Privacy notice

1. Who is responsible

Audacia Ltd (business registration number C20176915), Block E, River Court, St Denis Street, Port-Louis, Mauritius, trades as Audacia Corporate Services. It is the controller for everything described in this notice. This means it decides why and how your personal data is used. Here we act for ourselves, not on behalf of a client.

Lutchmenarraidoo Chambers (Yudish Lutchmenarraidoo trading as Lutchmenarraidoo Chambers) is a separate legal practice and a separate controller. This notice does not cover it.

Audacia Ltd is registered with the Data Protection Office and has a Data Protection Officer. Write to dpo@audacia.mu, or by post to the address above, for the attention of our Data Protection Officer.

2. What we hold and where it comes from

• Visits to this website. Our own analytics tool records:
  • the page you visit and its title;
  • the campaign tags in the link (the utm_ parameters and nothing else from the address);
  • the site that sent you, without its query string;
  • your browser, operating system, device type, screen size and language;
  • the country, region and city worked out from your internet address.

  It does not store your internet address. It groups one day's page views into a visit using a code that changes every day, so it cannot follow you from one day to the next. It records no clicks or other events. Its requests are left out of our web server's logs.

• Fonts. Pages load their fonts from Google Fonts. Your browser therefore sends your internet address to Google when you open a page.
• Our web host's records. We have not yet confirmed what records our website host keeps of requests to this website, or for how long. We will state both here once we know.
• Enquiries through the contact form. We record:
  • your name, email address and message (required);
  • your phone number and organisation (optional);
  • which product you asked about, the page you sent it from, the site that sent you to us, and any campaign tags in the link.

  We do not store your internet address or browser with your enquiry. To stop the form being flooded, our server briefly holds a scrambled form of your internet address in memory. It allows 10 submissions from the same address in 5 minutes. It never writes that code to disk, and it forgets it when the server restarts.

  As we deal with your enquiry, our staff record how far it has got (for example "contacted" or "proposal"). If it does not go ahead, they record a short reason.

• Enquiries we receive in other ways. If you contact us by email, by telephone, through a referral or at an event, our staff may record the same details by hand, together with how you reached us.
• Our mailing list. If you tick the box on the contact form, we record that you agreed, the exact words you agreed to, the version of the form, and when. We keep a record of every consent given or withdrawn. Where you agree in person or in writing instead, our staff record that agreement, how it was given, and a note of it.
• Business contacts. See section 3. For an organisation we think may need our services, we may record:
  • its name, website, sector and country;
  • why we think it may need our services;
  • the web pages the search cited, and the notes our system made when it checked them.

  We may also record the name, job title and email address of a person who works there, and the address of the web page where we found them.

• Emails we send. We record:
  • the address we sent to and the first name we used to greet you;
  • when we sent it and which campaign it belonged to;
  • whether it was delivered, bounced (permanently or temporarily), failed, or was reported as spam.

  We do not record whether you opened an email or clicked a link in it. When we choose who receives an email, we filter contacts by product, country, how we got their details, when they were added, and what they agreed to receive.

• Unsubscribes. When you unsubscribe, or an address bounces permanently or is reported as spam, we keep a one-way code made from the email address so that we never write to it again. We cannot read your address back from the code. Anyone who already knows your address can still match it to the code, so we treat the code as personal data about you.
• The vote-tally tool. If you use the free copropriété vote-tally tool, the owner references, shares and votes you enter go to our Syndic service (syndic.audacia.mu), which works out the result.
  • The owner references default to "owner-1", "owner-2" and so on. You do not need to enter names.
  • The Syndic service sends back the result and does not save what you entered.
  • To limit how often the tool can be used, it keeps your internet address with a count of your requests for that minute. Those counts are deleted after about ten minutes.

  We have not yet confirmed what the Syndic server's own access logs record about these requests, or for how long.

• Our own staff. For people at Audacia who sign in to our internal marketing console, we record:
  • their name and email address;
  • a scrambled form of their password;
  • their sign-in sessions;
  • which staff member checked, accepted or rejected a business contact, and who carried out an erasure;
  • their internet address, in the web server log for the console.

Giving us data is voluntary. You do not have to use the contact form. If you do, we need your name, email address and message to answer you. Joining the mailing list is optional. Not joining changes nothing about how we answer your enquiry.

3. If we found your details ourselves

If we write to you and you did not give us your details, we got them in one of these ways:

• Public web research. We ask an AI model with web search, xAI's Grok, to suggest organisations that may need our services.
  • We ask it only for business addresses that the organisation publishes itself.
  • We ask for a person's name and job title only when the organisation's own website names them.
  • Our server then opens each page the model cites. It keeps an email address only if that address is actually written on the page.
  • A member of our staff decides whether to add the suggestion to our contacts. When they accept it, our server checks the page again. We record that page's address, when it was checked and which staff member accepted it.
• Records we already hold. Our staff may add a contact by hand, or import a list, for example from our own client records.
• Lists we import. An imported address receives no email from us unless we also record a lawful basis for it. Where that basis is our legitimate interest, we must record the web address the list came from.

We rely on our legitimate interest in telling businesses about services that are relevant to their work (section 28(1)(b)(vii) of the Act). We do not rely on it where the processing would be unwarranted, given the harm and prejudice it could cause to your rights, freedoms or legitimate interests. You can object at any time, and if you object to our marketing we stop: see section 9. The rest of this notice applies to you in full: who receives your data, how long we keep it, and your rights. If you ask, we tell you where we found your details (section 37(2)(g)).

4. What we use it for, and on what basis

Our legal bases are in section 28 of the Act.

• To answer your enquiry and follow it up. Where you ask about our services, this is a step you asked us to take before a contract (section 28(1)(b)(i)). For any other enquiry, it is our legitimate interest in answering people who write to us (section 28(1)(b)(vii)).
• To send you our insights on AML/CFT, data protection and intellectual property, if you ticked the box. This is based on your consent (section 28(1)(a)). You can withdraw it at any time (section 24(2)): use the one-click unsubscribe link in every email, or write to us. Withdrawing does not affect what we did before.
• To tell businesses about our services. This is based on our legitimate interests (section 28(1)(b)(vii)), as described in section 3.
• To understand how the website is used, so that we can improve it. This is based on our legitimate interests (section 28(1)(b)(vii)). It is measured without cookies and without storing your internet address.
• To work out a vote tally you asked for, and to stop the tool being flooded with requests. This is based on our legitimate interests in providing the tool you chose to use and keeping it running (section 28(1)(b)(vii)).
• To stop writing to people who asked us to stop, and to prove who agreed to what. This is based on our legitimate interests (section 28(1)(b)(vii)). It is how we respect an objection to direct marketing (section 40(3)). The Act also puts on us the burden of proving your consent (section 24(1)).
• To keep the site and our systems secure, including stopping automated spam on the contact form and keeping server logs. This is based on our legitimate interests (section 28(1)(b)(vii)).
• To give our staff access to the marketing console. This is necessary for their work with us (section 28(1)(b)(i)) and for our legitimate interest in keeping the console secure (section 28(1)(b)(vii)).

We also use AI models to help write our marketing copy: Anthropic's Claude, and xAI's Grok if Claude is unavailable. They receive release notes and change descriptions from our own software projects. They do not receive your enquiry or your contact details.

5. Automated processing

• Spam checks on the contact form. Two checks catch automated submissions: a hidden field that people cannot see, and a check on whether the form was sent less than two seconds after the page loaded. A submission that fails either check is not kept. If this happens to you by mistake, email us at contact@audacia.mu.
• Stopping mail automatically. If an email to you bounces permanently, the system stops writing to that address. If you unsubscribe or report an email as spam, it stops writing to you and also withdraws any consent on record.
• Finding businesses. An AI model suggests organisations and published contacts, and our server checks that each email address appears on the page cited, as described in section 3. Neither decides anything. A member of our staff decides whether to add each suggestion.
• Choosing who receives an email. An email goes only to people who have a consent or legitimate-interest record and have not unsubscribed. Our staff choose the recipients using the filters listed in section 2. We do not score, rank or profile individuals.

No decision that produces legal effects for you or significantly affects you is taken by automated processing alone (section 38 of the Act).

6. Who receives it

Some of these companies are our processors. A processor handles data only on our instructions, to provide a service to us. Others decide for themselves how they use what they receive, and are controllers of it.

• Hostinger (processor) provides the server that runs our analytics, contact form backend and mailing list. It also keeps its own backups of the whole server.
• Our website host (StackCP, which we buy through mauritius.biz) (processor) serves the pages of this website.
• Resend (processor), an email delivery service, sends our marketing emails and passes each enquiry on to us.
  • It receives your email address and the email we send. For an enquiry, it also receives your name, email address, organisation, phone number, the product you asked about, the page you sent it from, and your message.
  • It tells us whether an email was delivered, bounced, failed or was reported as spam.
  • Open and click tracking are switched off.
• Google hosts the mailbox where your enquiry arrives, and stores our encrypted backups in Google Drive (processor). It also serves the website's fonts. For fonts, your browser contacts Google directly, and Google receives your internet address under its own terms.
• Online Office, our own practice management system, reads the mailbox where your enquiry arrives and uses AI models to help prepare a reply. A person reads and sends every reply. Online Office's own privacy notice names those AI providers and explains what they receive.
• xAI receives the searches we write when we look for businesses (section 3). These describe the kind of organisation we are looking for. Its web search reads the public pages where your business details appear and returns them to us. xAI also receives the release notes we use to draft copy if Anthropic is unavailable (section 4).
• Anthropic receives the release notes and change descriptions we use to draft marketing copy (section 4). They contain no personal data about you.
• Our Syndic service receives what you enter in the vote-tally tool.
• Courts, public authorities and others where the law requires it.

We do not sell personal data or share it with advertisers. Our analytics runs on our own server and is shared with no one.

7. Transfers outside Mauritius

None of the systems this notice describes runs in Mauritius.

• Our marketing server is in a Hostinger data centre outside Mauritius. Hostinger's backups of the whole server are also kept outside Mauritius.
• The Syndic service that works out vote tallies also runs outside Mauritius.
• We have not yet confirmed where our website host's servers are.
• Resend sends our emails from its region in Ireland (European Union). Resend is a United States company.
• xAI and Anthropic are based in the United States, as are the AI providers that Online Office uses.
• Google processes data in its own facilities in several countries.

Those countries may not protect personal data to the standard of the Act.

We transfer an enquiry abroad because the transfer is necessary for steps you asked us to take before a contract (section 36(1)(c)(i)). You can ask us about the safeguards that apply to any transfer (section 37(2)(i)).

8. How long we keep it

We keep personal data only as long as we need it for the purposes in section 4. When that need ends, we destroy it (section 27 of the Act).

• Website analytics: 13 months, then deleted automatically every night. Backups of the analytics data stay on the same server and are kept for 7 nights.
• Enquiries, contacts and the record of emails sent: until you ask us to delete them, or until we no longer need them to deal with your enquiry or to write to you. The system does not yet delete them automatically.
• Records of consent and of consent withdrawn: kept for as long as we hold your contact details, as proof of what was agreed. If we erase your details, the record stays, marked as withdrawn. The one-way code described in section 2 replaces your address.
• Unsubscribes, permanent bounces and spam reports: kept permanently, but only as the one-way code described in section 2, so that we never write to you again.
• Businesses we found: when a staff member accepts or rejects a suggestion, it loses the person's name, job title and email address at once. An accepted contact is then kept like any other contact. The organisation's details, the pages cited and the check notes stay with no end date. A suggestion nobody has reviewed yet also has no automatic end date.
• Vote-tally tool: nothing you enter is kept. The request counts tied to your internet address are deleted after about ten minutes.
• The contact form's flood check: held in memory only. It covers the last 5 minutes and is lost whenever the server restarts.
• Server logs:
  • Our web server's log for the contact form and unsubscribe pages does not record internet addresses and hides unsubscribe codes. Its log for the marketing console records the internet addresses of our staff.
  • A new log file is started when the current one reaches 50 MB. Earlier files are deleted once they are 30 days old, and at most 5 are kept. The file currently in use can hold entries older than 30 days.
  • Our application also keeps a log. It records the web address of each request, including the unsubscribe code in an unsubscribe link, but not your internet address. It keeps at most three files of 10 MB each, and the oldest is overwritten as new entries arrive. It has no fixed time limit.
• Staff sign-in sessions: a session ends after 48 hours without use, or after 14 days at most. Its record is deleted the next time a staff member signs in, once more than 7 days have passed since the 14-day limit.
• Backups:
  • Our marketing database is backed up every night and encrypted before it leaves the server.
  • Copies on the server are kept for 7 days.
  • Copies in Google Drive have no automatic end date yet.
  • Hostinger also keeps backups of the whole server. We have not yet confirmed how long it keeps them.
  • When we erase your details, copies already in a backup are not changed. They are removed only when that backup is deleted.

9. Your rights

Under the Act you can:

• ask whether we hold personal data about you, and for a copy (section 37). This includes where we got it, if not from you. Ask in writing. It is free unless the request is manifestly excessive. In that case we may charge the fee set by regulation (currently Rs 100) or refuse, and we must show why the request is excessive. We answer within one month. For complex or numerous requests, we may take one further month. We may ask you to confirm who you are;
• have inaccurate data corrected and incomplete data completed (section 39(1));
• have data erased (section 39(2)), for example:
  • when we no longer need it;
  • when you withdraw the consent it was based on and we have no other ground;
  • when you object and we have no overriding grounds;
  • when it was processed unlawfully;
• ask us to restrict processing, for example while you dispute its accuracy. The Act allows us to restrict it in the cases it lists (section 39(5));
• object in writing, at any time, to our processing of your personal data (section 40(1)). We then stop, unless we have compelling legitimate grounds that override your interests, rights and freedoms, or need the data for a legal claim;
• object to the use of your personal data for direct marketing (section 40(2)). If you do, we no longer use it for that purpose (section 40(3));
• not be subject to a decision based solely on automated processing (section 38);
• withdraw your consent where we rely on it, without affecting what was done before (section 24(2)).

The quickest way to stop our emails is the unsubscribe link at the foot of every one. It works in one click and takes effect at once.

Some rights have limits. For example, we need not erase data that we need to comply with a legal obligation or for a legal claim (section 39(4)). Other exceptions in the Act can apply.

When we erase your details, we delete your contact record and remove your name, email address, organisation, phone number and message from our other records. We also remove your name, job title and email address from any suggestion about you that nobody has reviewed yet. Only a member of staff with an owner account can do this. We keep, linked only to the one-way code described in section 2:

• the code itself on our "do not write" list, so that we never write to you again;
• the record of any consent, marked as withdrawn, which we may need to show what you agreed to (section 24(1));
• the facts of any enquiry: when it arrived, the product it was about, the page it was sent from, the campaign tags, how far it got and why it did not go ahead;
• the record of the emails we sent to you and what happened to them, without your address or name.

Copies in our backups are not changed (section 8).

If we refuse a request, we tell you why in writing within one month, and that you can complain to the Data Protection Commissioner (section 37(6)).

To use any of these rights, write to dpo@audacia.mu. Someone you authorise in writing can also make the request for you (section 41).

10. Complaints

You can complain to the Data Protection Commissioner at the Data Protection Office: dataprotection.govmu.org. If the European Union's General Data Protection Regulation applies to you, you also have the rights it gives and can complain to your own supervisory authority.

11. Cookies and similar technology

This website sets no cookies and stores nothing on your device.

• Our analytics tool writes nothing to your device. It checks whether you have saved a setting called umami.disabled in your browser, and it respects your browser's Do Not Track setting. Content blockers can also stop it.
• The contact form and the vote-tally tool send no cookies.

For more detail, see How we measure this site.

Our internal marketing console is used only by our staff. It sets one cookie, growth_session, to keep them signed in. It is strictly necessary, cannot be read by scripts, and is sent only over encrypted connections.

12. Security

• Connections to this website, the contact form and our server are encrypted.
• Our marketing database cannot be reached from the internet.
• The part of the system that receives the contact form can add an enquiry, but it cannot read any stored data.
• Backups are encrypted before they leave the server.
• Only Audacia staff with their own account can sign in to the marketing console, and only an owner account can erase a contact.

13. Changes to this notice

We update this notice when our website or systems change, and change the date at the top.