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This is the privacy policy of Ward Gemstones, company number
00607011. (‘we’, ‘our’, or ‘us’).
Our registered office is at 167 Turners Hill, Cheshunt,
Herts, EN8 9BH
Introduction
This notice describes how we collect, store,
transfer and use personal data. It tells you about your privacy rights and how
the law protects you.
In the context of the law and this notice, ‘personal data’
is information that clearly identifies you as an individual or which could be
used to identify you if combined with other information. Acting in any way on
personal data is referred to as ‘processing’.
This notice applies to personal data
collected through our website and through social media platforms and online
retail platforms, including Facebook, Instagram, Twitter, Etsy, eBay and Amazon.
Except as set out below, we do not share, or
sell, or disclose to a third party, any information collected through our
website.
Personal data we process
1.
How we obtain personal data
The information we process about
you includes information:
·
you have directly provided to us
·
that we gather from third party databases and
service providers
·
as a result of
monitoring how you use our website or our services
2.
Types of personal data we collect
directly
When you use our website, our services or buy from us, [for example, when you create an account on our website,]
we ask you to provide personal data. This can be categorised into the following
groups:
·
personal identifiers, such as your first and
last names, your title and your date of birth
·
contact information, such as your email address,
your telephone number and your postal addresses for billing, delivery
and communication
·
account information, including your username and
password
·
payment information, such as a debit or credit
card number and expiry date and bank account details
·
records of communication between us including
messages sent through our website, email messages and telephone conversations
·
marketing preferences that tell us what types of
marketing you would like to receive
3.
Types of personal data we collect
from third parties
We confirm some of the information you provide to us directly using
data from other sources. We also add to the information we hold about you,
sometimes to remove the need for you to provide it to us and sometimes in order to be able to assess the quality of the services
you offer.
The additional information we collect can be categorised as follows:
·
information that confirms your identity
·
business information, including your business
trading name and address, your company number (if incorporated), and your VAT
number (if registered)
·
information that confirms your contact
information
·
reviews and feedback about your business on
other websites through which you sell your services
·
unsolicited complaints by other users
4.
Types of personal data we collect
from your use of our services
By using our website and our services, we process:
·
your username and password and other information
used to access our website and our services
·
information you contribute to our community,
including reviews
·
your replies to polls and surveys
·
technical information about the hardware and the
software you use to access our website and use our services, including your
Internet Protocol (IP) address, your browser type and version and your device’s
operating system
·
usage information, including the frequency you
use our services, the pages of our website that you visit, whether you receive
messages from us and whether you reply to those messages
·
transaction information that includes the
details of the products services you have bought from us
and payments made to us for those services
·
your preferences to receive marketing from us;
how you wish to communicate with us; and responses and actions in relation to
your use of our services.
5.
Our use of aggregated information
We may aggregate anonymous information such as
statistical or demographic data for any purpose. Anonymous information is that
which does not identify you as an individual. Aggregated information may be
derived from your personal data but is not considered as such in law because it
does not reveal your identity.
For example, we may aggregate usage information to
assess whether a feature of our website is useful.
However, if we combine or connect aggregated
information with your personal data so that it can identify you in any way, we
treat the combined information as personal data, and it will be used in
accordance with this privacy notice.
6.
Special personal data
Special personal data is data about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health and genetic and
biometric data.
It also includes information about criminal
convictions and offences.
We do not collect any special personal data about
you.
7.
If you do not provide personal data we need
Where we need to collect personal data by law, or
under the terms of a contract we have with you, and you fail to provide that
data when requested, we may not be able to perform that contract.
In that case, we may have to stop providing a
service to you. If so, we will notify you of this at the time.
The basis on which we process information about you
The law requires us to determine under which of
six defined basis we process different categories of your personal data, and to
notify you of the basis for each category.
If a basis on which we
process your personal data is no longer relevant then
we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the
change and of any new basis under which we have determined that we can continue
to process your information.
8.
Information we process because we
have a contractual obligation with you
When you create an account on our website, buy a
product or service from us, or otherwise agree to our terms and conditions, a
contract is formed between you and us.
In order to carry out our
obligations under that contract we must process the information you give us.
Some of this information may be personal data.
We may use it in order to:
·
verify your identity for security purposes when
you use our services
·
sell products to you
·
provide you with our services
·
provide you with suggestions and advice on
products, services and how to obtain the most from using our website
We process this information on the basis there is a
contract between us, or that you have requested we use the information before
we enter into a legal contract.
We shall continue to process this information until
the contract between us ends or is terminated by either party under the terms
of the contract.
9.
Information we process with your
consent
Through certain actions when otherwise there is no
contractual relationship between us, such as when you browse our website or ask
us to provide you more information about our business, including our products
and services, you provide your consent to us to process information that may be
personal data.
Wherever possible, we aim to obtain your explicit
consent to process this information, for example, we ask you to agree to our
use of non-essential cookies when you access our website.
If you have given us explicit permission to do so,
we may from time to time pass your name and contact information to selected
associates whom we consider may provide services or products you would find
useful.
We continue to process your information on this basis
until you withdraw your consent or it can be
reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by
instructing us [email protected] However, if
you do so, you may not be able to use our website or our services further.
We aim to obtain and keep your consent to process
your information. However, while we take your consent into account in decisions
about whether or not to process your personal data,
the withdrawal of your consent does not necessarily prevent us from continuing
to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so.
For example, we may have a legal obligation to do so.
10.
Information we process for the
purposes of legitimate interests
We may process information on the basis there is a
legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we
do after having given careful consideration to:
·
whether the same objective could be achieved
through other means
·
whether processing (or not processing) might
cause you harm
·
whether you would expect us to process your
data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis
for the purposes of:
·
improving our services
·
record-keeping for the proper and necessary
administration of our business
·
responding to unsolicited communication from you
to which we believe you would expect a response
·
preventing fraudulent use of our services
·
exercising our legal rights, including to detect
and prevent fraud and to protect our intellectual property
·
insuring against or obtaining professional
advice that is required to manage business risk
·
protecting your interests where we believe we
have a duty to do so
11.
Information we process because we
have a legal obligation
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information
to legal authorities if they so request or if they have the proper
authorisation such as a search warrant or court order.
This may include your personal data
How and when we process your personal data
12.
Your personal data is not shared
We do not share or disclose to a third party, any information collected
through our website.
13.
Information you provide
Our website allows you to post information with a
view to that information being read, copied, downloaded, or used by other
people.
For example, when you leave a review or
post a message on our website, we reasonably assume that you consent for the
message to be seen by others. We may include your username with your message,
and your message may contain information that is personal data.
Other examples include:
·
tagging an
image
·
clicking on an
icon next to another visitor’s message to convey your agreement, disagreement or thanks
In posting personal data, it is up to you to satisfy
yourself about the privacy level of every person who might use it.
We do not specifically use this information
except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in
the future in any way we decide.
Once your information enters the public domain, we
have no control over what any individual third party may do with it. We accept
no responsibility for their actions at any time.
Provided your request is reasonable and there is no
legal basis for us to retain it, then at our discretion we may agree to your
request to delete personal data that you have posted. You can make a request by
contacting us at [email protected]
Payment information
We store information about your
debit or credit card or other means of payment when you first provide it to us.
We store this payment information
in order to make repeat purchasing
of goods and services easier next time you visit our website.
We also store it to help us
prevent fraud.
We take the following measures to
protect your payment information:
We do not keep all your payment
information so as:
a)
to prevent the possibility of our duplicating a
transaction without a new instruction from you;
b)
to prevent any other third party from carrying
out a transaction without your consent
·
Access to your payment information is restricted
to authorised staff only.
·
If we ask you questions about your payment
information, we only show last four digits of the debit or credit card number,
so that you can identify the means of payment to which we refer.
14.
Information obtained from third
parties
Although we do not disclose your personal data to
any third party (except as set out in this notice), we sometimes receive data
that is indirectly made up from your personal data from third parties whose
services we use.
No such information is personally
identifiable to you.
15.
Third party advertising on our
website
Third parties may advertise on our website. In doing
so, those parties, their agents or other companies working for them may use
technology that automatically collects information about you when their
advertisement is displayed on our website.
They may also use other technology such as cookies
or JavaScript to personalise the content of, and to measure the performance of
their adverts.
We do not have control over these technologies or
the data that these parties obtain. Accordingly, this privacy notice does not
cover the information practices of these third parties.
16.
Credit reference
To assist in combating fraud, we share information
with credit reference agencies, so far as it relates to clients or customers
who instruct their credit card issuer to cancel payment to us without having
first provided an acceptable reason to us and given us the opportunity to
refund their money.
17.
Disputes between users
In the event of a dispute between you and another
user, provided that you consent, we may share your
basic personal data, business information and contact information with the
other user.
At our discretion, we may share other information to
enable the dispute to be resolved through litigation or alternative dispute
resolution methods.
18.
Service providers and business
partners
We may share your personal data with businesses that
provide services to us, or with business partners.
As examples:
·
we may pass your payment information to our
payment service provider to take payments from you
·
we may use fraud prevention agencies and credit
reference agencies to verify your identity and we may pass your information to
those agencies if we strongly suspect fraud on our website
·
we may pass your contact information to
advertising agencies to use to promote our services to you
19.
Referral partners
This is information given to us by you in your
capacity as an affiliate of us or as a referral partner.
It allows us to recognise visitors that you have
referred to us, and to credit to you commission due for such referrals. It also
includes information that allows us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the
information and of the terms of our relationship.
We expect any affiliate or partner to agree to
reciprocate this policy.
Use of information we collect through automated systems
20.
Cookies
Cookies are small text files that are placed on your computer's hard
drive by your web browser when you visit a website that uses them. They allow
information gathered on one web page to be stored until it is needed for use at a later date.
They are commonly used to provide you with a personalised experience
while you browse a website, for example, allowing your preferences to be
remembered.
They can also provide core functionality such as security, network
management, and accessibility; record how you interact with the website so that
the owner can understand how to improve the experience of other visitors; and
serve you advertisements that are relevant to your browsing history.
Some cookies may last for a defined period of time,
such as one visit (known as a session), one day or until you close your
browser. Others last indefinitely until you delete them.
Your web browser should allow you to delete any cookie you choose. It
should also allow you to prevent or limit their use. Your web browser may
support a plug-in or add-on that helps you manage which cookies you wish to
allow to operate.
The law requires you to give explicit consent for use of any cookies
that are not strictly necessary for the operation of a website.
When you first visit our website, we ask
you whether you wish us to use cookies. If you choose not to accept them, we
shall not use them for your visit except to record that you have not consented
to their use for any other purpose.
If you choose not to use cookies or you prevent their use through your browser settings, you may
not be able to use all the functionality of our website.
We use cookies in the following ways:
·
to track how you use our website
·
to record whether you have seen specific
messages we display on our website
·
to keep you signed in to
our website
·
to record your answers to surveys and
questionnaires on our site while you complete them
·
to record the conversation thread during a live
chat with our support team
21.
Personal identifiers from your
browsing activity
Requests by your web browser to our servers for web
pages and other content on our website are recorded.
We record information such as your geographical
location, your Internet service provider and your IP
address. We also record information about the software you are using to browse
our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the
popularity of the webpages on our website and how we perform in providing
content to you.
If combined with other information we know about you
from previous visits, the data possibly could be used to identify you
personally, even if you are not signed in to our
website.
22.
Re-marketing
Re-marketing involves placing a ‘tracking
technology’ such as a cookie, a ‘web beacon’ (also known as an ‘action tag’ or
a ‘single-pixel GIF’) to track which pages you visit and to serve you relevant
adverts for our services when you visit some other website.
The benefit of re-marketing technology is that we
can provide you with more useful and relevant adverts, and not show you ones
repeatedly that you may have already seen.
We may use a third-party advertising service to
provide us with re-marketing services from time to time. If you have consented
to our use of such tracking technologies, you may see advertisements for our
products and services on other websites.
We do not provide your personal data to advertisers
or to third-party re-marketing service providers. However, if you are already a
member of a website whose affiliated business provides such services, that
affiliated business may learn of your preferences in relation to your use of
our website.
Other matters
23.
Your rights
The law requires us to tell you about your rights
and our obligations to you in regard to the processing
and control of your personal data.
We do this now, by requesting that you read the
information provided at http://www.knowyourprivacyrights.org
24.
Use of our services by children
We do not sell products or provide services
for purchase by children, nor do we market to children.
If you are under 18, you may use our
website only with consent from a parent or guardian.
We collect data about all users of and
visitors to these areas regardless of age, and we anticipate that some of those
users and visitors will be children.
25.
Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our
identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check
that it is done so using SSL by looking for a closed padlock symbol or other
trust mark in your browser’s URL bar or toolbar.
26.
Delivery of services using third
party communication software
With your consent, we may communicate using
software provided by a third party such as Facebook (WhatsApp), Apple (Facetime),
Microsoft (Skype) or Zoom Video Communications (Zoom).
Such methods of communication should secure
your personal data using encryption and other technologies. The providers of
such software should comply with all applicable privacy laws, rules, and
regulations, including the GDPR.
If you have any concerns about using a particular software
for communication, please tell us.
27.
Data may be processed outside the UK
Our websites are hosted in the United Kingdom
We may also use outsourced services in countries outside
the UK from time to time in other aspects of our business.
Accordingly data obtained
within the UK or any other country could be processed outside the UK.
We use the following safeguards with respect to data
transferred outside the UK:
28.
Control over your own information
It is important that the personal data we hold about
you is accurate and up to date. Please inform us if your personal data changes.
At any time, you may contact us to request
that we provide you with the personal data we hold about you.
At any time you may review or update
personally identifiable information that we hold about you, by signing in to
your account on our website.
To obtain a copy of any information that is not provided on
our website you should contact us to make that request.
When we receive any request to access, edit or
delete personal data we first take reasonable steps to verify your identity
before granting you access or otherwise taking any action. This is important to
safeguard your information.
Please be aware that we are not obliged by law to
provide you with all personal data we hold about you, and that if we do provide
you with information, the law allows us to charge for such provision if doing
so incurs costs for us. After receiving your request, we will tell you when we
expect to provide you with the information, and whether we require any fee for
providing it to you.
If you wish us to remove personally identifiable
information from our website, you should contact us to make your request.
This may limit the service we can provide to you.
We remind you that we are not obliged by law to
delete your personal data or to stop processing it simply because you do not
consent to us doing so. While having your consent is an important consideration
as to whether to process it, if there is another legitimate basis on which we
may process it, we may do so on that basis.
29.
Communicating with us
When you contact us, whether by telephone, through
our website or by email, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We may keep personally identifiable
information associated with your message, such as your name and email address
so as to be able to track our communications with you to provide a high quality service.
30.
Complaining
If you are not happy with our privacy policy, or if
you have any complaint, then you should tell us.
When we receive a complaint, we record the
information you have given to us on the basis of
consent. We use that information to resolve your complaint.
If we think your complaint is vexatious or
without any basis, we shall not correspond with you about it.
If your complaint reasonably requires us to notify
some other person, we may decide to give to that other person some of the
information contained in your complaint. We do this as infrequently as
possible, but it is a matter for our sole discretion whether we do give
information, and if we do, what that information is.
We may also compile statistics showing information
obtained from this source to assess the level of service we provide, but not in
a way that could identify you or any other person.
If a dispute is not settled
then we hope you will agree to attempt to resolve it by engaging in good faith
with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we
process your personal data, you have a right to lodge a complaint with the
Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/.
We would, however, appreciate the opportunity to talk to you about your concern
before you approach the ICO.
31.
Retention period
Except as otherwise mentioned in this privacy
notice, we keep your personal data only for as long as required by us:
·
to provide you with the services you have
requested
·
to comply with other law, including for the
period demanded by our tax authorities
·
to support a claim or defence in court
32.
Compliance with the law
Our privacy policy complies with the law in the
United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’)
accordingly incorporating the EU General Data Protection Regulation (‘GDPR’)
and the Privacy and Electronic Communications Regulations (‘PECR’).
33.
Review of this privacy policy
We shall update this privacy notice from time to time as necessary.
Last updated:16/10/2021