RRP Diamond PRIVACY POLICY

Last Updated: March 13, 2022

This privacy policy (“Privacy Policy”) governs how we, RRP Diamond ([email protected]) (“RRP Diamond” “we”, “our” or “us”) use, collect and store information pertaining to you (“User”, “you”), such as in the following use cases:

• When you browse or visit our website, http://www.rrpdiamonds.com/ (“Website”)
• When you make use of, or interact with, our Website
  • When you create an account and purchase a product
  • When you request a customized design
  • When we request a review of our products / services
  • When you contact us for support or otherwise (e.g. customer support and/or via chat)
• When we use the Personal Data of our service providers
• When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Finally, please note that some of the abovementioned personal data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for network and information systems security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your personal data and further use it.

HOW WE PROTECT AND STORE YOUR INFORMATION

2.1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

2.2. Retention of your Personal Data. In addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually.

HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described in Section 1, we may share your information as follows:

• • Affiliates: We may share your information with our affiliates and subsidiaries for business, operational, promotional, and/or marketing purposes;
  • Our Service Providers: We share your information with our third party service providers that provide business, professional or technical support functions for us (including to the extent necessary or desirable to fulfill or ship your order or complete your transaction; provide customer support; process your purchases), help us operate our business, IT and the Website, or administer activities on our behalf. We also share your Personal Information with our business partners with whom we jointly offer products or services.
  • Legal Matters; Safety: We may share your information to the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order. We also may disclose your information to protect the security of our Site, servers, network systems, and databases, including for fraud prevention purposes. We also may disclose your information as necessary, if we believe that there has been a violation of our Terms of Use, any other legal document or contract related to our services, or the rights of any third party.
  • Sale or Transfer of Business or Assets: If, in the future, we sell or transfer some or all of our business or assets to a third party, or in the event of bankruptcy or a comparable event, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
  • With Your Consent: Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with any marketing consents or opt-in to optional additional services or functionality, if required by applicable law).

Aggregate or Anonymous Non-Personal Information: We may share aggregate, anonymous, or de-identified non-personal data with third parties for their marketing or analytics uses.

YOUR PRIVACY RIGHTS AND CHOICES

5.1. Rights under GDPR: The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

• You have a right to access information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
• You have the right to request that we rectify any Personal Data we hold that it is inaccurate or misleading;
• You have the right to request the erasure/deletion of your Personal Data (e.g. from our records).. Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
• You have the right to object to or to request restriction of the processing.
• The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• You have the right to object to profiling;
• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
• The right to withdraw your consent at any time. Please note that t there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
• You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
• You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality.

5.2. Rights under CCPA: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the CCPA:

• You have the right to know what personal information is being collected about you;
• You have the right to request the erasure/deletion of your personal data (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
• You have the right to know whether your personal information is sold or disclosed and to whom;
• Restriction of, or object to, processing of your Personal Information, including the right to opt in or opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;
• You have the right to equal service and price, even if you exercise your privacy rights.

You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution. You can exercise your rights by contacting us at [email protected] or, if you are an individual protected by CCPA, you can make your requests by email. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

5.3. Deleting your account: Should you ever decide to delete your account, you may do so by emailing [email protected]. If you terminate your account, any association between your account and personal data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

COOKIES, TRACKING OPTIONS AND DO NOT TRACK DISCLOSURES

• • Cookies. Our Website utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Website and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Website. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. You are free to adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Website or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences.
  • Do Not Track Disclosures. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website.
  • Log files. We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.
  • Analytic tools.
    • Google Analytics: The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
    • Facebook Pixels. We use Facebook pixels, which is a tool that provides help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
    • We reserve the right to use additional analytic tools.

Use By Children

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen 18, do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].

Links to and interaction with third party products

The Website enable you to interact with third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

SPECIFIC PROVISIONS APPLICABLE UNDER PRIVACY LAW

9.2. We, including our Website, collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, our websites and agents, have collected the mentioned categories of Personal Information in Section 1 from consumers within the last twelve (12) months.

9.3. Your Choices. You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any issue to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

9.4. Sale of Personal Information. Disclosure of Personal Information for business purposes. Financial incentives for collection of Personal Information. We do not sell any Personal Information and we do not disclose any Personal Information for any business purpose. Therefore, we have not sold or disclosed consumers’ Personal Information for a business purpose in the preceding 12 months. We do not offer financial incentives for collection of Personal Information.

9.5. We obtain the mentioned categories of Personal Information in Section 1 from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.
• From third-party business partners, who provide data services available in the public domain.

9.6. Questions. If you have further questions with respect the collection, use, disclosure or sale of your personal information, please make your request by contacting us to [email protected].

9.8. Non-Discrimination. If you decide to exercise your rights, you will not receive any discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. However, note that some features of our Website, our products and/or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

HOW TO CONTACT US.

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected].