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Ritani website privacy policy

This Privacy Policy was last updated on May 23, 2018


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. This Privacy Policy also sets out the choices you have in relation to the way we use your Personal Data.

Please make sure you carefully read this Privacy Policy and understand how we use your Personal Data. If you have any questions about this Privacy Policy or our practices please contact us at privacy@ritani.com or 1.888.9RITANI (1.888.974.8264).

For the purposes of applicable data protection law (in particular, the General Data Protection Regulation (EU) 2016/679 (the "GDPR")), your data will be controlled by Ritani.

Information we collect

We will only collect information about you when you willing provide it. You are not legally required to provide us with any information, but in order to access our services, order products, ask us questions or give us feedback you will need to provide with certain details.

Personal Data That You Provide Through the Sites: We may collect the following personal data from you:

  • Identity and Contact Data, including your name, address, telephone number, date of birth, email address, tax status and other personal data concerning your preferences relevant to our services;
  • Financial and Payment Data, including your and other data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
  • Profile and Usage Data, including passwords to Ritani Sites or password protected platforms or services, your preferences in receiving marketing information from us, your communication preferences and information about how you use our websites(s) including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-overs). To learn more about our use of cookies or similar technology please check our cookies section below;
  • Technical Data, including information collected during your visits to our website(s), the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform. To learn more about our use of cookies or similar technology please check our cookies section below;
  • Physical Access Data, relating to details of your visits to our stores for collection of products you purchased.

Statistical information: We use statistical information which may include Personal Data for aggregated anonymised analysis. Our Sites receive and store certain aggregated anonymised information. Such information, which is collected passively using various technologies, is not used to specifically identify you. We use this information to understand how our Sites are performing. The types of information we collect include, 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.

Third-party Internet Based Advertising

We also use third parties service providers for online advertising. These third-party advertising service providers may use information (not including your name, address, email address or telephone number) about your visits our Sites 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.

Cookies

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 analyse 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 on-going 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 analysed 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.

We also use Google Analytics, to monitor the performance of our website and platform for optimization and to monitor performance of certain functionalities. For more information about Google Analytics please go to https://support.google.com/analytics/answer/6004245?hl=en.

Our Use of Your Personal Data and Other Information

Ritani uses the Personal Data you provide as necessary and in a manner that is consistent with this Privacy Policy.

We may use your Personal Data for the following purposes:

  • process any transactions you make using the website, including contacting you if we have any query regarding orders or responding to any of your queries;
  • provide our goods and services to you and for associated purposes;
  • carry out our obligations arising from any contracts entered into between you and us;
  • contact you (including by post, email and SMS) about our products, services, offers which we think may be of interest to you and for market research purposes, subject always to your marketing preferences;
  • improve your browsing experience by developing and improving the design and layout of the website, through analysis of your usage;
  • contact you for your feedback on our products and services, including requests for reviews, ratings and satisfaction surveys;
  • contact you to provide you information about third party products, services or offers which may be of interest to you, subject always to your consent (if applicable) or your chosen marketing preferences (which you can update at any time);
  • contact you in relation to any prize draws, competitions or other promotions that you have entered or subscribed to;
  • for research, analysis and risk management; and
  • enable us to comply with any legal or regulatory requirements and in the detection and prevention of theft, fraud or other crimes.

Marketing

We would like to keep in touch with you about our services and products, but if you do not want to receive updates about our products and services, you can let us know at any time. You can do this either by emailing us at privacy@ritani.com or "opt-out" by following the instructions in our emails.

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 such use Personal Data and, if required, your consent will be obtained.

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. We will only disclose your information in relation to such potential transactions where it is necessary to do so.

Ritani affiliated companies: We may also share your Personal Data with our affiliates and retail jewelers we have a relationship with 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. If required under applicable data protection laws, we will obtain your consent prior to sharing your Personal Data with such third parties for marketing. You can ask us and our affiliates to stop sending you marketing information at any time by either clicking on the unsubscribe link at the bottom of our emails or by contacting us at privacy@ritani.com.

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. This in-store experience will only be available to our customers in North America.

Agents, Consultants and 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 (for example, Border Free, our third party service provide for international shipping). When we use another company to perform services on our behalf we only provide them with the information that they need to perform their specific function. In some cases these third parties may request additional information directly from you in order to carry out their services, these third parties may have their own privacy terms which we recommend you review.

Financing options: We also allow customers to purchase our products with third party finance. These financing options are not provided by Ritani, but by selected third parties. If you choose to use a financing option you will be directed to an unaffiliated third party website (for example, Synchrony Financial). Any finance product you obtain through these third parties will be governed by separate terms and conditions and the Personal Data you provide directly to these third parties will be governed by their own privacy policy. We recommend you review such additional terms thoroughly. We do not have any control over these third parties and we do not provide them with any of your Personal Data unless you ask us to.

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.

Data Transfers

If you provide Personal Data to the Sites, you acknowledge that such Personal Data may be transferred from your home country to Ritani and appointed third parties (as referred to in this Privacy Policy) to the United States. We take measures to provide appropriate level of data privacy protection. For example, we use approved standard contractual clauses, intragroup agreements, and other measures designed to ensure that recipients of your personal information protect it.

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 or we may not be able to provide you with our products.

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 and Data Retention

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.

We will only keep your Personal Data for as long as required in order to provide you with the services and products requested. In some cases, we may retain Personal Data for longer periods where we are required to do so under applicable law.

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

We may make changes to this Privacy Policy in order to comply with our legal or regulatory obligations, to reflect a change in our business or updates to our Sites. 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.

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 Data 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 Data 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.

Your European Privacy Rights

The GDPR entitles European residents certain rights in relation to their Personal Data. Under certain circumstances, if you are a European resident by law you have the right to:

  • update, modify, delete or obtain (commonly known as a "subject access request") a copy of the Personal Data that we hold on you; or
  • restrict or stop us from using any of the Personal Data which we hold about you;

you can request this by contacting privacy@ritani.com. We endeavour to respond to such requests within a month or less, although we reserve the right to extend this period for complex requests.

Where appropriate, we will respond to your requests relating to your Personal Data in writing or by email. If you require our response in a different format, please let us know.

If you are not happy with the way that we have handled your Personal Data or a data subject request you also have the right to lodge a complaint with a supervisory authority, in particular (for EU based individuals) in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: [0303 123 1113].

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