Effective as of January 8, 2018
We pledge to fully meet and comply with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong. By doing so, the Company will ensure compliance by members of its staff to the standards of security and confidentiality in respect of all personal information and data submitted by users through www.WPDiamonds.hk (the Website), which is accessible through tablets, cell phones, personal digital assistants, connected televisions and other devices. The Website is herein referred to as the “Platform.”
The Information We Collect
When you use our Platform to sell your diamonds or fine jewelry, sign up to receive our newsletters or product information, or contact us electronically, you may be required to provide us with personal information about yourself, such as your name, e-mail, and phone number (collectively, the “Personal Information’). We do not collect any Personal Information from you when you use the Platform unless you provide us with the Personal Information voluntarily.
If you sell us your diamond or fine jewelry and wish to be paid by direct bank transfer, you will be required to provide us certain of your account details (collectively, the “Billing Information”). We use this information to pay you and to fulfil the obligations of our Anti-Money Laundering policy, which requires us to identify our customers and verify that they are not on any Office of Foreign Assets Control (“OFAC”) watch list (US Department of the Treasury).
Certain features and functionalities of the App are based on your location. In order to provide these features and functionalities while you are using a mobile device, we may, with your consent, automatically collect geo-locational information from your mobile device, wireless carrier, and/or certain third-party service providers. Such information is collectively called the “Geo-locational Information.” Collection of such Geo-locational Information occurs only when the Platform is running on a mobile device. You may decline to allow us to collect such Geo-locational Information, in which case we will not be able to provide certain features or functionalities to you.
We may collect additional information (collectively, the “Other Information”). Such Other Information may include:
- From You. Additional information that you voluntarily provide to us, such as characteristics of your diamond or other fine jewelry (shape, weight, color, clarity, retail value, and appraisal details) hobbies, personal interests, household income range, gender, product and service preferences, and other information that does not identify you personally.
- From Your Activity. Information that we automatically collect when you use the Platform, including, without limitation:
- IP address, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, sections of the Website and App visited, etc.;
- Information about a mobile device, including universally unique ID (“UUID”), Platform type and version (e.g., iOS or Android), carrier and country location, hardware and processor information (storage, chip speed, camera resolution, NFC enabled, and network type (WiFi, 2G, 3G, 4G, LTE); and
- Activity and usage information occurring via the Platform.
- From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Platform. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Platform may not function properly.
- Transaction Information
We collect and retain information regarding our Transactions with you processed via the Platform.
The Information Collected by or Through Third-Party Advertising Companies
Accessing and Modifying Personal Information and Communication Preferences
If you have provided us Personal Information, you may access, review, and make changes to your Personal Information and certain Other Information by following the instructions found on the applicable Platform or by contacting us. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the unsubscribe link located on the bottom of any WPDiamonds’ marketing email. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to your Transactions with us.
How We Use and Share the Information
We use the Personal Information, the Billing information, the Geo-locational Information, the Other Information, and the Transaction Information (collectively, the “Information”) to process your Transactions, provide and improve the Platform and our services, solicit your feedback, inform you about our products and services and those of our third-party marketing partners, and administer our rewards and promotional programs. Also, we may share Information as described below.
- In order to administer our rewards and promotional programs, we may share your Personal Information, Other Information, and certain Transaction Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
- In an ongoing effort to better understand our users, Platform, and services, we might analyze the Other Information, the Transaction Information, and the Geo-locational Information in aggregate form in order to operate, maintain, manage, and improve our services and/or Platform. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products, Platform, and services to current and prospective business partners and to other third parties for other lawful purposes.
- We may from time to time share Personal Information and/or Other Information with other companies who may provide you information about the products and services they offer. However, to the extent required by law, you will be given the opportunity to opt-out of such sharing.
- We may employ other companies and individuals to perform functions on our behalf. Examples may include providing marketing assistance, information technology support, and customer service. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
- With your permission, third-party applications or services may access your Personal Information. We use standard OAuth (open authorization) to enable you to give permission to share your Personal Information with other websites and services, such as Facebook and LinkedIn. We also use OAuth to allow us to share information about you that is stored by us without sharing your security credentials.
- We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
- As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
- To the extent permitted by law, we may also disclose the Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing the such information is necessary or advisable, for example, to protect the rights, property, or safety of WPDiamonds or others.
How We Protect Your Information
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Platform may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
Important Notice to Non-U.S. Residents
How to Contact Us
We guarantee the safety, security, and privacy of your valuables