Privacy Policy (14 January 2021)

We are De Beers India Private Limited. We are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect will be processed, used, and shared by us. Please read this privacy policy carefully to understand our views and practices and your rights regarding your personal data. By visiting our website or by using our services, your personal information will be processed as described in this policy. If you are a supplier, authorised jeweller or other business stakeholder of Forevermark or the De Beers Group, please also see the De Beers Group privacy notice for information about how your personal data is processed.

Your use of the site (including accessing, browsing or registering to use the site) confirms your unconditional agreement to be bound by this privacy policy and is subject to your continued compliance with its terms.

What information do we collect from you?

We will collect and process the following data about you:

    • Information that you provide by filling in forms on our sites. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services including, for example, name, home and/or business address, e-mail address, telephone number, demographic information such as age and/or other information that may identify you as an individual, username and password if you create an account on our site and such other information as may be necessary for the purposes identified in this policy. We may also ask you for information when you enter a competition or promotion sponsored by us, sign-up for e-mail newsletters and when you report a problem with our site.
    • If you contact us, we may keep a record of that correspondence.
    • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
    • Details of (if applicable) transactions and appointment bookings you carry out through our site and of the fulfilment of your orders, including payment information that is collected and handled by our payment processing vendors.
    • Any other data you may provide to us in connection with our services and/or our site, including but not limited to:
      • information you provide when you compile wishlists or other gift registries;
      • information you provide when you use interactive areas of our site;
      • information you provide when using the ‘Account’ features, including the ‘My Details’, ‘Register My Diamonds’ and ‘Marketing Preferences’ features;
      • e-mail addresses of your friends and others that you give us in relation to a service; and
      • pictures, videos and messages which you submit to us either via our social media sites (including by use of hashtags associated with us) or our site.
    • Information collected from your use of our website or other digital services:
      • Details of your visits to our site and information generated in the course of the use our site (including the timing, frequency and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise as set out in this policy, and the resources that you access;
      • We will collect information about how you interact with our advertisements and newsletters, including whether you open or click links in any correspondence. If you do not interact with our communications for a period of time, we will use this information to assess whether to continue to send you communications;
      • We may collect information about the device you use to access our website or digital services, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns. We use this information for internal system administration, to help diagnose problems with our server, and to administer our site. Such information may also be used to gather broad demographic information, such as country of origin and internet service provider. Any or all of activities with regard to our site usage information may be performed on our behalf by our service providers (see the Service Providers section below).
      • We also may acquire information about you, from publicly available sources, social media platforms, and other parties that may share information as permitted in their privacy policies.
      • We may combine information collected as described above with information available from other sources (such as other platforms, service providers, analytics services, or publicly available information). If the combined information is maintained, used or shared in a manner that associates it with your name or contact information (online or offline), we will treat such information as your personal data.
    • Our server automatically collects data about your server’s internet address when you visit us. This information, known as an Internet Protocol address, or IP Address, is a number that’s automatically assigned to your computer by your internet service provider whenever you’re on the internet. When you request pages from our site, our servers may log your IP Address and sometimes your domain name. Our server may also record the referring page that linked you to us (e.g., another website or a search engine); the pages you visit on our site; the website you visit after our site; the advertisements you see and/or click on; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on our site or a referral site; and other web usage activity and data logged by our web servers.

To the extent permitted by law, it will be necessary for us to verify the details you have supplied. Such verification could be done through third party service providers, who shall be bound by the obligation of confidentiality and data protection.

 

Social Media

We may also use personal data we obtain from social media (for example, Facebook, Instagram, Twitter, YouTube and WeChat to display on our site, our social media pages and for our (and our businesses’) research and analytics purposes. This is usually personal data that you submit to us (e.g., on our site or our social media pages) or you bring to our attention using hashtags or tagging relating to us, our business, our industry and our interests.

Cookies

We use cookies and similar technologies as set out in our Cookies Policy.

Your browser or device may include “Do Not Track” functionality. At this time, Forevermark does not respond to browser “Do Not Track” signals; however, we reserve the right to do so in the future.

Why do we collect this information?

We process your personal information for the following reasons:

  • To fulfil our promise to you where we agree to provide you with our products and services in order to:
    • process information at your request to take steps to enter into a contract for sale or for services;
    • provide you with our products and services, including the 'Register My Diamond' service;
    • process payments;
    • make deliveries;
    • maintain business and service continuity;
    • send service communications so that you receive a full and functional service and so we can perform our obligations to you. These may be sent by e-mail or post or, if the circumstances require it and you have agreed, we may contact you by phone or text message. These text messages may be sent manually or by using automatic dialing technology. By providing your phone number, you consent to receiving autodialed text messages. These will include notifications about changes to our service and record information to facilitate your rights under our guarantees and warranties.
  • On the basis of your consent:
    • Where we rely on your consent for processing this will be brought to your attention when the information is collected from you or be a result of a request by you, such as you choosing to share your wishlists or gift registry;
    • To display your messages/captions, photos and/or videos (which may include 'likes', comments or other reactions to such messages/captions, photos and/or videos) on our site
    • We will contact you with direct marketing communications if you consent to us doing so and you have the right to withdraw consent, by a notice in writing, at any time. Where you have consented to receiving marketing and promotional communications by text messages and phone calls, these may be sent manually or by using automatic dialing technology. Your consent to receive autodialed marketing text messages is not a condition of making a purchase or receiving services from De Beers India Private Limited. See the What are your rights? section below for more information.

  • To provide you with the best service and improve and grow our business (our legitimate interests) we will process information in order to:
    • provide you with a personalised service;
    • respond to your queries and to provide guidance about our products and stockists;
    • improve our products and services;
    • keep our site and systems safe and secure;
    • protect our customers and business against payment fraud;
    • understand our customer base and purchasing trends;
    • tailor advertising to you;
    • create custom audiences on social media sites based on your information and engagement with us so we can target our advertising to similar audiences;
    • defend against or exercise legal claims and investigate complaints; and
    • understand the effectiveness of our marketing.

We will also carry out analytics either ourselves or using third parties (including but not limited to Adobe and Google analytics) to improve our products and services as set out above.

You have the right to object to processing carried out for our legitimate interests. See the What are your rights? section below for more information.

  • To comply with legal requirements relating to:
    • the provision of products and services;
    • data protection;
    • health and safety;
    • anti-money laundering;
    • fraud investigations;
    • assisting law enforcement; and
    • any other legal obligations placed on us from time to time.
 

How long do we keep hold of your information?

  • We will keep information about you for as long as we need; we need it for our legitimate interest in accordance with applicable law, to fulfill your registration and application process and to perform services as you have opted for, or to meet legal requirements, after which we will take steps to delete your personal data or hold it in a form that no longer identifies you.

Who might we share your information with?

For the purposes set out in the ‘Why do we collect this information?’ section above, we will share your personal information with:

  • the following categories of third parties, some of whom we appoint to provide services, including:
    • business partners, subsidiaries, suppliers and sub-contractors for the performance of any contract we enter into with you, including jewelers, payment processing vendors and fraud prevention agencies.

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      (such as website or database hosting companies, address list hosting companies, email and other messaging service providers, distribution companies, fulfilment companies and other similar service providers that use such personal data on our engagement).

    • analytics and search engine providers that assist us in the improvement and optimisation of our site, including through the use of persistent identifiers to track your internet usage across other websites and mobile applications in their networks.

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      (such as analytics companies, social media management and analysis providers, social media companies that provide advertising, media, marketing and advertising companies and other similar service providers that use such personal data on our engagement).

    • Customer survey providers in order to receive feedback and improve our services.
  • any member of our group of companies (see list below). In particular, De Beers Forevermark Ltd is also a Controller of your data and is registered with its local data protection regulator, the Information Commissioner’s Office whose contact details may be found at https://ico.org.uk/global/contact-us/
  • marketing agencies, media agencies and analytics providers in the form of aggregate statistics regarding user behaviour as a measure of interest in, and use of, our site and marketing e-mails in the form of aggregate data, such as overall patterns or demographic reports. These third parties will not be able to relate this data to identifiable individuals.

Additionally, we will disclose your personal information to the relevant third party:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • If we are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation. We reserve the right to share your personal data to respond to duly authorised information requests of governmental authorities or where required by law. In exceptionally rare circumstances where national, state, or company security is at issue, we reserve the right to share our entire database of visitors and customers with appropriate governmental authorities. We may be required to disclose your personal data in the event of a legal investigation or any such other process or where we have to establish our legal rights or where disclosure is required to prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person. We may also be required to disclose your personal data in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our customers, our regulator, or others. This may in some circumstances include exchanging information with other companies and organisations for the purposes of fraud protection and prevention of money laundering and credit risk reduction.

 

How is your data stored and kept secure?

At De Beers India Private Limited, we take your safety and security very seriously and we are committed to protecting your personal and financial information. All information kept by us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and we recommend that you choose a complex password and change your password every three months.

While we have implemented reasonable technical and organisational precautions such as firewalls, antivirus software and data encryption to protect the security and integrity of personal data provided to our site, due to the inherent nature of the internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the internet (which transmission is at your own risk) or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. We do however maintain physical, electronic and procedural safeguards to protect your personal data.

Your personal data will be processed in or accessed from jurisdictions outside India by members of Forevermark group entities and categories of third-parties in jurisdiction that do not have equivalent data protection laws to those in India for the purpose outlined above. When we transfer your personal data to outside India in any way, we will take steps to ensure that your privacy rights continue to be protected, as outlined in this privacy policy and in accordance with the Information Technology Act 2000 and the rules made thereunder (“IT Act”) to safeguard the transfer, unless we transfer the data to third party that has implemented applicable data protection laws including the IT Act, in which case, we may rely on one of those mechanisms to safeguard the transfer. If you use the platform while you are outside of India, your personal data may be transferred outside India to provide you with these services.

More specifically, we may transfer your data to your local Forevermark entity within our group of companies for the purpose of managing our relationship with you and for the purposes outlined in this policy.

A list of local Forevermark entity locations can be found here:

Forevermark entity

Address

Forevermark Limited (UK)

17 Charterhouse Street, London, EC1N 6RA, UK

Forevermark China

Suite 4608, The Park Place, No. 1601, Nanjing West Road, Shanghai 200040, China

Forevermark KK (Japan)

Yebisu Garden Place Tower 30F, 4-20-3 Ebisu, Shibuya-ku, Tokyo, 150-6030, Japan                                                                 

Forevermark Hong Kong

26/F Kinwick Centre, 32 Hollywood Road, Central, Hong Kong

De Beers India Private Limited

TCG Finance Centre, 6th floor, C-53, G Block, Bandra Kurla Complex, Bandra ( East), Mumbai 400098, India

Forevermark US Inc

300 First Stamford Place. Stamford, CT, 06902,  USA

 
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

What are your rights?

By creating an account, you agree to receive transactional and informational e-mail messages. By subscribing to our newsletter, you agree to receive promotional or marketing e-mails. By requesting marketing e-mails or texts, you agree to receive marketing emails or texts. Push notifications will involve mobile notification and acceptance before they are sent.

Where processing of your personal data is based on consent, you can withdraw that consent, by notice in writing, at any time. However, if you asked to withdraw your consent, to us processing your data, this will not affect any processing which has already taken place at that time.

You have the following rights.  You can exercise these rights at any time by contacting us at support@forevermark.com or De Beers Forevermark Customer Services, 20 Carlton House Terrace, London, SW1Y 5AN.  You have the right:

  • to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes;
  • To ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;
  • To ask us not to process your personal data for scientific or historical research purposes, where relevant, unless the processing is necessary in the public interest;
  • to request from us access to personal information held about you or copy of your personal data;
  • to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
  • to ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation or the data is children’s data and was collected in relation to an offer of information society services;
  • to ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing);
  • to ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract.

These rights may be limited, for example, if fulfilling your request would reveal personal data of another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us using the contact details above or by updating your information in your account details. In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the applicable authority.

Other websites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or content contained on those sites. Please check these policies before you submit any personal data to these websites.

Changes to our Privacy Policy

This policy may be updated from time to time. Any changes to this privacy statement will become effective upon posting. Your continued use of the services following these changes means that you accept such revisions. If we make any material changes to this privacy statement, we will post the changes here and communicate with you in the manner and to the extent required by law. Please check back frequently to see any updates or changes to our privacy policy.

Children's Information

Our sites and services are not directed toward persons under 18 years of age. We do not knowingly market to or collect any personal information from children under the age of 18. If you are under 18, you are not permitted to submit any personal information to us. If you provide information to us, you represent that you are 18 years of age or older. If a parent or guardian believes that we have in our database the personal information of a child under the age of 13, please contact us immediately at support@forevermark.com  and we will promptly remove such information from our records.

Contact us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@forevermark.com or De Beers Forevermark Customer Services, 20 Carlton House Terrace, London, SW1Y 5AN. Our compliance officer can be contacted at dataprotection@angloamerican.com. Our grievance officer can be contacted as mentioned below:

Name of the Grievance Officer: Merwyn Mascarenhas

E-mail: Merwyn.Mascarenhas@debeersgroup.com (with a copy to dataprotection@angloamerican.com)

Landline: +91 (022) 67865591

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