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a) General purpose and Miravia Platform brief description. For us, protecting privacy means trust. We at Miravia Platform ("Miravia Platform", "we" or "us") care about your privacy and take it seriously. This Privacy Notice explains who we are, why and how we collect, share and use personal data about you, and how you can exercise your privacy rights.
b) miravia.es ("Miravia Platform" or, the "Platform") is a business to consumer (or "B2C") platform which connects and facilitates sales and purchases between business sellers (or "Sellers") and consumer buyers, who are registered users of Miravia Platform (or "Buyers"). This Privacy Notice sets out the ways in which we process personal data about you who act as a, Seller, Buyer, visitor of Miravia Platform including content creators, KOLs, bloggers and publishers, or a potential Buyer or Seller (i.e. non-registered users and collectively referred to as "Leads"). It applies to personal data we collect about you via the websites and Platform (including through the use of the Platform via your mobile device) operated by Miravia Platform.
a) Data Controller: Miravia is operated by Arise Operating E-commerce Private Limited , a company incorporated and existing under the laws of Singapore, registered with the Accounting and Corporate Regulatory Authority of Singapore under number 202218799Z, with registered office at 51 Bras Basah Road #01-21, Lazada One, Singapore, 189554 (“Arise”). Arise is the data controller for all personal data processed via or in relation with the Platform.
b) If you have any questions or concerns about our use of your personal data, you can also contact our data protection officer here (https://www.miravia.es/privacy/submit-request?type=request).
The personal data we collect either directly or indirectly from you will depend on how you interact with us and with Platform. We collect personal data about you from the following different sources:
(1) Directly from you. We collect personal data such as your name and contact information directly from you when you voluntarily choose to provide us with this information. Information such as your IP address, your preferred language/currency and your location can be collected indirectly, including through automated means, while you use our Platform. Some of the information we collect indirectly is captured using cookies and other tracking technologies, as explained further in our Cookie Notice.
(2) Third parties.
The table below describes the personal data we collect from and about you depending on the service of the Platform's functionality used, some of which we combine in our systems.
| Personal data Description | Source |
|---|---|
| Identity Verification Data including your name, title, identity number (such as passport number or national identity number such as DNI), facial ID, email address, telephone number. If you are a Seller, we may also collect personal data of your authorized persons, your company name, address, date of incorporation, bank account and other business-related information (including company registration number, business license, VAT numbers and other tax information, shareholder, director and ultimate beneficiary owner information). |
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| Account Data, such as your name, title, country of residence, date of birth, gender, user ID, username and login method, email address, telephone number, your social media accounts, your account settings. |
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| Buyer Transaction Data, including your transaction statements, billing name and address, your delivery address if different to the billing address or the delivery address and contact details of the intended recipient of your order or the preferred pick up point of the order, payment method and status [of the order], any discount coupon or gift card used, your order number, details of other products that you have purchased through the Platform including the status of their delivery, possible return and refund. |
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| Seller Transaction Data, including your transaction statements, details of the Buyer's orders to you and their order number, details of products that you have supplied through the Platform including the status of their delivery, any returns received and refunds paid. |
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| Social Media/External Account Data, including social media handle and log in details where you choose to log in to the Platform using your social media account or when you otherwise interact with us via an external service or application, such as Facebook or Google. |
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| Communications Data, including your feedback and other communications with us (including when you interact with our outsourced customer service agents offline), competition entries, chat, email or call history and recordings on the Platform or with third party service providers and your likes or posts of any comments on the content uploaded on the Platform, including your comments in our livestreaming events. |
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| Marketing and Advertising Data, including your interests based on Platform usage and purchases, interviews or focus groups or survey responses, promotions you enter, preferences in receiving marketing materials from us, communication preferences, your preferences for particular products or services and your subscription details. |
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| Device Data, that we collect using cookies and similar technologies such as device type, unique device identification numbers or other identifiers and advertising identifiers. |
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| Platform Usage Data, including information about your activity and App interactions that we capture using cookies and similar technologies (see section 5 below), including page views and searches, information that particular content had been viewed, watched or downloaded, purchase and selling history, metrics on listing and products and on fulfillment of your services and customer segmentation including new buyers and repurchasers, and other functional information for platform performance (collecting information about your application version, system preferences, diagnostics, and crash logs) together with log information about your registration and account deletion time, last log in and last account modification time. |
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| Location Data, (collected using IP address, WiFi access points and GPS) from which we can identify your general geographic location, like your country or city-level location, and other technical information that associates your location to your use of the Platform to use it for the delivery / pick-up status of orders or to provide you with the information about deals near your location. |
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| Uploaded Content, including any personal data in photographs/videos or audio recordings that you upload onto our Platform (such as Platform profile pictures) as part of product reviews, or when sharing content as part of the socialization functions on the Platform (like your comments in our livestreaming events) or when sharing Miravia related content on your social media and you allow us to use such content, or as part of your store’s decoration or product description if you are a Seller. |
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a) We use the personal data that we collect from and about you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your information. Our legal basis for processing the personal data we collect include the following bases, depending on our purpose for collecting your information:
(1) Contract – we require certain personal data to provide and support the services you purchase or request from us
(2) Consent – in certain circumstances, we may ask for your consent before we will collect, use, or disclose your personal data, in which case you can voluntarily choose to give or deny your consent without negative consequences to you
(3) Legitimate Interests – we may use or disclose your personal data for the legitimate business interests of either Miravia Platform or a third party, but only when we’re confident that your privacy rights will remain appropriately protected
(4) Legal Obligation – there may be instances where we must process and retain your information to comply with laws or to fulfil certain legal obligations
(5) Vital Interests – there may be circumstances where we will process your information to protect your vital interests or those of another person or party
b) If we rely on our (or a third party’s) legitimate interests to collect and use your personal data, these interests will normally be to operate and provide our Platform, communicate with you and respond to your questions, improve our Platform or use the insights to improve or develop our market or promote our Platform, or to detect or prevent illegal activities and/or manage the security of our IT infrastructure.
c) The following table provides more details on our purposes for processing your personal data and the related legal bases.
| Purpose | Personal data | Data Subject | Legal basis |
|---|---|---|---|
| Verify your identity to register you on and grant you access to the Platform. | Identity Verification Data Account Data |
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| Register you on our Platform, manage and administer your account with us and facilitate transactions you make over the Platform, including the management and use of gift cards or vouchers. | Identity Verification Data Account Data Buyer Transaction Data Seller Transaction Data Device Data Platform Usage Data Communication Data Location Data |
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| Issue invoices for the services provided directly by Miravia or to facilitate the issue of invoices for products purchased via Miravia Platform | Identity Verification Data (such as name, address, identity number) Account Data Buyer Transaction Data Seller Transaction Data |
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| Provide support with custom clearance declarations / applications | Identity Verification Data (such as name, address, identity number) Buyer Transaction Data Seller Transaction Data |
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| Verify the eligibility of your content | Identity Verification Data Account Data Transaction Data Social media/External Account Data |
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| Communicate with you about the services, including service updates | Identity Verification Data Account Data Platform Usage Data Communication Data Location Data |
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| Respond to your inquiries, requests, complaints or reports, including for customer service support, product warranty, quality assurance and training purposes, or reports for inappropriate content on our Platform, or requests submitted through our Privacy Center and related recordkeeping | Identity Verification Data Account Data Transaction Data Communication Data Uploaded Content Device Data Platform Usage Data |
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| Keep the Platform and our users secure, prevent and identify fraud, and address threats to your safety, the safety of others or abuse of benefits offered by or through Miravia. At times we will use malware and spyware monitoring tools to detect suspicious activity and algorithms to detect unauthorised access. | Identity Verification Data Account Data Buyer Transaction Data Seller Transaction Data Device Data Location Data Platform Usage Data Communication Data |
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| Manage compliance with our Platform terms, bring and defend legal claims, or respond to authority investigations. | Identity Verification Data Account Data Uploaded Content Communication Data Buyer Transaction Data Seller Transaction Data Device Data Location Data Platform Usage Data |
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| Maintain, support, and improve our IT systems, including to repair and debug our systems. | Identity Verification Data Account Data Device Data Location Data Platform Usage Data |
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| Learn about our Platform users (and prospective users) to improve our Platform, conduct research and develop new products and services. This includes identifying usage trends and patterns and evaluating this information on an aggregated, specific group(s), and individual basis, and using anonymized data to train our algorithms. | Identity Verification Data Account Data Device Data Location Data Platform Usage Data Uploaded Content and Sensory Data Social media/External Account Data |
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| Contact current and prospective users of the Platform about services, promotions games or competitions and events we conduct and we think may be of interest to you, including with promotional mailers and electronic communications | Account Data Platform Usage Data Marketing Data Communication Data Social media/External Account Data Device Data |
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| Personalize and customize your Platform experience, including to provide local or otherwise targeted content and information for Buyers or benefits such as birthday rewards, and tailor the content and advertising that forms part of our services | Account Data Marketing Data Platform Usage Data Social media/External Account Data Location Data Device Data |
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| Personalize, target, and deliver advertising for our services on third party websites, apps, and other online services (including to identify audiences and individuals like you to better tailor our marketing campaigns and communications), and measure the effectiveness of our campaigns and adjust our methods | Account Data Marketing Data Platform Usage Data Social media/External Account Data Location Data Device Data |
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| Administer surveys to collect user perceptions and measure satisfaction | Communication Data |
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| Manage our use of tracking technologies such as cookies, and enable you to manage your cookies preferences | Platform Usage Data Device Data |
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| Comply with legal and regulatory obligations to which we are subject and to protect our legal rights (for example to defend claims against us, to report cases to the competent authorities or conduct litigation to defend our interests) | Identity Verification Data Account Data Transaction Data Platform Usage Data Communication Data |
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We or our authorised service providers use cookies, web beacons, and other similar technologies (collectively, “cookies”) to collect and use personal data about you for several purposes, including to serve interest-based advertising. For further information, please see our Cookies Notice.
We may share (or permit the sharing of) your personal data for the above-mentioned purposes with the following categories of recipients:
(1) Other Platform Buyers and/or Sellers where necessary to support Platform purchases and communications made between you. If you are a Buyer, Sellers that you purchase from will also control personal data about you relevant to or connected with your Platform purchases and communications with them. Please refer to Sellers' Privacy Notices for information about how they will process your personal data;
(2) To our group companies and affiliated companies and/or their designated service providers, who provide data processing services to us (for example, to support the delivery of our Services, provide functionality on, or help to enhance the security of our Platform, or who otherwise process personal data for purposes that are described in this Privacy Notice (including processing services such as software, tools, systems and messaging services for purposes described in this Privacy Notice).
(3) To our third party services providers and partners engaged by or working with us to assist us in providing services to you, including those who provide data processing services to us and process personal data for purposes that are described in this Privacy Notice. Categories of these third party service providers include:
(a) Marketing and advertising partners, including Google, Twitter, Facebook, Criteo or other marketing media, so that they may tailor the content and/or serve advertising to you see when visiting our Platform. These partners may combine information they collect on our Platform with data on their platforms and data they collect from other websites or through other sources in order to conduct targeted advertising. The processing activities of these third parties marketing platforms are governed by their own privacy notices, which we encourage you to read carefully before giving your express consent;
(b) Our business partners (for example, in order for them to provide you with discounts or offers that may interest Buyers or Leads) where you have consented to receiving such information from them, if required by applicable data protection laws;
(c) Payment service providers that provide payment processing services. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Notice, so we encourage you to read them carefully before providing your payment data;
(d) Risk control service providers to assess the security of Buyer and Seller accounts and transaction risks;
(e) Logistics partners for providing delivery services for Buyers and Sellers, including return and exchange of products, and warehousing services for Sellers;
(f) Customs agents for customs clearances purposes, where applicable to support Buyers and Sellers with international sales/purchases;
(g) Cloud computing and other hosting providers for providing hosting services;
(h) Customer service support providers to provide after-sale services or other customer service support.
(4) To our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations where we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person; or as otherwise required or permitted by applicable laws.
(5) To an actual or potential buyer (and its agents and advisers, if applicable) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice; or
(6) any other person with your consent to the disclosure.
a) We store your personal data processed through the Platform in our servers located in Germany and Singapore. Our group companies, to which we transfer your personal data, operate in the European Union, Singapore and China. Our third-party service providers and partners operate in a number of countries, within the European Union, United States, Colombia, Egypt, Singapore and China. This means that to provide the services and to operate our Platform, we might transfer and permit the transfer of your personal data to any of these countries outside of the European Union for any of the purposes set out in this Privacy Notice. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
b) However, we will only permit any international transfer of your personal data (either to our group companies or third-party service providers) if it is in compliance with applicable laws.
c) To ensure that your personal data remains protected in accordance with this Privacy Notice, we rely on appropriate safeguards, including European Commission adequacy decisions or the European Commission’s standard contractual clauses as issued on 4 June 2021 under Article 46(2) using [modules 1 and 2 for controller to controller and controller to processor transfers].
d) You can consult the content of the relevant standard contractual clauses through the following link: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en
a) You have the following personal data protection rights. You can exercise these rights via our ‘Privacy Center’ portal (https://www.miravia.es/privacy/privacy-center) or by contacting us using the contact details provided under the “Data controller and contact details” section above.
(1) You may access, correct, update or request deletion of your personal data.
(2) You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data.
(3) You have the right to opt-out of marketing communications we send you at any time. You can exercise this right (a) by clicking on the “unsubscribe” or “opt-out” or any similar link in the e-marketing we send you, (b) via your in-app settings, (c) via your ‘My Privacy Center’ portal after logging on to your account (on desktop) or (d) by contacting us using the details above.
(4) If we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
(5) In addition to the above, you have the right to complain to a supervisory authority about our collection and use of your personal data. For more information, please contact your local supervisory authority. (Contact details for supervisory authorities in Europe are available here. https://edpb.europa.eu/about-edpb/about-edpb/members_en.) Our lead supervisory authority is the Spanish Data Protection Authority (AEPD) (www.aepd.es).
b) We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
We do not engage in automated decision-making that will have a significant effect on you (legally or otherwise) using your personal data.
a) To safeguard your personal data from unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification or similar risks during the course of your use of our Platform and/or Services, we implement appropriate organizational, physical and technical measures.
b) While no method of transmission over the Internet or method of electronic storage is completely secure, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
c) You are also advised to exercise caution with respect to the sharing of your personal data and your authentication / security details (such as passwords, credit card details, transaction details) outside of our Platform / Services. For registered users of the Platform, some of your information can be viewed and edited through your account, which is protected by a password. It is your responsibility to keep your password secure and confidential. We have instructed our personnel to never ask you for your password. If you share a computer with others, you should not save your log-in information (e.g., user ID and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session.
a) We will only retain your personal data for as long as we are either required or permitted to by law or as relevant for the purposes for which it was collected.
b) When we have no legal obligation or ongoing legitimate business need to process your personal data, we will either delete or anonymise it, or if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store and isolate it from any further processing until deletion is possible. How long your data is kept for will also depend on how you use our Platform (for example if you are logged in as a member) and what the data you provide to us is used for. For example, if you are a registered member, certain data will be retained for a length of time following termination or deletion of your account, in order to comply with applicable laws (for example, if a court order is received about your account, we would retain your account data for longer than the usual retention period when an account is deleted) or in case of disputes. In other instances, the period of retention may be determined according to your activity on the Platform or to comply with a specific arbitration period/resolve a dispute.
c) In certain cases, we need to keep your information longer for the legal reasons. Such legal reasons include: (i) complying with applicable law (e.g. to respond to a court order, warrant or a valid legal request), (ii) to resolve requests and complaints, (iii) for litigation or regulatory matters, or (iv) to address issues relating to the safety and integrity of our Platform and users' property and rights. We keep this data in accordance with our Personal Data Retention Limitation Policy.
Miravia Platform is intended for adults and users must be over 18 to use our Platform. Miravia Platform does not intend to sell products to minors (as defined by applicable law), nor does it intend to provide any of the Services or the use of the Platform to minors. We do not knowingly collect any personal data relating to minors. If a minor has provided us with personal data without parental or guardian consent, the parent or guardian should contact us (using the contact details provided under section "Data controller and contact details" above) to remove the information.
Please note that our Platform may include links to third party sites and/or services. This Privacy Notice does not apply to the collection and processing of personal data on those third-party sites and/or services. We encourage you to carefully read their terms and conditions and privacy policies before using their services.
a) We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
b) You can see when this Privacy Notice was last updated by checking the “Version dated” date displayed below.