- When you browse or visit our website, www.finjewelrydesigns.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 you use our “drop a hint” functionality
- When you use our “refer a friend” functionality
- When you use our “Tryon share” functionality
- When you use our “Ambassador program” functionality
- When you participate in our Ambassador Surveys
- When you participate in our “Ambassador Pro Tips” functionality
- When you send an “engagement moment”
- 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 you sign up for our newsletters/email list
- When we use the Personal Data of our service providers
- When you make use of the Digital Photo Booth in our store
- When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
Table of contents:
- What information we collect, why we collect it, and how it is used
- How we protect and store your information
- How we share your Personal Data
- Additional information regarding transfers of Personal Data
- Your privacy rights and choices
- Cookies, tracking options and California do not track disclosures
- Use by children
- Links to and interaction with third party products
- Specific provisions applicable under California privacy law
- How to contact us
- 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. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
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.
- Select Third Parties: With our joint marketing partners for the purposes described in this Policy, including when we believe such partners may have offers of interest to you;
- 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.
ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
- Storage: Internal servers of FIN Jewelry Designs located in New York, US.
- Access from Israel is covered by the adequacy decision issued by the European Commission.
- Access from the US is covered by our privacy shield registration.
- Internal transfers: We ensure transfers within the FIN Jewelry Designs group will be covered by an agreement entered into by members of the FIN Jewelry Designs group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.
- External transfers: Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
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 firstname.lastname@example.org or, if you are an individual protected by CCPA, you can make your requests by email or via our toll-free telephone number: +1 877-826-9866. 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@example.com. 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 CALIFORNIA 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.
- We reserve the right to use additional analytic tools
- Interest-Based Advertising Choices. Through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, Website identifiers, page(s) visited, location, time of day). We also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know. To understand your choices for receiving more relevant advertising provided on the Website or across other websites and online services, please review the information below:
- DAA: To opt-out of such collection and use for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit: http://www.aboutads.info/choices.
- EDAA: To opt-out from the use of information about your online activities for interest-based advertising by European Interactive Digital Advertising Alliance (EDAA) participating companies, please visit: http://www.youronlinechoices.eu/.
- NAI: To opt-out from the use of information about your online activities for interest-based advertising by Network Advertising Initiative (NAI) participating companies, please visit: http://www.networkadvertising.org/choices/.
- For Mobile Devices: On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.
Even if you opt out, you still may receive advertising from us that is not customized based on your Service or usage information, or advertising from other third parties if they are not a DAA or NAI participating company.
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 firstname.lastname@example.org.
Links to and interaction with third party products
SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA 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.
9.4. 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@example.com.
9.7. Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject “BLOCK” to firstname.lastname@example.org. Please note that the email must come from the email account you wish to block.
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@example.com.