PRIVACY POLICY
Last updated July 19,
2023
This privacy notice for
Legacy Jewelers LLC (doing business as Smith's Jewelers) ("we,"
"us," or "our"), describes how and why we might
collect, store, use, and/or share ("process") your information when you use our
services ("Services"), such as when you:
- Visit our website at http://www.smithsonthesquare.com, or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy
notice will help you understand your privacy rights and choices. If you do not agree with our
policies and practices, please do not use our Services. If you still have any questions or
concerns, please contact us at accounts@smithsonthesquare.com.
SUMMARY OF KEY
POINTS
This summary provides key points from our privacy
notice, but you can find out more details about any of these topics by clicking the link
following each key point or by using our table of contents below to find the section you are looking
for.
What personal information do we process? When you
visit, use, or navigate our Services, we may process personal information depending on how you
interact with us and the Services, the choices you make, and the products and features you use.
Learn more about personal information you disclose to
us.
Do we process any sensitive personal information?
We may process sensitive personal information when necessary with your consent or as otherwise
permitted by applicable law. Learn more about sensitive information we process.
Do we receive any information from third parties?
We may receive information from public databases, marketing partners, social media platforms, and
other outside sources. Learn more about information collected from other
sources.
How do we process your information? We process your
information to provide, improve, and administer our Services, communicate with you, for security and
fraud prevention, and to comply with law. We may also process your information for other purposes
with your consent. We process your information only when we have a valid legal reason to do so.
Learn more about how we
process your information.
In what situations and with which parties do we share
personal information? We may share information in specific situations and with specific
third parties. Learn more about when and with whom we share your personal
information.
How do we keep your information safe? We have
organizational and technical processes and procedures in place to protect your personal information.
However, no electronic transmission over the internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorized third parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Learn more about how we keep your information
safe.
What are your rights? Depending on where you are
located geographically, the applicable privacy law may mean you have certain rights regarding your
personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to
exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in
accordance with applicable data protection laws.
Want to learn more about what we do with any information we
collect? Review the privacy
notice in full.
TABLE OF CONTENTS
1.
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In
Short: We collect
personal information that you provide to
us.
We collect personal information that you voluntarily
provide to us when you register on the
Services, express an interest in obtaining information about
us or our products and Services, when you participate in activities on the Services, or
otherwise when you contact us.
Personal Information Provided by You.
The personal information that we collect depends on the context of your interactions with us and
the Services, the choices you make, and the products and features you use. The personal
information we collect may include the following:
- names
- phone numbers
- email addresses
- mailing addresses
- usernames
- passwords
- contact preferences
- contact or authentication data
- billing addresses
- debit/credit card numbers
- job titles
- wishlist
- favorites
- mobile numbers
- household info
Sensitive
Information. When necessary, with your consent or as otherwise permitted by applicable
law, we process the following categories of sensitive information:
- financial data
- data about a person's sex life or sexual orientation
- information revealing religious or philosophical beliefs
- student data
- credit worthiness data
- social security numbers or other government identifiers
Payment Data. We may collect data
necessary to process your payment if you make purchases, such as your payment instrument number,
and the security code associated with your payment instrument. All payment data is stored by Shopify payments and affirm.
You may find their privacy notice link(s) here:https://www.shopify.com/legal/terms-payments-us and https://www.affirm.com/en-ca/privacy.
__________
Social Media Login Data. We may
provide you with the option to register with us using your existing social media account details,
like your Facebook, Twitter, or other social media account. If you choose to register in this way,
we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL
LOGINS?" below.
All personal information that you provide to us must be
true, complete, and accurate, and you must notify us of any changes to such personal
information.
Information automatically collected
In
Short: Some
information — such as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our
Services.
We automatically collect certain information when you
visit, use, or navigate the Services. This information does not reveal your specific identity
(like your name or contact information) but may include device and usage information, such as your
IP address, browser and device characteristics, operating system, language preferences, referring
URLs, device name, country, location, information about how and when you use our Services, and
other technical information. This information is primarily needed to maintain the security and
operation of our Services, and for our internal analytics and reporting
purposes.
Like many businesses, we also collect information
through cookies and similar technologies.
The information we collect
includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
Information collected from other sources
In Short: We
may collect limited data from public databases, marketing partners, social media platforms,
and other outside
sources.
In order to enhance our ability to provide relevant
marketing, offers, and services to you and update our records, we may obtain information about you
from other sources, such as public databases, joint marketing partners, affiliate programs, data
providers, social media
platforms,and from other third parties. This information includes
mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior
data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom
profiles, for purposes of targeted advertising and event promotion.If you interact with us on a
social media platform using your social media account (e.g. , Facebook or Twitter), we
receive personal information about you such as your name, email address, and gender. Any
personal information that we collect from your social media account depends on your social
media account's privacy settings.
2.
HOW DO WE PROCESS YOUR INFORMATION?
In Short: We
process your information to provide, improve, and administer our Services, communicate
with you, for security and fraud prevention, and to comply with law. We may also process
your information for other purposes with your
consent.
We process your personal information for a
variety of reasons, depending on how you interact with our Services,
including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
- To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
- To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
- To post testimonials. We post testimonials on our Services that may contain personal information.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To administer prize draws and competitions. We may process your information to administer prize draws and competitions.
- To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
- To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In Short: We only
process your personal information when we believe it is necessary and we have
a valid legal reason (i.e., legal basis) to do so under applicable law, like
with your consent, to comply with laws, to provide you with services to enter
into or fulfill our contractual obligations, to protect your rights, or to
fulfill our legitimate business interests.
If
you are located in Canada, this section applies to
you.
We may process your information if you have
given us specific permission (i.e., express consent) to use your personal
information for a specific purpose, or in situations where your permission can
be inferred (i.e., implied consent). You can withdraw your
consent at any
time.
In some exceptional
cases, we may be legally permitted under applicable law to process your
information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
In
Short: We may share information in specific
situations described in this section and/or with the following third
parties.
Vendors, Consultants, and Other
Third-Party Service Providers. We may share your data with
third-party vendors, service providers, contractors, or agents ("third
parties") who perform services for us or on our behalf and require
access to such information to do that work. We have contracts in place with our
third parties, which are designed to help safeguard your personal information.
This means that they cannot do anything with your personal information unless we
have instructed them to do it. They will also not share your personal
information with any organization apart from us. They also commit to protect the
data they hold on our behalf and to retain it for the period we instruct. The
third parties we may share personal information with are as
follows:
- Advertising, Direct Marketing, and Lead Generation
Facebook Audience
Network and
Google AdSense
- Affiliate Marketing Programs
etsy
- Cloud Computing Services
Google Cloud
Platform
- Communicate and Chat with Users
clientbook, google
business messenger, Meta, Facebook
Customer Chat, instagram, twitter, etsy and
shopify
- Content Optimization
YouTube video
embed, Google Site
Search, Instagram
embed, Vimeo
video, Adobe Edge
Web Fonts and
Fonts.com Web Fonts
- Data Backup and Security
Google Drive
Backup
- Functionality and Infrastructure Optimization
Termly.io, gemfind, shopify, clientbook, text4moreplatform.com and
duda.com
- Invoice and Billing
shopify, Amazon
Payments, affirm, Android
Pay, Apple
Pay, Google
Wallet and
PayPal
- Retargeting Platforms
Facebook Custom
Audience, Google Ads
Remarketing , Google
Analytics Remarketing and
Facebook Remarketing
- User Account Registration and Authentication
Facebook
Login, Google
Sign-In, Instagram
Authentication and
YouTube OAuth 2.0
- Web and Mobile Analytics
Facebook Ads
conversion tracking, Google
Ads, Google Tag
Manager, Google
Analytics, Facebook
Analytics and
text4moreplatform.com
- Website Hosting
Shopify, tex4moreplatform.com, duda.com, Altervista
Platform and
The edge
- Website Testing
shopify
We also may need to
share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API).
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
In
Short: We may use cookies and other tracking
technologies to collect and store your
information.
We may use cookies and similar
tracking technologies (like web beacons and pixels) to access or store
information. Specific information about how we use such technologies and
how you can refuse certain cookies is set out in our Cookie Notice.
In
Short: If you choose to register or log in to
our Services using a social media account, we may have access to certain
information about you.
Our Services offer you the
ability to register and log in using your third-party social media account
details (like your Facebook or Twitter logins). Where you choose to do
this, we will receive certain profile information about you from your
social media provider. The profile information we receive may vary
depending on the social media provider concerned, but will often include
your name, email address, friends list, and profile picture, as well as
other information you choose to make public on such a social media
platform.
We will use the information we
receive only for the purposes that are described in this privacy notice or
that are otherwise made clear to you on the relevant Services. Please note
that we do not control, and are not responsible for, other uses of your
personal information by your third-party social media provider. We
recommend that you review their privacy notice to understand how they
collect, use, and share your personal information, and how you can set
your privacy preferences on their sites and apps.
7. HOW LONG DO WE KEEP YOUR
INFORMATION?
In
Short: We keep your information for as long as
necessary to fulfill the purposes outlined in this privacy notice unless
otherwise required by law.
We will only keep your personal
information for as long as it is necessary for the purposes set out in
this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements).
No purpose in this notice will require us keeping your personal
information for longer than one (1) months past
the termination of the user's account .
When we have no ongoing
legitimate business need to process your personal information, we will
either delete or anonymize such information, or, if this is not possible
(for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and
isolate it from any further processing until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION
SAFE?
In
Short: We aim to protect your personal
information through a system of organizational and technical security
measures.
We have implemented appropriate
and reasonable technical and organizational security measures designed to
protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage
technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized third
parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Although we will do our best to
protect your personal information, transmission of personal information to
and from our Services is at your own risk. You should only access the
Services within a secure environment.
9. DO WE COLLECT INFORMATION FROM
MINORS?
In
Short: We do not knowingly collect data from or
market to children under 18 years of age.
We do not knowingly solicit data
from or market to children under 18 years of age. By using the Services,
you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of the
Services. If we learn that personal information from users less than 18
years of age has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records. If you
become aware of any data we may have collected from children under age 18,
please contact us at Accounts@smithsonthesquare.com.
10. WHAT ARE YOUR PRIVACY
RIGHTS?
In
Short:In some
regions, such as Canada, you have rights that allow you greater access
to and control over your personal information.You
may review, change, or terminate your account at any time.
In some regions (like Canada),
you have certain rights under applicable data protection laws. These may
include the right (i) to request access and obtain a copy of your personal
information, (ii) to request rectification or erasure; (iii) to restrict
the processing of your personal information; and (iv) if applicable, to
data portability. In certain circumstances, you may also have the right to
object to the processing of your personal information. You can make such a
request by contacting us by using the contact details provided in the
section "HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?" below.
We will consider and act upon
any request in accordance with applicable data protection
laws.
If you are located in the EEA or
UK and you believe we are unlawfully processing your personal information,
you also have the right to complain to your Member State
data protection
authority
or UK data protection
authority.
If you are located in
Switzerland, you may contact the Federal Data Protection and Information
Commissioner.
Withdrawing your
consent:
If we are relying on your consent to process
your personal information, which may be express and/or implied consent
depending on the applicable law, you have the right to withdraw your
consent at any time. You can withdraw your consent at any time by
contacting us by using the contact details provided in the section
"HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?" below.
However, please
note that this will not affect the lawfulness of the processing before its
withdrawal nor, when applicable law allows, will it affect the processing of
your personal information conducted in reliance on lawful processing grounds
other than consent.
Opting out of marketing and
promotional
communications:
You can
unsubscribe from our marketing and promotional communications at any time by
clicking on the unsubscribe link in the emails that we send, replying "STOP"
or "UNSUBSCRIBE" to the SMS messages that we send, Reply "stop" to any
Email, or by contacting us using the details provided in the section
"HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the
marketing lists. However, we may still communicate with you — for example,
to send you service-related messages that are necessary for the
administration and use of your account, to respond to service requests, or
for other non-marketing purposes.
Account
Information
If you would at
any time like to review or change the information in your account or
terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to terminate your account,
we will deactivate or delete your account and information from our active
databases. However, we may retain some information in our files to prevent
fraud, troubleshoot problems, assist with any investigations, enforce our
legal terms and/or comply with applicable legal
requirements.
Cookies and similar
technologies:
Most Web browsers are set to accept cookies
by default. If you prefer, you can usually choose to set your browser to
remove cookies and to reject cookies. If you choose to remove cookies or
reject cookies, this could affect certain features or services of our
Services.
If you have questions or comments about your
privacy rights, you may email us at
accounts@smithsonthesquare.com.
11. CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web browsers and some
mobile operating systems and mobile applications include a Do-Not-Track
("DNT") feature or setting you can activate to signal your privacy
preference not to have data about your online browsing activities
monitored and collected. At this stage no uniform technology standard for
recognizing and implementing DNT signals has been finalized. As such, we
do not currently respond to DNT browser signals or any other mechanism
that automatically communicates your choice not to be tracked online. If a
standard for online tracking is adopted that we must follow in the future,
we will inform you about that practice in a revised version of this
privacy notice.
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?
In
Short: Yes, if you are a resident of
California, you are granted specific rights regarding access to your
personal information.
California Civil Code Section
1798.83, also known as the "Shine The Light" law, permits our users who
are California residents to request and obtain from us, once a year and
free of charge, information about categories of personal information (if
any) we disclosed to third parties for direct marketing purposes and the
names and addresses of all third parties with which we shared personal
information in the immediately preceding calendar year. If you are a
California resident and would like to make such a request, please submit
your request in writing to us using the contact information provided
below.
If you are under 18 years of
age, reside in California, and have a registered account with Services,
you have the right to request removal of unwanted data that you publicly
post on the Services. To request removal of such data, please contact us
using the contact information provided below and include the email address
associated with your account and a statement that you reside in
California. We will make sure the data is not publicly displayed on the
Services, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of
Regulations defines a "resident"
as:
(1) every individual who is in
the State of California for other than a temporary or transitory purpose
and
(2) every individual who is
domiciled in the State of California who is outside the State of
California for a temporary or transitory purpose
All other individuals are
defined as "non-residents."
If this definition of "resident"
applies to you, we must adhere to certain rights and obligations regarding
your personal information.
What categories of
personal information do we collect?
We have collected the following
categories of personal information in the past twelve (12) months:
Category | Examples | Collected |
A.
Identifiers | Contact details, such
as real name, alias, postal address, telephone or mobile contact
number, unique personal identifier, online identifier, Internet
Protocol address, email address, and account
name | YES |
B. Personal
information categories listed in the California Customer Records
statute | Name, contact
information, education, employment, employment history, and
financial information | YES |
C. Protected
classification characteristics under California or federal
law | Gender and date of
birth | YES |
D. Commercial
information | Transaction
information, purchase history, financial details, and payment
information | YES |
E. Biometric
information | Fingerprints and
voiceprints | NO
|
F. Internet or other
similar network activity | Browsing history,
search history, online behavior, interest data, and interactions
with our and other websites, applications, systems, and
advertisements | NO
|
G. Geolocation
data | Device
location | YES |
H. Audio, electronic,
visual, thermal, olfactory, or similar
information | Images and audio,
video or call recordings created in connection with our business
activities | NO
|
I. Professional or
employment-related information | Business contact
details in order to provide you our Services at a business level
or job title, work history, and professional qualifications if
you apply for a job with us | YES |
J. Education
Information | Student records and
directory information | YES |
K. Inferences drawn
from other personal information | Inferences drawn from
any of the collected personal information listed above to create
a profile or summary about, for example, an individual’s
preferences and characteristics | YES |
L. Sensitive Personal Information | Account login information, contents of email or text messages, debit or credit card numbers, drivers' licenses, social security numbers, state id card numbers, sex life or sexual orientation and religious or philosophical beliefs | YES |
We will use and retain the collected personal information as
needed to provide the Services or for:
- Category A - As long as the user has an account with us
- Category B - As long as the user has an account with us
- Category C - As long as the user has an account with us
- Category D - As long as the user has an account with us
- Category G - As long as the user has an account with us
- Category I - As long as the user has an account with us
- Category J - As long as the user has an account with us
- Category K - As long as the user has an account with us
- Category L - As long as the user has an account with us
Category L information may
be used, or disclosed to a service provider or contractor, for
additional, specified purposes. You have the right to limit the use
or disclosure of your sensitive personal
information.
We may also collect other
personal information outside of these categories through instances
where you interact with us in person, online, or by phone or mail in
the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and
share your personal information?
We collect and share your
personal information through:
- Targeting cookies/Marketing cookies
- Social media cookies
- Beacons/Pixels/Tags
- Social media plugins: instafeed and __________. We use social media features, such as a "Like" button, and widgets, such as a "Share" button, in our Services. Such features may process your Internet Protocol (IP) address and track which page you are visiting on our website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with a widget or button belonging to that social media platform, this information may be recorded to your profile of such social media platform. To avoid this, you should log out from that social media platform before accessing or using the Services. Social media features and widgets may be hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy notices of the companies that provide them. By clicking on one of these buttons, you agree to the use of this plugin and consequently the transfer of personal information to the corresponding social media service. We have no control over the essence and extent of these transmitted data or their additional processing.
More information
about our data collection and sharing practices can be found
in this privacy
notice.
You may contact us by
email at Accounts@Smithsonthesquare.com,
by calling toll-free at 317-773-3383, by
visiting https://www.smithsonthesquare.com/pages/contact-us,
or
by referring to the contact details at the bottom of this
document.
If you are using an
authorized agent to exercise your right to opt out we may deny a
request if the authorized agent does not submit proof that they
have been validly authorized to act on your
behalf.
Will your
information be shared with anyone
else?
We may disclose your
personal information with our service providers pursuant to a
written contract between us and each service provider. Each
service provider is a for-profit entity that processes the
information on our behalf, following the same strict privacy
protection obligations mandated by the CCPA.
We may use your personal
information for our own business purposes, such as for undertaking
internal research for technological development and demonstration.
This is not considered to be "selling" of your personal
information.
We have not sold or shared any personal
information to third parties for a business or commercial purpose in
the preceding twelve (12) months. We have disclosed the following
categories of personal information to third parties for a
business or commercial purpose in the preceding twelve (12)
months:
The
categories of third parties to whom we disclosed
personal information for a business or commercial
purpose can be found under "WHEN AND WITH WHOM DO WE
SHARE YOUR PERSONAL INFORMATION?".
Your
rights with respect to your personal
data
Right
to request deletion of the data — Request to
delete
You can
ask for the deletion of your personal information.
If you ask us to delete your personal information,
we will respect your request and delete your
personal information, subject to certain
exceptions provided by law, such as (but not
limited to) the exercise by another consumer of
his or her right to free speech, our compliance
requirements resulting from a legal obligation, or
any processing that may be required to protect
against illegal activities.
Right
to be informed — Request to
know
Depending
on the circumstances, you have a right to
know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell or share personal information to third parties;
- the categories of personal information that we sold, shared, or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- the business or commercial purpose for collecting, selling, or sharing personal information; and
- the specific pieces of personal information we collected about you.
In
accordance with applicable law, we are not
obligated to provide or delete consumer
information that is de-identified in response to a
consumer request or to re-identify individual data
to verify a consumer request.
Right
to Non-Discrimination for the Exercise of a
Consumer’s Privacy
Rights
We will
not discriminate against you if you exercise your
privacy rights.
Right to Limit Use
and Disclosure of Sensitive Personal
Information
If the business
collects any of the following:
- social security information, drivers' licenses, state ID cards, passport numbers
- account login information
- credit card numbers, financial account information, or credentials allowing access to such accounts
- precise geolocation
- racial or ethnic origin, religious or philosophical beliefs, union membership
- the contents of email and text, unless the business is the intended recipient of the communication
- genetic data, biometric data, and health data
- data concerning sexual orientation and sex life
you have the right to
direct that business to limit its use of your
sensitive personal information to that use which is
necessary to perform the Services.
Once a business
receives your request, they are no longer allowed to
use or disclose your sensitive personal information
for any other purpose unless you provide consent for
the use or disclosure of sensitive personal
information for additional purposes.
Please note that
sensitive personal information that is collected or
processed without the purpose of inferring
characteristics about a consumer is not covered by
this right, as well as the publicly available
information.
To exercise your right
to limit use and disclosure of sensitive personal
information, please email
accounts@smithsonthesquare.com or submit a data subject access
request.
Verification
process
Upon
receiving your request, we will need to verify
your identity to determine you are the same person
about whom we have the information in our system.
These verification efforts require us to ask you
to provide information so that we can match it
with information you have previously provided us.
For instance, depending on the type of request you
submit, we may ask you to provide certain
information so that we can match the information
you provide with the information we already have
on file, or we may contact you through a
communication method (e.g., phone or email) that
you have previously provided to us. We may also
use other verification methods as the
circumstances dictate.
We will
only use personal information provided in your
request to verify your identity or authority to
make the request. To the extent possible, we will
avoid requesting additional information from you
for the purposes of verification. However, if we
cannot verify your identity from the information
already maintained by us, we may request that you
provide additional information for the purposes of
verifying your identity and for security or
fraud-prevention purposes. We will delete such
additionally provided information as soon as we
finish verifying you.
Other
privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To
exercise these rights, you can contact
us by
email at Accounts@Smithsonthesquare.com, by
calling toll-free at 317-773-3383, by
visiting https://www.smithsonthesquare.com/pages/contact-us,
or
by referring to the contact details at the bottom of
this document. If you have a complaint about how we
handle your data, we would like to hear from
you.
13. DO VIRGINIA RESIDENTS
HAVE SPECIFIC PRIVACY
RIGHTS?
In
Short: Yes, if you
are a resident of Virginia, you may be granted
specific rights regarding access to and use of
your personal information.
Virginia CDPA
Privacy Notice
Under the Virginia
Consumer Data Protection Act (CDPA):
"Consumer" means a
natural person who is a resident of the Commonwealth
acting only in an individual or household context.
It does not include a natural person acting in a
commercial or employment context.
"Personal data" means
any information that is linked or reasonably
linkable to an identified or identifiable natural
person. "Personal data" does not include
de-identified data or publicly available
information.
"Sale of personal data"
means the exchange of personal data for monetary
consideration.
If this definition
"consumer" applies to you, we must adhere to certain
rights and obligations regarding your personal
data.
The information we
collect, use, and disclose about you will vary
depending on how you interact with us and our
Services. To find out more, please visit the
following links:
Your rights with
respect to your personal data
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
We have not sold any personal
data to third parties for business or commercial
purposes. We will not sell personal data in the future
belonging to website visitors, users, and other
consumers.
Exercise your rights
provided under the Virginia CDPA
More information about our
data collection and sharing practices can be found in
this privacy notice.
You may contact us by
email at accounts@smithsonthesquare.com, by
submitting a data subject access
request, or by referring to the
contact details at the bottom of this
document.
If you are using an
authorized agent to exercise your rights, we may
deny a request if the authorized agent does not
submit proof that they have been validly authorized
to act on your behalf.
Verification
process
We may request that you
provide additional information reasonably necessary
to verify you and your consumer's request. If you
submit the request through an authorized agent, we
may need to collect additional information to verify
your identity before processing your
request.
Upon receiving your
request, we will respond without undue delay, but in
all cases, within forty-five (45) days of receipt.
The response period may be extended once by
forty-five (45) additional days when reasonably
necessary. We will inform you of any such extension
within the initial 45-day response period, together
with the reason for the extension.
Right to
appeal
If we decline to
take action regarding your request, we will inform
you of our decision and reasoning behind
it. If you wish to appeal our
decision, please email us at
accounts@smithsonthesquare.com. Within sixty (60)
days of receipt of an appeal, we will inform you in
writing of any action taken or not taken in response
to the appeal, including a written explanation of
the reasons for the decisions. If your appeal if
denied, you may contact the Attorney General to
submit a complaint.
14. DO WE MAKE
UPDATES TO THIS
NOTICE?
In
Short: Yes, we will update this
notice as necessary to stay compliant with
relevant laws.
We may
update this privacy notice from time to time. The
updated version will be indicated by an updated
"Revised" date and the updated version will be
effective as soon as it is accessible. If we make
material changes to this privacy notice, we may
notify you either by prominently posting a notice
of such changes or by directly sending you a
notification. We encourage you to review this
privacy notice frequently to be informed of how we
are protecting your
information.
15. HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
If you
have questions or comments about this notice, you
may email
us at
Accounts@smithsonthesquare.com or
contact us by post
at:
Legacy Jewelers
LLC
98 North 9th Street
noblesville, IN
46060
United States
16. HOW CAN YOU
REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM
YOU?
Based on
the applicable laws of your country, you may have
the right to request access to the personal
information we collect from you, change that
information, or delete it. To request to review,
update, or delete your personal information,
please fill out and submit a data subject access
request.