PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING OUR WEBSITE

The website www.tracr.com is provided to you by The Diamond Trading Company Limited, trading as Tracr (“we”, “us” or “our”). This privacy policy (“Privacy Policy”) (together with our website terms of use (“Terms of Use”)) applies to your use of the website and sets out the basis on which any personal information that we collect from you, or that you provide to us, will be processed by us. Please read this Privacy Policy carefully to understand our practices regarding your personal information and how it will be treated.

By visiting our website and/or purchasing a product through our website, you agree to the terms of this Privacy Policy as may be amended from time to time.

Tracr™ is a trade mark of the De Beers Group of Companies.

PURPOSES OF PROCESSING YOUR PERSONAL INFORMATION

We process your personal information in order to operate, maintain and provide you with the features and various functionalities of the website. We also process your personal information to provide customer service and support. We will always indicate where the provision of certain information is voluntary and you will be able to withdraw your consent or exercise your rights in relation to this information at any time as described under section 8 of this Privacy Policy.

This means that the legal basis for us processing your personal information as described above will typically be one of the following:

• because it is necessary to fulfil a contract that we have in place with you;
• for our or our third parties’ legitimate business interests;
• your consent; or
• where the processing is necessary for compliance with our legal obligations.

INFORMATION WE MAY COLLECT FROM YOU AND HOW WE USE IT

We may collect and process the following data about you:

Information you give us

We may collect information that you provide to us when you complete forms on our website to request information. This kind of information may include your first name, surname, email address, your involvement in the diamond industry (if applicable), telephone number, company name and address and/or any relevant comments. We will use this information to send you the information that you request and to update you on the evolution of the Tracr platform. And if you contact us with a complaint or query about the website, we may keep a record of that correspondence to ensure we provide a good customer service.


Device information

We may collect information about the computer or device you use to access the website, including, where available, the device's unique device identifiers and operating system. We may associate this with the above information for customer services and system administration purposes and will treat the combined information as personal data in accordance with this Privacy Policy for as long as it is combined.

Log Information

When you use the website, we may also automatically collect and store certain information in our server logs to get a better understanding of how people use the website and to ensure we provide a good user experience and customer service. This type of information includes information about your server’s internet protocol address (i.e. IP address); when, how, and what parts of the website you use; viewed and exit pages on the website as well as date or time stamps.

COOKIES AND SIMILAR TECHNOLOGIES

The website uses cookies and technologies which are similar to cookies. A cookie is a small file of letters and numbers that we may set on your device. This allows us to distinguish you from other users of the website, which helps us to provide you with a good experience when you use the website and also to improve the services provided through it.

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

WHERE WE STORE YOUR PERSONAL INFORMATION

We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. We apply criteria to determine the appropriate retention period for different categories of personal information you provide us with. For example, we will keep information necessary to protect us in a legal claim, such as information relating to a contract, for the lifetime of the contract and up to seven years after. After this period it will be deleted or in some cases anonymised. Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information.

The information that we collect may be transferred to, and stored at, a destination outside the European Economic Area (the “EEA”) in countries, which have less strict, or no data protection laws, when compared to those in Europe. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, for example in the provision of support services. By submitting your personal information, you consent to this transfer, storing or processing of your personal information.

Whenever we transfer your information outside of the EEA, we will take all steps reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this Privacy Policy. If you are located in the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted via the website; any transmission is at your own risk.

YOUR RIGHTS AND ACCESS TO INFORMATION

Data Protection Legislation in the European Union and the UK gives you certain rights in relation to your personal information. These include: the right to object to and / or withdraw consent to the processing of your personal information, the right to access to your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information.

We will handle any request to exercise your rights in accordance with applicable law. If you wish to exercise any of these rights please refer to the “Contact Us” section of this Privacy Policy.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may disclose your personal information to third parties: (a) in the event that we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets; (b) if we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our users will be one of the transferred assets; or (c) if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request.

We may also disclose your personal information: (a) to enforce any part of this Privacy Policy or the Terms of Use or to investigate potential breaches; or (b) to protect the rights, property or safety of us or our users, or others.

We may share your information with our service providers and other third party partners who help us to operate the website and deliver our products and services, for example, website or database hosting companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfilment companies, marketing and promotional companies and other similar service providers. Such parties may process information about you on our behalf to assist, for example, with provision of support services.

We may disclose to our third party partners aggregate, anonymous data regarding user behaviour as a measure of interest in and use of our website. Such data may include overall patterns or demographic reports from which an individual cannot be identified.

CHANGES TO PRIVACY POLICY

We reserve the right to revise this Privacy Policy at any time by amending this page, and your continued use of the website after any such amendments are published on the website will be considered acceptance by you of such amended terms. Updated terms will supersede all previous versions of this Privacy Policy. Please check this page regularly to take notice of any changes we have made, as they are binding on you. The date this Privacy Policy was last updated appears at the bottom.

CONTACT US

Questions and comments regarding this Privacy Policy should be sent to: contact@tracr.com

The Diamond Trading Company Limited, a limited liability company incorporated in England and Wales, with registered number 07816513 and with its registered office at 20 Carlton House Terrace, London, SW1Y 5AN.

You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. For the purposes of European Data Protection Law the data controller in respect of your personal information is: The Diamond Trading Company Limited, trading as Tracr.

This Privacy Policy was last updated on April 30, 2018