MANDALA EXCHANGE, LTD.
Privacy Policy
This privacy policy discloses the privacy practices for the Mandala Exchange LTD. (“the Company”) and any affiliates of the Company (“Affiliates”), whether now or hereafter formed. This privacy policy applies to information collected on this site (https://mandala.exchange/) and other sites operated by the Company or its Affiliates (collectively “the Sites”).
Compliance with GDPR. Effective as of May 25, 2018 (the “Effective Date”), the European Union and European Economic Area (EU/EEA) have adopted the General Data Protection Regulation (“GDPR”) covering all residents of the EU/EEA, whether or not the company issuing the privacy regulations is domiciled in the EU/EEA. The Company and its Affiliates have issued these amended privacy provisions in compliance with GDPR in order to provide appropriate disclosures and protection to all users of the Sites, whether or not domiciled in the EU/EEA. All existing users of the Sites as of the Effective Date will be notified promptly by email as to the existence of these provisions with a link to review the same.
Introduction
Your privacy is important to us and we strive for a high level of protection in all processing of personal data.
As defined in GDPR and in accordance with applicable data protection legislation, the Company, or such Affiliate as may be specified at the end of this Privacy Policy, is the “data controller” and as such is responsible for the processing of your personal data as set out below. If you have any questions about this information, or if you wish to exercise any of your rights as set out below, contact the Company via the contact information listed under Section 6 below.
Processing of Personal Data
General
The term ‘personal data’ refers to information which, directly or indirectly, may refer to you as an individual. Examples of personal data are name, email address, government-issued identification number, billing information, financial information (such as Know Your Customer disclosures), contact details, and IP address. Personal data processing refers to any action that we or a third party that we have engaged take with the personal data, such as its collection, registration, and storage. It also may include Cookies (see our Cookie Notice).
Personal data may only be processed for specified and explicitly stated purposes and may not be subsequently processed for any purpose that goes beyond these stated purposes.
Website and Social Media
We collect personal data such as name, e-mail address, and other information which you voluntarily provide, e.g. when you choose to interact with the Company by subscribing to offerings, signing up for updates such as newsletters, deals, and offers, webinars, trade shows, events, etc. through email (which you can opt-out from via a link in each message sent through email), or by otherwise interacting with the Company or an Affiliate through one of the Sites. We also automatically receive and store information from your web browsers, such as IP address, language preferences, cookie information, and the pages you visit, to log files on our server. We use the information collected to respond to your requests regarding products and services, to improve the content on our Sites and the services, to track and prevent abuse of our Sites and services, and to develop anonymous usage statistics.
We also use personal data for legally required notices, direct marketing, and advertising in accordance with applicable law and market practice. You may opt-out of such direct marketing and advertising at any time. We may use the information we collect with regard to how you, as a user, use the Sites so that we can analyze search and usage behavior to provide you with personalized content. Personal data may also be processed indirectly in connection with the development and administration of the Company’s IT systems.
The legal grounds for such usage include (i) performance of a contract where you request services/resources through the Sites and (ii) legitimate interest for other processing activities, such as for the purpose of improving services and the content of the Sites, as well as for prevention of abuse and for statistical purposes.
We delete collected personal data when the purpose of the processing has been completed. Our Cookie Notice includes retention periods in respect of cookies that we use.
Customers buying our products online or potential customers
When you are a customer buying products online, or a potential customer inquiring about our products and services, we may process the information you have volunteered, such as name, home and/or delivery address, telephone number, e-mail address, payment information, historical order information and the product you have bought. When you buy or inquire about, our products online via our Sites, we also collect the information specified in Section 2.2.
The legal grounds for such usage include (i) performance of a contract where you request services/resources through the Sites and (ii) legitimate interest for other processing activities, such as for the purpose of improving services and the content of the Sites, as well as for prevention of abuse and for statistical purposes.
We delete most collected personal data when the purpose of the processing has been completed. However, some of this information is retained for the duration required by applicable securities laws and regulations, as well as tax and bookkeeping legal records requirements.
Registered purchasers and users of our services and products
We collect personal data such as name, address, phone number, e-mail address, payment information, designation, and other information that you voluntarily provide. When you use our services via our Sites, we also collect the information specified in Section 2.2. We use the information collected to provide you with the services/products, to respond to your requests and handle support cases regarding products and services, to improve the support/services, and to develop anonymous usage statistics.
The legal grounds for such usage include (i) performance of a contract where you request services/resources through the websites and (ii) legitimate interest for other processing activities, such as for the purpose of improving services and the content of the websites, as well as for prevention of abuse and for statistical purposes.
We delete collected personal data when the purpose of the processing has been completed. However, some of this information is retained for the duration required by applicable securities laws and regulations, as well as tax and bookkeeping legal records requirements.
Security for the protection of personal data
We protect your personal data against unauthorized or unlawful processing and against accidental loss, destruction, or damage, by implementing appropriate technical and organizational security measures.
Restrictions on the Disclosure of Personal Data
We do not share personal data with third parties except under circumstances described herein. We may appoint external agents to perform tasks on our behalfs, such as providing IT services or helping with marketing and recruitment, administration of press releases, data analysis, or statistics. The performance of these services may mean that such agents, both within and outside the EU/EEA, are able to gain access to your personal data. Companies that process personal data on our behalf must always affirm that they are GDPR compliant and sign a non-disclosure agreement with us so that we are able to ensure a high level of protection of your personal data even with our partners. If such a company reports a breach that may involve your personal data, we are required to report such a breach to you within 72 hours.
Special safeguards are taken with regard to partners outside the EU/EEA, such as signing agreements that include the standardized model clauses for data transfers adopted by the EU Commission and which are available on the EU Commission’s Sites.
We may also disclose your personal data to third parties, for example, the police or other public authorities, pursuant to a subpoena or other legal process, or if we are otherwise required to disclose such data by law or public authority decision. We will not disclose your personal data to any extent other than described in this section.
Your Rights and the Right to File a Complaint
Under applicable data protection legislation, you are entitled, at any time, to request access to the personal data that is processed about you, to have erroneous personal data corrected, to request that we stop processing and delete your personal data, to request that the processing of your personal data is restricted, to exercise your right to data portability, to withdraw consent to particular processing (where such consent has been obtained) and to object to the processing of your personal data. The aforementioned provision notwithstanding, Mandala reserves the right to retain data as required by law by and through the usage of our services. In such an event, you may contact the Company via the contact details listed below. If you consider that your personal data has been processed in contravention of applicable data protection legislation or of these provisions, you may file a complaint with the applicable regulatory authority in your country or in the Seychelles.
Your Right to Data Erasure
Under applicable data protection legislation, you are entitled, at any time, to request access to the personal data that is processed about you, to have erroneous personal data corrected, to request that we stop processing and delete your personal data, to request that the processing of your personal data is restricted, to exercise your right to data portability, to withdraw consent to particular processing (where such consent has been obtained) and to object to the processing of your personal data. The aforementioned provision notwithstanding, Mandala reserves the right to retain data as required by law by and through the usage of our services. In such an event, you may contact the Company via the contact details listed below or email support@mandala.exchange. If you consider that your personal data has been processed in contravention of applicable data protection legislation or of these provisions, you may file a complaint with the applicable regulatory authority in your country or in the Seychelles.
Data Controller and Contact Details
Data Controller
For all purposes and unless otherwise specifically disclosed herein or to the customer or user, the data controller of this Site is Mandala Exchange LTD.
Contact Details
If you have any questions on how we process your personal data or want information about further contact details for the data controllers above, please contact us through this Site at https://support.mandala.exchange/
Miscellaneous Provisions
Cookies
The Company, in common with many web site operators, may use standard technology called “cookies” on its Sites. A cookie is a piece of data stored on a site visitor's hard drive to help us improve its access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance their experience on our site. Usage of a cookie is in no way linked to any personally identifiable information. You can disable cookies by turning them off in your browser; however, some areas of the Sites may not function properly if you do so.
Acceptance of Privacy Policy
By using this Site or any other Company or Affiliate Site or interactive banner ads, you represent that you are of legal age and signify your acceptance of our Privacy Policy, and you adhere to the terms and conditions posted on the Site. By submitting your information, you agree that it will be governed by our Privacy Policy.
Amendments to this Policy
This privacy policy may be amended from time to time, in which case all registered users of the Sites will promptly be advised by email to their registered email addresses. Nevertheless, users are advised to periodically review the privacy policy of this Site to receive the latest information and advice as to privacy protections and processes.