Policy & Agreement

Baktriana B.V. (Baktriana.com / Baktriana.Luxe)

Privacy Policy and Cookie Statement (Effective October 14, 2020)

Baktriana / Baktriana Luxe (“we” “us” or “our”) values your privacy and takes steps to protect the privacy and security of information that you provide to us that either identifies you or could, when combined with other information, be used to identify you (“Personal Information”). Baktriana complies with all applicable laws regarding your privacy. This Privacy Policy explains how and why we collect and use the Personal Information you provide to Baktriana.  In this statement we explain how Baktriana deals with personal data. We obtain this information through our Websites baktriana.com & baktriana.luxe. In addition, we acquire personal data when customers contact us offline, for example to request information. This statement also pertains cookies we use on the Websites

Consent to Baktriana’s Privacy Policy

By accessing or otherwise using any of our owned and/or operated Baktriana powered web shopping platforms, you agree to the terms and conditions of this Privacy Policy. You expressly consent to the processing of your Personal Information and Anonymous Information according to this Privacy Policy.

Baktriana respects the privacy of its customers, business relations and users of its Websites. We make sure that any personal data Baktriana has obtained, is protected and treated confidentially. Your Personal Information may be processed and stored in The Netherlands under privacy laws of the EU (including the United States where visitors reside outside of the EU) where laws regarding processing of Personal Information may be less stringent than the laws in your country. Your Personal Information will not, however, be used or disclosed for purposes for which you have not given consent, or which are not permitted under applicable EU law.

Information Collection

Provided Personal Information: In general, we collect Personal Information that you submit to us voluntarily through Baktriana. We also collect information that you submit in the process of creating or editing your account and user profile on Baktriana. For example, our registration and login process require you to provide us with your full name, valid and current email address and password of your choice. When you personalize your profile and use the features of Baktriana, we will collect any information you voluntarily provide, and we may also request optional information to support your use of Baktriana, such as your birthday, gender and other demographic information. We collect information in the form of the content that you submit during your use of Baktriana, such as photos, reviews, ratings and other information you choose to submit. We may also collect information about you and your friends who use Baktriana, from any social network you may have connected from, in order to provide you with a more personalized experience. For instance, we may collect your user ID or profile information that you have permitted to be displayed through Baktriana in order to display you as a friend or in association with your profile and collections. When you purchase an item, you will need to submit your credit card or other payment information, which we may collect and store, so that our service providers can process your payment for the item. When you sign up for Baktriana or engage in other activities that we make available on Baktriana, we will collect the information designated along with such activity, which may include your contact information such as your address and phone number. We will also collect transactional information based on your activity on Baktriana, such as buying or any other information you provide to purchase an item. If you choose to sign up to receive information about products or services that may be of interest to you, we will collect your email address and other related information. Additionally, we collect any information that you voluntarily enter, including Personal Information, into any postings, comments, or forums of any Baktriana powered websites.

Baktriana may require you to submit additional personal information to authenticate yourself if we believe you are violating Baktriana policies, such as identification or a utility bill to verify your address. If you do not wish to share such information with us, you will be unable to complete any further transactions on Baktriana. We also collect information about your personal data and navigation behaviour on our Websites, and whether you found our Web Shop through one of our ad partners. Amongst this data is for example (but not limited to):

  • Country
  • Viewed products
  • IP-address
  • How you entered our Websites
  • Where you leave our Websites
  • With what kind of device you visit our Websites
  • Preferences in the Wish List
  • Ordered products
  • Contact information
  • First and last name
  • E-mail address
  • Password
  • Delivery address
  • Phone number
  • Payment method
  • Company name (if applicable)
  • VAT number (if applicable)
  • CoC (Chamber of Commerce) number (if applicable)

The data mentioned above is used for the following purposes:

  • To optimise claims and to keep track of contact history concerning Website orders and products offered by third parties

The data mentioned above and your account information are used, among other things, for the following purposes:

  • To keep you informed about the status of your orders
  • To complete the order/agreement, amongst other things the delivery and so-called after-sales obligations.
  • To create and manage your account
  • To counteract fraud, abuse and/or improper use of your account
  • To show the products you have ordered in your account
  • For Billing
  • To improve our service
  • To handle questions and complaints
  • To personalise marketing activities
  • To place orders on behalf of a company
  • To be shown on the invoice
  • To contact you concerning the finalisation of the order, billing or delivery
  • To be able to receive payment and to optimise the checkout process
  • To prevent fraud and hacking
  • The selected method of payment and your IP-address are forwarded to our payment provider Adyen,after which they handle the payment

The data is saved at least as long as you have an account with Baktriana.

Amongst other things, the above information is used to better understand Website Visitors, to load the correct Website and to show relevant ads.

Personal Information from 3rd Parties: We may receive Personal Information about you from other sources with which you have registered, companies who we have partnered with (collectively, "Partners") or other third parties. We may associate this information with the other Personal Information we have collected about you.

E-mail: If you send an e-mail to us, or fill out our "Feedback" form through Baktriana, we will collect your e-mail address and the full content of your e-mail, including attached files, and other information you provide. We may use and display your full name and email address when you send an email notification to a friend through Baktriana or the social network from which you have connected to Baktriana (such as in an invitation, or when sharing your content). Additionally, we use your email address to contact you on behalf of your friends (such as when someone sends you a personal message) or notifications from a social network or other website with whom you have registered to receive such notifications. We may use this e-mail address to contact you, for things such as notifications of limited-edition shop sales and other related information. You may indicate your preference to stop receiving further promotional communications as further detailed below.

Information Collected with Technology: As you use Baktriana, certain information may also be passively collected and stored on our or our service providers’ server logs, including your Internet protocol address, browser type, type of device, operating system, and the address of the referring website. We may also place small data files on your computer or other device. These data files may be various types of Cookies, pixel tags, or other local storage provided by your browser or associated applications ("Cookies"). We use these technologies to: recognize you as a customer; customize Baktriana Services, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our site. We use Cookies and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the information for which you searched and viewed. In order to use our Services offered through Baktriana, your web browser must accept Cookies. If you choose to disable Cookies, some aspects of Baktriana may not work properly, and you may not be able to receive our Services. This type of information is collected to make Baktriana and solutions more useful to you and to tailor the experience with Baktriana to meet your special interests and needs

We engage in remarketing to market our sites across the web. When a user visits our site, a cookie is placed on the user’s computer. Users with this cookie may be targeted across advertising networks to receive relevant advertisements.

"Internet protocol address" or "IP Address" is a number that is automatically assigned to your computer when you use the Internet. In some cases, your IP Address stays the same from browser session to browser session; but if you use a consumer internet access provider, your IP Address probably varies from session to session. We, or our service providers, may track your IP Address when you access Baktriana to assist with ad targeting.

We may also enable advertisers and ad servers to promote third-party products and/or services by placing advertisements on Baktriana. These advertisers and ad servers may use Cookies and/or "Web Beacons" (which are usually small, transparent graphic images) in order to monitor information related to served advertisements. Clicking on such advertisements will direct you to the website of a third-party and the advertiser. This Privacy Policy does not cover the privacy practices of any advertisers or ad servers.

Disclosure & Use of Information

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent for marketing purposes the Personal Information that we collect with third parties, unless you ask or authorize us to do so.

In general, Personal Information you submit to us is used by us to provide you access to Baktriana; to improve Baktriana; to respond to your emails and other feedback; to provide customer service; to send you alerts, updates, administrative messages and otherwise facilitate your use of, and our administration and operation of, our Services; to monitor and analyse usage and trends; to resolve disputes; to better tailor the features, performance, and support of Baktriana; collect fees; to offer you additional information, opportunities, promotions and functionality from us, our partners or our advertisers at your request; and for any other purpose for which the information was identified at the time of collection. Additionally, we do share your content preferences and other information with the social network with which you have connected to Baktriana, along with those companies and persons you have asked us to share your information with.

We may provide your Personal Information to 3rd party service providers who work on behalf of or with us to provide some of the services and features of Baktriana and to help us communicate with you. Examples of such services include sending email, analysing data, providing marketing assistance, processing payments (including credit card payments), and providing customer service. We require our third-party service providers to agree not to use such information except as necessary to provide the relevant services to us. We may share some or all of your Personal Information (other than credit card information) with Merchants whose items you have purchased for their commercial purposes and to provision the item. If you do not want us to use or disclose Personal Information collected about you in the manner identified in this Privacy Policy, do not use Baktriana powered websites. We share information only with companies that have also committed to compliance with the GDPR and bind each of those companies via a Data Privacy Agreement to provide you with substantially equivalent privacy and security protections as those that Baktriana provides to you. Baktriana may be liable for any onward transfers of your Personal Information in violation of our commitments to you pursuant to this Privacy Policy or GDPR.

Additionally, we may create Anonymous Information records from Personal Information by excluding information (such as your name) that would otherwise make the Anonymous Information personally identifiable to you. Generally, we aggregate this information and use it in statistical analysis to help us analyse patterns in the use of Baktriana. This Privacy Policy does not limit our use or disclosure of any Anonymous Information in any way, and we reserve the right to use and disclose Anonymous Information to our partners, advertisers and other third parties at our discretion.

We may share some or all of your Personal Information with Baktriana affiliated companies that are under a common control, in which case we will require them, via written contract, to honour this Privacy Policy.

In the event we go through a business transition such as a merger & acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of ours or that acquirer’s assets may continue to process your Personal Information as set forth in this Privacy Policy.

By using Baktriana and providing us with your Personal Information, you understand and agree that we may disclose your Personal Information if we believe in good faith that such disclosure is necessary to: (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce the Baktriana Terms, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect the rights, property or safety of Baktriana, its users and the public. You hereby consent to us sharing your Personal Information under the circumstances described herein.

Baktriana may also be required to disclose an individual’s Personal Information in response to a lawful request by government officials, including to satisfy law enforcement or national security requirements.

Ability of Others to View Information: Helping you to protect your information is a vital part of our ethos. It is up to you to make sure you are comfortable with the information you choose to provide us and the information you choose to publish. You understand that when you use Baktriana, certain information you post or provide through Baktriana, such as your name, profile, comments, collections and reviews, may be shared with other users and posted on publicly available portions of Baktriana, including without limitation, social media applications and other public fora in which you choose to participate. Please keep in mind that if you choose to disclose Personal Information when posting comments or other information or content through Baktriana, this information may become publicly available and may be collected and used by others, including people outside the Baktriana collective websites and areas of activity. We will not have any obligations with respect to any information that you post to parts of Baktriana that are available to others and recommend that you use caution when giving out personal information to others through social media networks or otherwise.

3rd Party Sites and Ads: Baktriana may contain links to other websites. Please be aware that we are not responsible for the privacy practices or the content of such other websites. We encourage our users to read the privacy statements of each and every website they visit. This Privacy Policy applies solely to information collected by us through Baktriana and does not apply to these third-party websites. The ability to access information of third parties from Baktriana, or links to other websites or locations, is for your convenience and does not signify our endorsement of such 3rd parties, their products, their services, other websites, locations or their content.

Choices Regarding Personal Information: We offer you choices regarding the collection, use, and sharing of your Personal Information. You have a right at any time to stop us from contacting you for marketing purposes. When you receive promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly [email protected]. You can object to the use of your personal data free of charge. Your objection to the use of your personal data can be directed to our customer service via email or in writing. Within four weeks you will receive an answer from Baktriana

Despite your indicated email marketing preferences, we may send you administrative emails regarding Baktriana, including, for example, administrative and transactional confirmations, and notices of updates to our Privacy Policy.

You have the right to request a copy of the Personal Information that we hold about you. If you would like a copy of some or all of your Personal Information, please contact us directly [email protected]. We want to make sure that your information is accurate and up-to-date. You may ask us to correct or remove information which you think is inaccurate. You may change any of your profile information by editing it in the profile settings page. You may ask us to stop processing your information or delete your information by contacting us, [email protected]. We will delete that information within a commercially reasonable period of time unless prevented from doing so by applicable law.

European Union Residents & GDPR

Baktriana complies with all applicable privacy laws and regulations that apply to residents of the EU. Residents of the European Union (“EU”) may only use our Services after providing Baktriana your freely given, informed consent for Baktriana to collect, transfer, store, and share your Personal Data, as that term is defined in the EU’s General Data Protection Regulation (“GDPR”).

Baktriana complies with EU GDPR and makes it easy for EU residents to exercise their rights described in that regulation. The purposes for which Baktriana collects your Personal Information, which is defined in the GDPR as Personal Data, the categories and specific types of Personal Data we collect, and our practices and policies regarding your Personal Data are described in this Privacy Policy. As discussed throughout this Privacy Policy, Baktriana makes it easy for you to access, correct, delete, or demand deletion of your Personal Data. You may object to our processing of your Personal data by emailing us, although if you prohibit our processing, it may make some of our Services either impossible to offer or less useful. Any of those requests should be sent to [email protected]. Should you ever wish to leave Baktriana and take an electronic copy of the Personal Data and information we have collected about you, you may make that request to [email protected]. In addition to contacting our Data Protection Officer, EU residents may contact their country’s https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Privacy Framework

Baktriana is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission and the EU.

You have the right to obtain our confirmation of whether we maintain personal information relating to you. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe (normally no more than 4 weeks).

Rights to access your Personal Information may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or when the rights of persons other than you would be violated by the provision of such access. If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.

We will also provide an individual opt-out or opt-in choice before we share their Personal Information with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, please submit a written request to [email protected].

Baktriana’s accountability for Personal Information that it receives and subsequently transfers to a third party unless Baktriana proves that it is not responsible for the event giving rise to the damage.

Baktriana commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States. European Union and Swiss individuals’ inquiries or complaints should first contact Baktriana’s  Chief Marketing Officer (CMO), Dr. Frank Dzokoto at [email protected].

California Residents

If you reside in California you are entitled to exercise certain rights outlined in the California Consumer Protection Act. You have the right to obtain our confirmation of whether we maintain personal information relating to you.

Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to CMO, Dr. Frank Dzokoto at [email protected].

If requested to remove data, we will respond within a reasonable timeframe. Baktriana will not and may not discriminate against you for exercising these rights.

Regarding Individuals Under the Age of 18 & Minors

No matter where they live, individuals under the age of 18 are not permitted to use Baktriana and we do not intentionally collect or maintain Personal Information from those who are under 18 years old. Protecting the privacy of minors is very important to us. Thus, if we obtain actual knowledge that a user is under 18, we will take steps to immediately remove that user's Personal Information permanently from our databases. We always recommend that minors under the age of 18 obtain their parent’s permission before submitting any information over the internet.

In some countries the consent age that you may be legally able to use our service may be 13, 14, 15, 16, or 17 years of age. By using Baktriana, however, you are either (i)_representing that you are at least 18 years old; (ii) that you are at least 18 years old and have a parent’s or guardian’s permission over the age of 18 to use Baktriana; or (iii) if you reside in a country with an different age of consent that you are at least the appropriate number of years old and have a parent’s or guardians permission with the appropriate age of consent to use Baktriana.

Feedback

If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy. You agree that any such comments and any email we receive becomes our property. We may use feedback for marketing purposes or to add to or modify our services without paying any royalties or other compensation to you.

Security

We are committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. Even though we have taken significant steps to protect your Personal Information, you acknowledge that no company, including us, can fully eliminate security risks associated with Personal Information.

Contact and Revisions

If you have questions or concerns about our Privacy Policy, please contact [email protected]. If you are a resident of the EU and wish to exercise your rights pursuant to GDPR, please contact CMO, Dr. Frank Dzokoto at [email protected].

This Privacy Policy is subject to occasional revision at the sole discretion of Baktriana, and if we make any substantial changes in the way we use your Personal Information, we will post an alert on this page and send an email to registered users. If you object to any such changes, you must cease using Baktriana. Continued use of Baktriana following notice of any such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.