Privacy Policy

We are PHOENIX STAR LTD (‘PHOENIX STAR’ ‘we’ ‘us’ or ‘our’), a company registered in Bermuda. 

Our registered office is: PHOENIX STAR LTD, 5th Floor, 51 Church Street, Hamilton HM12, BERMUDA. 

Our mailing address is: PHOENIX STAR LTD, Executive Suite 505, 11 Bermudiana Road, Pembroke HM08, BERMUDA.

We collect, use, and are responsible for certain personal information about you. When we do so, we are regulated by the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom), and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

MBUNDU.COM(Site) is operated by PHOENIX STAR. We collect information that you provide to us by filling in forms on our Site. This includes information provided at the time of registering to use our Site (where applicable), subscribing to our services (where applicable), ordering products through our Site, personalising our Site with your preferences, posting material, or requesting further services

PHOENIX STAR takes seriously the trust you place in us. We have very strong security measures in place to ensure your data are transferred safely. 

Fundamentally, the transmission of information via the internet is not completely secure. We will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our Site and any transmission is at your own risk. Although PHOENIX STAR cannot provide a 100% guarantee that your data will be safe, PHOENIX STAR policies and procedures minimise the chance of a breach taking place. 

Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access; we require our suppliers to do the same.

Log data

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type, browser version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.

Device data

We may also collect data about the device you’re using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

Personal information

We may ask for personal information, such as your:

• Name
• E-mail
• Social media profiles
• Date of birth
• Phone / mobile number
• Home / Mailing address
• Work address
• Payment information

We will process your personal information lawfully, fairly, and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.

These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:

• It’s 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 (for example, when we provide a service you request from us)
• It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests
• You give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter)
• We need to process your data to comply with a legal obligation

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use, or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

We may collect, hold, use, and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:

• To enable you to customise or personalise your experience of our website
• To allow you to access and use our website, associated applications and associated social media platform
• To contact and communicate with you
• For internal record keeping and administrative purposes
• For analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms
• To run competitions and / or offer additional benefits to you
• For advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you
• To comply with our legal obligations and resolve any disputes that we may have 
• To consider your employment application

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

• Third-party service providers to enable them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors, and payment systems operators
• Our employees, contractors, and / or related entities
• Credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
• Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or to establish, exercise, or defend our legal rights
• Third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
• Third parties to collect and process data

International Transfers of Personal Information

The personal information we collect is stored and processed in Bermuda and the United States, or where we or our partners, affiliates, and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

Your Rights and Controlling Your Personal Information

Choice and consent 

By providing personal information to us, you consent to us collecting, holding, using, and disclosing your personal information in accordance with this privacy policy. 

If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. 

You do not have to provide personal information to us: however, if you do not, it may affect your use of this website or the products and / or services offered on or through it.

Information from third parties 

If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have said person’s consent to provide personal information to us.

Restrict 

You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.

Access and data portability 

You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or another easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.

Correction 

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Notification of data breaches 

We will comply with laws applicable to us in respect of any data breach.

Complaints 

If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe

To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Google Analytics Tracking

Our Site tracks and gathers data using a third-party app by Google called Google Analytics. This stores information anonymously on Google’s servers. It gathers information such as a visitor’s country of origin, the device used, pages visited, and basket value. 

We use these stats to identify any pinch points for our customer journeys and then use it to improve their journey through our Site. 

These statistics help us to identify the most common devices used to visit our Site, so we can target specific roadmap improvements for those commonly used platforms (mobile, iPad etc.) Google Analytics only reflects the code update being applied to anonymise your IP address, therefore the user’s identity cannot be tracked back to their online account details.

PHOENIX STAR LTD uses LIMESPOT to provide suggestions on products that might be of interest to our consumers. The LIMESPOT Privacy Policy follows

LimeSpot Solutions Inc. (together with its affiliates, “LimeSpot”, “we”, “us” or “our”) is committed to protecting the privacy and the security of the personal information provided to us via our Products, while continuing to provide shoppers of our Store-based Clients, at the written direction of our Store-based Clients (defined below), with a personalized shopping and advertising experience and with recommendations that are personal, meaningful, and dynamic, as well as to provide general market intelligence or analysis based on aggregated information (the “Purpose”). While we accept personal information regarding shoppers from our Store-based Clients, any output of that information provided to those Store-based Clients, or any other third party, is limited to aggregated, non-identifying, and non-personal information and, moreover, LimeSpot will not sell, rent, lease, share or disclose any shoppers’ information, or the information of any Store-based Clients, except as permitted by this Privacy Policy. All capitalized terms used herein shall have the meaning as defined herein, or if not defined, the meaning as set forth in our LimeSpot. The term “Shoppers” shall be used herein to mean those individuals that use our Store-based Clients’ webpages or other accessible platforms or portals and who may or may not provide their personal information. Customer Terms of Service 

This Privacy Policy is based on the following principles/requirements: ​

Transparency

LimeSpot, via its Store-based Clients, shall notify Shoppers that their data shall be processed by LimeSpot as described in this Privacy Policy. ​

Consent

LimeSpot shall require that its Store-based Clients, as part of its engagement therewith, obtain informed consent for the processing of Shoppers’ data by LimeSpot as described in this Privacy Policy.​

Accountability

LimeSpot shall require that its Store-based Clients, as part of its engagement therewith, provide the means for Shoppers to inquire from LimeSpot, through the Store-based Clients, regarding their personal data, and to withdraw consent (including by deleting all identifying personal information), or to inquire from LimeSpot or its Data Protection Officer (“DPO”).

Security

LimeSpot shall provide a secure means in which to store data, as well as to transfer data to LimeSpot via the Products from the Store-based Client.

Breaches

LimeSpot shall notify the applicable Store-based Client in the event of any breach of security or other unauthorized processing of any of their Shoppers’ information.

LimeSpot provides its Services to help its approved and contracted store-based clients (hereinafter “Store-based Clients”) to achieve the Purposes, as defined above. LimeSpot, at the written direction and authorisation of our Store-based Clients, may obtain certain information regarding Shoppers as they use and provide information to our Store-based Clients. No matter who provides us with personal information, however, our commitment to privacy remains strong.

While LimeSpot ensures that any collection and subsequent disclosure to LimeSpot of any personal information via our Store-based Clients is in compliance with this Privacy Policy, we rely on and require our Store-based Clients to obtain Shoppers’ informed consent, and to provide access to this policy.

In some cases, Shoppers using LimeSpot may enable or authorize their access to a Store-based Client’s e-Commerce platform, and / or LimeSpot Products operating therein, using a third-party tool or a social networking site (“Third-Party Platform”), such as Facebook or Google. Accordingly, a Shopper must read and accept the terms of service and privacy policy of that Third-Party Platform, and LimeSpot cannot assume liability for any Shopper’s failure to do so. Further, LimeSpot may also process data previously, independently, or concurrently provided to the applicable Store-based Client by a Shopper (e.g. LimeSpot may obtain data through a Store-Based Client’s CRM or other data repository, or from other third-parties with whom they interact in association with providing their services to a given Shopper). LimeSpot takes reasonable administrative efforts to ensure that Store-based Clients provide an opportunity to Shoppers to have access to, and be given an opportunity to consent to, this Privacy Policy. Shoppers should also read and accept the terms of service and privacy policy of the Store-based Client. In some cases, LimeSpot may use Cookies (as that term is defined below) in association with a Third-Party Platform (e.g. Facebook, Google) in order to provide information to a Shopper via such Third-Party Platforms, particularly in the form of advertising, the content of which is selectively determined by such Shopper’s interaction with the Third-Party Platform in question. None of such Shopper’s personal information is copied by or transferred to LimeSpot from any Third-Party Platform in this circumstance.

LimeSpot relies upon its Store-based Client to obtain informed consent regarding the use of LimeSpot Products on their e-Commerce Platforms, including providing access to this Privacy Policy prior to acquiring consent. LimeSpot is not responsible for any act or omission of a Store-Based Client if the client fails to acquire, or is deficient in any way in acquiring, such informed consent. To the extent that the client’s collection, use, or disclosure of personal information provided to LimeSpot, prior to, independently of, or concurrently with the provision of Shopper data to LimeSpot fails to comply with this Privacy Policy or applicable data protection or other laws, LimeSpot has no ability to control, manage, or indeed identify such non-compliance. Any inquiries regarding independent acts or omissions involving a Shopper’s personal information by our Store-based Client must be directed to that Store-based Client.

Directly from a store-based client site 

Shoppers engage LimeSpot Products or Services when a Store-based Client installs one of our Plug-ins or other Products in association with its eCommerce Platform. This incorporates functionality through the LimeSpot API Platform. Using the LimeSpot API, or other similarly installed Product, through a Shopper’s interaction with one of our Store-based Client’s e-commerce platforms, we collect certain information that is provided to such e-commerce platforms about Shoppers, Shoppers’ interest in product offerings, Shoppers’ historical and new orders, Shoppers’ details that are provided to the e-commerce platform, and Shoppers’ behavior and interactions while visiting the e-commerce platform. By engaging in any of the foregoing activities and/or providing consent to provide such information by accepting the terms of this Privacy Policy (as required by applicable law, and which should be incorporated into our Store-based Client’s privacy or data protection policies), Shoppers, by virtue of such engagement or consent, authorize LimeSpot to collect, store and use any such data that comprises personal information in accordance with this Privacy Policy.

Through a third-party platform and / or store CRM 

In some cases, Shoppers may authenticate themselves within your LimeSpot-enabled store by signing on using a Third-Party Platform, or a Store-based Client may provide LimeSpot access to some other form of Shopper identification pursuant to such Store-based Client’s privacy policy (e.g. an eCommerce Platform’s customer management tools, external CRM, or Loyalty Program). This information is necessary to carry out the Purpose. This information may vary and may be affected by the privacy settings Shoppers establish with the applicable Third-Party Platform and/or the Store-based Client. Shoppers should be able to control and find out more about these settings at the Third-Party Platform used to access or use LimeSpot Products or Services, and/or through the terms and/or privacy policy of the applicable Store-Based Client or its CRM tool, if there is one. By using or accessing any of our products or software through a Third-Party Platform login, and/or a store CRM, Shoppers, pursuant to the terms of the applicable Third-Party Platform and/or e-Commerce Platforms (including their CRM), authorize us to process such information in accordance with this Privacy Policy and the corresponding privacy terms and settings of the applicable Third-Party Platform and/or e-Commerce Platform.