Privacy Policy for Potential Diamond Sellers

May 8, 2018

 

INTRODUCTION

Adama Capital I d/b/a Mondiamo (“Company”, “we”, “our” or “us”) understands that privacy is important to our users.  We have created this Privacy Policy in order to demonstrate our commitment to your privacy. The Privacy Policy below discloses our practices regarding information collection and usage solely for the website located at https://www.mondiamo.com/ (“Website”).  This Privacy Policy does not apply to any other websites, apps or services provided by us, or by our affiliates or our clients, unless it appears on such website, app or service.

 

LINKED SITES AND PLATFORMS

Other Websites, Apps and Services:  As a convenience to you, we may provide links to third party websites, apps or services from within the Website. We are not responsible for the privacy practices or content of these third party sites, and by providing a link we are not endorsing or promoting such third party sites.  When you link away from our Website, you do so at your own risk. We encourage you to read the policies and terms of every website, app or service you visit.

Social Networking Websites:  The Website may integrate with social networking services, including Facebook, Twitter, Instagram, Snapchat and Pinterest.  For example, you may be given the option to log in, access or register for the Website through the use of your user name and passwords for certain services provided by third parties such as Facebook.  In addition, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may allow third parties to collect information about you. You understand that we provide you with the ability to use such services in connection with our Website merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.  We do not control such services and are not liable for the manner in which they operate, and in many cases, we are not a party to and do not receive access to the information collected by these services. Please carefully read the policies and terms of every social networking service referenced on our Website before using our Website. Finally, please be aware that personally identifiable information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others.  We are unable to control such uses of your personally identifiable information, and by using such services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties.

 

INFORMATION COLLECTED

Personally Identifiable Information That We Collect:  The provision of your personally identifiable information to us is completely voluntary; it is not a statutory or contractual requirement. We do not collect personally identifiable information about you unless that information is provided to us by our partners, is collected via third party social networking services (in which case such information collection is detailed on that social networking service’s policies and terms), or you voluntarily submit that information to us.  Information provided via social networking services is generally provided to us if you use your user name and password for those social networking services to log in to our website. With respect to information you voluntarily submit to us, this information can be provided through our log in, contact or registration pages; by editing your account; by filling in any forms we provide or radio buttons we request executed; by providing feedback, reviews or user-generated content or interacting with our customer service personnel; by using our chat or communication channels with other users or utilizing our other community features; by communicating with us via email (including in connection with a transaction); by providing us with a Request or providing information attendant to the acceptance or rejection of a Conditional Offer or Final Offer (as those terms are defined in the Terms and Conditions for this Website) or any shipping, insurance or other items related thereto; by providing information to facilitate payments to you or your accounts; or by some other means including your consent.  The personally identifiable information which is provided to us or which you may provide to us could include your name, date of birth, gender, telephone number, email, physical address, screen or user name, profile picture, and IP address. It may also include information necessary to process your payments, including a copy of your Driver’s License, Passport, Passport Card, Military ID, or State Non-Drivers ID (including any numerical identifiers connected thereto); proof of address such as utility or credit card bills; a purchase receipt or insurance policy indicating ownership of the Article(s) (as that term is defined in the Terms and Conditions for this Website); and bank account to deposit payments.

Non-Personal Or Aggregate Information That We Collect:  When you visit or use the Website, our partners may provide or you may voluntarily submit non-personally identifiable information to us through the means detailed in the previous section.  This information may include a detailed description of the Article(s) at issue, including the GIA grading report numbers for those Article(s). Further, we may automatically collect certain non-personally identifying information about you, including without limitation device usage data, the type of browser or device operating system you use, the domain name of the website from which you linked to us, the amount of time you spend on the Website and the pages on the Website that you view. We may also aggregate information collected from you with information from our other users (such as the number of users in a particular region or having particular demographic characteristics).

Collection of Information About Others:  Some features of our Website may require or allow you to send information about our Website, services or offerings to another person or provide information about another person to us.  This information will treated be as personal or non-personal information based on the type of information provided, and be utilized in accordance with this Privacy Policy.

 

INFORMATION USAGE

Personally Identifiable Information - Information Usage and Disclosure:  The legal basis for our processing of your personally identifiable information is that it is necessary for the performance and fulfilment of the contract between us and to provide you with our services. We will only use your personally identifiable information as described below:

 

  • We will use personally identifiable information to operate the Website and to provide you with any specific products or services that you have requested, including the processing of Requests, Conditional Offers, Final Offers, Acceptance (as that term is defined in the Terms and Conditions for this Website) and shipping, insurance and payment related thereto.

  • We may share your personally identifiable information with our affiliates for their benefit and with third parties such as our partners, vendors and subcontractors for our benefit. To opt out of such disclosures, please see the “Opt Out” section below.

  • We may use your personally identifiable information to respond to your direct inquires.

  • We will use your personally identifiable information to add you to our mailing lists and to send you emails from time to time.  

  • We may disclose personally identifiable information as required by law or legal process.

  • We may disclose personally identifiable information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the Website.  

  • We may transfer your personally identifiable information in connection with a bankruptcy proceeding or the sale, merger or change of control of Company or the division of the Company responsible for the services with which your personally identifiable information is associated.

  • When you submit a resume or job application through our Website, we may share those documents and the information therein with our third party service providers that help us manage personnel matters. They may only access and use such records in connection with performing services for us.  They are not authorized by us to use the information for their own benefit.

Please note that we will also process, transfer, disclose and preserve personally identifiable information when we have a good faith belief that doing so is necessary.  If you specifically consent to additional uses of your personally identifiable information, we may use your personally identifiable information in a manner consistent with that consent.  Finally, we reserve the right to supplement your personally identifying information with information we gather from other sources which may include information we gather from online and offline sources.

Communications with Us or Through the Website:  By providing your email address to us, you expressly consent to receive emails from us.  We may use email to communicate with you concerning a Request, Conditional Offer, Final Offer, Acceptance and shipping, insurance and payment related thereto.  We may also use email to send information that you have requested or to send information about other services provided by us, provided that we will not give your email address to another party to promote their products or services directly to you without your consent or unless otherwise set forth in this Privacy Policy. Any communication or material you transmit to us by email or otherwise, including any data, questions, comments, suggestions, or the like, are and will be treated as non-confidential and non-proprietary.  Except to the extent expressly covered by this policy, anything you transmit or post may be used by us for any purpose, including but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting. While it is our policy not to accept unsolicited ideas, you expressly agree that we are free to use any ideas, concepts, know-how, or techniques contained in any communication you send to us without compensation and for any purpose whatsoever, including but not limited to, developing, manufacturing and marketing products and services using such information.

Non-Personally Identifiable Information - Information Usage and Disclosure:  Non-personally identifying information or aggregate information may be shared with any number of parties, provided that such information shall not specifically identify you. We may also use tracking information and other non-personally identifying information for the purposes described in this Privacy Policy, such as to serve interest based advertising content to you and for any other business purposes permitted by law.

 

INTEREST BASED ADVERTISING

Interest Based Advertising:  We may ourselves, or with third party vendors, use non-personally identifiable information in connection with our own or vendor information to deliver targeted advertising to you when you visit other websites or our Website. Cookies, clickstream data, and other similar technologies described below may be used in this process. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on our Website or other websites you view with information on that product. This form of advertising, sometimes called “behavioral advertising” or “interest based advertising” is based on anonymous information and not on any personally identifiable information. As a result, we and our vendor know your interests, but cannot personally identify you in connection with the delivery of that specific ad. We believe that such advertising is helpful because you will see advertisements that are relevant to your interests. However, if you would like to opt out of these interest-based advertisements, please follow the opt-out process described below under “Opt-Out.”

Cross Device Matching: We use non-personally identifying information to facilitate cross device association. We or our third party vendors analyze device activity data using a mathematical tool known as a “probabilistic algorithm” to determine if you have interacted with content across multiple devices and to match such devices. In connection with this analysis, we may rely on non-personally identifiable information (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies or we may use the non-personally identifiable information we collect in conjunction with such third party data.  Based on this data, we may then display targeted advertisements across devices that we believe are associated and may provide other services to our advertisers such as tools, analyses, data and insights to see how their website is used and to further enable the display of targeted advertisements to you, including across your devices. For further instructions on restricting our use of certain cross-device data, please see “Opt-Out,” below.

 

COOKIES

Cookies and Similar Technologies:  We may store some information on your device or device hard drive such as a "cookie" or similar type of file (such as clear gifs, web beacons, tags, JavaScript and similar technologies that work on mobile devices) to collect data related to usage of the Website and for the purpose of facilitating and enhancing your communication and interaction with the Website. Such data may include, without limitation, your device type, operating system type, the language your system uses and the country and time zone where your device is located in, the address of the websites you visited before and after you visited the Website, the type of browser you are using, your IP address, what pages in the Website you visit and what links you clicked on, the latitude and longitude (i.e., lat/long) coordinates of your device, the region where your device is located, and geo-IP data. We use this information to help us maintain and enhance the efficiency and usefulness of the Website and may use it and other non-personally identifiable information for the purposes described in this Privacy Policy, such as to serve targeted advertising to you.  Our cookies persist on your hard drive for thirty (30) days.

Google Analytics:  Company uses Google Analytics to help analyze how you and other users utilize the Website. Google Analytics uses cookies to collect standard internet log information and visitor behavior information in an anonymous form. Google Analytics will not collect personally identifiable information about you unless you explicitly submit that information on this Website.  Please note that the information generated by Google Analytics cookies about your use of this website is transmitted to Google, and not to Company. This information is processed to compile aggregate statistical reports on Website activity, and these reports are then provided to Company. Company may use these reports on aggregate visitor usage for its business purposes or as permitted in this Privacy Policy, including for interest based advertising.  More information on Google Analytics can be found at https://www.google.com/analytics/. Company is not responsible for the acts and omissions of Google or for Google Analytics, any Google Analytics cookies, or any Google Analytics opt-outs.

Third Party Cookies:  We may also use and place cookies on your device from our third party service providers in connection with the Website, such as social networking services.  These social networking services’ cookies may allow third parties to collect information about you even when you do not interact with their service or buttons. In addition, we may use advertisers, third party ad networks, and other advertising companies to serve advertisements on the Website. Please be advised that such advertising companies may gather information about your visit to the Website or other sites to enable such advertising companies to market products or services to you, to monitor which ads have been served to your browser and which webpages you were viewing when such ads were delivered.  Please be advised that social networking services and other third parties are beyond the scope of this Privacy Policy. We are not responsible for the acts or omissions of such social networking services or third parties.

Clickstream Data: As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of device and browsing software you use and the address of the website from which you linked to the Website. We may collect and use clickstream data to anonymously determine how much time visitors spend on websites, how visitors navigate throughout websites and how we may tailor our website to better meet consumer needs. This information will be used to improve our website and our services. Any collection or use of clickstream data will be anonymous, and will not intentionally contain any personally identifiable data.

DATA SECURITY

Security and Data Retention:  We have undertaken and will undertake commercially reasonable efforts designed to prevent unauthorized access to user data retained in our servers, however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We will retain your information for as long as your account or inquiry is active or as needed to provide you with the Websites and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your personally identifiable information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your personally identifiable information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

Children: Our Website is designed for those thirteen (13) years of age and older. We do not knowingly collect information from anyone under the age of thirteen (13).  If we are made aware that we have received such information, or any information in violation of our policy, we will use commercially reasonable efforts to locate and remove that information from our records. 

 

OPT-OUTS

Personal Information Opt-Out:  If you do not want us to retain or use your personal information, you may withdraw your consent by contacting us at privacy@mondiamo.com.

Marketing Opt-Out:  To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at privacy@mondiamo.com.  If you do not want your personal information shared with any of our affiliates or third parties who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an email to privacy@mondiamo.com.  We will process your request within a reasonable time after receipt. However, we are not responsible for removing your personally identifiable information from the lists of any third party who has previously been provided with your information in accordance with this Privacy Policy or your consent. Please note that if you opt out in this manner, certain aspects of the Website may no longer be available to you.

Cookie Opt-Out:  As noted above, you may opt-out of or restrict the placement of cookies on your device or remove them from your browser by adjusting your web browser preferences, in which case you may still use our Website, but it may interfere with some of its functionality. Please note that cookie-based opt-outs are not effective on many mobile devices. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

Google-Analytics Opt-Out:  You may opt out of data collection via Google Analytics through the installation of the Google Analytics opt-out browser add-on.  More information about this add-on can be found at https://tools.google.com/dlpage/gaoptout.

Location Opt-Out:  You may also adjust the settings on your mobile device to allow or restrict the sharing of location information. For example, the "location" permissions on your mobile device may allow you to elect whether to never share location information with us, to share location information only while you are using the Website, or always share location information even if you are not using the Website. If you elect to not share your location information, you may be unable to access some features of our Websites that are designed for mobile devices. Also, in the event that you prevent the sharing of location information, we may still estimate your general location based on the IP address you use to access our Website.

Interest Based Advertising Opt-Out:  We may, and may work with third parties, to use non-personally identifiable information to deliver targeted advertisements to you based upon your online activities and other information.  The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs.  We comply with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance (DAA). You can opt-out of targeted advertising from certain providers at www.aboutads.info/consumers.  Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. To be clear, cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device.

Do Not Track: Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.

 

CALIFORNIA PRIVACY

California Privacy: Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship (a) a list of the categories of personally identifiable information, such as name, email address and mailing address and the type of services provided to the customer 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 (b) the names and addresses of all such third parties. To request the above information, please contact us at privacy@mondiamo.com. If you do not want your personally identifying information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at privacy@mondiamo.com.  

 

CROSS BORDER TRANSFERS & GDPR

EU Data Subject Rights: If you are a resident of the European Union (“EU”), under the General Data Protection Regulation (“GDPR”), you, as a data subject, have the following rights:

  • Right to access – This right allows individuals to obtain confirmation as to whether or not personally identifiable information concerning him or her is being processed and provides access to such personally identifiable information. It also allows individuals to request details of the processing of his or her personally identifiable information, including, without limitation, categories of recipients to whom the personally identifiable information have been or will be disclosed and purposes of processing.  

  • Right to rectify – This right allows individuals to rectify any inaccurate personally identifiable information about him or her.

  • Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances.

  • Right to be forgotten – This right is also known as the “right to erasure.”  It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.

  • Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.

  • Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.

To exercise your rights under the GDPR, please contact us at privacy@mondiamo.com.

Cross border transfers:  Our Website is maintained in the United States of America (“USA”).  By using the Website, you freely and specifically give us your consent to export your personally identifiable information to the USA and to store and use it in the USA as specified in this Privacy Policy.  You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA. Further, please note that we transfer personally identifiable information from the EU and Switzerland to the USA and other countries, some of which have not been determined by the EU to have an adequate level of data protection. Personally identifiable information of EU residents will be transferred in compliance with the requirements of the GDPR.

 

MISCELLANEOUS

Changes to Privacy Policy:  This Privacy Policy may be changed at any time without prior notice. We will make such changes by posting them on the Website. You should check the Website for such changes frequently.  Your continued access of the Website after such changes conclusively demonstrates your acceptance of those changes.

Contact:  For questions or concerns relating to this Privacy Policy or your information, we can be contacted at: privacy@mondiamo.com. Our data protection officer can be contacted here: privacy@mondiamo.com. If you are an EU resident and have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority.