Data Privacy Policy

At Pure North Markets, we recognize the importance of personalinformation entrusted to us. It is one of our fundamental responsibilities as afinancial institution to ensure that we protect the information entrusted to usby our clients and our website visitors.

This Privacy Notice will inform you as to how we look after yourpersonal data and tell you about your privacy rights and how the law protectsyou. It applies to any personal information you provide to PNMandsubject to local law, any personal information we collect from other sources.

Throughout this Notice, “PNM”refers to Pure North Markets,including its affiliated companies and subsidiaries (also referred to as “we ”,“us ”or “our ”).

To preserve the confidentiality of all information you provideto us, we maintain the following privacy principles:

·      We only collect personal information that we believe arerelevant and required to understand your needs and to conduct our business.

·       We use your personalinformation to provide you with better customer services and products.

·       We will not discloseyour personal information to any external organization unless we have yourconsent or are required by law.

·       We may be required fromtime to time to disclose your personal information to Governmental or judicialbodies or agencies or our regulators, but we will only do so under properauthority.

·       We aim to keep yourpersonal information on our records accurate and up-to-date.

·       We maintain strictsecurity systems designed to prevent unauthorized access to your personalinformation by anyone, including our staff.

Lawful basis for processing your personal data

Your privacy is protected by law and this section explains howthat works. In accordance to the Data Protection Act, we are allowed to useyour personal information only if we have a proper reason to do so. Thisincludes sharing it outside RHC. The law states that we must have one or moreof these reasons:

·      Fulfil a contract we have with you, or

·       When it is our legal orregulatory duty, or

·       Where it is necessaryfor our legitimate interests (or those of a third party) and your interests andfundamental rights do not override those interests or

·       When you consent to it.

A legitimate interest is when we have a business or commercialreason to use your information. But even then, it must not unfairly go againstwhat is right and best for you.

Your Consent

PNM will process your personal data onlyafter obtaining your express consent, where it is necessary for the performanceof a contract to which you are a party or to enable you to enter into acontract or in accordance with the law. You give your consent to us through ouraccount opening mandate and during your relationship with us. We will only disclose your personal data if:

·      the law requires it or such personal data is exempted from dataprotection laws;

·       such disclosure is forthe administration of justice or in the public interest or relates to the useof a unique identification number to facilitate sharing information and avoidmultiple registrations among public sector agencies;

·       such disclosure isnecessary for the performance of a contract to which you are a party or toenable you to enter into a contract; or

·       such disclosure isrequired to protect your vital interests;

·       you agreed that we maydisclose your data for the purposes for which such data has been collected andof which you have been informed.

Change of Purpose

We will only use your personal data for the purposes for whichwe collected it, unless we reasonably consider that we need to use it foranother reason and that reason is compatible with the original purpose.

What type of information PNM may collect from you?

National Identifier:  A number given to you by a governmentto identify who you are, such as a National Identity Card, Passport.

Contact details:  Where you live and how to contact you

Socio-Demographic:  This includes details about your workor profession, nationality, education and where you fit into general social(Social Research/Survey) or income groupings.

Financial:  Your financial position, status andhistory

Contractual/ Transactional:  Details about payments to andfrom your accounts with us, and insurance claims you make.

Locational:  Location data from your mobile phoneand the IP address of your connection when using a computer while using our /my PNM Mobile application or our Online Portal. Data pertainingto the shops where you make a purchase with your PNMCard –Rewards.

Transactional:  Details about payments to and fromyour accounts with us and insurance claims you make.

Behavioural:  Details about how you use ourproducts and services.

Usage Data:  Other data about how you use ourproducts and services.

Technical:  Details on the devices and technologyyou use.

Communications: What we learn about you from letters,emails and conversations between us.

Social relationships:  Your family, friends and otherrelationships.

Open Data and Public Records:  Detailsabout you that are in public records such as the Electoral Register andinformation about you that is openly available on the internet.

Documentary Data:  Details about you that are stored indocuments in different formats or copies of them. This could include thingslike your passport, driver ’s license or birth certificate.

Special categories of personal data: The law and otherregulations treat some types of personal information as special. We will onlycollect and use these types of data if the law allows us to do so:

·      Racial or ethnic origin

·       Political Opinion

·       Religious orPhilosophical beliefs

·       Trade Union membership

·       Genetic and biometric  data

·       Physical or mentalhealth or condition

·       Sexual orientation,practices and preferences

·       Criminal convictionsand offences

Why does PNM collect information about you?

We collect personal information to carry out and administer ourservices and products to you. These may include claims management, riskmanagement consulting and other forms of insurance services (includingunderwriting of insurance products and reinsurance), employee benefits programadministration and investment advisory services.

How does PNM  collect your personal information?

When you request our services, we ask you to provide accurateand necessary information that enables us to respond to your request.

While the personal information we collect may come directly fromyou, it may also be provided by our affiliates or other third parties (such asemployers, insurance companies, insurance brokers or agents, creditorganizations, motor vehicle and driver licensing authorities, financialinstitutions, medical professionals, etc.). If you provide personal informationabout other individuals (such as employees, dependents, etc.), you must obtaintheir consent prior to your disclosure to RHC.

PNM may collect information online whenyou:

Visit PNM Websites

For purposes of this Notice, "website "includes ourmobile applications.

By using PNM websites and associated microsites,you agree to the processing of your personal information as explained in theTerms and Conditions, including placing cookies on your device as described inthe Cookie Notice.

We collect personal information to fulfil your requests forproducts and services and to improve your online experience. We strive to limitthe amount of personal information collected to support the intended purpose ofthe collection.

In some instances, PNM automatically collectscertain types of information when you visit our websites and through e-mailsthat we may exchange. Automated technologies may include the use of web serverlogs to collect IP addresses, "cookies "and web beacons. The collectionof this information allows us to improve the effectiveness of PNMwebsitesand our marketing activities.

Cookies

PNM may collect information during yourvisit to an PNM website through the use of cookietechnology. A cookie is a piece of programming information contained in a verysmall text file that is placed in your Internet browser or elsewhere on yourhard drive. You can control acceptance of cookies by modifying your Internetbrowser preferences. You have the ability to accept all cookies, to be notifiedwhen a cookie is set or to reject all cookies. Please note that, if you chooseto block all cookies (including essential cookies) you may not be able toaccess all or part of our site and may be unable to use those services orengage in activities that require the placement of cookies. PNMusescookies to distinguish you from other users of our website and to help uscompile aggregate statistics about usage of our websites.

In addition, on some occasions, PNM may use trackingtechnologies such as web beacons, to collect information about your visits toPNM websites. These are small electronic images embedded inweb content or e-mail messages and are ordinarily not visible to users. Likecookies, this tracking technology enables us to track pages and contentaccessed and viewed by users on PNM websites. The use ofthese technologies also helps us to provide you with a positive experience whenyou browse our websites, and it also helps refine our content and personalizeyour experience. For more detailed information, you may wish to visit ourCookie Notice.

Engage with PNM through Social Media

You can engage with us through social media websites or throughfeatures such as plug-ins or applications on PNM websites that integratewith social media sites. You may also choose to link your account with us tothird party social media sites. When you link your account or engage with us onor through third party social media sites, plug-ins, or applications, you mayallow us to have ongoing access to certain information from your social mediaaccount (e.g., name, e-mail address, photo, gender, birthday, the posts or the'likes 'you make).

If you post information when you interact with our websitesthrough social media sites, plug-ins or other applications, depending on yourprivacy settings, this information may become public on the Internet. You cancontrol what information you share through privacy settings available on somesocial media sites. For more information about how you can customize yourprivacy settings and how third party social media sites handle your personallyidentifiable information, please refer to their privacy help guides, privacystatements and terms of use.

Access our Websites through Mobile Devices

If you access our websites on your mobile telephone or mobiledevice, we may also collect your unique device identifier and mobile device IPaddress, as well as information about your device 's operating system, mobilecarrier and your location information.

When you provide us your mobile device phone number as yourcontact phone number, you consent to the use of your mobile device phone numberfor the purposes identified in this Notice. If you choose to receivenotifications from us on your mobile device (e.g., text notifications), youalso consent to the use of your mobile phone number for that purpose.

Marketing

We may use your personal information to tell you about relevantproducts and offers. This is what we mean when we talk about “marketing ”.

We may collect personal information from visitors of our websiteand those individuals that participate in a contest or promotion (online orover the telephone, or at one of our branches). Such information is onlycollected from individuals who voluntarily provide us with their personalinformation.

The personal information we have for you is made up of what youtell us and data we collect when you use our services or from third parties wework with.

We study this to form a view on what we think you may want orneed, or what may be of interest to you. This is how we decide which products,services and offers may be relevant for you.

We can only use your personal information to send you marketingmessages if we have either your consent or a “legitimate interest ”.

You can choose to receive marketing and other promotionalmaterials by e-mail. If you do receive email or promotional direct mailings,you will always have an opportunity to opt-out. If at any time you would likeus to cease sending you direct mailings, please contact us or ourrepresentatives by emailing to support@metadoro.com

How does PNM use your personal information?

The personal information we collect may be used to:

·      provide information and services as requested by you;

·       determine eligibilityand process applications for products and services;

·       understand and assessyour ongoing needs and offer products and services to meet those needs;

·       carry outcommunication, service, billing and administration;

·       administer claims;

·       obtain and updatecredit information with appropriate third parties, such as credit reportingagencies, where transactions are made on credit;

·       personal data wecollect from ads will be used for the purpose to discuss the potential ofestablishing business relation;

·       market products andservices (subject to your consent); and

·       conduct processingnecessary to fulfil other contractual obligations

With your consent, we may also use your personal information foradditional purposes.

Does PNM disclose your personal information?

Business Partners

We disclose personal information to business partners that arenecessary to provide our products and services. Examples include: credit andfraud reporting agencies, reinsurers, medical service providers, our adviserssuch as loss adjusters, lawyers and accountants and others involved in theclaims handling process.

We do not rent, sell or otherwise disclose personal informationabout our clients with unaffiliated third parties for their own marketing use.

Authorized Service Providers

We may disclose your information to service providers we haveretained to perform services on our behalf. These service providers arecontractually restricted from using or disclosing the information except asnecessary to perform services on our behalf or to comply with legalrequirements.

Legal Requirements and Business Transfers

We may disclose personal information

1.   if we are required to do so by law or legal process,

2.   in response to law enforcement authority or other governmentofficial requests,

3.   when we believe disclosure is necessary or appropriate toprevent physical harm or financial loss,

4.   in connection with an investigation of suspected or actualillegal activity or

5.   in the event that PNM is subject to a mergeror acquisition to the new owner of the business. Disclosure may also berequired for company audits or to investigate a complaint or security threat

Does PNM transfer your personal informationacross geographies?

PNM may transfer certain personalinformation across geographical borders to PNM entities or serviceproviders in other countries working on our behalf in accordance withapplicable law. We may transfer personal data to another country where you havegiven explicit consent to the proposed transfer.

Notwithstanding the above, consent is not necessary in the caseof Reinsurance.

Does PNM have security measures in place toprotect your information?

PNM has implemented reasonable physical,technical and administrative security standards to protect personal informationfrom loss, misuse, alteration or destruction.

Our service providers and agents are contractually bound tomaintain the confidentiality of personal information and may not use theinformation for any unauthorized purpose.

How can you access and update your information?

PNM takes reasonable steps to keep yourpersonal information accurate and complete. You can access or update yourpersonal information in the following ways.

Profile

To amend your personal data, please reach us atsupport@metadoro.com

Mobile Devices

If you previously chose to receive push notifications on yourmobile device from us but no longer wish to receive them, you can manage yourpreferences either through your device or the application settings. If you nolonger wish to have any information collected by the mobile application, youmay uninstall the application by using the uninstallation process available onyour mobile device.

Cookies

As described in our Cookie Notice, you can adjust your browsersettings to accept or refuse cookies.

Email

Contact us at the e-mail or postal address listed in the"Contact Us "section at the bottom of this Notice. Please includeyour current contact information, the information you are interested inaccessing and your requested changes. We will provide you access to thepersonal information requested, subject to reasonable limitations provided bylaw, unless it infringes on the privacy of other individuals.

If we do not provide you with access, we will provide you withthe reason for refusal and inform you of any exceptions relied upon.

How PNM uses your information to makeautomated decisions?

We sometimes use systems to make automated decisions based onpersonal information we have or allowed to collect from others about you andyour business. This helps us to make sure our decisions are quick, fair,efficient and correct, based on what we know. These automated decisions canaffect the products, services or features we may offer you now or in the futureor the price that we charge you for them.

You have the right to object to an automated decision.

What are your legal rights?

Right of Information and Access

This right enables you to receive a copy of all your personalinformation we hold about you free of charge and to check that we are lawfullyprocessing it.

Right to rectify

This enables you to have any incomplete or inaccurate data wehold about you corrected, though we may need to verify the accuracy of the newdata you provide to us by a supplementary statement.

Right of Erasure

This enables you to ask us to delete or remove personal datawhere it is no good reason for us continuing to process it. You also have theright to ask us to delete or remove your personal data where you havesuccessfully exercised your right to object to processing, where we haveprocessed your information unlawfully or where we are required to erase yourpersonal data to comply with local law. Note, however, that we may not alwaysbe able to comply with your request for erasure for specific legal reasons whichwill be notified, if applicable, at the time of your request.

Right to object

Where we are relying on a legitimate interest (or those of athird party) and there is something about your particular situation which makesyou want to object to processing on this ground as you feel it impacts on yourfundamental rights and freedoms, you have the right to object in writing at anytime to the processing of your personal data.

Right to restrict

This enables you to ask us to suspend the processing of yourpersonal data in the following scenarios:

·      If you want us to establish the data ’s accuracy;

·       Where our use of thedata is unlawful but you do not want us to erase it;

·       Where you need us tohold the data even if we no longer require it as you need it to establish,exercise or defend legal claims; or

·       You have objected toour use of your data but we need to verify whether we have overridinglegitimate grounds to use it.

·        

Right to withdraw consent at any time

This will not affect the lawfulness of any processing carriedout before you withdraw your consent. If you withdraw your consent, we may notbe able to provide certain products and services to you. We will advise you ifthis is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above,please write to us at the following address:

The Data Protection Officer

Pure North Markets

3 Emerald Park, Trianon, Quatres Bornes, 72257 Republicof Mauritius

You will not have to pay a fee to access your personal data (orto exercise any of the other rights). However, we may charge a reasonable feeif your request is clearly unfounded, repetitive or excessive.

What we may need from you

We may need to request specific information from you to help usconfirm your identity and ensure your right to access your personal data (or toexercise any of your rights). This is a security measure to ensure thatpersonal data is not disclosed to any person who has no right to receive it. Wemay also contact you to ask you for further information in relation to yourrequest to speed up your response.

Time Limit to respond

We try to respond to all legitimate requests within one month.Occasionally it may take us longer than a month if your request is particularlycomplex or you have made a number of requests. In this case, we will notify youand keep you updated.

Third Parties

We ask third-party service providers to agree to our privacypolicies if they need access to any personal data to carry out their services.

We will not disclose your personal data to externalorganizations that are not our service providers, unless you gave us yourconsent, or unless we may do so by law, or if it is necessary for theconclusion or performance of our agreement with you.

Does PNM collect information from children?

Children have the same rights as adults over their personaldata. They can exercise their own rights as long as they are competent to doso. Where a child is not considered to be competent, an adult with parentalresponsibility may exercise the child ’s data protection rights on theirbehalf. For children under 16, we need to get consent from whoever holdsparental responsibility for them.

Our websites are not directed to children and we do notknowingly collect personal information from children on our websites.

Storing Personal Data

We store your personal data during your relationship with us andeven after we have ceased our relationship, as required by law.

Your right to lodge a complaint with the Commissioner

Please let us know if you are unhappy with how we have used yourpersonal information. You can contact the Data Protection Officer. You alsohave the right to lodge a complaint with the Commissioner. Find out on theirwebsite how to report a concern.

Contact Us

If you have any questions relating to this Notice, pleasecontact our Data Protection Officer at PNM

3 Emerald Park, Trianon, Quatres Bornes, 72257 Republic ofMauritius.

Changes to this Notice

We may need to update this Notice from time to time. Weencourage you to periodically check our website so that you will be aware ofour latest privacy practices. This Notice was last updated on September, 2024.

It is important that the personal data we hold about you isaccurate and current. Please keep us informed if your personal data changesduring your relationship with us.

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