Updated August 16, 2023
1. Types of Information We Collect
a. Personal Information that we collect about you. We collect Personal Information about our users. “Personal Information” is information relating to an individual that can be used to contact or identify you or individuals about whom you enter information as part of your activities on our Website or Services, such as first name, last name, phone number, street address, payment information, records of products purchased, comments, company name and address, title, username and/or e-mail address, geolocation, or that we receive about you from a third party, as well as information that is linked to the forgoing information.
b. “Aggregated Information”. After stripping out any information that directly identifies you, or directly relates to you, from the Personal Information that we collect about you, we may combine that information with information we collect about other users.
c. Cookies and Pixel Tags which collect information about users of our Website. We may also use tools such as cookies and pixel tags to gather information as well. “Cookies” are small pieces of information that a website sends to your device while you are viewing the Website. We use both session Cookies (which expire once you close your web browser), persistent Cookies (which stay on your device until you delete them) and third-party Cookies (which are placed by a website from a domain other than ours) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following web browser help file directions. "Pixel Tags" (sometimes called "web beacons" or "clear gifs") are a snippet of code that collects information about a visitor's behavior on a website, and then sends the information back to the originating platform to be processed and reported.
d. Unique Device Identifiers. Like most website providers, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system.
e. User-Provided Information. We collect information that you provide directly to us when you engage in the following:
● When you engage with or participate in our Services and any other products or other offerings made available through the Services, including when you:
○ Register for an account, including when you login in through your Amazon account
○ Sign up for our notifications about new designs, collaborations, special events and more
○ Complete any questionnaires or surveys
○ Utilize the “favorite” feature or add items to a “wish list”
○ Participate in special activities, offers, or programs
● When you communicate with us via e-mail, telephone, video conference, text message, or other methods
● When you communicate or engage with us on our social media accounts (e.g., Facebook, Instagram, LinkedIn
g. Geolocation. If you access the Website through a desktop or mobile device, we will collect, monitor and/or remotely store geo-location data.
h. Third-Parties. We may also obtain information from other sources and combine that with information we collect directly. For example:
● We may also collect information about you from third parties, including but not limited to identity verification services, fraud detection service providers, credit bureaus, and publicly available sources. If you create or log into your account through a social media site or other third party (e.g., Amazon or Google), we will have access to certain information from that site, such as your name, account information and, in the case of social media sites or services, in accordance with the authorization procedures determined by the applicable third party.
● We use third-party services, such as Google Analytics, Google AdWords, Facebook Pixel, and DoubleClick to track and analyze online behavior of our Users. These services may help inform, optimize, target and serve ads based your visits to our Website. We do this to better understand how you use the Website and Service, with a view to offering improvements for all Users, and to tailor our business and marketing activities accordingly.
● When you interact with us through social media networks, such as when you follow us, share content or contact us through Facebook, Twitter, Instagram, YouTube, Snapchat or other sites, we may receive information about you, including your profile information, picture, user ID associated with the social media account, friends list, and any other information you permit the social media network to share with third parties. The data we receive is dependent upon your privacy settings with the social network in question.
2. How We Use Your Information
a. Personal Information. We may use your Personal Information for the following representative purposes:
● Review and process your orders, save your favorited items, and otherwise provide the Services and related functionality to you
● Send communications and administrative e-mails to you
● Satisfy our contractual obligations to you and provide the materials, goods and/or services that you request
● Send you promotional/marketing information, newsletters, events information, offers or other information
● Perform internal operations, processing services, maintain user accounts, resolve disputes, establish, exercise, and defend legal claims, prevent and identify fraud, verify your identity and authenticate users
● Personalize and tailor the features, performance and support of the Services
● Analyze, benchmark and conduct research on user data and interactions with the Services
● Identify your preferences, so we can notify you of new or additional products, services, contests, and/or promotions that might be of interest to you
● Improve our services, content, programs, customer service, and overall user experience by aggregating and analyzing user data
● Analyze the use of our products and services and information about users of the Services to enhance our marketing efforts
● Communicate with you by e-mail, video conferencing, telephone, text message or other means about our company, our products, events, collaborations, or other information that we believe may be of interest to you
● Send you notices of a transactional, administrative or relationship nature, or as required by law
b. Aggregated Information. We may use Aggregated Information for the following representative purposes:
● Perform internal operations on the Services
● Improve the Website and customize the user experience
● Aggregate the information collected via Cookies and Pixels to use in statistical analysis to help us track trends and analyze patterns
c. Targeting. We may use Personal Information and Aggregated Information that we collect to target and measure the performance of advertisements to Users both on and off of the Website on our own and through different ad networks and exchanges, using the following data, whether separately or combined: (i) data from advertising technologies such as Cookies, Pixels, web beacons, ad tags and device identifiers; (ii) User-provided information; (iii) data from your use of the Website; (iv) information from others (e.g., advertising partners, publishers and data aggregators); and (v) social media platforms.
● Performing a contract with you, or to take steps at your request prior to contracting with you
● Protecting your vital interests or the interests of another person
● Complying with our legal obligations
● Pursuing our legitimate interests, including without limitation:
○ Providing, improving and customizing our Website and Services;
○ Administration of our operations;
○ Understanding how our Website and Services are being used;
○ Exploring ways to develop and grow our business;
○ Ensuring the safety and security of our employees and others;
○ Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
○ Meeting our obligations and enforcing our legal rights
4. How We Share and Disclose Personal Information
b. We may disclose your Personal Information to outside individuals and/or companies that help us bring you the services and products we offer and to create, operate, and maintain our Website. For example, we may work with third-parties to: (a) manage a database of customer information; (b) assist in the calculation of sales tax; (c) as necessary to comply with applicable laws (e.g., Americans with Disabilities Act and applicable data privacy and security laws and regulations), (d) assist us in distributing e-mails; (e) assist with direct marketing and data collection; (f) assist with shipping, sales and returns, (g) process payments, (h) provide data storage and analysis; (i) provide fraud prevention; (j) provide customer service; and (k) provide other services designed to assist us in developing and running our Website and/or Services and maximizing our business potential. We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us.
5. Use of Aggregated Information.
a. We use Aggregated Information to maintain and administer the Website, analyze trends, gather demographic information and comply with applicable law. We may share Aggregated Information with third-parties. We may share this information with others without express notice to you or consent from you, and we may, subject to applicable laws, exploit, use and disclose Aggregated Information without limitation of any kind. We authorize certain service providers to utilize Aggregated Information for their business purposes and in accordance with their privacy policies, such as to report on usage or industry trends to their customer base.
c. We may also use Pixel Tags, which help us analyze users' online behavior and measure the effectiveness of the Website and our advertising and marketing. Pixel Tags or Clear gif files are tiny graphics with a unique label that work in a similar way to cookies and are used to monitor the user's online activities. In contrast to cookies that are saved on a user's computer hard disk, clear gif files are embedded invisibly in websites and are about as big as the full stop at the end of this sentence. Where appropriate, we may combine the information collected by such Pixel Tags with the Personal Information of our customers. We may also use other analytical tools to evaluate site performance through the use of aggregated data, which contain no Personal Information. We work with service providers that help us track, collect, and analyze this information.
d. Cookies, Pixel Tags, and/or other analytical tools that we may use on the Website may collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with the Website. This information may include your computer's Internet protocol (IP) address, your browser type, your operating system, date and time information, and other technical information about your computer. We may also track certain information about the identity of the Website you visited immediately before coming to the Website. Cookies, pixel tags, and/or other analytical tools in our e-mails may also be used to track your interactions with those messages, such as when you receive, open, or click a link in an e-mail message from us. We may also work with businesses that use tracking technologies to deliver advertisements on our behalf across the Internet. These companies may collect information about your visits to the Website and your interaction with our advertising and other communications, but no Personal Information is shared with them.
e. We may combine the information collected through Cookies, Pixel Tags and other analytical tools with other information we may have collected from you. This information may be used to improve the Website, to personalize your online experience, to help us deliver information to you, to determine the effectiveness of advertising, and for other internal business purposes. We may use and share aggregated and anonymous information to conduct market research and analysis for ourselves and/or for our business partners. For example, we may freely share such information with third parties who may use such data for their own marketing, advertising, research, or other business purposes. We may also freely share such information with our service providers in order for them to perform services to or for us.
f. The Website contains links to and/or enables certain third-party functionalities to enhance your experience on the Website, including social plug-ins, tools and APIs. Prior to using any third party functionalities (e.g., Facebook “Like” button) on the Website, you should consult the privacy notices of the third party providers of such functionalities (e.g., Facebook). The privacy policies and data practices of such third parties may significantly differ from ours, and we make no representation or warranty whatsoever about their policies and practices in respect of their own processing of your Personal Information. Your communications and interactions with such third parties in respect of their own processing of your Personal Information are solely between you and them and are at your own risk.
6. Data Retention.
b. Where we are processing Personal Information based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.
c. Where we are processing Personal Information as set out in this policy, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Information erased (see Section 8, Deleting, Changing & Updating Your Personal Information).
d. Where we are processing Personal Information based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
b. Google Analytics, Facebook, and Apple. Our products and services may use Google Analytics Advertising Features and its associated tracking technologies to help display and retarget our ads you see on other sites, and to help us manage and optimize our online advertising efforts. To opt out of Google Analytics Advertising Features, visit Google’s Ad Settings page, currently located at https://adssettings.google.com/authenticated. Website users can also access the Google Analytics Opt Out Browser Add-on, currently located at https://tools.google.com/dlpage/gaoptout. We may also work with Facebook and Apple to provide analytics and advertising retargeting in connection with our Website, including our mobile applications.
For more information about Facebook’s privacy practices, visit https://www.facebook.com/about/privacy, and to opt-out you can visit https://www.facebook.com/help/568137493302217.
c. Ad Industry Opt-Outs. You can opt out of Internet-based and mobile advertising on your mobile device by visiting TRUSTe’s Ad Preference Manager, currently available at https://preferences-mgr.truste.com/.
You may can opt out of receiving online behavioral or internet based advertising by using the tools located at the Digital Advertising Alliance’s consumer choice page, currently available at http://www.aboutads.info/choices/ or the Network Advertising Initiative (NAI) opt out tool currently available at http://www.networkadvertising.org/choices/.
When using the ad industry opt out tools, note that: (a) if you opt-out we may still collect some data about your online activity for operational purposes (such as fraud prevention), but it will not be used by us for the purpose of targeting ads to you; (b) if you use multiple browsers or devices you may need to execute this opt out on each browser or device; and (c) other ad companies’ opt-outs may function differently than our opt-out, and we have no control over the practices of any third parties. We do not make any representations or warranties about such opt-out services. Such services are independent from us, and we have no control over, or responsibility for their performance.
9. Notice to Californian Users Regarding Your Privacy Rights
a. Shine the Light. Pursuant to California Civil Code Section 1798.83, also known as the "Shine The Light" law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third-parties. We do not share Personal Information with third-parties for those parties’ direct marketing. To request the above information, California residents can e-mail us at contact us via e-mail at email@example.com or write to us at Sidney Garber Jewelers, Inc., Attn: Privacy Office, 118 East Delaware Place, Chicago, IL 60611. Please note that, under California law, a business is only required to respond to such a request twice in any calendar year.
b. Access To Specific Information And Data Portability Rights. You have the right, subject to certain exceptions defined in the California Consumer Privacy Act, Cal. Civ. Code §1798.100 et. seq. (“CCPA”), and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your personal information over the past 12 months. This right of access includes information about:
● the categories of personal information we collected about you;
● the categories of sources for the personal information we collected about you;
● our business or commercial purpose for collecting that personal information;
● the categories of third parties with whom we share that personal information;
● the categories of personal information that each recipient received; and
● the specific pieces of personal information we collected about you.
c. Deletion Request Rights. You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your personal information that it has collected from you and retained, subject to certain exceptions.
d. Exercising Access, Data Portability, And Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
● E-mailing us at firstname.lastname@example.org; or
● Calling us at 1-877.427.2377
The verifiable consumer request must:
● Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected personal information. This may include requesting that you provide us with at least two or more pieces of personal information to match against personal information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.
● Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
e. Do Not Sell Rights. You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that companies stop selling your personal information and refrain from doing so in the future. You may exercise this right by:
● E-mailing us at email@example.com; or
● Calling us at 1-877-427-2377
We may deny a Do Not Sell request if we have a good-faith, reasonable, and documented belief that the request is fraudulent.
f. Authorized Agent. Only you, or a person you have designated in writing as your authorized agent, or who is registered with the California Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465, (“Authorized Agent”), may make a verifiable consumer request or do not sell request related to your personal information. You may also make a verifiable consumer request or do not sell request on behalf of your minor child.
If you wish to have an Authorized Agent make a request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.
g. Non-Discrimination. You have the right not to receive discriminatory treatment for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
● deny you services;
● charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
● provide you a different level or quality of services; or
● suggest that you may receive a different price or rate for services or a different level or quality of services.
To the extent required by applicable law, California residents may ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request, California residents may contact us as specified in the Contact Us section of this Online Privacy Notice.
h. Do Not Track. Some web browsers may let you enable a "do not track" feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a "do not track" feature enabled may still accept cookies. There is currently no industry standard for how companies should respond to "do not track" signals, although one may develop in the future. We do not respond to "do not track" requests or signals at this time.
This Website is not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Website is targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13. If we later obtain actual knowledge that a User is under 13 years of age we will take steps to remove that User's Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at contact us via e-mail at firstname.lastname@example.org or write to us at Sidney Garber Jewelers, Inc., Attn: Privacy Office, 118 East Delaware Place, Chicago, IL 60611 so that we may delete and remove such information from our system.
We strive to keep your Personal Information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access. Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Website, any transmission of Personal Information by you is at your own risk. We cannot guarantee that such information will not be intercepted by third-parties and we shall not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for circumvention of any privacy settings or security measures contained on the Website.
12. Third-Party Websites
14. Contact Us