GDPR - Privacy Notice
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Your privacy is very important to us at QualityDiam, registered diamond dealers located at 55-Hoveniersstraat, 2018 Antwerpen, Belgium, hereinafter also "we" and/or "us" and/or "QualityDiam". To better protect your privacy, we provide this notice explaining our [online] information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage and at every point where personally identifiable information may be requested.
1. General terms
This privacy statement informs you about how QualityDiam collects and manages personal data. In order to offer our products and/or services and their functions, and to improve these products and/or services if needed, it is necessary for us to process certain personal data such as Name, Address, Email address, Phone number, etc.
This information is only collected when voluntarily submitted by you. Additionally, when you subscribe and/or order products and/or services, information required for the sale and delivery of the goods and services is processed and, as far as necessary for the handling and fulfilment of the order and ongoing provision of our services, this information can be disclosed to any of our service providers who are involved in the process.
Furthermore, all information related to the order, including your address, is gathered and processed in the interest of our own marketing purposes. We may for example send you emails to inform you of various opportunities our site has to offer or news about our products and services. This is an 'opt-in' list, which means that you can choose to receive our communication when you give us your contact details.
Finally, note that while we are offering links to other websites we are not responsible for the policies of other companies, so please review their privacy policy should you visit their websites.
2. Contact information
If you have any questions in relation to this privacy statement, please get in touch with us at QualityDiam, Data Protection Officer Mr. N. Mehta, at qd@pandora.be.
Purpose of processing and legal grounds
In the following paragraphs, you can read about the purposes of collecting personal data and the applicable legal grounds.
2.1 Providing our product and our services: First, it will be necessary for us to process certain personal data such as your identification data, financial data, email address, telephone or mobile contact number, in order to provide the products and services that you ordered or to which you subscribed, in the context of delivery of the product and/or service and billing, as well as customer support. This is therefore necessary for performance of our contract with you. If you are ordering and/or subscribing on behalf of an organization, we have a legitimate interest in processing your data as contact details for the performance of the contract.
2.2 Customer management: In order to provide optimal customer experience, we process personal data such as identification data, electronic identification data, for the purpose of customer management. We carry out this processing on the basis of our legitimate interest in knowing our customer and maintaining our relationship with you, with a view to providing a stellar customer experience.
2.3 Anti-money laundering compliance: In order to comply with our "know-your-customer" obligations under applicable Anti-Money Laundering legislation, we process personal data such as identification data,. We carry out this processing on the basis of our legal obligation to verify your identity before engaging a business relationship with you in accordance with the applicable legal requirements.
2.4 Product development and improvement: Naturally we strive to always improve our products and services in order to make them fit our customers' needs. For this reason, and based on our legitimate interest in doing so, we process personal data such as your name, address and email address and draw insights in relation to possible improvements.
2.5 Direct marketing: for marketing purposes we will process personal data such as your identification data and email address and we may contact you in this regard. The legal ground for this processing is our legitimate interest in promoting our products and/or services, within the limits that are legally acceptable [Note: direct marketing can be justified by Company’s legitimate interest in promoting its products, but consent will be required for any marketing by electronic mail (e.g. e-mail, SMS, direct messages on social media, …) that does not meet the double condition of being made (i) to existing customers and (ii) for similar products/services to those products/services for which the customer is already client.], or your given consent where and to the extent required by law (e.g. in relation to specific kinds of electronic mail marketing).
3. Duration
We will process your data as long as necessary to provide our products and services, and beyond such time to the extent legally permitted and based on our legal obligations (e.g. in relation to invoice retention, we are legally obliged to keep invoices for 10 years) or legitimate interests (e.g. in retaining data for the purposes of responding to possible disputes or complaints or for possible reactivation of subscriptions). With respect to our obligations under the applicable anti-money laundering legislation (AML), we are required to store your identification data for 10 years as from the end of the business relationship or as from the date of an occasional transaction. As a result, not all your data will be deleted after the end of the provision of the services, but we limit our processing to what is necessary.
Data transfer
The personal data collected by us may be transferred to any third parties to whom QualityDiam subcontracts all or part of this processing. This may for instance include IT service providers, hosting providers, affiliated companies, financial institutions, public authorities and any other relevant roles. Note that we will never sell your personal information to a third party.
In the event of transfer of personal data to a country outside of the European Economic Area, QualityDiam systematically ensures the application of an adequate level of protection of such personal data by means approved by applicable data protection legislation.
QualityDiam may also, pursuant to a valid legal process (such as a search warrant, subpoena, or court order), allow access to information in our possession, including personal data, in order to comply with such process and to protect our rights and property. If warranted, we may also allow access to this information in special emergencies where physical safety is at risk. We reserve the right to disclose any personal data or other information obtained from or about you, to third parties in connection with a merger, acquisition, bankruptcy or sale of all or substantially all of our assets, to the extent that this is necessary for the process.
4. Your rights
Under EU data protection legislation, you may benefit from various rights as "data subject". You can exercise any of the rights listed hereunder by submitting your request by email to qd@pandora.be. Please include your personal details as well as some means of verifying your identity. Please note that we may reject requests that are excessive or a misuse of the relevant right. Furthermore, your rights may be affected by Anti-Money Laundering laws and regulations by which QualityDiam is bound in the context of our legal obligation to identify you when establishing a business relationship.
4.1 Access right and data portability.
You have the right to access your personal information processed by us, as well as the portability of data you have provided to us to the extent applicable.
4.2 Data accuracy: right of rectification and right to erasure. At all times, you have the possibility to request the rectification or erasure of your personal data, provided that the applicable legal requirements are met. The right to erasure is nevertheless subject to various exceptions, notably as regards personal data whose processing is necessary to support litigation or for compliance with statutory retention requirements. In such a case, however, we limit our processing to the extent possible, even without your request.
4.3 Limits to processing: right to restriction, right to object & consent withdrawal. You have the right, if applicable legal provisions are met, to object to the processing of personal data based on our legitimate interests and to otherwise obtain the restriction of certain forms of processing in specific circumstances. In particular, in relation to the processing of personal data for direct marketing purposes, you have the right to object at any time thereto. Where any processing is based on consent, you have the right to withdraw such consent at any time (without affecting the lawfulness of processing prior to the consent withdrawal). We will in each case examine your request a check whether you meet the requirements for the processing to be stopped.
4.4 Right to lodge a complaint with the supervisory authorities: you have the right to lodge a complaint with the data protection supervisory authority, notably (depending on your place of residence) the Belgian Data Protection Authority (https://www.privacycommission.be/burger/acties/contact).
5. Commitment to data security
In order to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
