Effective Date: 01.01.2025

Note: This Privacy Policy is a part of set of Policies of the Seller. Definitions and terms used in this Policy correspond to major definitions and terms as described in “General Terms and Conditions of Sale” unless explained differently herein below.

1. Introduction

We respect your privacy and are committed to safeguarding the personal data you provide to us. This Privacy Policy details how we handle (collects, uses, discloses, store and/or share) your personal data when you engage with our e-commerce platform, evaluate, research, order, purchase products from us, or utilize and use any of other our services by visiting e-platform through web, mobile features including available social media channels. By using our website or purchasing our products, you agree to the collection and use of your personal data as described in this Policy or any other Policy associated with e-platform. We ensure our practices comply with the General Data Protection Regulation (GDPR), Directive 2011/83/EU, Directive 2019/771, and other applicable European laws.

2. Data Controller

We are the data controller responsible for processing your personal data. This means we determine the purposes and means of processing personal data in compliance with the GDPR. As the data controller, we are committed to ensuring that your personal data is processed lawfully, fairly, and transparently.

Contact Information:
BATSAM TRADING S.à r.l.
8, rue de la Grève,
L-1643 Luxembourg,
Grand-Duché de Luxembourg
Email: info@batsam.lu

3. Information We Collect

We collect various types of information to provide our services effectively and to enhance your shopping experience. The types of data we collect include:

• Personal Identification Data: This includes your name, mailing address, email address, phone number, and other identifiers that you voluntarily provide when you register or make a purchase on our Site.
• Order and Transaction Data: When you place an order with us, we collect details related to your purchase, such as products ordered, payment methods, transaction history, and billing and shipping information.
• Technical Data: We may collect information about the devices you use to access our Site, including your IP address, browser type, operating system, referring URL, and access times. This helps us optimize our website’s functionality and security.
• Communication Data: Any correspondence you have with us, including queries, feedback, and complaints, may be stored to ensure high-quality service and resolve any issues you raise.
• Cookies and Tracking Data: We use cookies and similar tracking technologies to understand how you use our website and to improve our services. For more information, refer to our Cookies Policy below.

4. Purpose of Data Collection

We process your personal data to deliver the products and services you request and to improve our customer service. Specifically, we use your data for the following purposes:

• Order Fulfillment and Delivery: To process your orders, manage payments, provide customer support, and ensure timely delivery of products.
• Customer Support and Communication: To respond to your inquiries, provide technical support, resolve any issues, and keep you informed about your orders.
• Improvement of Our Services: We analyze data to enhance the functionality and usability of our Site and to better understand your preferences for future improvements.
• Marketing and Promotions and Loyalty: With your consent, we may use your data to send you marketing communications about our latest products, offers, and news. You may opt out of these communications at any time.
• Legal and Regulatory Compliance: To fulfill our legal obligations, such as maintaining transaction records for tax, accounting, and reporting purposes, as well as complying with applicable consumer protection laws.
• Fraud Prevention and Security: To monitor transactions and user activities to detect and prevent fraud, cyber threats, and other security risks.

5. Legal Basis for Processing

Under the GDPR, we must have a legal basis for processing your personal data. Depending on the context in which we collect your data, we rely on the following legal grounds:

• Performance of a Contract: When you make a purchase, we process your data to fulfill our contractual obligations, such as processing your order and delivering products.
• Legitimate Interests: We may process your data for legitimate business purposes, such as improving our services, conducting analytics, or preventing fraud, as long as your rights and interests are not overridden.
• Legal Obligations: We process certain data to comply with our legal obligations, such as tax reporting, invoicing, and compliance with consumer protection laws.
• Consent: For specific processing activities, such as marketing communications, we rely on your consent. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

6. Your Rights under GDPR

As a data subject under the GDPR, you have specific rights in relation to your personal data. These include:

• Right of Access: You have the right to request access to the personal data we hold about you, along with details about how we use it.
• Right to Rectification: If you believe any information we hold is incorrect or incomplete, you can request that we correct or update it.
• Right to Erasure (“Right to be forgotten”): You may request the deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purpose it was collected or if you withdraw your consent.
• Right to Restrict Processing: In certain cases, you may ask us to limit the processing of your data. For example, if you dispute the accuracy of the data, you can request that we restrict processing while we verify its accuracy.
• Right to Data Portability: You may request to receive your personal data in a structured, commonly used, and machine-readable format, and have it transferred to another data controller.
• Right to Object: You have the right to object to our processing of your data, especially if the processing is based on legitimate interests or direct marketing.
• Right to Withdraw Consent: If you have given consent for processing, you may withdraw it at any time.

To exercise any of these rights, please contact us at info@batsam.lu. We will respond to your request accordingly.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or to comply with legal, accounting, or reporting obligations. When determining the appropriate retention period, we consider:

• The purposes for which we process your data.
• The nature of the data.
• Any legal requirements for retaining the data (e.g., for tax purposes).
• Your rights under GDPR to request deletion.

Data that is no longer needed is securely deleted or anonymized.

8. Cookies and Tracking Technologies

Our website uses cookies to distinguish you from other users and to provide a personalized experience. Cookies are small text files stored on your device when you visit certain websites.

Types of Cookies We Use:

• Essential Cookies: These are necessary for the operation of the Site. They allow you to navigate and use features such as the shopping cart and secure areas of the website.
• Performance Cookies: These cookies collect information about how visitors use our Site, such as which pages are most frequently visited. We use this information to improve the functionality and user experience of the Site.
• Functionality Cookies: These cookies remember your choices (e.g., your username, language, or region) to provide a more personalized experience.
• Targeting/Advertising Cookies: These cookies are used to deliver relevant advertisements to you based on your browsing behavior. They also limit how often you see an advertisement.

You can manage your cookie preferences through your browser settings. For more detailed information on how we use cookies, please review our Cookies Policy.

9. Security Measures

We take data security seriously and implement technical and organizational measures to protect your personal data from unauthorized access, alteration, or disclosure. These measures include:

• Data Encryption: We use encryption protocols to protect sensitive data during transmission (e.g., during checkout and payment).
• Access Controls: We restrict access to personal data to authorized personnel only, ensuring that they are bound by strict confidentiality obligations.
• Regular Security Audits: We conduct regular audits to assess the effectiveness of our security measures and to detect vulnerabilities.

Despite these precautions, no security system is completely foolproof. In the event of a data breach, we will notify affected users and the appropriate regulatory authorities in accordance with GDPR guidelines.

10. Third-Party Data Sharing

We do not sell, trade, or rent your personal data to third parties. However, we may share your information with trusted third parties under the following circumstances:

• Service Providers: We engage third-party companies to perform certain functions on our behalf, such as payment processing, order fulfillment, shipping, accounting and IT services. These third parties are contractually obligated to use your data solely for the purpose of providing services to us and to maintain confidentiality.
• Legal Compliance: We may disclose your personal data if required by law, court order, or governmental regulation, or if we believe that disclosure is necessary to protect our rights, property, or safety.
• Business Transfers: In the event of a merger, acquisition, or asset sale, your personal data may be transferred to the acquiring company as part of the transaction.

11. International Data Transfers

As a company based in Luxembourg, we comply with GDPR's requirements for international data transfers. If your data is transferred to a country outside the European Union (EU) that does not provide an adequate level of protection, we ensure that appropriate safeguards are in place. These may include:

• Standard contractual clauses approved by the European Commission.
• Binding corporate rules within our group of companies.
• Transfers based on your explicit consent.

For more information on the safeguards we use, please contact us at info@batsam.lu

12. Return and Refund Policy

We aim to provide the highest quality of Products. However, due to the perishable nature of our Products, the following return and refund policies apply. See respective Shipping and Return Policy.

13. Limitation of Liability

Our liability is limited to the value of the product purchased. The Seller’s liability for damages shall be limited to those arising from gross negligence, misinterpretation or willful misconduct, in accordance with applicable law. The Seller shall not be liable for any indirect, incidental, or consequential damages arising from the use, including but not limited to loss or leakage of data including personal data, loss of business opportunities, or any loss arising from the use or inability to use our products, dietary consequences during consumption or limitations arising from such consumptions, or inability to use the Products, including but not limited to loss of profits, business interruption, or personal injury. See other relevant Policies for details.

Your Personal Data will be processed using methods designed to protect confidentiality and only by people trained and authorized to process it. Company adopts appropriate technical and organizational measures designed to ensure a level of security appropriate to the risk presented in relation to the processing. We have organizational and technical processes and procedures in place to protect your Personal Data.

However no electronic data transmissions over the Internet or information storage technology can be guaranteed to be completely secure. While we strive to protect your data from unauthorized use or disclosure, subject to applicable laws Company’s liability is limited in respect that Company does not warrant or guarantee the security of the data that you provide to us and we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your Personal Information.

14. Compliance with EU Regulations

Our Products and business practices comply with relevant EU regulations and directives, ensuring that we uphold the highest standards of consumer protection and product safety as well as data compliance and GDPR:

• EC Directive on ePrivacy, Cookies and Electronic Communications: Our website complies with the EU ePrivacy Directive, ensuring transparency regarding the use of cookies and similar technologies. We provide users with clear options to accept or reject non-essential cookies in compliance with GDPR and cookie laws.
• EU Regulation Food Contact Materials: Our packaging materials are compliant with EU regulations on food contact materials, ensuring that no harmful substances transfer from packaging to our coffee products during storage or transportation.
• EU Regulation on GDPR: We are committed to protecting our customers' personal data in compliance with the General Data Protection Regulation. This includes ensuring that we only collect, process, and store personal information necessary for fulfilling orders and enhancing the customer experience. Customers have the right to access, rectify, or delete their data at any time.
• EC Directive on e-Commerce: This directive establishes a legal framework for online services in the EU, ensuring that consumers are protected in the digital marketplace. We comply with its requirements by providing transparent information about our services, prices, and terms and conditions of sale, as well as facilitating customer communication and complaints through accessible channels.

See other Policies for different respective applicable regulations and directives.

By aligning our practices with these directives and regulations, we aim to foster trust and transparency with our customers, ensuring their rights are upheld and providing high-quality products that meet all legal standards.

We continuously monitor changes in legislation to ensure compliance with these and other relevant EU regulations. Our commitment to legal and regulatory compliance allows us to provide a safe, reliable, and trustworthy shopping experience for our customers.

15. Governing Law

This policy shall be governed by and construed in accordance with the laws of the Grand Duchy of Luxembourg. The application of the UN Convention on Contracts for the International Sale of Goods (CISG) is excluded.

Any disputes arising from this policy or related to the sale of our products will be subject to the jurisdiction of the competent courts in Luxembourg. The Customer agrees to submit to the personal jurisdiction of such courts for the resolution of any disputes. You agree that any disputes will be resolved on an individual basis and not in a class, consolidated, or representative action. Nonetheless, all disagreements arising from the enforcement of these Rules are to be resolved by negotiation. In case of failing agreement, disagreement is resolved through alternative out-of-court dispute resolution practice.

16. Changes to this Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our practices, technologies, or legal obligations. Any updates will be posted on this page, and we will indicate the date of the last revision at the top of the policy.

• Notification of Significant Changes: If we make significant changes to this Privacy Policy, we will provide a more direct form of notification, such as sending you an email, or by prominently displaying a notice on our website. This ensures that you are fully informed of any material changes that may affect your rights or how your data is handled.
• Consent for Material Changes: In the event that we make changes to this policy that materially affect the processing of personal data based on consent; we will seek your renewed consent before such changes take effect. This may include changes to how we collect, use, or share your personal data with third parties.
• Review and Acceptance: We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your data and to ensure that you are aware of any updates. Your continued use of our website or services after any changes to this Privacy Policy are posted will constitute your acknowledgment and acceptance of those changes.
• Archived Versions: For your reference, we will maintain an archive of previous versions of this Privacy Policy, which will be available upon request, so you can review any changes made over time.

Contact Us

If you have any questions or concerns about this Privacy Policy, or if you wish to exercise your rights under GDPR, please contact us through e-platform or by written correspondence at:

BATSAM TRADING S.à r.l.
8, rue de la Grève,
L-1643 Luxembourg,
Grand-Duché de Luxembourg
Email: info@batsam.lu

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We appreciate your business and look forward to serving you!