Last Updated: [16 Jan 2025]
1. Introduction
1.1 EDENS S.A. (RCS Luxembourg B 43791) (“EDENS S.A.”, “we,” “us,” or “our”) operates several websites and services, including [moa.lu] and our mobile application AsiaMarket (collectively, the “Services”). We are committed to protecting your privacy and ensuring the security of your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable laws.
1.2 This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit or use our Services (including our AsiaMarket App). By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.
2. The Information We Collect
2.1 Non-Personally-Identifying Information
- Like most website operators, we collect certain information that web browsers and servers typically make available (e.g., browser type, language preference, referring site, date/time of each request). This helps us understand how users interact with our Services.
2.2 Potentially Personally-Identifying Information
- We may collect IP addresses for logged-in users or users leaving comments or reviews on our website. IP addresses can help us diagnose server issues, analyze traffic, or prevent malicious activities.
2.3 Personally-Identifying Information
- Account Registration (Website or App): When you register an account (e.g., for purchasing our products), we may ask for your email address, name, phone number, and physical address (for shipping). We collect only what is necessary to provide and fulfill our services (e.g., order processing, delivery).
- Payment/Financial Data: We rely on third-party payment processors (such as Stripe, PayPal, or Payconiq) to handle all transactions securely. We do not directly collect or store your complete card information on our servers. Instead, when you proceed to checkout, your payment details are securely transmitted to the chosen payment processor.
We may receive limited payment-related information from the processor (e.g., transaction ID, payment status) to confirm and record your order. This information is used solely for order management, customer service, and accounting purposes in compliance with applicable law.
- Direct Contact: If you contact us directly (e.g., email, chat, feedback form), we may collect your message content, attachments, and any additional information you choose to provide.
2.4 Location Information (via AsiaMarket App)
- Optional Google Location Services: To optimize delivery and provide nearby product/service suggestions, our App may request access to your approximate or precise location (depending on your device settings). We will only collect location data if you have granted permission in your device/app settings. You may disable or revoke location access at any time, though some features may become limited.
3. Legal Basis for Processing (GDPR)
We only process your personal data where we have a valid legal basis, including:
- Contractual Necessity: To fulfill a purchase contract with you (e.g., shipping your orders).
- Legitimate Interests: To improve our Services, prevent fraud, or secure our platforms.
- Legal Obligations: To comply with laws, regulations, or valid requests by public authorities.
- Consent: Where required (e.g., sending marketing emails, accessing your device’s location), we will ask for your explicit consent.
4. How We Use Your Information
We use the collected information to:
- Provide, operate, and maintain our website and AsiaMarket App;
- Process and ship orders, manage payments, and address customer service requests;
- Improve, personalize, and expand our Services;
- Understand and analyze how you use our Services;
- Develop new products, services, features, and functionality;
- Communicate with you (e.g., service updates, marketing campaigns, promotions);
- Send you transactional or administrative emails;
- Find and prevent fraud, detect security breaches, or enforce our Terms of Use;
- Comply with legal obligations.
5. Cookies & Tracking Technologies
5.1 Cookies
- We use cookies (and similar technologies) to help identify and track visitors, usage, and website access preferences. If you do not wish to have cookies placed on your computer, you can set your browser to refuse cookies. However, some features of our site may not function properly without cookies.
5.2 Consent Management
- Where applicable law requires, we will obtain your consent before using certain analytics or marketing cookies. You may withdraw or modify your consent at any time via your browser settings or our cookie preference tool (if available).
6. Third-Party Services
We use various third-party services (e.g., Intercom, Google Analytics, Woopra, MixPanel, Profitwell, MailChimp, Drip, Facebook/Google Ads pixels, Perfect Audience, LeadDyno, FirstPromoter) to analyze data and improve user experience.
- Data Processing Agreements: We require that such third parties process data in compliance with GDPR or other relevant data protection laws, for example by entering into Data Processing Agreements (DPAs) with them.
7. Cross-Border Data Transfers
Some employees, contractors, or affiliated organizations who need access to your personal data may be located outside the EU/EEA. In these cases, we implement appropriate safeguards (such as EU Standard Contractual Clauses) to ensure your personal data receives an adequate level of protection, in accordance with GDPR requirements.
8. Data Retention
We will retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (e.g., for tax/accounting or legal compliance). Once no longer needed, we securely delete or anonymize your data.
9. Disclosure of Personal Data
9.1 We do not rent or sell your personal data to anyone.
9.2 We may disclose your personal data:
- To our employees, contractors, and affiliates who need it to perform services on our behalf, subject to strict confidentiality;
- To comply with a subpoena, court order, or other lawful request;
- When we believe disclosure is necessary to protect the rights, property, or safety of EDENS S.A., our users, or the public;
- If EDENS S.A. or substantially all of its assets is acquired or undergoes bankruptcy proceedings, user information may be transferred to the acquiring entity under the same privacy commitments.
10. Security of Your Information
We take reasonable measures to protect your personal data from unauthorized access, use, alteration, or destruction. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
11. Your GDPR Data Protection Rights
Under GDPR, you have the right to:
- Access – Request copies of your personal data;
- Rectification – Request correction of inaccurate or incomplete data;
- Erasure – Request deletion of your data under certain conditions;
- Restriction – Request to restrict processing of your data under certain conditions;
- Objection – Object to our processing of your data under certain conditions;
- Data Portability – Request transfer of your data to another organization or directly to you.
If you wish to exercise any of these rights, please contact us at services@moa.lu. We will respond within one month (and may extend by a further two months if your request is complex, in which case we will notify you of the extension).
12. Children’s Privacy
Our Services are not directed to children under the age of 16. We do not knowingly collect personal data from children without parental consent. If you believe your child has provided us with personal data, please contact us so we can remove it.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time at our sole discretion. Material changes will be announced on this page with a new “Last Updated” date. Your continued use of our Services after any modifications indicates your acceptance of the revised Policy.
14. Contact Us
If you have questions or concerns regarding this Privacy Policy or our data practices, please contact us at:
EDENS S.A.
RCS Luxembourg B 43791
Address: 28, Rue de l’Eglise 8025 Strassen, Luxembourg
Email: services@moa.lu
15. Complaints
In compliance with GDPR, you have the right to lodge a complaint with the Luxembourg National Data Protection Commission (CNPD) or another competent supervisory authority in the EU if you believe we have infringed your data protection rights. We kindly invite you to contact us first so we can address your concerns.