This policy explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others, how we keep it safe and secure and your rights and choices in relation to your information.

Any questions regarding this policy and our privacy practices should be sent by email toinfo@haruni.comor by writing to39 Greville Street, London EC1N 8PJ United Kingdom. Alternatively, you can call us at+44 (0) 20 7242 3748.

We are Haruni Fine Gems, a third generation supplier of fine gemstones, principally rubies and sapphires, as well as natural colour diamonds and precision cut precious and semi precious stones. Our locations are in London, Geneva and Tel Aviv.

 In this policy Haruni Fine Gems, we, us or our means:

• Haruni Fine Gems, registered as ‘International Gemstones Limited under No. 05141720. Registered address is 39 Greville Street, London EC1N 8PJ United Kingdom.
• Its group of companies including International Gemstones Limited, Major Trading SA, Geneva, Switzerland and DY Diamonds Ltd, Tel Aviv, Israel.

We obtain information about you in the following ways:

Information you give us directly

For example, we may obtain information about you when you take part in one of our events or purchase gemstones and services and when you register to receive our weekly newsletters.

Information you give us indirectly

Your information may be shared with us by third parties, which might include:

• independent event organisers, for example GemGenève Fair and the Gem & Jewelry Exhibition, Tucson.
• professional gemstone suppliers; and
• subcontractors acting on our behalf who provide us with technical, payment or delivery services, our business partners, advertising networks analytics providers and search information providers.

You should check any privacy policy provided to you where you give your data to a third party.

When you visit this website

We, like many companies, automatically collect the following information:

• technical information, including the type of device you’re using, the IP address, browser and operating system being used to connect your computer to the internet. This information may be used to improve the services we offer.
• information about your visit to this website, for example we collect information about pages you visit and how you navigate the website, i.e. length of visits to certain pages, products and services you viewed and searched for, referral sources and how you arrived at our website.

We collect and use your personal information by using cookies on our website – more information on cookies can be found under the ‘Use of Cookies’ section below.

Social Media

When you interact with us on social media platforms such as Facebook and Twitter we may obtain information about you, for example, when you publicly tag us in an event photo. The information we receive will depend on the privacy preferences you have set on those types of platforms.

The personal information we collect, store and use might include:

• your name and contact details including postal address, email address and telephone number;
• your date of birth;
• information about your activities on our website and about the device used to access it, for instance your IP address and geographical location;
• your bank or credit card details. If you make a purchase, your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions and;
• any other personal information shared with us.

Data protection laws recognise certain categories of personal information as sensitive and therefore requiring greater protection, for example information about your health, ethnicity and religion.

We do not usually collect sensitive data about you unless there is a clear and valid reason for doing so and data protection laws allow us to.

Where appropriate, we will make clear why we are collecting this type of information and what it will be used for.

We may use your information for a number of different purposes, which may include:

• providing you with the services, products or information you asked for;
• processing orders that you have submitted;
• carrying out our obligations under any contracts entered into between you and us;
• keeping a record of your relationship with us;
• conducting analysis and market research so we can understand how we can improve our services, products or information;
• checking for updated contact details against third party sources so we can stay in touch;
• dealing with entries into a competition;
• seeking your views or comments on the services we provide;
• notifying you of changes to our services;
• sending you communications which you have requested and that may be of interest to you. These may include information about gemstone events and our newest gemstones in stock.

We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal information for is determined by operational and legal considerations. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations. Example, tax and accounting purposes.

We review our retention periods on a regular basis.

We do not sell or rent your information to third parties.

We do not share your information with third parties for marketing purposes.

However, we may disclose your information to third parties in order to achieve the other purposes set out in this policy. These third parties may include:

Third parties working on our behalf: We may pass your information to our third party service providers, suppliers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf, for example to process your gemstone order and send you mailings. However, when we use these third parties, we disclose only the personal information that is necessary to deliver the services and we have a contract in place that requires them to keep your information secure and prevents them from using it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

Third Party Product Providers we work with: our trusted third party product providers provide a range of quality and reliable products and services designed to meet the needs of our customers (e.g. Royal Mail, WorldPay, Malca-Amit, FedEx). When you enquire about or purchase one or more of these products, the relevant third party product provider will use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them. They will be acting as a joint controller of your information and therefore we advise you to read their Privacy Policy. These third party product providers will share your information with us which we will use in accordance with this policy.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our staff, supporters, customers, users of the website or others. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

When you give us personal information, we take steps to ensure that appropriate technical and organisational controls are in place to protect it.

Any sensitive information such as credit or debit card details is encrypted and protected with the following software 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.

Non-sensitive details including your email, address etc. are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given or where you have chosen a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. You should be aware that these countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy.

If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services. We undertake regular reviews of who has access to information that we hold to ensure that your info is only accessible by appropriately trained staff and contractors.

• Haruni Fine Gems reserves the right to delay, pending investigation, or refuse to ship any International order that it determines may be fraudulent. Due to high risk of fraud on International shipments, Haruni Fine Gems will not currently ship to the following countries: Afghanistan Albania Angola Colombia Cambodia Congo Cuba Egypt Ethiopia Iran Indonesia Iraq Lebanon Lithuania Libya Malaysia Nigeria Sierra Leone Syria Pakistan
• The above list of countries is not exhaustive and is subject to change at any time, at our sole discretion. We also reserve the right to refuse shipments to countries that we may have shipped to previously, but which, due to an increase in insurance claims, fraudulent credit card transactions or that country’s revised trade restrictions or import practices, have become a problem for us to ship to.
• Depending upon which country we are shipping to, the total cost of your order, including all Duties and Taxes, may increase beyond the original cost quoted. It is the responsibility of each customer to pay all import tariffs, brokerage fees and any other costs related to delivering the product(s) to you. These costs are always passed along to you. In the event you decide you do not want the gemstones, after they’ve ordered, but prior to delivery, we urge you NOT to refuse delivery. If you refuse delivery, you agree to be responsible for all return freight. Accept all deliveries and we will advise you of the proper procedure for returns.
• We advise you to check your country’s rules for the import of diamonds and gemstones, Haruni Fine Gems takes no responsibility for providing individual information for the rules of any particular country it may be asked to ship to.

Shipping, Insurance and Liability

We ship worldwide on a daily basis. Depending on your location and the value of the item you purchase, your item will be sent via FedEx or United States Postal Service (USPS). All client details, including shipping addresses, must match the authorization information of the credit card used. If you would like your shipment sent to a non-confirmed address, you can arrange to add an “alternative confirmed address” with your credit card company. Please call us at 0207-099-3786 or email us if you have any questions regarding shipping. If paying by wire transfer we will ship anywhere you request. Signature is REQUIRED for all deliveries. Customers are responsible for all items after the package has been signed for. All deliveries are sent to street addresses only. PO Boxes are not accepted as shipping destinations. Saturday delivery is not available for international shipments. International shipments may be subject to customs fees, import duties, taxes, and other charges. These additional charges required for customs clearance are the responsibility of the recipient. Please contact us to clarify what amount (if any) might be due for import duties in your country.

Import Duties / VAT

VAT, Import Duty, Clearance: We ship worldwide on a daily basis. FedEx and USPS international reach most parts of the world within 2-3 business days for a relatively low cost, so we do it for free! VAT can vary from 0% to 10% or even higher depending on your country. We handle each order individually and will advise you of all (if any) additional import fees that could be levied by the shipping carrier. From our many years of experience shipping to all parts of the world, the process and costs have been minimal and streamlined by carriers (FedEx). There are also various legal options in importing jewelry and gemstones with little or no VAT due. Please contact us related to your specific country and item(s) of interest so we can answer all questions properly.

Please note our return policy varies depending on the item/s you are considering for purchase. The following three item types are explained below:

• Loose Sapphires, Rubies and Diamonds
• Ready-Made Finished Jewellery
• Custom Jewellery Orders

For Loose Gemstone and Finished Jewellery Orders: We offer a 21 day inspection period for you to review your sapphire or finished jewellery item. The 21 day period begins when you sign for and receive your item from the shipping carrier. If you are not completely satisfied with your item, you can return it for a full refund. Returns after the 21 day inspection period can be returned for store credit, as long as the item you are returning is not damaged or worn from regular use. While you have possession of any item you are fully responsible for its value and care. If you need an extended inspection period, special circumstances can be agreed upon; however, they must be done so prior to the shipment of your item. Please contact us at 0207-2423748 to make special arrangements for an extended inspection period. Please note: Loose gemstones will not be accepted for a refund if they have been set, scratched, chipped, fractured, weigh differently or have been altered in any way. We strongly recommend that you do not set your gemstone with another jeweller until you fully intend to purchase it. For Custom Orders, aka “Design Your Own Jewellery” Orders: Our primary business is centred around manufacturing one-of-a-kind custom designed jewellery which our customers design and ask us to create for them. There are two primary costs that go into making a custom order and we have different policies on which can be returned:

• The Centre Gemstone: The stone being used in the design can almost always be returned for a full refund within 14 days after receiving the item.
• The Setting and Materials Used: The Setting that was made for the specific gemstone is not returnable for a few reasons. Custom made settings are created to fit the precise dimensions of the centre stone and the finger size of the client. Custom made orders are crafted to the specific taste and liking of the client, and unfortunately we cannot issue refunds on the setting component of the order as it is highly unlikely that another client will purchase the specific design and centre stone that was created. We WILL allow the centre stone to be returned for a refund within 14 days of receipt because the stone can still be used in countless other design options that our future customers can choose from. Should you request a custom setting to be manufactured for your stone selection, payment in full is required before production will begin.

There are situations where we will reserve the right to refuse a return on custom orders, such as if a setting style (bezel setting) poses risk to remove from the ring or if we are required to recut the centre stone for a special issue, such as altering the shape for various reasons to work in the setting design. In this case we will inform you in writing of this special circumstance. We encourage our clients to preview the loose gemstone they are interested in before creating a custom order jewellery setting for that stone. To help our customers better imagine their custom jewellery pieces, we provide two complimentary computer rendered images of the setting. For a fee of £100 we can provide a wax model of the setting. The wax model is available to see the design in person before you place your order. The fee will be deducted from the final purchase price if the order proceeds. Please contact us to inquire about these services. If you have any specific questions regarding returns, please call us at 0207-242-3748 or email us at info@haruni.com. Refunds will be issued in the same method by which it was received, meaning the original form of payment via wire transfer, PayPal, or cash. In the event of a refund, approved refunds will reflect the amount of the transaction as mentioned on the invoice provided by Haruni Fine Gems. Haruni Fine Gems is not responsible for any additional fees or charges applied by the banks, any duties, VAT, taxes, or surcharges that may be levied by the customer’s country of importation, or any other parties throughout the process. If Haruni Fine Gems chooses to authorise a refund after 30-days from the purchased date, 10% of the total cost will be deducted for any expenses paid. After 30 days from the point a loose diamond or piece of jewellery is reserved, if a customer neglects to complete the payment installations, Haruni Fine Gems reserves the right to cancel the reservation and return the fees paid, minus a $300.00 handling fee.

How to Return an Item

If you have purchased an item that you would like to return, you must contact us to confirm your intention. Do not send in a return unless you have contacted our office. All shipments will be refused and returned to sender if not authorised in advance. Depending on the value of the item you are returning, you will be given special instructions on how to send in a return. Items returned MUST be in the same new condition as they were when they were delivered to you. We will NOT accept damaged items. Please review our return policies before requesting to return an item. A refund will be issued after we receive your return. Shipping costs cannot be refunded. If you paid by credit card, the charge will be credited back to your card. If you paid by cheque or wire transfer, a company cheque will be issued to the name on the account from which the purchase was made from. In order to deter potential theft, please do not write any words on the package shipping label that may allude to the contents of the package (such as gems, sapphires, jewellery, etc.). Do not declare the exact nature of the contents you are sending. If required by customs or the shipping company, specify the item is an “Antique Sample” or “Rock Crystal Sample”. Send returns to: Haruni Brothers Ltd 39 Greville Street London EC1N 8PJ ENGLAND Please Note: NO insurance coverage OR value is to be declared on returned items. Our insurance company will issue insurance coverage on the return shipment once a return has been authorised.

Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:

Specific Consent

Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text or call.

Performance of a contract

Where we are entering into a contract with you or performing our obligations under it like when you purchase Haruni Fine Gems products and services.

Legal obligation

Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority such as HM Revenue & Customs.

Legitimate interests

Where it is reasonably necessary to achieve our or others’ legitimate interests as long as what the information is used for is fair and does not duly impact your rights.

We consider our legitimate interests to operating Haruni Fine Gems as a gemstone supplier in pursuit of our aims and ideals. For example to:

• send email communications which we think will be of interest to you;
• conduct research to better understand who our customers are to better target our campaigns;
• monitor who we deal with to protect the business against fraud, money laundering and other risks;
• enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers; and
• understand better how people interact with our website.

When we legitimately process your personal information in this way, we consider and balance any potential impact on you both positive and negative, and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive unless, for instance, we are otherwise required or permitted to by law.

When we use sensitive personal information, we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law.

We may use your contact details to provide you with information about the work we do in the gemstone industry, our upcoming events as well as the products and services you can buy, if we think it may be of interest to you.

Email, Text or Call

We will only send you marketing communications by email, text and telephone if you have explicitly provided your prior consent. You may opt out of our marketing communications at any time by clicking the unsubscribe link at the end of our marketing emails.

Post

We may send you marketing communications by post unless you have told us that you would prefer not to hear from us.

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about the work we do for the gem industry and the exciting products and services you can buy from us, then you can select your choices by ticking the relevant boxes situated on the form used to collect your information.

We’re committed to putting you in control of your data so you’re free to change your marketing preferences including to tell us that you don’t want to be contacted for marketing purposes at any time by contacting us by email: info@haruni.com, telephone: +44 (0) 20 7242 3748 or post 39 Greville Street, London EC1N 8PJ United Kingdom.

We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure that we do not continue to contact you. However, we may still need to contact you for administrative purposes like where we are processing an order or thanking you for your participation in an event.

We may analyse your personal information to create a profile of your interests and preferences so that we can tailor and target our communications in a way that is timely and relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. This allows us to be more focused, efficient and cost effective with our resources and also reduces the risk of someone receiving information they may find inappropriate or irrelevant.

We’re committed to putting you in control of your data so you’re free to opt out of your information being used in this way at any time by contacting info@haruni.com.

We may also use your personal information to detect and reduce fraud and credit risk.

Under UK data protection law, you have certain rights over the personal information that we hold about you. Here is a summary of the rights that we think apply:

Right of access

You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.

If you want to access your information, please send a description of the information you want to see and proof of your identity by post to the address provided below.

Right to have your inaccurate personal information corrected

You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us so we’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please contact us via email or post. Alternatively, you can call us at +44 (0) 20 7242 3748.

Right to restrict use

You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy or we’re not lawfully allowed to use it.

Right of erasure

You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to. In many cases, we will anonymise that information, rather than delete it.

Right for your personal information to be portable

If we are processing your personal information

1. based on your consent, or in order to enter into or carry out a contract with you, and;
2. the processing is being done by automated means; you may ask us to provide it to you or another service provider in a machine-readable format.

Right to object

You have the right to object to processing where we using your personal information

1. based on legitimate interests;
2. for direct marketing or;
3. for statistical and research purposes.

If you want to exercise any of the above rights, please email us at info@haruni.com or write to 39 Greville Street London EC1N 8PJ United Kingdom. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.

Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office, https://ico.org.uk

Any changes we may make to this policy in the future will be posted on this website so please check this page occasionally to ensure that you’re happy with any changes. If we make any significant changes we’ll make this clear on this website.

We keep this policy under regular review. This policy was last updated in June 2018.