Your privacy is important to us.
It is PHOENIX STAR LTD’s policy to respect your privacy regarding any information we may collect from you across our website, MBUNDU.COM, and other sites we own and operate.
We ask that you read this Privacy and Cookies Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
We are PHOENIX STAR LD (‘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.
Security Of Shared Information
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.
Information We Collect
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.
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.
We may ask for personal information, such as your:
- Social media profiles
- Date of birth
- Phone / mobile number
- Home / Mailing address
- Work address
- Payment information
Legal Bases for Processing
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.
Collection and Use of Information
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
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
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.
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.
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.
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.
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”).
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.
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.
Our relationship to our clients and their shoppers
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.
How we collect shopper information
Directly from a store-based client site
Through a third-party platform and / or store CRM
The types of information we may collect
We collect two types of information. Both types of information are required to provide the LimeSpot Purposes that are offered via a LimeSpot-enabled Store-based Client’s eCommerce platform, or through related channels (e.g. Emails, Messages, Advertising, etc.).
The first type of information is Personally Identifying Information (“PII”). The other type of information is Non-Personally Identifying Information (“NPII”).
PII includes information that is uniquely associated with an identifiable Shopper, or that identifies a Shopper, and may specifically include age, gender, location, email address, phone number, and, in some cases, IP address.
NPII may include information that is collected directly from a Shopper, during a Shopper’s interaction with the site, or from information provided to a third party, and which does not identify, or is not uniquely associated with, an identifiable Shopper. NPII includes, but is not limited to, a Store-based Client’s name and location, Store-based Client product and collections information, non-identifying order information, Store-based Client CRM / Loyalty programs, age range, association with a geographical or network area, Shoppers’ general interests as indicated by their interaction with an e-Commerce Platform (such as selections thereon), Shoppers’ shopping behavior, and Shoppers’ choices within LimeSpot enabled e-Commerce Platforms. NPII may also include information that is non-personally identifying but was generated from PII, such as by aggregation with other PII or anonymization.
How we use and disclose information
Performance of services
We may use Shoppers’ PII and NPII to fulfil the Purposes. We may also use Shoppers’ NPII in connection with other services and features we provide to third parties or other Store-based Clients. This includes by assessing information relating to, and historical patterns associated with, Shoppers, and / or profiles or categories of classes of Shoppers, such as by observing shopping choices and activities of Shoppers (or Shoppers fitting characteristics relating to such profiles or categories, but not necessarily any information relating to an identifiable Shopper). We may also process Shoppers’ data in association or combination with information relating to that Shopper, or information relating to Shoppers belonging to the same profile or category, from other Store-based Clients. We will also use this information to improve the quality of our Products and Services.
Performance of services associated with third-party platforms
In order to provide personalized advertising on Third-Party Platforms, LimeSpot pushes certain NPII information relating to a Shopper (e.g. non-personally identifying shopping preferences profile information) to such Third-Party Platform which then selectively provides advertising. Except as provided below, none of a Shopper’s PII or NPII information is provided to LimeSpot from any Third-Party Platform.
In some cases, LimeSpot uses authentication services provided by Third-Party Services to authenticate a Shopper with their LimeSpot data.
Investigations and protection
LimeSpot may release Shopper information: when we believe it is appropriate or required in order to comply with the law; to investigate, prevent, or take action regarding illegal activities; to detect or investigate suspected fraud; in situations involving potential threats to the physical safety of any person or other similar exigent circumstances; to prevent violations of LimeSpot’s Customer Terms of Service, or to enforce the provisions thereof; to comply with any other agreement that we may have entered into with you; or to protect the rights, property or safety of LimeSpot and others. This may include exchanging information with other companies and organizations for fraud prevention and credit risk reduction. LimeSpot may cooperate with and disclose information to any authority, government official or third party, without giving any notice, in connection with any investigation, proceeding or claim arising from an asserted illegal action or infringement.
Third-party service providers
LimeSpot may employ or engage other companies to perform tasks on our behalf and may need to share some of your information with them to provide products and services to you. Examples of this may include data storage and analysis. These third parties have access to information needed to perform their functions but may not use it for any other purpose.
Granting us this permission not only allows us to provide our Products and Services as they exist today, but also allows us to provide innovative features, products, software and services we may develop in the future that use the information we receive about Shoppers in new ways.
LimeSpot owns the databases and all rights to our applications and software. While Store-based Clients and Shoppers allow us to process the information we receive, such Store-based Clients and Shoppers using LimeSpot enabled stores always own all their own personally identifiable information.
How we keep your information secure
The security of Shopper information is important to us. We implement reasonable security measures to protect the security of your information both online and offline, and we are committed to the protection of Shopper information. Only those individuals at LimeSpot that have an obligation to maintain confidentiality may access Shopper PII.
When we handle Shopper information on the Internet, we encrypt the transmission of that information using secure socket layer technology (“SSL”). Shopper information is pseudonymized and rendered as NPII. LimeSpot has redundant and distributed systems, and other system measures, that provide for ongoing confidentiality, integrity, availability and resilience. Our systems are routinely tested or assessed for their measures to ensure the security of Shopper Data.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Shopper information, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.
We will notify the Store-based Client, who is ultimately the data controller, from whom we obtain information in the event of an unauthorized access or disclosure of such information. We will take reasonable administrative steps, by making it a condition of our terms of services with them, to ensure that such Store-based Client take steps to inform the affected Shopper to the extent that it is required under applicable law.
If you have any questions about how we strive to keep information secure, you can contact us at firstname.lastname@example.org .
Storage and transfer of your information
We may transfer, store and process Shoppers’ information, both PII and NPII, to or on computers located in the United States, Europe, or Canada. Accordingly, such information may be subject to the laws of these relevant jurisdictions.
LimeSpot’s technical infrastructure relies on data centers and cloud service providers that are located outside Europe on Microsoft’s Azure platform. Microsoft became the first global cloud service provider to appear on the Department of Commerce’s list of Privacy Shield certified entities as of August 12th 2016. The European Commission adopted the EU-US Privacy Shield Framework on July 12th 2016, replacing the International Safe Harbor Privacy Principles as the mechanism for allowing companies in the EU and the US to transfer personal data across the Atlantic in a manner compliant with the EU data protection requirements, as stated on PrivacyShield.gov .
Canada has been recognized as ensuring an adequate level of protection for personal data. See https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en .
There is no fixed period for storage of Shoppers’ PII. We will remove Shoppers’ PII upon any of the following:
- A request from the Shopper via our Shopper Rights Access Portal (see below).
- A request from the applicable Store-based Client from which the Shopper, whose data is being deleted, was obtained, or such Shopper notifies LimeSpot in writing that their consent has been withdrawn.
- An objection from a Shopper, via a Shopper or an applicable Store-based Client, is received by LimeSpot in writing relating to the processing of any Shopper PII.
- If LimeSpot learns that any PII has been collected unlawfully.
- A request from any supervisory authority or legal authority (e.g. police, third-party having an applicable court order) having sufficient legal authorization or LimeSpot being made aware that PII should be deleted to ensure compliance with an applicable legal obligation.
The storage period for any NPII that does not relate to, or uniquely identify, a Shopper is indefinite.
LimeSpot supports Shoppers’ rights in the following ways:
Accountability and DPO
While LimeSpot is not a controller of Shopper data, LimeSpot nevertheless encourages Shoppers to contact the LimeSpot DPO ( email@example.com ) for issues relating to Shopper information that is collected or processed by LimeSpot via a Store-based Client (although LimeSpot reserves the right to take no action, and/or to forward Shopper’s concerns to the applicable Store-based Client, in cases where the issue relates to Shopper data collected or processed by the Store-based Client). Furthermore, the Shopper has the right to lodge a complaint about LimeSpot’s data protection with an applicable supervisory authority with jurisdiction to receive such a complaint. We note that for European Shoppers, there is no requirement for LimeSpot to have a European representative (as LimeSpot is not a controller); however, the applicable Store-based Client may, if applicable law requires such a representative, may be contacted regarding the processing of any data relating to a European person, if that requirement applies to such Store-based Client.
Access, rectification, and deletion
LimeSpot provides the Shopper Rights Access Portal, via its Store-based Clients, or directly from our Privacy Tool , which is an automated tool for viewing the PII and NPII that LimeSpot may have in data storage. The Shopper Rights Access Portal further allows any Shopper to delete all PII in LimeSpot storage upon request. See our Privacy Tool If any information is incorrect or is incomplete, please direct any requests for rectification to firstname.lastname@example.org after which they shall be addressed as is practicable.
LimeSpot shall notify the Store-based Client that collected the information in the event of any breach or unauthorized access to Shoppers’ PII of the following information: the existence and nature of such breach, our DPO, possible or likely consequences, and measures taken to address or, where possible, mitigate the breach. Our standard terms with our Store-based Clients require them to comply with this requirement, where required by applicable law.
Questions and concerns
We don’t store personally identifiable information such as credit card details in cookies we create, but we do use encrypted information gathered from them to help improve your experience of the Site. For example, they remember the items you have in your basket and also recommend related products to show you when you’re browsing.
You are free to manage cookie settings via your browser setting at any time. We are unable to guarantee that the Site will function correctly without cookies being enabled.
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur and that any parties who acquire us may continue to use your personal information according to this policy.
Limits of Our Policy
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.
Site Development and Maintenance
We use a third-party service integrator to support the maintenance and development of the Site. This means that they can see and access live customer data if required. This only happens if we are making improvements to areas such as your account functionality, improvements in ordering, or other areas that interact with customers and their data. They cannot export this data without our approval or use it for anything other than providing us with support to improve our service to you.
Changes to This Policy
Written communications should be addressed to:
PHOENIX STAR LTD
Executive Suite 505
11 Bermudiana Road
PHOENIX STAR LTD Data Controller
This policy is effective 2020 October 20
Iconic Brand, Timeless Products
MBUNDU is the online digital collective that exclusively curates the most unique, innovative, and exotic gifts in one place. Every piece in our exotic bazaar of luxury items is selected with an eye to the unusual and a nod to the sublime. We make luxury available to the world’s most discerning clientele. MBUNDU has something for everyone and is not for just anyone. Celebrated are individuals who that lead active international lifestyles, have an immense sense of personal style, and a deeply-held appreciation for incomparable materials, exceptional build quality and timeless design.
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