SPIRITUAL MINDSET a businessin  Luxembourg  with registered address at 39, rue Zénon Bernard, L-4031 Esch/Alzette – Luxembourg, registered with the Luxembourg Trade and Companies Register under number  our “SPIRITUAL MINDSET”.

Our Company processes your personal data in accordance with the applicable legislations, particularly:

• Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”);
• The Act of 1 August 2018 on the organisation of the National Data Protection Commission and the general data protection framework;
• The Act of 30 May 2005, as amended, concerning the processing of personal data in the electronic communications sector.

Our Company undertakes to process personal data in a fairly and transparent way and based on valid legal grounds, obtained for specific lawful purposes, adequate, relevant, and not excessive; accurate and kept up to date; not held for longer than necessary, protected in appropriate ways and not transferred outside of the European Economic Area, unless adequate protective measures are in place.

Our privacy policy particularly covers the following issues:

WHO IS RESPONIBLE FOR YOUR PERSONAL DATA?. 2

WHO IS CONCERNED?. 2

WHAT KIND OF PROCESSING DO WE PERFORM AND WHY ?.. 3

HOW DO WE OBTAIN YOUR PERSONAL DATA?.. 5

WHO WE SHARE YOUR PERSONAL DATA WITH?. 6

DO WE USE COOKIES ?. 6

WHICH COUNTRIES DO WE TRANSFER YOUR PERSONAL DATA TO?. 8

HOW LONG DO WE KEEP YOUR PERSONAL DATA?. 8

YOUR RIGHTS REGARDING YOUR PERSONAL DATA.. 9

ACCESS TO THIRD PARTIES WEBSITE.. 10

If you receive the present policy in electronic format, please click on the links below to be immediately directed to the relevant information.

We reserve the right to update our personal data protection policy in line with any changes in legislation or in the way we treat your personal data. Every modification made will be notified on the Website and by email.

WHO IS RESPONIBLE FOR YOUR PERSONAL DATA?

Your personal data is processed by SPIRITUAL MINDSET, acting as the “data controller” in respect of the processing of your personal data ( “OUR COMPANY ”, “We” or “Us”):

A Luxembourg business having its registered address at 39, RUE ZENON BERNARD, L-4031 ESCH/ALZETTE,

registered with the Luxembourg Trade and Companies Register under number ,

VAT Number: LU34596522

For any concerns regarding your personal data feel free to contact, either by:

E-mail: [email protected]

Telephone: +352 621 716 935

WHO IS CONCERNED?

We may collect Personal Data from :

• Website users visiting our website:spiritualmindsetshop.com

WHAT KIND OF PROCESSING DO WE PERFORM AND WHY ?

The chart below explains how we use your personal data, being (i) the different types of data being processed, (ii) the persons concerned, (iii) the legitimate purpose(s), (iv) the legal basis of the processing.

PURPOSES of the processing	WHAT ? data is processed	WHO’s?	Which  LEGAL BASIS ?
1.     Management of the Website pages to promote our business	IP address (see Cookies section)	Website users	Your consent (article 6.I.a) of the GDPR)
2.     Management of the contact form and answers your question	Name and email	Users contacting Us via the contact form	Your consent (article 6.I.a) of the GDPR)
3.     Management of your order	Identification data your name, first name; Contact data your phone number, email, address, postal code; Personal characteristics your gender, date of birth; Electronic identification data: (cookies) Banking and financial data : banking details , VAT number; Data about goods and services provided and received;	Client	The processing is necessary for the performance of the contract the client  is party (article 6.I. b)
4.     Birthday program and commercial communication	Loyalty program and commercial communication data such as your birthday voucher number, contact details ;	Client	Your consent (article 6.I.a) of the GDPR)
5.     Analyticy tracking	Consumption habits such as your favorite departments, favorite product families, favorite brands, number of orders and checkouts, amounts spent;	Client	Our legitimate interests where such interests do not override your fundamental rights and freedom (article 6.I.f) of the GDPR)
6.     Satisfaction and commercial promotion of our services	Data relating to your satisfaction with our services, your complaints, questions and observations;	Client	Our legitimate interests where such interests do not override your fundamental rights and freedom (article 6.I.f) of the GDPR)
7.     Management of claims, unpaid invoices	Identification data your name, first name; Contact data your phone number, email, address, postal code; Personal characteristics your gender, date of birth; Electronic identification data: (cookies) Banking and financial data : banking details , VAT number; Data about goods and services provided and received;	Client	Our legal obligations in terms of anti-anti money laundering and payment fraud (article 6. I. c) and our legitimate interests where such interests do not override your fundamental rights and freedom (article 6.I.f) of the GDPR) in the case of the defense of our interests.

 

HOW DO WE OBTAIN YOUR PERSONAL DATA?

We may collect the above-identified Personal Data directly from you on several occasions such as:

• directly from you:

– when you visit our Website, or

– when your make an order on our Website ;

– when you contact us.

WHO WE SHARE YOUR PERSONAL DATA WITH?

Insofar as they are necessary for the purposes defined in this policy, your Personal Data may be shared internally with our employees.

Certain of your Personal Data may be shared externally when necessary to achieve the purpose for which they have been processed, with the following entrusted third parties:

• Our service provider for the management of our Website.

These entrusted third parties may be required to receive or have access to some of your Personal Data in different ways, each according to their roles, in line with the purposes specified above and within the limits set by the applicable law. When needed, we stipulate processing agreements with such third parties so to ensure the maximum protection of your Personal Data.

We may also transfer, when required, your Personal Data to the local public authorities such as the Luxembourg Business Registers, to our lawyers, to the public bailiffs, to the police etc., in order to comply with the legal or regulatory requirements to which we are subject or to assert our rights or exercise them in Court.

DO WE USE COOKIES ?

SPIRITUAL MINDSET uses cookies and similar tracking technologies to track the activity on the Website and hold certain information.

A cookie is a text file sent on the user’s browser and saved on the hard drive of its device when the user visit the Website.

Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our service.

You can manage your cookies and trackers with preferences device’s set up and can refuses all cookies or indicate when a cookie is being sent.

You may alter your consent preferences – including to withdraw consent to non-essential cookies which you have previously given – at any time by clicking ‘Reject all non-essential cookies’ to reject all optional cookies.

Any selections you make will be automatically saved and you may navigate away from the cookies settings.

Type of cookies	Purposes	Description	Other information
Essential cookies	help make a Website usable by enabling basic functions like page navigation.	to operate the core functions of our Website, so that you may visit and move around it, and use its features. The website cannot function properly without necessary cookies.	We do not require your consent to use these cookies.
Statistic cookies	for statistical analysis purposes.   These help us to understand how visitors use and move around our Website, which inform improvements and adaptions to our Website.	Statistic cookies help the Website publisher to understand how users interact with the Website by collecting and reporting information anonymously.   These cookies work by using a distinctive sequence of characters from which your browser or device can be identified (‘unique ID’), which, for example, can be used by us to recognize the date and time of your visit(s) to our site. Our analytics cookies may also collect information about your browser type and settings, device type and settings, operating system, and mobile network. This information is used to distinguish you from other visitors to our site, but it cannot be used to identify you as a named individual. We will only set these types of cookies where you have provided us with your consent to do so by either choosing to ‘Allow all cookies’ or by adjusting your cookie settings via your cookie settings.	You may decide to accept or reject them.   Rejecting these cookies prevents us from collecting such data.   The performance of our site will not be affected.

Google Analytics

is a widely used platform for measuring the performance of a website.

It helps us to understand things like what our visitors are reading and what technology (e.g. browsers) we should prioritize for testing. This information is used to help us give you the best possible experience – more of what you want, and less of what you don’t.   We process the data collected by these Google Analytics cookies.  Google Analytics may provide us with technical support.   Data may be collected – in aggregate form only from which no one visitor to our site can be identified or distinguished from another – by Google Analytics to help improve Google Analytics products and services.

Rejecting analytic cookies will prevent us from using Google Analytics cookies to collect data about your visit(s) to our site, which would be used by us in aggregation with other visitors’ data to understand visitors’ behavior and how many visits are made to our site. This will not affect any consent to the use of Google Analytics cookies that you may give to other websites.

Names of the cookies we use		Description	Duration
ga_LNGZYJZMLK	installed by Google Analytics	Registers a unique ID that is used to generate statistical data on how the visitor uses the website.	2 years
ga – the _ga cookie

 WHICH COUNTRIES DO WE TRANSFER YOUR PERSONAL DATA TO?

Your Personal Data will not in principle be transferred to a third country outside the European Economic Area (“EEA”) or an international organization.

However, in the event that it would be necessary for the purposes defined in this policy, we may have to transfer your Personal Data to countries outside the European Economic Area, which may not offer the same level of data protection as the Grand Duchy of Luxembourg. Some of these countries, such as the US, are subject to an adequacy provision by the European Commission and the transfer of data to such countries is in principle safe.

If there is no adequacy provision of the European Commission, as such is the case for the US, We make sure that appropriate safeguards to the processing are undertaken (these include contractual clauses, binding corporate rules, codes of conduct, approved certification mechanisms etc.) and/or that the processing is carried out in conformity with the GDPR requirements.

In particular, our website uses a web analysis service called “Google Analytics” provided by Google. This means that if you consent to the use of non-essential cookies related to Google Analytics, your personal data may be processed by Google and may be accessed on the side of Google from the United States of America. More details on such a processing is provided by Google on the following link: https://policies.google.com/technologies/partner-sites?hl=en

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We commit to keeping your Personal Data only for the period necessary for the purposes set out in this Privacy Policy.

In determining this period, we take into account the following criteria:

• the requirements of applicable data protection laws;
• the duration of the applicable legal prescription;
• the purposes of the processing involving your data and whether and for how long the processing of your data in necessary to serve such purposes;
• our legal obligations to keep certain information for a minimum period.

Data processed on the basis of your consent will not be kept by Us in the event you withdraw your consent.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

 The GDPR provides you with specific rights according to the legal basis on which Our Company bases the processing of your Personal Data.

In this context, you have:

• A right of access: you have the right to obtain confirmation on whether your personal data are being processed or not. When this is the case, you have the right to access the personal data which are processed by Our Company.
• A right of rectification: you have the right to obtain rectification of inaccurate or incomplete information about you that is processed by Our Company.
• A right to the erasure of your data: you have the right to obtain the erasure of your Personal Data in the following situations: (i) your data are no longer necessary for the purposes for which we collected them; (ii) you withdrew your consent where the processing is based on consent and there is no other legal basis for such processing; (iii) you object to the processing of your Personal Data and there is no compelling legitimate reason justifying the processing; (iv) the data is subject to unlawful processing; (v) the data must be erased due to a legal obligation.
• A right of opposition: you can oppose the processing of your Personal Data in two situations: (i) where the processing concerned is based on your consent, in which case you can oppose such processing without having to provide any particular reasons; (ii) where the processing is based on the legitimate interests of Our Company , you can oppose it for reasons related to your particular situation, unless we are able to demonstrate that there are legitimate grounds and imperative reasons for such processing which prevail over your interests, rights and freedoms, or else for the verification, exercise or defense of our rights in Court.
• A right to limitation of the processing of your data: you have the right to suspend processing of Personal Data while a verification is being carried out (verification of the accuracy of information, of the legal basis of processing, and of the legitimate reasons that Our Company opposes to their erasure).
• A right to request the transfer of your data to another provider. This right applies when the processing is based on your consent or the performance of a contract and is performed using automated processes.

If you have any additional questions or would like to file a complaint about the processing of your Personal Data, you can contact Our Company. at

Finally, the GDPR provides you with the right to lodge a complaint with the supervisory authority. In Luxembourg the competent authority is the National Commission for the Protection of Data (Commission Nationale pour la Protection des Données) (https://cnpd.public.lu/fr.html).

 ACCESS TO THIRD PARTIES WEBSITE

The Website may contain links to third party websites that may be useful or interesting to the user.

We are not liable for the content of third parties websites that may use specific terms of use and specific policies that the user may take into account.