Last Updated: September 12, 2024

AJS Creations, Inc., its subsidiaries and affiliates (“AJS”), is redefining diamond jewelry and is passionate about cultivating a more transparent, sustainable, and compassionate jewelry industry.

AJS takes its responsibility to protect your personal information seriously. This includes a commitment to transparency and fairness in relation to our collection and processing of your personal information.

This Privacy Notice provides relevant information about how AJS and affiliated brands may collect and use your personal information when you interact with us, including online, over the phone, and through other means, and how you may exercise your applicable privacy rights.

By interacting with us, you consent to the use of your personal information as described in this Privacy Notice.

UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time-to-time. If we make any material changes, we will revise the date at the top of this Privacy Notice and, in some cases, may provide you with additional notice.

We encourage you to review our Privacy Notice whenever you visit https://www.bespokejewels.com/ (the “Site”) or otherwise interact with us to stay informed about our privacy practices.

COLLECTION OF PERSONAL INFORMATION

We may collect or obtain the following categories of personal information through this Site or by other means, including through any email message, webform, chat box, survey, social media page, event, or other communication or correspondence:

Contact Data	First and last name, email address, postal address, phone number, and other similar contact data
Login Credentials	Passwords and other information for authentication and account access
Demographic Data	Age, gender, and country
Payment and Transaction Data	Data necessary to process your payment if you make a purchase, including your credit card number, and the security code and expiration date associated with your payment instrument (not stored after purchase), shipping and fulfillment information, and details concerning your order
Profile Information	Interests, favorites, wish lists, ring size preferences, and other profile data
Contacts	Data about your contacts in order to fulfill a request by you. For example, when you email a product to a friend or refer a friend to us, we request that you provide names and email addresses for you and your friend to help ensure that your friend will know you have requested that AJS send them an email. The information AJS collects from you and your friend will only be used in ways as set forth in this Privacy Notice. By using this functionality, you acknowledge and agree that you have your contacts’ consent for us to use their contact information to fulfill your request.
Government IDs	Personal identifying information such as an image of your driver’s license or other government-issued identification for fraud prevention purposes. You may also be required to provide government-issued identification numbers such as your social security number for tax reporting purposes in the event that you win a sweepstakes prize
Communications, Testimonials, Feedback, and User-provided Data	Content of messages and communications you send to us, such as feedback and product reviews, including surveys and polls, questions and information you provide to customer support or comments and content that you may post online, and the content of any email, web chat, or web form messages
Telephone Recordings	Telephone recordings when you speak with us or our representatives over the telephone, e.g., telephone orders and customer support
Social Media Data	Information and messages shared with us through social media pages, including your associated profile information
Referral Data	Information about you provided to us from other sources, including your email address
Interaction Data	Information that may be identifiable to you when you access or use the Site or otherwise interact with us, including: Log Data (e.g., IP addresses, referral URLs, date and time, and crash data); Device Data (e.g., information about your device, including type of device, operating system, application IDs, and unique device identifiers); Browser Data (e.g., information about your browser type and settings, language preferences, and cookie data); and Analytics Data (e.g., approximate geolocation, information about your time of access, session and duration, and your interactions with the Site
Recruiting and Job Applicant Data	Information concerning your recruitment and/or application for employment, including resume data, references, education records, certificates, biodemographic information (e.g., race, ethnicity, gender, sexual orientation, nationality, veteran status), trade union membership, citizenship and residency information, SSN, and reputational information, as may be provided by you or through a recruiter, staffing agency, or other referring party, and background check information, as may be provided by you or supplied by a background verification service and/or consumer reporting agencies
Data From Other Sources	Information about you from other sources, including, information from: Data brokers from which we purchase demographic data to supplement the data we collect; Social networks when you reference our Service or grant permission to AJS to access your data on one or more of these services; Financing providers with which we offer financing for purchases, and financial services providers used for processing payments; Firms with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities; Advertising and marketing firms; Publicly-available sources such as open government databases or other data in the public domain.

USES OF PERSONAL INFORMATION

We may use personal information collected about you for the following purposes:

• Presenting the Site and its contents to you;
• Processing and fulfilling transactions and orders, including billing and shipment;
• Managing, operating, and administering our business, including your registration and account;
• Communicating by email, phone, and other means to respond to your comments, questions, and requests;
• Providing you with customer support;
• Sending appointment reminders and confirming or scheduling interactions with us;
• Verifying your eligibility for prizes in connection with promotions;
• Business insights and product development, including improving our marketing and promotional efforts;
• Monitoring and analyzing trends, usage, activities, and tracking interactions;
• Conducting surveys and research on consumer demographics, interests, and behavior;
• Providing and serving advertising on our Site and unaffiliated websites and services;
• Sales and marketing, including developing and sending you direct marketing, such as advertisements and communications about our and other parties’ products, offers, promotions, rewards, events, and services;
• Evaluating and processing applications for employment;
• Detecting and preventing abuse, security threats, and illegal activities, including suspected fraud;
• Complying with applicable legal and regulatory requirements, including legal process and government requests;
• Engaging in corporate transactions involving our business;
• Notifying you regarding updates, security alerts, and changes to the Site, Terms & Conditions, and Privacy Notice;
• For any other purpose disclosed to you or upon your intention, direction, or consent.

COOKIES AND SIMILAR TECHNOLOGIES

We may use various technologies, including small data files placed on your computer or device when you visit the Site, such as “Cookies,” “Pixels,” “Web Beacons,” and similar technologies, including those provided by third parties, with whom your information may be shared. A Cookie file may contain information that can identify you each time you visit the Site. The Site may use Cookies as a way to measure activity and traffic patterns on the Site in order to improve your experience, remember user preferences, monitor usage, compile analytics, and for advertising and marketing purposes. By interacting with our Site, you agree to our use of Cookies.

Your web browser may provide certain features to manage your Cookies settings. Users in certain jurisdictions may also be able to adjust their Cookie preferences through our Site’s Privacy Preference Center, including opting out of certain categories of Cookies. Note that Cookie preferences may only apply to the web browser used at the time your preferences are selected and may need to be reapplied each time you clear your web browser’s Cookie cache.

DO NOT TRACK SIGNALS

Under the California Online Privacy Protection Act (“CalOPPA”), we want to inform you about our “Do Not Track” (“DNT”)request policy. DNT is a feature that some web browsers offer to allow users to send signals to websites so that no information about their browser session will be shared. While we take all reasonable steps to protect your online privacy, we cannot promise that our current Site will address every browser setting or preference. In particular, we have not implemented the necessary programming changes to honor “DNT” browser signals. Please return to this Privacy Notice for further updates on this topic. You can learn more about DNT here: https://www.eff.org/issues/do-not-track

DISCLOSURE OF PERSONAL INFORMATION

We may disclose any category of personal information and Interaction Data to the following categories of recipients for the purposes described below:

Related Entities, Subsidiaries, and Affiliates	We may disclose personal information with related entities, subsidiaries, and affiliates to operate and improve our business, provide customer support, in connection with offering you co-branded products and services, selling or distributing our products, or engaging in joint marketing activities.
Vendors and Service Providers	We may disclose personal information to our vendors and service providers for business and commercial purposes. For example, if we need to ship something to you, we must share your name and address with a shipping company. Vendors also include: web hosting companies, shipping and fulfillment companies (e.g., companies that ship or fulfill product orders), insurance companies, data analysis firms, analytics and advertising technology companies, affiliates, customer service providers, consulting or marketing firms/providers, accounting, bookkeeping or legal firms, financial services firms, technology companies including, but not limited to, web hosting, IT, and enterprise application firms, and firms which provide technologies to enable electronic communications and data storage. Additionally, if you use a credit card or other financing alternative to place an order with AJS, we will use a payment processor to process your information in association with the transaction. We will also share information with other companies and organizations for credit fraud protection and risk reduction. Vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. Information will be disclosed to vendors and other parties in connection with tailoring advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.
Advertising and Analytics Services and Ad Networks	We may disclose personal information to advertising and analytics services providers, advertising networks, and social media platforms to deliver advertising and promote our products and brand.
Special Events Partners	If you participate in a special event (e.g., a promotion), we may share your information with those organizations participating in the applicable event. Typically, these other parties do not use your information for any other purpose other than to manage the event. In some cases, these promotional affiliates may send you promotional materials regarding their products and services.
Recruiting Services Providers	We may disclose personal information to recruiting and staffing service providers to identify job candidates and facilitate the evaluation and processing of applications for employment.
Security, Compliance, and Fraud Protection Partners	We may disclose your personal information as we deem necessary to comply with any applicable law, regulation, rule, legal process or governmental request. We will also share your information in order to investigate, prevent or take action regarding illegal activities, including suspected fraud, or as otherwise required by law. We will also share your information to protect the rights, property, life, health, security and safety of us and/or any person or party.
Corporate Transaction	We may disclose personal information as part of a corporate transaction or investment, e.g., to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets, whether as a going concern or as a part of a bankruptcy, liquidation or similar proceeding.

INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

Your personal information may be transferred to countries other than the country from which it originated. Such countries may have different or less protective privacy and data protection laws than the originating country. Where required, AJS ensures that international transfers of personal information are subject to an appropriate transfer mechanism or consent.

CALIFORNIA PRIVACY NOTICE

This section supplements the Privacy Notice and applies only to residents of the state of California:

Categories of personal information we collect

We may collect, and have collected in preceding 12-months, the following categories of personal information for business and commercial purposes:

Categories of sensitive personal information we collect

From you, directly or indirectly, or from third parties, we may collect, and have collected in preceding 12-months, the following categories of sensitive personal information for business and commercial purposes:

Retention period or criteria

AJS retains personal information for a period commensurate with the purposes for which the personal information was collected or obtained. For example, the criteria used to determine the retention of personal information includes any time necessary to complete a transaction or for legal and compliance, fraud prevention, or security purposes. Personal information may be retained in archival format (e.g., data backups) beyond its retention period so long as it is not subject to further access.

Sale and sharing of personal information

AJS may “sell” or “share” your personal information as described in California Privacy Rights. You may exercise your right to opt-out of the sale and sharing of your personal information by using the methods provided in Opt-out of the sale and sharing of personal information.

Opt-out preference signals

Our Site has been configured to respond to web browser universal opt-out mechanisms, including Global Privacy Control. While we are using industry-standard technologies to comply with universal opt-out mechanisms, given the newness of this technology, including potentially different protocols adopted by web browsers, we encourage you to double check that your opt-out requests are being properly processed by our Site and to notify us at [email protected] if you believe that our Site is not responding to your browser request.

Personal information of minors

AJS has no knowledge of having collected the personal information of minors under 16 years of age.

California Privacy Rights

Under the California Consumer Privacy Act of 2018, as amended, and its respective implementing regulations (the “California Privacy Laws”), eligible California residents may be entitled to certain privacy rights subject to certain limitations, including:

• Right to Know. You may have the right to access the personal information collected about you, the sources from which such information was obtained, the categories of information that have been sold or disclosed for a business purpose, and the commercial purpose for which the information was collected or sold, provided to you in a reasonably portable format.
• Deletion. You may have the right to request that we delete any of the personal information we have collected or maintain about you.
• Correction. You may have the right to correct inaccuracies in your personal information.
• Opt-out of the “Sale” and “Sharing” of Personal Information. You may have a right to opt-out of the “sale” and “sharing” of your personal information.
• Sensitive Personal Information. You may have the right to opt-out of the use and disclosure of your sensitive personal information in certain circumstances.
• Restrict Profiling. You may have the right to restrict the use of your personal information for the purposes of profiling.
• Portability. You may have the right to obtain a copy of certain personal information in portable (e.g., machine readable) format.
• Opt-out of Automated Decision-making. You may have the right to opt-out to certain types of automated decision-making, subject to certain exceptions.
• Non-Discrimination. You may have the right to not be discriminated against in the event you exercise your California privacy rights, such that you will not be denied goods or services, charged a higher rate, or provided with lower quality products or services.

Exercising your rights under the California Privacy Laws

You, or an authorized agent, may exercise your rights by submitting a request at [email protected]. Unless otherwise required by law, AJS will allow two disclosure requests per 12-month period at no cost to you. For subsequent requests, we may charge a fee if we determine that the request is excessive, repetitive, or manifestly unfounded, but will not do so without providing you with a cost estimate before processing your request.

We respond to legitimate privacy requests within 10 days of receipt and process requests within 45 days unless there is cause for an extension. We will notify you with further information if any extension is necessary. Except with respect to requests to “opt-out” of the sale or sharing of personal information, all privacy requests are subject to proper prior verification before processing. Typically, this means you will be required to verify certain pieces of information we maintain about you, such as name, phone number, date of birth, transaction details, or other information. Requests involving a high risk to personal information may require completion of a Sworn Declaration.

If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.

Do not sell or share my personal information

AJS may “sell” or “share,” and has sold or shared in the preceding 12-months, personal information, such as internet or electronic activity information and unique device identifiers, for cross-context behavioral advertising.

Opt-out of the sale and sharing of personal information

To opt-out of the sale or sharing of your personal information, please visit the Preference Center.

Please note that your opt-out choices may apply only to this specific web browser and persist only until the opt-out Cookie is removed or “cleared” from your web browser, e.g., by clearing Cookies in your browser settings.

Your Privacy Rights: California “Shine the Light” Law

AJS does not share personal information, as defined by Cal. Civ. Code § 1798.83, with third parties for their own direct marketing purposes.

U.S. STATE CONSUMER PRIVACY RIGHTS

• Access. You may have the right to access the personal information collected about you.
• Deletion. You may have the right to request that we delete any of the personal information we have collected or maintain about you.
• Correction. You may have the right to correct inaccuracies in your personal information.
• Opt-out of the “Sale” of Personal Information or its Use for Profiling or Targeted Advertising. You may have a right to opt-out of the “sale” of your personal information, profiling, and/or the use of your personal information for targeted advertising.
• Sensitive Personal Information. You may have the right to consent (opt-in) prior to the use and disclosure of your sensitive personal information in certain circumstances.
• Portability. You may have the right to obtain a copy of certain personal information in portable (e.g., machine readable) format.
• Opt-out of Automated Decision-making. You may have the right to opt-out to certain types of automated decision-making, subject to certain exceptions.
• Non-Discrimination. You may have the right to not be discriminated against in the event you exercise your privacy rights.

Exercising your U.S. state consumer privacy rights

You, or an authorized agent, may exercise your rights by submitting a request at [email protected].

Opt-out of the sale of personal information and its use for targeted advertising

To opt-out of the “sale” of your personal information or its use for targeted advertising, please visit the Preference Center.

PRIVACY RIGHTS OF EU AND UK DATA SUBJECTS

• Withdraw Consent. If processing is based on consent, you may have the right to withdraw consent to our processing at any time.
• Access and Rectification. You may have the right to access, correct, and update your personal data.
• Deletion/Erasure. You may have the right to erase and delete your personal data, including the “right to be forgotten.”
• Portability. You may have the right to move, copy, and/or transfer certain personal data from our service to another service.
• Stop Processing. If processing is based on legitimate interests, you may have the right to object to the processing of your personal data and to ask us to restrict the processing of your personal data, subject to certain limitations.
• Submit a Complaint. You have the right to submit a complaint to a data protection authority about our collection and use of your personal data. Contact details for the EU/UK Data Protection Authorities can be found here: EDPB Members. Contact details for the UK ICO can be found here: UK ICO.

Lawful basis of processing

• Legitimate Interests. Where the processing is necessary for the purposes of the legitimate interests pursued by AJS or a third party and not overridden by your rights and freedoms;
• Performance of a Contract. Where the processing is necessary for the performance of a contract with you;
• Consent. Where you have given consent to the processing of your personal data for one or more specific purposes;
• Legal Obligation. Where processing is necessary for compliance with a legal obligation to which AJS is subject.

Exercising your rights under the GDPR

You, or an authorized agent, may exercise your rights by submitting a request at [email protected].

We respond to and process requests promptly and within the timeframes required by the European Data Protection Laws, typically, this means within 30 days from receipt. Please note that all requests are subject to proper prior verification before processing.

If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.

International transfer of EU/UK personal data

Your personal data may be transferred to third countries, including to the United States. By sharing personal information with us, you consent to the transfer of your personal information to such third countries. Where applicable, we have adopted appropriate transfer mechanisms to safeguard the transfer of your personal data in accordance with applicable laws, including the EU Standard Contractual Clauses.

Retention of EU/EEA and UK personal data

AJS retains personal data for a period commensurate with the purposes for which the personal data was collected or obtained. The criteria used to determine the retention of personal data includes any time necessary for legal and compliance purposes. Personal data may be retained in archival format (e.g., data backups) beyond its retention period.

Data protection inquiries

You may contact AJS regarding data protection matters at the following: [email protected]

PRIVACY RIGHTS OF CANADIAN RESIDENTS

• Openness and Transparency. You may have the right to know the personal information we collect about you and the purposes for its collection.
• Access. You may have the right to access personal information we maintain about you, subject to certain exceptions.
• Correction. You may have the right to correct inaccuracies in personal information we maintain about you.
• Deletion. You may have the right to request that we delete personal information we have collected or maintain about you.
• De-indexing. You may have the right to request your personal information be “de-indexed” from certain types of distribution.
• Withdraw Consent. You may have the right to withdraw consent to our use of your personal information, subject to certain exceptions.

Exercising your rights under the Canadian privacy laws

You, or an authorized agent, may exercise your rights by submitting a request to [email protected].

We respond to and process requests promptly and within the timeframes required by the Canadian Privacy Laws. Please note that all requests are subject to proper prior verification before processing.

If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.

Transfer of Canadian personal information

Your personal information may be transferred to third countries where an adequate level of data protection can be ensured. By providing personal information to us, you consent to the transfer of your personal information to such third countries.

PRIVACY RIGHTS OF AUSTRALIAN RESIDENTS

• Know why your personal information is being collected, how it will be used, and who it will be disclosed to.
• Have the option of not identifying yourself, or of using a pseudonym in certain circumstances.
• Ask for access to your personal information.
• Stop receiving unwanted direct marketing.
• Ask for your personal information that is incorrect to be corrected.
• Make a complaint if you think your personal information has been mishandled.

Exercising your rights under the Australian privacy laws

You, or an authorized agent, may exercise your rights by submitting a request to [email protected].

We respond to and process requests promptly and within the timeframes required by the Australian privacy laws. Please note that all requests are subject to proper prior verification before processing.

If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.

Transfer of Australian personal information

Your personal information may be transferred to third countries where an adequate level of data protection can be ensured. By providing personal information to us, you consent to the transfer of your personal information to such third countries.

THIRD-PARTY SITES, BLOGS, AND SOCIAL MEDIA

Our Site includes links to other websites, social media widgets, such as the Facebook “Follow Us” button, and other interactive features, blogs, and videos hosted by third parties whose privacy practices may differ from our own. When you use a link to go from our Site to an unaffiliated website, or interact with any such features, the privacy policies of those respective third parties will apply to the processing of your personal information.

USE BY MINORS

AJS does not knowingly collect personal information from or about minors. Minors should not use the Site or otherwise provide us their personal information. If we learn that we have collected or received personal information from a minor without parental consent, we will delete that information.

SECURITY OF PERSONAL INFORMATION

Taking into account the nature and scope of the processing and the particular risks to personal information, AJS utilizes reasonable technical and organizational measures to help protect personal information. Such measures include, as applicable, the Payment Card Industry Data Security Standards (PCI DSS).

COMMUNICATIONS PREFERENCES

To opt-out of receiving email promotions from AJS, please follow the unsubscribe instructions in our promotional email correspondence or contact us as set forth in the section entitled "Privacy Inquiries" below. Please note that opting out of promotional communications received does not affect our non-promotional communications with you, service messages, orders placed with AJS, or our ongoing business relations.

PRIVACY INQUIRIES

For inquiries concerning this Privacy Notice, you may contact:

[email protected]

877-476-9627

By mail: AJS Creations, Inc., Attn: Legal / Privacy, 4900 Highway 169 N, Suite #307, New Hope, MN 55428