What Legal Bases Do We Rely On?
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Where agreed by an individual, consent must be given freely, specifically, unambiguously and in an informed manner
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters.
We’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order an item from us that you wish us to deliver to you, we’ll collect your address details to deliver your purchase and pass them to the courier company that will be carrying out your delivery.
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we may use your purchase history to send you or make available personalised offers. Or we may use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
When Do We Collect Your Personal Data?
• When you visit any of our websites.
• When you make an online purchase and check out as a guest
• When you register a web account with us to make a purchase
• When you engage with us on social media.
• When you’ve given a third party permission to share with us the information they hold about you.
What Sort Of Personal Data Do We Collect?
Non Identifiable Information
As is common, when you visit our website, information is collected from you or your computer that does not identify you personally. These are sometimes referred to as Log Files. These files may include your IP (Internet Protocol) address, your ISP (Internet Service Provider, such as BT), the browser you used to visit or page (such as Internet Explorer, Firefox, Safari etc.), the time you visited our site, the pages you visited and accessed on our website.
These data identifiers do not include any personally identifiable information. We can’t tell who you are, only what you did when you were on our site. We use this information, in aggregate, to determine how many people visit our site, how they found us and if they experienced any problems whilst they were on the site.
We do not collect any personal information from you unless you provide this information to us by entering details onto our website.
The information gathered is generated by the use of your IP address and cookies. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets us know when you visit a site.
Cookies allow web applications to respond to you as an individual; the website can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Cookies also allow our website to “remember” your basket as you move from one page to another or to allow web account holders to login to their web accounts.
A cookie does not give us access to your computer or any information about you, other than the data you choose to share with us. You can choose to disable or selectively turn off our cookies in your anti-virus programme or firewall settings. However, such changes can affect how you are able to interact with our site as well as other websites.
Personally Identifiable Information
When you choose to do so, you may provide us with personal identifiable information such as your name, email address, postal address, phone number etc. This information will be used to process your order, send emails or SMS messages. For your security, if you have opted to create a web account, we also keep an encrypted record of your web account login password. We will also collect notes from conversations with you, items viewed and/or added to your basket, purchase details, brands you show interest in, web pages you visit, complaints made and how and when you contact us and, where applicable, which site you came from to ours.
At no time whatsoever do we collect or store your credit or debit card information on any of our systems. Instead, we use third party Merchant Service providers who process your payment information on our behalf. Immediately your payment details have been processed, they will delete your card information.
If you interact with us though social media channels, we may collect your comments and product reviews and your social media username to help us to respond to your comments, questions or feedback.
The information that you provide to us when placing an order or subscribing to emails is done so entirely voluntarily.
How And Why Do We Use Your Personal Data?
We want to give you the best possible customer experience when visiting us and we want to get the best possible picture that we can of who you are by combining the data we have about you. We then use this to offer you products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the best possible service. If, however, you wish to change how we use your data, you’ll find details in the ‘What Are Your Rights Over Your Personal Data?’ section below.
Please be aware that if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s How We’ll Use Your Personal Data And Why:
• To process any orders that you make by using our websites or in our store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
• To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To protect our business and your web account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your web account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
• With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centre about relevant products and services and so on. You are free to opt out of hearing from us by any of these channels at any time.
• To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
• To comply with our contractual or legal obligations to share data with law enforcement.
• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. You are free to opt out of receiving these requests from us at any time by updating your preferences
• Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). Without sharing your personal data, we’d be unable to fulfil your request.
• We may share information with our suppliers for the purposes of providing you with statutory or additional and/or extended warranties.
• For the purposes of product and consumer safety, should a manufacturer or supplier issue a product recall, we may share information with said manufacturer or supplier to ensure you are informed about the recall without delay.
How We Protect Your Personal Data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. We secure access to all transactional areas of our websites and apps using ‘https’ technology.
All customer information entered via our websites are stored on our secure servers, where it can only be accessed by authorised personnel for the purposes of processing customer orders. Access to your personal data is password-protected, and sensitive data is secured by SSL encryption. We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
We have also installed a mechanism that uses digital server identities so that you can be sure that the website you access is our website. This is done using one of the internet Trusted Certification Authorities. If you access any secure pages of our website, your browser will be provided with an electronic certificate confirming that you have accessed our website and all communications will be encrypted. Firewalls are used to block unauthorised traffic to the servers and the actual servers are in a secure location which can only be accessed by authorised personnel.
How Long Will We Keep Your Personal Data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Who Do We Share Your Personal Data With?
We sometimes share your personal data with trusted third parties, for example, delivery couriers.
We provide only the information they need to perform their specific services. They may only use your data for the exact purposes that we specify in our contract with them.
We work closely with third parties to ensure that your privacy is respected and protected at all times. If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies. For reasons of security and confidentiality, we do not share the names of these organisations with you.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
We may, from time to time, expand, reduce or sell the business and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
International Transfer of Data
We do not currently transfer any data to any third parties working outside of the EEA
We do not knowingly ask for personal information from anyone under the age of 18. If personal information is submitted to us and we know that, or we learn that the person providing the information is under the age of 18, we will not use it for any purpose and will delete the information as soon as possible.
What Are Your Rights Over Your Personal Data?
An Overview Of Your Different Rights
Under the terms of The General Data Protection Regulations 2018 (GDPR) you have the following rights:
• The right to be informed as to what data we collect and hold on you, the individual
• The right of access to the personal data we hold about you
• The right to the correction of your personal data when incorrect, out of date or incomplete.
• The right to erasure
• The right that we stop using your personal data for direct marketing if so required.
• The right that we stop any consent-based processing of your personal data after you withdraw that consent.
• The right not to be subject to automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
• The right to data portability
You can contact us to request to exercise these rights at any time. This is normally termed as a Subject Access Request (SAR). You have certain rights as to how and when a SAR is processed by us.
• In most cases, a SAR will be provided without charge
• We must provide the requested information within 1 (one) calendar month of the SAR being received by us
• If, in our opinion, a SAR is manifestly unfounded or excessive, we can refuse to provide the information requested or charge a fee to provide the information
• We can refuse a request, but we must tell the individual who requests the information the reason for our refusal and also advise them that they have the right to a judicial remedy by complaining to the Information Commissioners Office (ICO). If we choose to take this course of action, we must do so within 1 (one) calendar month of the SAR being received by us
To Ask For Your Information Please Send A Subject Access Request To:
Data Protection Department,
Just Diamonds Ltd.co.uk. Ltd,
33 Tenby Street
or email us at email@example.com
If we choose not to action your request, we will explain to you the reasons for our refusal.
Your Right To Withdraw Consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where We Rely On Our Legitimate Interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Checking Your Identity
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
How Do We Deal With Breach In Your Personal Data?
We have a duty to report certain types of data breaches to the ICO (Information Commissioners Office) however we only have to do so where such a breach is likely to result in a risk to the rights and freedoms of an individual. For example, where such a data breach could result in discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage.
Where such a breach is likely to result in a high risk and freedoms of an individual, we may have to report such breaches to that said individual.
We have effective policies, procedures and systems to detect, report and investigate a data breach but, for reasons of security and confidentiality, choose not to reveal them in this policy
How Can You Stop The Use Of Your Personal Data For Direct Marketing?
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
There are several ways you can stop direct marketing communications from us:
• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
• Write to
Data Protection Department,
Just Diamonds Ltd.co.uk. Ltd,
33 Tenby Street
or email us at firstname.lastname@example.org
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
Contacting The Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)
Links From The Website To Other Sites
Our website 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. Please check these policies before you submit any personal data to these websites.
Updating Your Details
If any of the personal data that you have provided to us changes, please provide us with the correct details by sending an e-mail entitled “Change of details” to email@example.com
Changes To Our Policy
If we change our policy, we will post the changes on this page and we may also place notices on other pages of the website, so that you can check our current policy at any time. If we make any changes that might significantly affect the way we deal with your information, we may also email you to notify you of the proposed changes, so that you may have your details removed from our records if you do not agree with the changes.
forums or accounts.
We welcome your views about our website and this policy. You can contact us as follows:
Telephone: 0121 236 8809
Just Diamonds Ltd
33 Tenby Street
Page last updated 25th May 2018