on www.linxia.mu  

By submitting your purchase order to us through our e-shop, you= hereby confirm having read and understood this privacy notice and agree to= adhere to Linxia Ltd=E2=80=99s terms and conditions of sale and the terms = and conditions of our website.
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