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Ritani Privacy Policy

This Privacy Policy was last updated on October 9th, 2013


Our Policy

Welcome to the web site and mobile application (the "Sites") of Electronic Commodities Exchange, L.P. (d/b/a Ritani) ("Ritani", "we", "us" and/or "our"). The Sites are operated by Ritani and have been created to enable purchases of diamonds, bridal and other fine jewelry and to provide information about our organization (the "Ritani Services") to our visitors ("you", "your"). This Privacy Policy sets forth Ritani's policy with respect to information including personally identifiable data (including, by way of example, name, address, preferences, credit card number, Wish List items, favorite local jeweler, billing and shipping addresses) ("Personal Data") and other information that is collected from visitors to the Sites.

Information we collect

When you interact with us through the Sites, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Sites: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Ritani Services or use certain Ritani Services. Wherever Ritani collects Personal Data we make an effort to provide a link to this Privacy Policy.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Sites, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Ritani and the authorized third parties referred to herein located in the United States.

Other Information:

Non-Identifiable Data: When you interact with Ritani through the Sites, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Ritani may store such information itself or such information may be included in databases owned and maintained by Ritani affiliates, agents or service providers. The Sites may use such information and pool it with other information to track, for example, the total number of visitors to our Sites, the number of visitors to each page of our Sites, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.

Our third-party advertising service providers may use information (not including your name, address, email address or telephone number) about your visits to these and other Web sites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information collected and used by these companies, please visit DAA opt-out program or NAI opt-out program.

In operating the Sites, we may use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Sites gives to your browser when you access a Site. Our cookies help provide additional functionality to a Site and help us analyze Site usage more accurately. For instance, one of our Sites may set a cookie on your browser that allows you to access a Site without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Sites’ features.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Ritani Services, Ritani often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Ritani may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Ritani may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Our Use of Your Personal Data and Other Information

Ritani uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Ritani Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services (including, by way of example, to complete particular transactions, to provide personalized services and to place you on mailing lists for newsletters). Ritani and its subsidiaries and affiliates (the "Ritani Related Companies") may also use your Personal Data and other personally non-identifiable information collected through the Sites to help us improve the content and functionality of a given Site, to better understand our users and to improve the Ritani Services. Ritani and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to "opt-out" of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

If Ritani intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Our Disclosure of Your Personal Data and Other Information

Ritani is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies: We may also share your Personal Data with our Related Companies and our retail jeweler affiliates for purposes consistent with this Privacy Policy, including, without limitation, to provide personalized services, to notify you of special and/or promotional offers, discounts and sales and to place you on mailing lists for newsletters.

Retail Affiliates: We will share your Personal Data with our retail jeweler affiliates which you select in order for you to engage in an in-store retail experience with such retail jeweler affiliate.

Agents, Consultants and Related Third Parties: Ritani, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, managing customer reviews and moderation and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: Ritani may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Ritani, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.

Your Choices

You can use the Sites without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Ritani Services.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Ritani other than Personal Data collected through the Sites. This Privacy Policy shall not apply to any unsolicited information you provide to Ritani through the Sites or through any other means. This includes, but is not limited to, information posted to any public areas of the Sites, such as bulletin boards (collectively, "Public Areas"), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, "Unsolicited Information"). All Unsolicited Information shall be deemed to be non-confidential and Ritani shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children

Ritani does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Sites. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Sites without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Ritani through the Sites, please contact us, and we will endeavor to delete that information from our databases.

This Privacy Policy applies only to the Sites. The Sites may contain links to other web sites not operated or controlled by Ritani (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Sites do not imply that Ritani endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Security

Ritani takes reasonable steps to protect the Personal Data provided via the Sites from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Sites may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Ritani via the Internet.

Other Terms and Conditions

Your access to and use of the Sites is subject to the Terms of Use.

Change to Ritani's Privacy Policy

The Sites and our business may change from time to time. As a result, at times it may be necessary for Ritani to make changes to this Privacy Policy. Ritani reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Sites after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information; Contacting

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Sites.

Please also feel free to contact us if you have any questions about Ritani's Privacy Policy or the information practices of the Sites.

You may contact us as follows: privacy@ritani.com or 1.888.9RITANI (1.888.974.8264)

Your California Privacy Rights

Applicable California privacy legislation permits visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request to access such information, please contact us at privacy@ritani.com. Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.

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