Introduction
We respect your right to privacy and aim to ensure that we are fair and transparent when collecting and using the personal information you have provided to us.
This Privacy Notice (or “Notice”) applies to our website visitors and customers and details how we use your personal data under global privacy requirements, including GDPR (General Data Protection Regulation and CCPA (Californian Consumer Privacy Act).
Contacts
A Diamond Is Forever is part of De Beers plc, a company registered in Jersey under company number 122752 whose registered office is at 3rd Floor, 44 Esplanade, St Helier, Jersey, JE4 9WG, operating under De Beers UK Ltd.
To contact us for more information about this Privacy Policy or to exercise your rights, please see the following link.
De Beers is the data controllers for data collection, processing and analysis of website data, including analytical, statistical and cookie & cookie consent data (see cookie notice) for further information.
Personal Information we Collect
If you provide us with personal data through the Websites, we will process your personal data in order to, in accordance with applicable law:
allow you to participate in the registration-only features of the Websites and to download relevant brand content, when you choose to do so
ensure that content from the Websites is presented in the most effective manner for you and for your computer
provide you with information that you request from us or which we feel may interest you, including through subscribed alerts (where applicable)
notify you about changes to the Websites and branding which may be relevant to you
serve you with relevant advertising on third party websites, such as Google, YouTube and LinkedIn
Why and How We Collect your Personal Information
We process the following personal data in connection with our Websites:
If you contact us using the “Contact Us” section of our Websites, the personal data that you provide to us, such as your name, your contact details (such as email address and telephone number) and the content of your query. If you leave a comment on a blog or other post on our Websites the personal data that we process to do so will be the personal data that you provide to us, such as the content of your comment and any personal data you choose to provide.
If you sign up to subscriber alerts:
The personal data that we process to do so will be the personal data that you provide to us, such as your name, your email address, your country of residence and your occupation.
General use
We process any other personal data which you choose to disclose to us during the course of your use of the Websites, whether through email or otherwise. We may automatically process some technical data such as your Internet Protocol (IP) address to identify what companies have interacted with the website. This processing only identifies a company name and will not be used to identify an individual. We use your IP address to track traffic flows and make our websites easier for you to use and better understand how our websites are used.
Cookies
Cookies will collect personal data about you. The personal data that is collected by these cookies is IP address, operating system and browser type. Please see our Cookie Policy for details. One of the analytics tools that our website uses is Google Analytics, to learn more about Google Analytics, you can visit www.google.com/policies/privacy/partners/.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
What are the legal grounds relied on to carry out these processing activities?
If the personal data processing activity falls under the jurisdiction of the EEA or South Africa:
This processing is necessary to take steps at your request to enter a contract with you.
We may need to use your personal data to comply with a relevant legal or regulatory obligation that we have.
This processing is necessary for the purpose of the legitimate interests pursued by the Company.
If you sign up for subscriber alerts, we process your personal data in connection with the same on the basis of your consent.
With regards to the legitimate interests referred to above: The Company considers that it has a legitimate interest in managing and operating its business. This includes undertaking promotional activities and managing an online presence. In particular, we use cookies to ensure the effective operation of our Websites. This includes ensuring that content from our Websites is presented in the most effective manner for you and for your computer. Further, if you review or download information on our Websites, we track the visit to give us information about which part of the site is frequented.
If the personal data processing activity falls under any other jurisdiction, the legal grounds for processing your data is your Consent.
With Whom we Share your Personal Information
Your personal data is shared internally, as set out in this Policy.
In addition, some of your personal data will be shared externally with our partners as needed and as otherwise set out in this Policy.
In particular, your personal data may be shared with the following third parties in connection with your use of our Websites.
We may share in aggregate, statistical form, non‑personal data regarding the visitors to our Site, traffic patterns, and website usage with our partners, affiliates or advertisers.
Your rights under the CCPA
If you are a California resident, you are entitled to the following rights under the California Consumer Privacy Act (CCPA). You can exercise these rights at any time by contacting us at
to be informed about the personal information that the business collects and shares, including the categories and specific pieces of personal information
to request from us access to personal information that we collect and share to services providers and third parties.
to opt-out of the sale of your personal information to third parties.
to request the deletion of your personal information
to not be discriminated against for exercising any of your consumer rights.
There is not charge for exercising your consumer rights.
“Do not sell my information”
If you are a Californian resident and have provided personal information to a business, you may be entitled by California law to opt-out of selling of your personal information by a business to a third party. The CCPA broadly defines the term “sale”, where it may include when we share your personal information to a third party for a value, where it is not for a business purpose, you have not directed us to sharing the personal information with a third party or is not pursuant to a written contract. A Diamond Is Forever does and will not sell your personal data, please see the Sale and Disclosure for Business Purposes below for further information.
Please not that we have also adopted a policy (“Third Party Opt-Out Policy”) of not sharing your personal information with third parties for their direct marketing purposes if you request that we do not do so.
Your rights under GDPR
Whether these rights apply to you will depend on the nature of the personal data processing activity, and the jurisdiction in which the processing takes place:
Right to access and correct your personal data
The Company aims to ensure that all personal data is correct. You also have a responsibility to ensure that changes to your personal data are notified to the Company as soon as possible so that we can ensure that your data is up-to-date.
You have the right to request access to any of your personal data that the Company may hold, and to request correction of any inaccurate data relating to you.
You should note that we do not always need to comply with your requests, but we will ensure that this is explained to you if this is the case.
Data portability
Where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the reason or legal ground for processing, and that personal data is processed by automatic means, you have the right to receive all such personal data which you have provided to the Company in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
Right to rectify or erase personal data
You have a right to request that we rectify inaccurate personal data. We may seek to verify the accuracy of the personal data before rectifying it.
You can also request that we erase your personal data in limited circumstances where:
it is no longer needed for the purposes for which it was collected; or
you have withdrawn your consent (where the data processing was based on consent); or
you have made a successful objection (see right to object below); or
it has been processed unlawfully; or
it is necessary to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase personal data if the processing of your personal data is necessary:
for compliance with a legal obligation; or
for the establishment, exercise or defence of legal claims.
Right to restriction of processing
You have the right to restrict our processing of your personal data but only where:
you contest the accuracy of the personal data, pending us taking sufficient steps to correct or verify its accuracy;
processing is unlawful but you do not want us to erase the data;
we no longer need the personal data for its original purpose, but we require it for the establishment, exercise or defence of legal claims; or
you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether the Company has compelling legitimate grounds to continue processing.
Where personal data is subjected to restriction in this way, we will only process it with your consent; for the establishment, exercise or defence of legal claims; or to protect the rights of another natural or legal person.
Right to withdraw consent
Where you have provided us with your consent to process data, you have the right to withdraw such consent at any time. You can do this by (i) in some cases deleting the relevant data from the relevant IT system (although note that in this case it may remain in back-ups and linked systems until it is deleted in accordance with our policy) or (ii) contacting us. In some cases, your withdrawal of consent may mean that we will no longer be able to continue our relationship with you. We will always inform you of the likely consequences of your withdrawal of consent.
Right to object to processing justified on legitimate interest grounds
Where the reason for processing your personal data is our legitimate interests, you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as the legal ground for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
Right to object to automated decision making
You have the right to object to any decision that significantly affects you being taken solely by a computer or other automated process. In such a case, you have the right to obtain human intervention, to express your point of view, and to contest the automated decision.
Right to object to how we use your personal data for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your personal data to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to obtain a copy of personal data safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the EEA. We may redact data transfer agreements to protect commercial terms.
Right to complain to a supervisory authority
You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the processing of your personal data infringes applicable law.
Further information
For further information regarding your rights, or to exercise any of your rights, please contact us.
Sale and Disclosure for Business Purposes
At De Beers, A Diamond Is Forever does not sell any personal data that we collect. We do disclose personal details as detailed in “With Whom We Share Your Personal Information”, the categories of data that is disclosed for business purposes.