Privacy Notice

ASP Partners Limited is a company incorporated in Mauritius with business registration number C26237058 and registered office at 52 Cybercity, 8th Floor Ebene Tower, Ebene, Mauritius.

For the purposes of applicable data-protection law, ASP Partners Limited (“ASP”, “we”, “us” or “our”) is generally the controller of the personal data described in this Privacy Notice. This means that ASP determines why and how that personal data is processed.

Questions about this Privacy Notice or ASP’s use of personal data may be sent to [email protected].

This Privacy Notice explains how ASP collects, uses, stores, shares and protects personal data relating to:

• visitors to this website;
• people who contact us or submit an enquiry;
• prospective, current and former clients;
• business contacts, professional advisers, suppliers and referral partners;
• recipients of ASP insights or updates; and
• job applicants or potential recruits.

This notice applies to personal data processed through this website and in connection with ASP’s business-development, client-acceptance and professional-service activities. A specific engagement letter, client notice or contractual term may provide additional information for a particular service and will apply alongside this notice.

We may collect the following categories of personal data:

• Identity and contact data — such as your name, title, employer or organisation, postal address, email address, telephone number and preferred method of contact.
• Professional and business data — such as your role, industry, business interests, jurisdiction, professional background and relationship with ASP or a referral source.
• Enquiry and correspondence data — including the information you enter in a website form, emails, meeting notes, documents you provide and records of communications with ASP.
• Client-acceptance and service data — where relevant, including identification documents, ownership and control information, tax residence, billing details, conflict-check information, due-diligence information and information required to provide or assess professional services.
• Recruitment data — such as a curriculum vitae, qualifications, employment history, references and other information supplied in connection with a role or collaboration.
• Marketing and preference data — including whether you wish to receive ASP insights, event invitations or other updates and your communication preferences.
• Technical and usage data — such as internet protocol address, browser and device information, operating system, referring pages, pages viewed, dates and times of visits, website interactions, security logs and cookie or similar identifiers.
• Information from third parties or public sources — including referrals, professional networks, public registers, company websites, event organisers, compliance databases and service providers, where lawful and relevant.

Please avoid submitting special-category, highly confidential or unnecessary personal data through the general website contact form. Where such information is necessary for an engagement, ASP will request it through an appropriate channel.

• Directly from you when you complete a form, email or call us, meet with us, subscribe to updates, provide documents, apply for a role or enter into an engagement.
• Automatically when you use the website, through server logs, security tools, cookies and similar technologies.
• From third parties, including referral partners, professional advisers, service providers, public authorities, public registers and publicly available sources.

ASP will process personal data only where there is an appropriate lawful basis. Depending on the circumstances, we may rely on one or more of the following: your consent; steps requested by you before entering into a contract; performance of a contract; compliance with a legal or regulatory obligation; protection of vital interests; or ASP’s legitimate interests or those of a third party, provided those interests are not overridden by your rights and interests.

Where ASP relies on legitimate interests, we consider the nature of the data, the reasonable expectations of the individuals concerned, the benefit and necessity of the processing, and the potential effect on privacy rights. You may contact us for further information about the balancing assessment relevant to a particular activity.

You may choose whether to submit a general website enquiry. Certain information may, however, be required for ASP to respond meaningfully, perform requested pre-contractual steps, enter into or perform an engagement, issue invoices, meet professional obligations or comply with legal and regulatory requirements. If required information is not provided, ASP may be unable to respond fully, accept or continue an engagement, or provide the relevant service.

ASP does not seek to collect special-category personal data through the general website contact form. Such data may occasionally be processed where necessary for a specific professional matter and where an appropriate legal condition applies, including explicit consent, legal obligations, substantial public interest or the establishment, exercise or defence of legal claims.

This website and ASP’s services are directed to business and adult users and are not intended for children. A person under 16 should not submit personal data through the website without the involvement and consent of a parent or guardian. If ASP becomes aware that personal data of a child have been collected inappropriately, we will take reasonable steps to address the matter.

ASP may share personal data only where reasonably necessary and subject to appropriate confidentiality, professional, contractual and legal safeguards. Recipients may include:

• ASP directors, employees, consultants and authorised personnel who need the information for the relevant purpose.
• Independent tax, legal, accounting, regulatory, corporate-service and other professional advisers or referral partners involved in a matter, where appropriate and authorised.
• Website hosts, cloud and email providers, information-technology support providers, customer-relationship, document-management, accounting, analytics, form, newsletter, cybersecurity and other operational service providers acting for ASP.
• Banks, insurers, auditors and other advisers supporting ASP’s business operations.
• Government bodies, tax authorities, regulators, courts, tribunals, law-enforcement bodies or other authorities where disclosure is required or permitted by law.
• A purchaser, investor, successor or adviser in connection with a genuine proposed or completed reorganisation, investment, merger, sale or transfer of all or part of ASP’s business, subject to appropriate safeguards.
• Other persons where you have directed or consented to the disclosure or where disclosure is otherwise lawful.

ASP does not sell personal data to advertisers or data brokers.

ASP is based in Mauritius but may use service providers, cloud infrastructure or professional advisers located in other countries. Personal data may therefore be accessed from or transferred outside Mauritius. Where this occurs, ASP will take steps required by applicable law to ensure an appropriate level of protection, such as using suitable contractual and organisational safeguards, assessing the destination and recipient, obtaining any required authorisation or relying on another lawful transfer condition. Further information about safeguards relevant to a particular transfer may be requested from ASP.

ASP retains personal data only for as long as reasonably necessary for the purpose for which it was collected, including to meet legal, regulatory, tax, accounting, professional, insurance, dispute-resolution and record-keeping requirements. Retention periods may vary according to the nature of the data and the relationship.

ASP may retain information for longer where litigation, a complaint, an investigation, a regulatory request or another legal reason requires it. Data may also be securely anonymised and retained in a form that no longer identifies an individual.

ASP uses reasonable technical and organisational measures designed to protect personal data against unauthorised or unlawful access, use, alteration, disclosure, loss or destruction. Measures may include access controls, authentication, encryption where appropriate, secure cloud and email services, backups, confidentiality obligations, staff awareness, provider due diligence and incident-response procedures. No internet transmission or information system is completely secure, and absolute security cannot be guaranteed.

Subject to applicable law and any relevant exemptions, you may have the right to:

• ask whether ASP processes personal data about you and request access to that data and related information;
• ask ASP to correct inaccurate or incomplete personal data;
• ask for erasure of personal data where there is no lawful reason for continued processing;
• ask ASP to restrict processing in specified circumstances;
• object to processing based on your particular situation, including processing for direct marketing;
• withdraw consent at any time where processing is based on consent, without affecting processing carried out before withdrawal;
• ask not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects, where the relevant legal conditions apply; and
• lodge a complaint with the Data Protection Commissioner in Mauritius.

To exercise a right, email [email protected] and describe your request. ASP may ask for information reasonably necessary to confirm your identity and locate the relevant data. Rights are not absolute, and ASP may retain or continue processing information where permitted or required by law. We will respond within the period required by applicable law.

ASP may send professional updates, insights or invitations where you have requested them or where permitted by applicable law. Marketing consent must be separate from a general contact-form submission and should not be pre-selected. You may unsubscribe using the link in a message or by emailing [email protected]. ASP may retain a minimal suppression record to ensure that your preference is respected.

The website may use cookies and similar technologies for essential functions, security, preference management and, with appropriate consent, analytics or other non-essential purposes. Further information, including how to manage or withdraw consent, is provided in ASP’s Cookie Notice and the website’s cookie-preference centre.

ASP does not intend to make decisions about website visitors based solely on automated processing where the decision would produce legal or similarly significant effects. If this changes, ASP will provide appropriate information about the logic involved, the significance and expected consequences, and the rights available to the individual.

This website may link to third-party websites or services. ASP does not control their privacy practices. You should review the privacy and cookie information provided by the relevant third party before submitting personal data or using its services.

ASP may update this Privacy Notice to reflect changes in law, guidance, business activities, website tools or processing practices. The revised notice will be published on this page with an updated date. Material changes may also be communicated through another appropriate channel.

Privacy enquiries and requests may be addressed to:

You also have the right to lodge a complaint with the Data Protection Commissioner: