Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4 In this policy, “we”, “us” and “our” refer to NewportJewelers.com. For more information about us, see Section 13.

Credit

2.1 This document was created using a template from SEQ Legal.

How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

3.2 We may process data about your use of our website and service (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent or our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, and date of birth. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

3.5 We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include specify data. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, or to enter into such a contract.

3.6 We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

3.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this

processing is consent or the performance of a contract between you and us

and/or taking steps, at your request, to enter into such a contract.

3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data

may include the communication content and metadata associated with the

communication. Our website will generate the metadata associated with

communications made using the website contact forms. The correspondence

data may be processed for the purposes of communicating with you and

record-keeping. The legal basis for this processing is our legitimate interests,

namely the proper administration of our website and business and

communications with users.

3.14 In addition to the specific purposes for which we may process your personal

data set out in this Section 3, we may also process any of your personal data

where such processing is necessary for compliance with a legal obligation to

which we are subject, or in order to protect your vital interests or the vital

interests of another natural person.

Providing your personal data to others

4.1 We may disclose your profile data to any member of our group of companies,

this means our subsidiaries, our ultimate holding company and all its

subsidiaries, insofar as reasonably necessary for the purposes, and on the

legal bases, set out in this policy.

4.5 We may disclose your profile data to one or more of those selected third party

suppliers of goods and services identified on our website for the purpose of

enabling them to contact you so that they can offer, market and sell to you

relevant goods and/or services. Each such third party will act as a data

controller in relation to the enquiry data that we supply to it; and upon

contacting you, each such third party will supply to you a copy of its own

privacy policy, which will govern that third party’s use of your personal data.

Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are

designed to help ensure that we comply with our legal obligations in relation

to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept

for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) emails will be retained for a minimum period of 30 days following email

subscription consent, and for a maximum period of 30 days following

subscription withdrawal.

6.4 In some cases it is not possible for us to specify in advance the periods for

which your personal data will be retained. In such cases, we will determine

the period of retention based on the following criteria:

(a) the period of retention of emails will be determined based on status of

email subscription consent.

6.5 Notwithstanding the other provisions of this Section 6, we may retain your

personal data where such retention is necessary for compliance with a legal

obligation to which we are subject, or in order to protect your vital interests

or the vital interests of another natural person.

Amendments

7.1 We may update this policy from time to time by publishing a new version on

our website.

7.2 You should check this page occasionally to ensure you are happy with any

changes to this policy.

7.3 We may notify you of changes to this policy by email.

Your rights

8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a) the payment of a fee (currently fixed at USD 20); and

(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

8.2 We may withhold personal information that you request to the extent

permitted by law.

8.3 You may instruct us at any time not to process your personal information for

marketing purposes.

8.4 In practice, you will usually either expressly agree in advance to our use of

your personal information for marketing purposes, or we will provide you with

an opportunity to opt out of the use of your personal information for

marketing purposes.

About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that

is sent by a web server to a web browser and is stored by the browser. The

identifier is then sent back to the server each time the browser requests a

page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent

cookie will be stored by a web browser and will remain valid until its set

expiry date, unless deleted by the user before the expiry date; a session

cookie, on the other hand, will expire at the end of the user session, when the

web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a

user, but personal information that we store about you may be linked to the

information stored in and obtained from cookies.

Cookies that we use

10.1 We use cookies for the following purposes:

(a) status – we use cookies to help us to determine if you are logged into

our website;

(b) security – we use cookies as an element of the security measures used

to protect user accounts, including preventing fraudulent use of login

credentials, and to protect our website and services generally;

(c) advertising – we use cookies to help us to display advertisements that

will be relevant to you;

(d) analysis – we use cookies to help us to analyse the use and

performance of our website and services; and

(e) cookie consent – we use cookies to store your preferences in relation to

the use of cookies more generally;

Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your

computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics

gathers information about website use by means of cookies. The information

gathered relating to our website is used to create reports about the use of our

website. Google’s privacy policy is available at:

https://www.google.com/policies/privacy/.

11.3 We publish Google AdSense interest-based advertisements on our website.

These are tailored by Google to reflect your interests. To determine your

interests, Google will track your behaviour on our website and on other

websites across the web using cookies. You can view, delete or add interest

categories associated with your browser by visiting:

https://adssettings.google.com. You can also opt out of the AdSense partner

network cookie using those settings or using the Network Advertising

Initiative’s multi-cookie opt-out mechanism at:

http://optout.networkadvertising.org. However, these opt-out mechanisms

themselves use cookies, and if you clear the cookies from your browser your

opt-out will not be maintained. To ensure that an opt-out is maintained in

respect of a particular browser, you may wish to consider using the Google

browser plug-ins available at:

https://support.google.com/ads/answer/7395996.

Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies.

The methods for doing so vary from browser to browser, and from version to

version. You can however obtain up-to-date information about blocking and

deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-websi

te-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)

https://support.microsoft.com/en-gb/help/17442/windows-internet-expl

orer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f)

https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-p

rivacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many

websites.

12.3 If you block cookies, you will not be able to use all the features on our

website.

Our details

13.1 This website is owned and operated by Lettuce Gather LLC.

13.2 You can contact us:

(a) by email, using [email protected]

(b) using our website contact form;

Data protection officer

14.1 Our data protection officer’s contact details are: [email protected].