PRIVACY POLICY

Introduction

As a fine jewellers, we know that our relationship with you is built entirely upon trust. This important duty of care extends to how we collect, handle, process and store your personal information, both online and offline.

Our Privacy Policy is provided below and sets out the basis on which we will process and protect any personal data we collect from you or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Data Controller and Governing Law

• The Website www.JuliaPharo.com (“Website”) is owned and operated by Julia Pharo Jewellery (“we/us/our”).
• Our contact information may be found on the Contact Us page of the Website detailed here.
• We undertake to fully comply with data protection legislation as applied in The Republic of South Africa.
• The terms of this Privacy Policy (and any dispute, controversy, proceedings or claims of whatever nature in relation to them) shall be governed and interpreted in accordance with the Law of the Republic of South Africa and the Courts of the Republic of South Africa shall have exclusive jurisdiction in relation thereto.
• By interacting with and/or using the Website, you indicate your acceptance of the terms of the Privacy Policy and that you agree to abide by them. If you do not agree to this Privacy Policy, please refrain from using our Website.

Information We May Collect From Or About You

We may collect and process the following data from or about you:

• Information that you provide by filling in forms or using interactive services on our Website, via our social media channels or other electronic means, by telephone, or in person by visiting our studio or attending our events. The information you give us may, as well as other information, include your name, postal and/or physical address, email address and telephone number, as well as any financial information you provide to us to enable us to process payments and transactions that you may request us to undertake. No financial information (including, but not limited to, bank account details or bank card information) will ever be requested by us via the Website. You must not provide your banking details (or other sensitive, private or restricted data) in any online form found on this Website nor in any email that you send to us.
• Information about your computer (or other electronic viewing device) including, where available, your IP address, operating system and browser type for the purpose of system administration and to analyse our client base by aggregating such data into anonymised reports. Such anonymised data does not personally identify any individual. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will treat this combined data as personal data which will be used in accordance with the Privacy Policy.
• Electronic, telephonic and written records of any correspondence or communication between us.
• Details of interactions you carry out through our Website, at our studio, at our events or by other means, including the fulfilment of any commission you may request we undertake and any subsequent communications regarding your interactions with us.
• Details of your visits to our Website including, but not limited to, traffic data, location data and other communication data, as well as the resources that you access while visiting our Website.
• Details of your visits to our studio or our events.
• Closed circuit television recordings within our studio and at our events and recordings of your Virtual Studio sessions with us for the purposes of quality control, safety, security and crime prevention.

The above list is not exhaustive but we do not routinely collect any “special categories” of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health or genetic/biometric data), nor do we collect any information about criminal convictions and offences. If we need to process any such data for a particular purpose we will explain this to you at the time and will gain your consent prior to such processing.

How We Use Your Personal Information

We will only use your personal data when the law allows us to do so and relying on a relevant basis for lawful processing in each instance. We will use your personal data in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into with you.
• To provide you with information, products or services that you request from us.
• To carry out our obligations arising from any contracts entered into between you and us.
• To ensure that content from our Website is presented in the most effective and user-friendly manner for you and for your computer (or other electronic viewing device).
• To provide you with information and news of jewellery, events or services that we feel may interest you, (where you have consented to be contacted for such purposes to the extent consent is required by law).
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service.
• To maintain a basic amount of information about you and your correspondence and purchase history, in order to provide you with a high standard of client service tailored to your specific tastes, requirements and expectations.
• To note any special occasions/anniversaries of which we may be aware. Please note that if you provide us with any personal data relating to relatives, partners or other individuals it is your duty to make such persons aware that their personal data has been shared with us and to provide them with appropriate information about how their personal data may be processed by us.
• To retain basic transaction details for the purposes of satisfying any legal, accounting or reporting requirements.
• Where you have provided your consent for us to do so, to use certain non-essential cookies delivered to your computer from our Website. You have the right to withdraw consent to such use at any time by contacting us but please note that by withdrawing your consent some or all parts of our Website may no longer be accessible to you or function as expected.
• To send you direct marketing communications via email or postal services (where you have consented to be contacted for such purposes to the extent consent is required by law). You have the right to withdraw consent to such use at any time by contacting us. Please note we will keep a record of your name and contact information on our Suppression List if you request that we do not send you direct marketing materials.

Authorised Disclosure Of Your Personal Information

We may disclose your personal information to authorised third parties under the following conditions:

• Where we use third party service providers to assist with order fulfilment or otherwise to provide support services to us.
• In the event that we sell or buy any business or assets, in which case personal data held by it about its clients and customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms of Use and other agreements, or to protect our rights, property or safety, or those of our clients, third party service providers or others. This includes exchanging information with other companies, organisations and authorities for the purposes of fraud prevention and credit risk reduction.

We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will never sell your personal data to a third party for any reason.

Data Storage, Access, Safeguards & Retention Period

All digital information you provide to us is stored on our secure servers or those of our authorised third party Data Processors.

Records of information you provide to us at our studio or at our events (including financial information related to purchases) will, under normal circumstances, be created in hard copy format then also as electronic files.

All bank card payment transactions (in person at our studio or at our events) will be encrypted and securely transmitted via our appointed Data Processor using SSL encryption and other security technologies. Please note that there are no e-commerce (online sales) activities conducted on this Website.

The data that we process about you may be transferred to, and stored at, a data centre outside the Republic of Africa including where our third party service providers are operating outside this region.

Your personal data may also be processed by persons or entities operating outside the Republic of South Africa who work for us or for one of our third party service providers. By submitting your personal data, you agree to this transfer, storing or processing of data outside the Republic of South Africa. We will take all reasonable steps necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Whenever we transfer your personal data out of the Republic of South Africa, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

• We may transfer your personal data to countries that have been deemed to provide a high level of protection for personal data.
• Where we use service providers based in the United States, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide a high level of protection to personal data shared to organisations in the United States.

We have put in place appropriate physical and electronic security measures intended to help prevent your personal data from being lost or from being altered, disclosed, used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, contractors and other authorised third parties who have a business need to know this information. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to or from our Website or via other forms of electronic communications. Any data transmission is at your sole risk. Once we have received your information, we will use strict procedures and security measures designed to prevent unauthorised access.

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, as well as the applicable legal requirements. For example, whilst we retain transaction details only for so long as legally required, we may retain certain basic details on a longer term basis to ensure we can continue to offer you a highly personalised level of client service tailored to your unique preferences.

Your Data Protection Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, as summarised below.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (of our own or of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(i) if you want us to establish the data's accuracy;

(ii) where our use of the data is unlawful but you do not want us to erase it;

(iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you. We will provide to you your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us here. We aim to respond to all legitimate requests within 30 days. Occasionally it may take us longer than the stated period if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge you a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

Changes To Our Privacy Policy

We reserve the right to make changes to our Privacy Policy from time to time. It is your responsibility to review our Privacy Policy regularly and your continued use of our Website (or any part thereof) shall be deemed to be your acceptance of such changes.

If you do not agree to any change to our Privacy Policy then you must immediately refrain from using the Website.

Questions & Complaints

Please contact us should you have questions, comments or requests regarding our Privacy Policy.