PRIVACY POLICY

This Privacy Policy aims to provide you with a clear understanding of how we collect and process your personal information when you use this website. This includes any data you may provide while interacting on the website, such as entering contact information in conversations or messaging with our team, or when seeking information about our software and potential services. This policy is dedicated to ensuring the protection and preservation of your personal information, including data privacy and communication preferences. It is essential to review this Policy alongside our other policies available on this Website.

1. INTRODUCTION

vinusinternational is owned and operated by Vinus International Ltd, with registration number 15712 and registered address at Hamchako, Mutsamudu, The Autonomous Island of Anjouan, Union of Comoros. Vinus International Ltd, referred to as "Vinus International Ltd", "we", "our" or "Controller", is the designated controller responsible for processing your personal data. Pursuant to Article 27 of Comoros’ Constitution of 2018 regarding the privacy of personal data and the free movement of such data. For inquiries about this Policy, please contact [email protected].

POLICY UPDATES

This policy was last updated on May 15, 2024.

2. TYPES OF DATA COLLECTED

2.1. Privacy

This refers to any personally identifiable information, excluding deleted (anonymized/anonymized) data.

2.2. Personal information categories

  • Identification data: Limited to first name, last name, and middle name (if applicable).
  • Contact and communication data: Limited to email address, phone number, Skype, or other means of contact.
  • Technical data: This includes your IP address, browser type and version, time zone and location, operating system and/or device information, and other technical details of the device or means used to access this website.
  • Website data: Relates to information about your use and navigation of this website.

2.3. Aggregated data

We may collect, use, and share aggregated data, such as statistical or demographic data, for various purposes. This data, derived from some of your personal data, does not directly or indirectly reveal your real identity and may be used, for example, to calculate the overall percentage of visitors to a website or specific parts of a website.

2.4. Special categories and crime data

We do not collect specific categories of personal data (Article 9(1) GDPR), and we do not process personal data relating to criminal convictions and/or offenses.

PROCESSING OF MINORS' DATA

The Website is explicitly not designed for individuals under the age of 18, and we do not knowingly intend to process data of individuals under this age. If you are a parent or legal guardian and discover that your child has utilized our Website, kindly contact us through available communication channels, and we will promptly implement appropriate measures.

3. METHODS OF DATA COLLECTION

3.1. Various Means of Data Collection Include, But Are Not Limited To:

3.1.1. Information Provided through Website Contact Form and/or Website Online Chat:

This method involves the collection of Identification data, Contact and communication data, and other pertinent information voluntarily submitted by the individual. Such data is gathered through the individual's voluntary input on our Website and is processed to provide clear responses to queries or requests. Legal Basis: The legal justification for this processing is your explicit consent.

3.1.2. Information Collected Automatically:

In this mode, we gather Website data and Technical data, encompassing details about Website navigation, products of interest, dynamic IP address, browser type, operating system, referral sources, and other relevant information. Legal Basis: The legal basis for this processing is the ongoing monitoring and enhancement of our Website and user interactions.

3.1.3. Information Obtained through Third Parties and/or Publicly Available Sources:

Data may be acquired through third-party services, such as Analytics providers (e.g., Google Analytics for tracking and reporting Website traffic), or via Social Media platforms (e.g., Facebook, LinkedIn) to verify the authenticity of provided Identification data. Legal Basis: The legal basis for this processing is the protection of our own and third-party legal rights.

3.1.4. Information Collected via Our Cookies:

Cookies, small text files automatically sent to the user's device for Website access, facilitate data collection. Refer to the Cookie Policy in the respective Website Policy section using the provided link. Legal Basis: The legal justification for this processing is your explicit consent.

3.1.5. Information Recorded for Documentation and Correspondence:

We may retain and process personal information from Clauses 3.1.1 to 3.1.4 for record-keeping and defense against legal claims when necessary. Legal Basis: The legal basis for this processing is the protection of our own, yours, and, if applicable, third-party legal rights.

4. HOW IS THE COLLECTED DATA USED?

4.1. The use of collected data is subject to legal permissions. Personal data is generally utilized in the following scenarios:

  • Contacting you based on your contact form and/or online chat query, as per Article 6(1)(a) of the General Data Protection Regulation (GDPR).
  • Executing a non-disclosure agreement for subsequent business proposals, as described in Article 6(1)(b) of the GDPR.
  • Necessary to protect our legitimate interests and/or the legal rights of us, you, and third parties (as applicable), under Article 6(1)(d) and 6(1)(f) of the GDPR.
  • Fulfilling other legal obligations as a controller pursuant to Article 6(1)(c) GDPR.

In accordance with clause 4.1. (c), Personal data may be processed for our legitimate interests and for the purposes described below:

  • Collecting, recording, and processing information obtained, conducting statistical and other analyses, and further research to enhance and upgrade the website and services.
  • Managing and developing the website and its services.
  • Enhancing the website user experience, including providing personalized services.
  • Contacting you regarding your request/inquiry via follow-up correspondence.
  • Profiling you and/or your activities on the Website for the purpose of improving the marketing of the Website and Services.

5. PRINCIPLES OF DATA PROCESSING

5.1. Your fundamental rights are fully respected, and safeguarding your privacy is the top priority of Vinus International Ltd. In processing personal data, we adhere to the fundamental principles outlined in Article 5 of the GDPR.

5.1.1. Principles of Legality, Fairness, and Transparency (under Article 5(1)(a)):

We handle your personal data in a legitimate manner to ensure transparency throughout the data processing process.

5.1.2. Purpose Limitation and Data Minimization Principles (under Article 5(1)(b) and (c)):

Personal data is collected and processed solely for legitimate and explicit purposes as outlined in this Policy.

5.1.3. Accuracy Principle (under Article 5(1)(d)):

Received personal information is securely maintained and diligently verified with your assistance to ensure accuracy. Corrections or updates will be made as necessary.

5.1.4. Identification Principle (under Article 5(1)(e)):

Your personal data will be retained in identifiable form for as long as necessary for the processing purpose.

5.2. We confirm that your personal data is collected only for the purposes specified in this Policy, and we have no intention to collect it beyond this scope. Additionally, the personal data collected is not utilized for automated decision-making or profiling.

5.3. Without prejudice to this Policy, we will not disclose, intend to disclose, or transfer your personal data to any third party without your consent, except where permitted or obligated to do so by law or specific contractual agreement.

5.4. As a data controller, we ensure compliance with all applicable laws and legal obligations.

6. DATA SHARING AND DISCLOSURE

6.1. Under certain circumstances, we may share and disclose your personal data as described below:

6.1.1. Legal Compliance (Local and International Laws, Authorities Requests, Harm Prevention):

We disclose your personal information to courts, government authorities, law enforcement agencies, or authorized third parties where required or permitted by law.

  • Local and International Laws: We are obligated to comply with legal obligations under applicable laws.
  • Requests from Authorities: We must comply with legal obligations and respond promptly and appropriately to claims against us.
  • Preventing Harm: We must respond to requests related to criminal investigations or suspicions of illegal activity or activities that may expose us, you, or third parties to legal liability.

6.2. Service Providers (Third Parties):

We may engage third-party software and payment providers to assist us in providing services on this Website. These service providers may be located within or outside the Union of Comoros. Our service providers have limited access to your data and are bound by contracts requiring them to provide the same level of protection and security for information disclosed and provided by us as outlined in this Policy.

6.3. Our Affiliates:

We may share your personal information with any member of our group (including our subsidiaries, our ultimate holding company, and its subsidiaries) where reasonably and lawfully necessary for the purposes of this policy.

6.4. Aggregated Data (as described in Section 2.2 of this Policy):

We use aggregated and/or anonymized information for legal compliance, business and market analysis, demographic data analysis and research, marketing, and other business purposes. You can share it.

7. DATA SUBJECT RIGHTS

7.1. Under the GDPR, you possess the following rights regarding the personal information you provide:

7.1.1. Request access to or a copy of the personal information you have provided to us, along with information concerning its processing.

7.1.2. If your personal information is inaccurate or incomplete, please request correction.

7.1.3. Request, where technically feasible, your personal data in a portable format (structured, commonly used, and machine-readable) for transmission to another controller.

7.1.4. Request that we cease and restrict all processing of your personal data as explicitly stipulated by law.

7.1.5. Object to any processing of your personal data as explicitly stated in the law.

7.1.6. Object to automated processing, including profiling, that impacts or may affect you.

7.2. All rights outlined in 7.1. can be exercised by sending an email to the administrator email provided in the introduction section. Before taking action, we may request verification of your identity to ensure the protection and security of your processed personal data.

7.3. A response to your request will be provided within one month of receiving your request. Notwithstanding the aforementioned response period, it may be extended for an additional three months depending on the complexity of the request and the number of pending requests. We reserve the right to refuse to fulfill your request based on appropriate and relevant justification for such refusal.

9. OBJECTION OF PROCESSING

9.1. You have the right to object to the processing of your personal data where it is lawful and carried out for our legitimate interests. If we process your personal data based on the consent you have provided, you have the right to withdraw this. However, we may continue to process your personal data if we have another relevant legal basis or if we have compelling grounds to continue processing your personal data.

10. DATA RETENTION AND DELETION

10.1. We will retain your personal information for as long as necessary to communicate with you or execute the contract between you and us, or for as long as we are legally obliged to do so (in some cases, our retention period may be longer due to regulatory obligations). Your personal information is automatically deleted when it is no longer necessary.

10.2. In determining the appropriate retention period, we consider the size, quantity, nature, and sensitivity of your personal data, the potential risks arising from unauthorized use or disclosure of your personal data, the purposes for which your personal data is processed, and applicable laws (regulatory regulations) or other potential requirements.

10.3. You have the right to request the erasure of personal data that is no longer necessary, subject to certain exceptions. General exclusions include legal (regulatory) obligations and/or defense against legal claims.

11. DATA TRANSFER

11.1. We may transfer, store, and process your information within and outside the Union of Comoros for the purposes outlined in this policy.

11.2. We will take all necessary and appropriate measures to ensure that your personal data maintains the same level of security during transmission, both within and outside the Union of Comoros in accordance with this Policy.