1. Introduction
Welcome and thank you for visiting a website operated by EFA Diamonds Inc. (“deBebians,” “we,” “us” or “our”). We at deBebians take the privacy of all visitors to our websites very seriously. This Privacy Policy (“Policy”) informs you how we handle privacy matters and process your Personal Information. For the purpose of this Policy, "Personal Information" means any Personal Information relating to an identified or identifiable individual. We obtain Personal Information relating to you from various sources described below. “Services” means the design, manufacturing and sale of engagement rings, wedding bands, anniversary rings and custom jewelry.
2. Scope
This Policy applies to the debebians.com and efadiamonds.com websites, their subdomains, and all subdomains or portals that link to this Policy (collectively, “Site”), and all Personal Information that is shared when you visit the Site or interact with our Services. By using the Site, you agree to the terms and conditions of this Policy.
3. Information We Collect
Through our Site and our Services, we may receive information that, alone or in combination with other information, could be used to identify an individual. We may receive information (including Personal Information) in the following ways:
Information That You Provide to Us
When you request information from deBebians or interact with our Site or Services, we may receive the following Personal Information from you:
- Contact information such as your first and last name, job title, email address, business address, shipping address, telephone numbers, mobile numbers; and
- Financial information such as your business credit card or debit card number, bank account information and your payment, service and purchase history.
- If you apply for financing through Variant: other sensitive personal information, such as Social Security number, income information, citizenship status and photo identification. Please note that this information is provided to Variant Financial. You can learn more about Variant’s privacy practices here.
Information Automatically Collected
Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site. This information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device whenever you visit or interact with our Site. Usage Information may include:
· Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
· Your device functionality (including browser, browser language, operating system, hardware, mobile network information);
· Referring and exit web pages and URLs;
· The areas within the Site that you visit and your activities there, including remembering you and your preferences;
· Your device location or other geolocation information, including the zip code, state or country from which you accessed the Services;
· Your device characteristics; and
· Certain other device data, including the time of day you visit our Site or other information used to provide analytics or other usage information.
Information Collected by Third Parties
The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application, such as Shopify. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of the Site from third parties, or information about your orders. These third parties also use cookies and other tracking technologies to capture information about your interactions with the Site. We do not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.
Communications
When you send email or other communications to deBebians, we may keep those communications to process your questions, respond to your requests and improve our Site. We may use your email address to communicate with you about our Services.
4. How We Use Information Collected
We may use your Personal Information for the following business purposes:
1. To provide the products and Services you requested or bought from us.
2. To enhance our products and Services.
3. To operate, maintain, and provide features of the Services.
4. To respond to comments and questions, and otherwise to provide support to users.
5. To understand and analyze the usage trends and preferences of our users.
6. To improve the Services, and to develop new products, services, features, and functionality.
7. To contact you for administrative and informational purposes. This may include providing customer service or sending communications, including changes to our terms, conditions, and policies.
8. For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant or valuable.
9. For our business purposes, such as audits, security, compliance with our internal policies, license agreements with content providers, applicable laws and regulations, fraud and financial crime monitoring and prevention.
10. To enforce our Terms of Use or other legal rights.
5. Use Of Cookies and Other Tracking Technologies
We may use various methods and technologies (“Tracking Technologies”) to store or collect Usage Information, to recognize your browser or device, learn more about your interests to personalize your experience, and deliver our Site and Services to you. These tracking technologies allow us and other third parties to collect information such as your device type, browser type, interactions with our Site, geographic location, your web request, the date and time of your web request, your Internet Protocol address, the domain name of your Internet service provider and other data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information. Tracking Technologies may set, change, alter or modify settings or configurations on your Device. By using this Site, you consent to our use of Tracking Technologies.
First Party and Third-Party Cookies
We use “cookies” (small text files sent by your computer each time you visit our Site) to personalize your experience, analyze user trends, and improve the Services. First party cookies originate from the same domain as the website you’re currently visiting (in this case, deBebians.com or efadiamonds.com). Third-party cookies originate from a domain that’s different from the website being visited, such as Google Analytics, Meta, DoubleClick or others. We don’t control how these third parties use their cookies, so we suggest you check their website to see how they’re using them and how you can manage them.
Types of Tracking Technologies We Use
A few of the Tracking Technologies used on the Site include, but are not limited to, the following (there may be future-developed tracking technology or methods that are not listed here):
- Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Cookies themselves don’t hold Personal Information. They only have a unique alphanumeric identifier that sits on your browser. And in many cases, we won’t be able to link the information we collect by using a cookie back to you. They can, however, enable us to link that information back to you and your personal information, for example, when you log in, or choose to register for a service or a newsletter or buy a product. Our Site may use HTTP cookies, HTML5 cookies and other types of cookie technology to store information on local storage.
- Pixels: A pixel is a small graphic file that allows us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site. These tags may collect the IP address from the device which you loaded the page and the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our Site, and we may use this information in combination with cookies to display targeted advertisements.
- Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.
- ETag, or entity tag. An eTag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
- Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
- Recognition Technologies. These technologies, including application of statistical probability to data sets, attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
- Other data technologies may be used that collect comparable information for security and fraud detection purposes.
We may also engage third parties, such as Google Analytics or Meta, to track and analyze non-personally and personally identifiable website data and to serve advertisements. To do so, we may permit third parties to place cookies on devices of users of our Sites, where permitted by law, and subject to your right to opt out through the Sites. We use the data collected to help us administer and improve the quality of the Sites and to analyze the Site’s usage. Such third parties may combine the information that we provide about you with other information that they have collected.
We classify our cookies into the following categories:
- Essential/Strictly necessary cookies. These cookies are essential for you to browse the Sites and use its features, such as accessing secure areas of the site. You cannot disable this type of cookie on our Site.
- Functionality cookies. Also known as “preference cookies,” these cookies allow the Sites to remember choices you have made in the past, like what language you prefer, or what your username and password are so you can automatically log in. Disabling these cookies can cause some parts of the Site to not work properly, so we discourage you from disabling these cookies.
- Performance cookies. Also known as “analytics cookies,” these cookies collect information about how you use a website, like which pages you visited, and which links you clicked on. Their purpose is to improve website functions. This includes cookies from third-party analytics services. In some jurisdictions, you may be able to turn these cookies off.
- Targeting and Advertising cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always from third parties. In some jurisdictions, you may be able to turn these cookies off.
There are many ways to control cookies. For example, you can alter the configuration of your browser to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Site. In so doing, we may not be able to recognize your computer or device, and you may need to log in every time you visit. You can also opt out of non-essential cookies by opting-out of cookies in our Site’s cookie preference center or enabling an opt-out preference signal on your browser (a Global Privacy Control (“GPC”) or an Opt-Out Preference Signal (“OOPS”).
To control the use of cookies on most of the popular web browsers, you can use the links below to modify your web browser’s settings:
Our Use of Google Analytics and other Advertising Features
We use certain integrated services that require Google Analytics to collect data for advertising purposes, including the collection of data via advertising cookies and identifiers.
With respect to these advertising features, Company is the sole controller under all applicable data protection legislation. We will not identify users or facilitate the merging of Personal Information with additional information collected through any Google advertising product or feature unless we have your affirmative opt-in consent to that identification or merger.
You can opt out of Google AdWords Remarketing here.
You can block Google Analytics from accessing your online activity with a browser add-on here.
Separately, you can change your Facebook Ad Preferences here.
General Cookie Information
To generally find out more about cookies, visit this site which also has instructions on how to opt out of targeted advertising cookies here. More opt-out resources are also available from the Digital Advertising Alliance or the Network Advertising Initiative. We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs. Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective. We always do our best to honor your choices, but because some choices are set at the browser or device level, you may have to make these choices multiple times if you use different browsers or different Devices.
6. How We Share Your Personal Information
We may share your Personal Information as follows:
· With our affiliates and subsidiaries for the purposes described in this Privacy Policy.
· With business partners or advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you.
· With our business partner, Variant Financial, which provides financing for buying our products.
· With our third-party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other Services.
· With a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).
· If required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
We may also share Personal Information about you with other third parties with your permission. We may use and disclose aggregate information that does not identify or otherwise relate to an individual for any purpose unless we are prohibited from doing so under applicable law.
7. Security
deBebians has developed or engaged technical and organization measures designed to protect Personal Information against unauthorized access or misuse. However, the Internet cannot be guaranteed to be fully secure and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.
8. Visitors to the Site Outside of the United States and Canada
Our Site is not intended for users outside of the United States and Canada. This Site is operated in the United States and intended for users in the United States and Canada only. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using this Site and providing us with information, you consent to this transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as those in the European Union (“EU”). Our service providers use appropriate safeguards to transfer your Personal Information to the United States.
9. Retention Of Personal Information
deBebians will retain your Personal Information only for as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
All information you provide to us is stored on our secure servers or those of our third-party data storage providers.
10.Your Privacy Rights
Where applicable, you may be able to exercise the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.
We do not currently meet the threshold for the application of the California Consumer Privacy Act (CCPA). However, depending upon your jurisdiction of residency, you may have the following rights:
· Right to access. You may have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
o Categories of Personal Information we have collected about you and to which third parties these categories have been disclosed, sold or shared;
o Categories of sources from which the Personal Information is collected;
o Our business or commercial purpose for collecting or selling Personal Information;
o Categories of third parties with whom we share Personal Information;
o Specific pieces of Personal Information we have collected about you;
o Categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and
o Categories of Personal Information about you that we disclosed for a business purpose.
· Right to delete. Subject to certain limitations, you may have the right to delete Personal Information that we collect about you.
· Right to correct. You may have the right to correct Personal Information that we collect about you.
· Right to opt-out. You may have the right to opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
· Right to Limit the Use or Disclosure of Sensitive Personal Information. We do not use Sensitive Personal Information for reasons other than those listed in the CCPA.
· Right to Non-Discrimination. We may not discriminate against you because you have exercised any of the aforementioned rights, including by denying you goods or services; charging different prices or rates for goods or services; providing you a different level or quality of goods or services; or suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services.
11.Data Sharing For Direct Marketing Purposes
California Civil Code § 1798.83 permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at general@debebians.com.
12.Your Canadian Privacy Rights
Canadian laws provide specific privacy rights to our Canadian customers. If you are a resident of Canada, this section applies in addition to all other applicable rights and information contained in this Policy.
Where applicable, We follow applicable Canadian federal and provincial privacy laws (“Canadian Privacy Law”), including:
- The Personal Information Protection and Electronic Documents Act (PIPEDA)
- Alberta’s Personal Information Protection Act (Alberta PIPA)
- British Columbia’s Personal Information Protection Act (BC PIPA)
- Québec's Act respecting the protection of Personal Information in the private sector (Québec Act).
Consent
In most cases, we rely on implied consent to collect, use, or disclose your Personal Information. In some circumstances, including those involving sensitive Personal Information, we obtain express consent. Where you have provided your consent to the collection, use, and transfer of your Personal Information (whether orally, in writing, or electronically), you may have the legal right to withdraw your consent under certain circumstances. In addition to the methods described above with respect to your privacy choices, you may withdraw your consent by submitting a request using the information in the “Exercising Your Privacy Rights” section below. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time of your request to help you with your decision.
Use of Your Personal Information
We will not collect, use, or disclose Personal Information except for the identified purposes identified above, unless we have received additional consent or the processing is authorized without consent. Where we engage service providers who utilize the Personal Information we provide to them, those relationships are governed by a written agreement regarding the confidentiality of your information.
Canadian Access and Challenge Rights
Canadian Privacy Law provides the right to receive information about the existence, use, and disclosure of your Personal Information and be provided access to that information. You may also challenge the accuracy and completeness of your Personal Information and have it amended as appropriate. Depending on the nature of the challenged information, amendment may involve correction, deletion, or addition of information.
Exercising Your Canadian Privacy Rights
If you have an account with us, you may view and update your account information by logging into your account. To submit a request for access to information not contained within your account, or to challenge the accuracy or completeness of your Personal Information, you may also submit a written request using the information in the “Exercising Your Privacy Rights” section below. When submitting a request, we also may require you to confirm your identity and your residency to obtain the information. For emails, please include “Canadian Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a Canadian resident, and provide your province of residence. We will begin processing your request once you have completed the verification process and will respond within the time-frame required by law.
If we cannot substantively respond to your request in a timely manner, we will notify you and state the reason for the delay. Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort. However, we will respond to your request within a reasonable time, as required by law, and provide an explanation.
Additional information about how to exercise your rights under Canadian Privacy Law can be found here:
Office of the Privacy Commissioner of Canada
Website
Phone: 1-800-282-1376
Office of the Information and Privacy Commissioner of Alberta
Website
Phone: 1-888-878-4044
Edmonton office: (780) 422-6860
Calgary office: (403) 297-2728
Office of the Information and Privacy Commissioner of British Columbia
Website
Vancouver: (604) 660-2421
Elsewhere in BC: (800) 663-7867
Commission d'acces a' l' information du Quebec
Website
Phone: 1-888-528-7741
13.Exercising Your Privacy Rights
If applicable, you may exercise any of your rights by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name and email address in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency to obtain the information.
Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.
Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows:
deBebians
611 Wilshire Blvd.
Suite 909
Los Angeles, CA 90017
E-mail: general@debebians.com
Telephone: 213-627-1300
14.Children’s Privacy
Our Services and Site are not directed at children under 18 years of age, and we do not knowingly collect or receive Personal Information from them. If we learn that we have received Personal Information from a child who is under 18, we will delete the data. If you believe that we have received Personal Information from a child under the age of 18, you may contact us at general@debebians.com.
15.Do Not Track Signals
Our Site currently does not respond to Do Not Track (“DNT”) signals and operates as described in this Policy, whether or not a DNT signal is received.
16.Global Privacy Control
Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. In certain jurisdictions, when we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.
17.Changes To This Privacy Policy
We may change this Privacy Policy at any time. We will post all changes to this Privacy Policy on this page and will indicate at the top of the page the modified Policy's effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy Policy. If required by the applicable law, we will notify you of the changes. By continuing to use the Site and/or the Services or providing us with information following such a replacement Policy being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Policy as changed.
18.Contact Us
If you have any questions regarding this Privacy Policy, please contact us at:
deBebians
611 Wilshire Blvd.
Suite 909
Los Angeles, CA 90017
Email: general@debebians.com
Phone Number: 213-627-1300