O R I O N

Privacy Policy

THEFUTUR PRIVACY POLICY

Consent to installation of the App

Under Data Protection Act 2017, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data.

Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information).

How you can withdraw consent

Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us on 55002555 or send us an email on support@oriongroup.mu but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Consent to processing Location Data

Your consent includes consent to processing of your Location Data so that location-enabled Services are activated for purpose of location enabled services.

Location Data

TheFutur is committed to protecting your personal data and respecting your privacy.

Introduction

This policy (together with our end-user Terms and Conditions) applies to your use of:

  • TheFutur mobile application software (App) available on Playstore, Appstore and other platforms, once you have downloaded the App onto your mobile telephone or handheld device (Device).
  • Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Collection of Information

  • We may collect Personal Information about you that you provide to us while using TheFutur and information about how you use TheFutur, visit TheFutur or make purchases for any intended product or Service.

Making Purchases:

  • When you visit TheFutur, make purchases for any intended products or service, we may collect and process certain information (which may contain your Personal Information or may contain non-personally identifiable information but nevertheless linked to your Personal Information).
  • Feedback on and responses to surveys conducted by TheFutur relating to the Services which may be published, circulated or distributed by TheFutur;
  • Information automatically collected and stored in our server or the server of our third-party services provider by using or accessing to TheFutur (including your computers Internet Protocol (IP) address, browser type, browser information, pages visited, previous or subsequent sites visited).

Storage of Information

  • The Personal Information and other data we collect from you may be transferred to, processed, and stored in our servers or the servers of our third-party services providers. Your Personal Information will be stored as long as is necessary to fulfil any of the purposes described in this Privacy Policy, or to comply with any contractual or legal requirement.
  • TheFutur will use reasonable endeavours to maintain appropriate physical, electronic and organisational procedures to ensure that your Personal Information and other data is treated securely and in accordance with this Privacy Policy, and to protect such data against unauthorized access or unauthorized alteration, disclosure or destruction of data.
  • Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. TheFutur does not give any representation, warranty or undertaking that the Personal Information you provide to us will be secure at all times, and to the extent TheFutur has fulfilled its obligations under no circumstances shall TheFutur be responsible for any losses, damages, costs and expenses which you may suffer or incur arising from unauthorised access to or use of your Personal Information.
  • All payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using online encryption technology. You are responsible for keeping your chosen password confidential and not to share your password with any third party.

Usage of Information

  • TheFutur will not sell or rent your Personal Information to third parties.
  • TheFutur will use Personal Information and other data collected to provide you with the Services, to continually improve TheFutur and the Services, and to contact you in relation to the Services. Improving TheFutur and the Service implies that we use your Personal Information or such other data to achieve faster purchase requests, better customer support and to provide you with timely notice of new products, Services and special offers.
  • From time to time, we may also make use of your Personal Information to contact you for feedback on your use of TheFutur, to assist us in improving TheFutur.
  • We process the Personal Information collected in as far as necessary for performance of the contract with you, for example when you purchase a product via the Website. Besides, we process the other Personal Information collected on the basis of our legitimate interests, which are the further improvement of the Service and for direct marketing purposes.

Disclosure of Information

  • We may from time-to-time share and disclose your Personal Information and other data to third parties. The circumstances under which such sharing and disclosure will take place may include without limitation, the following:
  • To our third-party service providers (including Google Analytics), which we engage amongst others for the performance of certain services on our behalf, such as web hosting services, data analysis, marketing, market research, and to otherwise provide you with customer service.
  • If and to the extent required by any applicable law, order of court or requests by any governmental authority to make such disclosure.
  • Besides, in case of a corporate transaction, in connection with the sale, merger, acquisition, or other corporate reorganization or restructuring of our company, your Personal Information may be disclosed, shared or transferred to the new controlling entity or its authorised third party for carrying on our business.
  • To our advisors, agencies or other parties concerned in order to protect the rights and property of TheFutur.

In any other case, to any third parties with your prior written consent (and in which case we will make it possible for you to withdraw your consent as easily as it was to provide consent).

Important information and who we are

TheFutur is the controller and is responsible for your personal data (collectively referred to as [“Company”], “we”, “us” or “our” in this policy).

Contact details

Our full details are:

You have the right to make a complaint at any time for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 13th March 2024. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you [by SMS OR by email OR when you next start the App or log onto one of the Services Sites]. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data.
  • Contact Data.
  • Financial Data.
  • Transaction Data.
  • Device Data.
  • Content Data.
  • Profile Data.
  • Usage Data.
  • Marketing and Communications Data.
  • Location Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, [make an in-App purchase,] [share data via an App’s social media functions,] [enter a competition, promotion or survey,] and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
  • Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.
  • Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
  • Device Data from the following parties:

analytics providers [such as Google based outside Mauritius];

advertising networks based; and

search information providers.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
  • Identity and Contact Data from data brokers or aggregators; and
  • Identity and Contact Data from publicly available sources.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) (Playstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform a contract we are about to enter or have entered with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5).

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers.

In some circumstances you can ask us to delete your data.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of one year then we will treat the account as expired and your personal data may be deleted.

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Internal third parties

Other companies [acting as joint controllers or processors] which provide [IT and system administration services and undertake leadership reporting].

External third parties

Service providers [acting as processors] who provide [IT and system administration services].

Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers who provide [consultancy, banking, legal, insurance and accounting services].

HM Revenue and Customs, regulators and other authorities [acting as processors or joint controllers] [who require reporting of processing activities in certain circumstances].

Your legal rights

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
      1. if you want us to establish the data’s accuracy;
      2. where our use of the data is unlawful but you do not want us to erase it;
      3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
      4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services
  • to you. We will advise you if this is the case at the time you withdraw your consent.

Description of categories of personal data

  • Identity Data: [first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender].
  • Contact Data: [billing address, delivery address, email address and telephone numbers].
  • Financial Data: [bank account and payment card details].
  • Transaction Data: includes [details about payments to and from you and details of in-App purchases].
  • Device Data: includes [the type of mobile device you use,] [a unique device identifier [(for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device)],] [mobile network information,] [your mobile operating system,] [the type of mobile browser you use,] [time zone setting,] [OTHER INFORMATION].
  • Content Data: includes information stored on your Device, including [friends’ lists,] [login information,] [photos, videos or other digital content,] [check-ins,] [OTHER INFORMATION].
  • Profile Data: includes [your username and password, in-App purchase history, your interests, preferences, feedback and survey responses].
  • Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, [traffic data [and other communication data],] whether this is required for our own billing purposes or otherwise [and the resources that you access].
  • Marketing and Communications Data: includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
  • Location Data: includes [your current location disclosed by [GPS technology OR [OTHER TECHNOLOGY]].