Download as PDF file
This is the privacy statement (hereinafter also referred to as the "Statement") of Mani Bhadra - Phoenix Import. In this Statement, we explain in a simple and understandable way who we are, what personal data we process about you, why we collect this data, and what we do with it. Personal data includes all information and collection of data that can directly or indirectly identify you, such as your first and last name, email address, date of birth, etc.
We may change this Statement from time to time. The most current version of this Statement can always be found on our website: https://www.phoeniximport.com/en/2/privacy-and-cookie-statement.aspx . We recommend consulting this Statement regularly to stay informed of any changes.
This Statement was last updated on: November 26, 2024.
Who are we?
Mani Bhadra - Phoenix Import is an importer and wholesaler of spiritual and gift items. In this Statement, “we,” “us,” or “Mani Bhadra - Phoenix Import” refers to the controller of your personal data as defined in the GDPR. This refers to the entity affiliated with Mani Bhadra - Phoenix Import with which you have, have had, or will have a (business) relationship, or that otherwise determines which personal data is collected and how it is used.
Where this Statement refers to Mani Bhadra - Phoenix Import, it encompasses both the holding companies and operating companies within the organisation, namely:
Holding companies:
Mani Bhadra Holding B.V. (Chamber of Commerce number: 08206282)
Mani Bhadra Beheer II B.V. (Chamber of Commerce number: 76689913)
Operating companies:
Mani Bhadra B.V. (Chamber of Commerce number: 05050712)
Mani Bhadra Italy B.V. (Chamber of Commerce number: 68770227)
Mani Bhadra France B.V. (Chamber of Commerce number: 68758340)
Mani Bhadra Germany B.V. (Chamber of Commerce number: 68758367)
When does this Statement apply?
This Statement describes how we collect and use your personal data, for example, when you:
- Visit the website of Mani Bhadra - Phoenix Import.
- Use our social media channels.
- Purchase products from us.
- Subscribe to our newsletter.
- Supply goods and/or services to us.
- Apply for a position within Mani Bhadra - Phoenix Import; and/or
- Contact us for any reason.
This Statement applies to you only if we are considered the ‘controller’ of your personal data as defined in the General Data Protection Regulation (“GDPR”). This means that Mani Bhadra - Phoenix Import determines the purpose (the why) and the means (the how) of processing your personal data.
Which personal data do we process, and why?
1. Personal data of customers who purchase products from Mani Bhadra - Phoenix Import
Personal data refers to data that can directly or indirectly be traced back to an individual. Business data, such as company names, addresses, and payment details, are generally not considered personal data. However, this changes when such data can be traced back to a physical person, for example, in the case of a small business such as a sole proprietorship or freelancer, where information can be directly linked to an individual. If this data cannot be traced back to an individual, it is not considered personal data, and this Statement does not apply.
1.1. Creating an account
When customers create an account on our website, we process the following personal data:
- Contact details: first name, last name, email address, and phone number.
- Company details: company name, VAT number or equivalent (if applicable), and website.
- Address details: street, house number (including any additions), postal code, city, and country.
- Account details: username (email address) and password.
Purpose and legal basis:
The data is used for:
- Creating and managing your account.
- Communicating about orders and returns.
- Communicating about your account and its management.
The processing is necessary for the performance of the contract between you and Mani Bhadra - Phoenix Import, in accordance with Article 6(1)(b) GDPR.
1.2. Purchasing products
When you purchase products from Mani Bhadra - Phoenix Import, we process additional personal data required to process and manage your orders, including:
- Order information: purchase history, ordered products, and payment status.
- Payment details: bank account number, billing address, and payment method.
- Shipping information: delivery address (if different from the billing address) and delivery instructions.
Purpose and legal basis:
The data is used for:
- Processing and managing your order, including shipping and payment.
- Maintaining our financial records.
Processing orders is based on the performance of the contract (Article 6(1)(b) GDPR), while maintaining financial records is carried out to comply with legal obligations (Article 6(1)(c) GDPR, Article 52, paragraph 4 AWR).
1.3. Sending our newsletter
If you subscribe to our newsletter, we process your email address to send you news and product information.
Purpose and legal basis:
- Sending newsletters and product information to customers who have opted in.
- This processing is based on our legitimate interest in direct marketing to existing customers, in accordance with Article 6(1)(f) GDPR.
You may withdraw your consent at any time using the unsubscribe button in the newsletter or by contacting us directly.
2. Personal data of employees of our customers
If you work for an organization that is a customer of Mani Bhadra - Phoenix Import, we may process the following personal data:
Contact details:
first name, last name, business email address, and phone number.
Purpose and legal basis:
- Maintaining contact regarding orders and business arrangements.
- This processing is necessary for the performance of the contract between the customer and Mani Bhadra - Phoenix Import, in accordance with Article 6(1)(b) GDPR.
3. Personal data of employees of our suppliers
If you are an employee of a supplier providing goods and/or services to Mani Bhadra - Phoenix Import, or if you operate as a sole proprietor or small business, we process the following personal data:
- Contact details: first name, last name, business email address, and phone number.
- Company details: company name, VAT number or equivalent (if applicable), and website.
- Payment details: bank account number and billing address.
Purpose and legal basis:
- Verifying the identity of suppliers and communicating for the procurement of goods and services.
- Processing and managing payments.
- Maintaining our financial records.
The processing for the first two purposes is necessary for the performance of the contract between the supplier and Mani Bhadra - Phoenix Import (Article 6(1)(b) GDPR). Maintaining financial records is carried out to comply with legal obligations (Article 6(1)(c) GDPR, Article 52, paragraph 4 AWR).
4. Personal data of job applicants
If you apply for a position at Mani Bhadra - Phoenix Import, we process the following personal data during the recruitment process:
Contact details: first name, last name, address, phone number, email address, date of birth, nationality, and gender.
Relevant job-related data: CV, cover letter, references, and results of competency tests (if applicable).
Purpose and legal basis:
Verifying your identity and maintaining contact during the recruitment process.
Assessing your suitability for the open position.
Processing for the first purpose is necessary for the performance of the contract between the applicant and Mani Bhadra - Phoenix Import (Article 6(1)(b) GDPR). Suitability assessment is based on our legitimate interest (Article 6(1)(f) GDPR).
5. Personal data of individuals who contact us
If you do not fall under one of the above categories but contact us, for example, via the chat function on our website, email, telephone, or one of our social media channels, we may process the following personal data:
- Personal identification data: first name and last name.
- Contact details: email address and phone number.
- Communication data: content of emails, chat messages, or other information you share with us.
Purpose and legal basis:
- Maintaining contact and communicating about questions or other information.
- This processing is based on our legitimate interest in communicating with individuals who contact us, in accordance with Article 6(1)(f) GDPR.
What choices do you have on social media?
Mani Bhadra - Phoenix Import is active on social media platforms such as Facebook and Instagram. Through our social media pages, we receive statistics about visitors. Although Mani Bhadra - Phoenix Import and the social media platforms are jointly responsible for these statistics, the respective social media provider is your primary contact for exercising your rights and filing any complaints. We will support the social media provider where necessary in responding to your requests or complaints.
For more information about the personal data, we receive from social media providers and how you can adjust your settings, please refer to the websites and privacy statements of the respective social media platforms.
Cookies
When you visit or use our website, information is automatically collected and sent to us by your computer, mobile phone, or other devices. We use different types of cookies and similar technologies on our website, including functional cookies, statistical cookies, and marketing/tracking cookies.
In some cases, cookies may contain personal data, such as a unique ID linked to your device, IP address, or, when you are logged in, information traceable to your account. Marketing and tracking cookies can process personal data, for example, to show targeted advertisements and analyse user behaviour. For these cookies, we request your explicit consent.
When you first visit our website, a pop-up will appear where you can set your cookies preferences. By clicking "OK," you consent to our use of cookies. You can withdraw or adjust your consent at any time.
For more information about our use of cookies and similar technologies, you can consult the Cookies banner available on our website. Here, you can also manage your preferences and enable or disable cookies via your browser settings. Please note that disabling cookies may affect the functionality of the website.
Google Analytics
We use Google Analytics 4 to gain insight into how our website is used and to improve our services. Google Analytics is a web analytics service provided by Google LLC (Google), headquartered in the United States.
Google Analytics 4 uses IP anonymisation, which means the last octet of the IP address of users is removed before it is sent to Google servers. This ensures that the collected data cannot be used to identify individual visitors.
We do not use Google Signals or User IDs within Google Analytics 4. This means no user profiles are created based on Google accounts or login credentials from our website, and data is not linked across sessions or devices. Furthermore, we use Google Analytics solely for analytical purposes. The collected data is not used for personalised advertisements or other commercial purposes.
The data we collect is limited to the standard information collected by Google Analytics, such as:
- Location (based on an anonymized IP address).
- Latitude and longitude of the location (to the extent anonymised).
- Browser version and sub-version.
- User agent string of the browser.
- Brand, model, and type of device.
- Sub-version of the operating system; and
- Screen resolution.
The data may be transmitted to Google servers outside Europe, including the United States. Google is affiliated with the EU-U.S. Data Privacy Framework and uses the European Commission’s adequacy decision for transferring personal data to the U.S. To provide additional privacy protection, Google has also implemented standard contractual clauses and technical safeguards. For more information, please refer to Google’s privacy policy.
If you do not want Google Analytics to analyse your usage data, you can install the Google Analytics Opt-out Add-on in your browser. This prevents Google Analytics from collecting information about your website visits.
Integration of the Trusted Shops Trustbadge
Trusted Shops widgets are integrated into this website to display Trusted Shops services (e.g., Trustmark, collected reviews) and offer Trusted Shops products to shoppers after they place an order.
This is done to protect our legitimate interests in optimal marketing by enabling safe shopping in accordance with Article 6(1)(f) GDPR. The Trustbadge and the services advertised with it are an offer from Trusted Shops SE, Subbelrather Str. 15C, 50823 Cologne ("Trusted Shops"), with whom we share joint responsibility for data protection under Article 26 GDPR. In this data protection statement, we inform you below about the essential content of the agreement in accordance with Article 26(2) GDPR.
Under the joint responsibility between us and Trusted Shops SE, you can contact Trusted Shops regarding data protection questions and the exercise of your rights using the contact options specified in the Trusted Shops data protection information. However, you can also contact the responsible person of your choice at any time. Your query will then, if necessary, be forwarded to the other person responsible for an answer.
Data processing during the integration of the Trustbadge/other widgets
The Trustbadge is provided by a U.S. content delivery network (CDN) provider.
An adequate level of data protection is ensured by an adequacy decision of the EU Commission, which can be accessed here for the U.S. Service providers from the U.S. are generally certified under the EU-U.S. Data Privacy Framework (DPF). More information is available here. If service providers are not certified under the DPF, standard contractual clauses have been concluded as an appropriate safeguard.
When the Trustbadge is accessed, the web server automatically saves a so-called server log file, which also contains your IP address, the date and time of the access, the amount of data transferred, and the requesting provider (access data), and documents the access. The IP address is immediately anonymised after collection so that the stored data cannot be assigned to you personally. The anonymised data is primarily used for statistical purposes and for error analysis.
Processing of data after the completion of the order
After completing the order, order data (total order amount, order number, purchased product, if applicable) and your email address, hashed using a cryptographic one-way function, are transmitted to Trusted Shops.
The legal basis is Article 6(1)(f) GDPR. This is necessary for the verification of whether you are already registered for Trusted Shops services and is therefore necessary to safeguard our and Trusted Shops' overriding legitimate interests in the buyer protection linked to the specific order and transaction evaluation services under Article 6(1)(f) GDPR. If you are already registered, further processing takes place in accordance with the contractual agreement between you and Trusted Shops. If you have not yet registered for the services, you will be given the opportunity to do so for the first time. Further processing after registration is also subject to the contractual agreement with Trusted Shops.
If you do not register, all transmitted data will automatically be deleted by Trusted Shops, and a personal reference will no longer be possible.
Trusted Shops uses service providers for hosting, monitoring, and logging. The legal basis is Article 6(1)(f) GDPR to ensure a trouble-free operation. Processing may take place in third countries (U.S. and Israel).
An adequate level of data protection is ensured by an adequacy decision of the EU Commission, which can be accessed here for the U.S. and here for Israel. Service providers from the U.S. are generally certified under the EU-U.S. Data Privacy Framework (DPF). More information is available here. If service providers are not certified under the DPF, standard contractual clauses have been concluded as an appropriate safeguard.
Do we use automated decision-making?
We do not make decisions based solely on automated processing, including profiling, that have legal or other significant consequences for you. This refers to decisions made entirely by computer programs or systems without any human intervention from our employees.
With whom do we share personal data?
We do not sell your personal data to third parties. Nor do we share your personal data, except with your consent, when legally required, or in a limited number of cases described below.
To achieve the purposes mentioned in this Statement, we may share your personal data with the following entities:
- Distribution and logistics partners: To process, deliver, and return orders, we may share your address and contact information with our distribution and logistics partners. These partners process your data exclusively for product delivery and follow our instructions.
- External service providers: Mani Bhadra - Phoenix Import uses reliable external service providers for certain processing activities, such as hosting our website, IT management, the chatbot on our website, payment processing, and marketing services. These parties process your data solely on our behalf and in accordance with our instructions.
- Professional advisors: Your personal data may be shared with professional advisors, such as accountants, lawyers, banks, and insurance companies, when necessary to support our business activities or to fulfil legal, administrative, or tax obligations.
- Other parties in business transactions: Occasionally, your personal data may be shared during business transactions such as the sale of parts of our business or in reorganisations, mergers, joint ventures, or other forms of acquisition of our business, assets, or shares, including in the event of bankruptcy or similar proceedings.
If we share personal data with a third party, we enter into a (processing) agreement, where necessary, to ensure that this third party complies with the requirements of the General Data Protection Regulation (GDPR) and processes your data in a secure and responsible manner.
How long do we retain personal data?
We retain your personal data for as long as necessary for the purposes for which we process it, unless a longer retention period is required by law. Refer to the section "Which personal data do we process, and why?" for more information on specific processing purposes.
Our retention periods are determined based on the following criteria:
- Necessity for service or operations: How long are the data needed to provide our services or support the operations of Mani Bhadra - Phoenix Import?
- Account information: Data you provided for creating an account is retained as long as your account remains active. If your account has been inactive for 12 months, you will receive an email asking whether you wish to retain or delete your account. Without a response within two weeks, the account will be deleted, except for data we are legally required to retain.
- Order information: Data about your orders is retained for the duration of the customer relationship and up to five years after the last transaction, unless a longer period is required for tax or accounting obligations.
- Applicants: We retain applicant data for up to four weeks after the end of the application process, unless you join our company or give consent to retain your data for future vacancies.
- Legal and contractual obligations: In some cases, we are required to retain data longer, for example, based on legislation, government requests related to investigations, or to support legal proceedings or protect against potential claims. In such cases, data are retained for the required period, for example, up to seven years for tax administration.
Once the relevant retention period expires, your personal data will be deleted or anonymised, so they are no longer traceable to an individual.
Do we transfer personal data outside the EEA?
In principle, we process all your personal data within the European Union and work exclusively with parties that comply with this requirement. However, in exceptional cases, it may happen that we need to transfer personal data to a 'third' country outside the European Economic Area (EEA).
Should such a situation arise, and your personal data are transferred to a country with a lower level of protection than the GDPR, we will take appropriate measures to securely transfer your personal data. This may include the use of standard contractual clauses approved by the European Commission.
What security measures do we apply?
To protect your personal data, we take appropriate measures in accordance with applicable data protection laws. This also includes requiring our service providers to take measures to ensure the confidentiality and security of your data.
Although no system for data transmission or storage can guarantee complete security, we strive to prevent risks such as destruction, loss, alteration, unauthorised disclosure, or access through technical and organisational measures. These measures are chosen based on:
- The state of technology.
- Implementation costs.
- The nature of the data we protect.
If you have any reason to believe that your interaction with us or your data is no longer being treated securely, please contact us immediately.
What are your rights regarding your personal data?
You have the right to request access to your personal data (including a copy), correct or delete it, restrict its processing, object to the processing, and request the transfer of the personal data you provided. For this, please contact us using the contact details below.
We will do our best to process your request free of charge and within a reasonable time frame unless it requires disproportionate effort. To prevent misuse, we may ask you to sufficiently identify yourself before processing your request. In certain cases, we may not be able to fully comply with your request, for example, due to statutory retention periods. If this is the case, we will inform you. We generally respond within one month of receiving your request.
Do you have questions, comments, or complaints?
If you have questions, comments, or complaints regarding this Statement, we are happy to assist you. You can reach us via email or phone using the contact details below. Additionally, you have the right to file a complaint with the Dutch Data Protection Authority or, if you reside or work in another country, with the relevant privacy regulator in that country.
Contact
For questions or requests regarding the protection of your personal data, or about this Statement in general, you can contact us at:
Mani Bhadra B.V. - Mani Bhadra - Phoenix Import
De Vesting 14
7722 GA Dalfsen
+31(0)38-4235510
[email protected]