Privacy Policy

The Natural Diamond Council (“NDC” or “we”) recognize the importance of protecting the privacy of your personal information, and we have prepared this Privacy Policy to provide you with important information about our privacy practices.  This Privacy Policy applies when you use any website, application, or other online service that links to or refers to this Privacy Policy and that is owned and operated by NDC (the “Services”).  As a non-profit organization (as that term is defined under applicable laws), NDC will comply with jurisdictional privacy laws to the extent required by applicable laws. This Privacy Policy does not apply to information collected through other websites or online services.

By using the Services, you consent to the practices described in this Privacy Policy.  Please take a moment to review the terms of our Privacy Policy.  If you have any questions about this Privacy Policy, please contact us at info@naturaldiamonds.com.

Information We Collect

We may collect personal information about our users in various ways. For example, we may collect information that you provide to us, information that we collect through your use of the Services, and information that we collect from publicly available sources or third parties.

**Information You Provide to Us.  In order to take advantage of certain Services or features offered or provided on the Services, you may be asked to provide personal information, such as your name, e-mail address, mailing address and phone number. For example, we will collect certain personal information if you sign up to receive updates and newsletters, register for an event, send questions or comments to us via e-mail, or request information from us.  We also may collect other information that you provide us or authorize us to access.  For example, if you register any other person for an event, we may collect the name, e-mail address, and any other information that you provide us.

Information About Use of the Services.  We may collect information about your devices and information about your use of the Services and online activity.

• We may collect information concerning your computer and other devices used to access the Services. For example, we may collect your IP address and other unique device identifiers, operating system version, hardware model, and settings of the device you use to access the Services.  Depending on your permissions, we also may collect information that is stored on your device.

• We also may collect information about the Services you use, your interactions with content offered through the Services, and other online activity. For example, we may collect information about how many visitors visit a specific page on the Services, how long they stay on that page, and which hyperlinks, if any, they click on. We collect this information, in part, through the use of technologies such as cookies and web beacons, which are discussed in greater detail below. We may also group this information into aggregate visitor data.

• When you use location-enabled services, we also may collect specific location information drawn from your device’s GPS, Bluetooth, or WiFi signals.

Information From Third-Party Sources. We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you.

How We Use Information**

**To Provide and Manage the Services You Request.  If you provide us with personal information, we will retain and use that information to provide you with the products or services you use or request.  We may also use personal information to analyze, improve, and customize your experience with our products and services, including the Services.

To Contact You. We may use your personal information to respond to questions that you may submit to us via the Services or to communicate with you about our services, and promotions, such as e-mailing press releases, association announcements, and industry related information. If you provide a resume to us through the Services, we may retain your resume in our files in order to contact you for current or future job openings.

To Better Understand Our Users. We may use information we gather to determine which areas of the Services are most frequently visited to understand how to enhance the Services.

To Deliver Targeted Advertising.  We may use your information to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and advertisers, on and off the Services. Please see Online Tracking and Advertising for further information about our and third parties’ use of tracking technologies to provide you relevant ads, as well as information about how to disable cookies and make other choices related to targeted advertising.

Sharing of Information**

Except for the limited situations discussed in this Privacy Policy, we will not share your personal information with third parties.

**Service Providers. We rely on third parties to perform a variety of services for us, such as sending postal mail and providing data analysis.  To do so, we may need to provide your personal information to those businesses.

Other Parties When Required by Law or As Necessary to Protect Our Services.  We reserve the right to disclose visitor information in cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other visitors, or anyone else that could be harmed by such activities. We also reserve the right to disclose visitor information when we believe in good faith that the law requires it or when doing so is necessary to respond to a government request.

Otherwise With Your Consent or At Your Direction. In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you consent to or direct such sharing.

We also may share other information with third parties in a manner that does not identify particular visitors, including, for example, aggregate information about how the Services are used.

Cookie Policy

This Cookie Policy explains how the Natural Diamond Council (“NDC”, “we”, “us”) uses cookies and similar tracking technologies on the Services. It supplements the Privacy Policy above, which describes more broadly how we collect and use your information.

What are cookies and similar tracking technologies?**

Cookies are small files that are placed on your computer or device when you visit a website. Cookies may be used to store a unique identification number tied to your device so that you can be recognised as the same user across browsing sessions and across sites. Cookies serve many useful purposes — for example, remembering your preferences, keeping you signed in, or enabling site features to load correctly.

We, and certain third parties, also use other tracking technologies on the Services, including web beacons (also called “pixels”) — small pieces of code embedded in pages or emails that signal to a server when content has been viewed; software development kits (SDKs) — code libraries used inside mobile or third-party platforms that enable similar tracking; and local storage and similar technologies — browser-based storage that can perform functions similar to cookies. For convenience, in this policy we refer to all of the above collectively as “cookies”.

Why we use cookies

We and third parties that provide content, advertising, or functionality on our Services use cookies to: operate and secure the Services and remember your preferences (Strictly Necessary); understand how visitors use the Services and improve them (Performance / Analytics); provide a more personalised experience, such as remembering settings or supporting embedded features (Functional); and deliver advertising that may be more relevant to your interests, on our Services and on other sites, including by combining information about your use of one device with information about your use of other devices (Targeting / Advertising).

Cookies used on this site

The list below shows the specific cookies and tracking technologies in use on the Services, grouped by the categories above. It is maintained by our consent management platform and updated as our use of cookies changes.

Third-party services we use

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). To learn more about how Google collects and processes data, please visit https://policies.google.com/privacy.

We may also work with advertising technology providers and social platforms that set their own cookies on the Services. These third parties are listed in the cookie inventory above, and their use of information is governed by their own privacy policies.

Your choices: cookie preferences

You can review and change your cookie preferences at any time. In regions where prior consent is required (including the European Union, the European Economic Area, the United Kingdom, India, Saudi Arabia, and the United Arab Emirates), our cookie banner appears on first visit and lets you accept or refuse non-essential cookies before any are set. To change your preferences afterwards, click the “Cookie Settings” link in the footer of any page.

Your privacy choices (United States)

If you are a resident of California or another US state with applicable privacy laws, you have the right to opt out of the “sale” or “sharing” of your personal information for cross-context behavioural advertising. To exercise this right, use the “Your Privacy Choices” or “Do Not Sell or Share My Personal Information” link in the footer of any page.

Global Privacy Control (GPC)

We honour the Global Privacy Control browser signal as a valid opt-out of the “sale” and “sharing” of personal information for US visitors. If your browser is configured to send the GPC signal, we will automatically treat it as an opt-out for that device, and you do not need to take any further action.

Browser controls

Most browsers are initially set up to accept cookies. Your browser may offer settings that allow you to choose whether browser cookies are set and to delete them — for example, you may be able to configure your browser not to accept cookies, or to notify you when a cookie is being sent. For more information about whether these settings are available, what they do, and how they work, please visit your browser’s help material. Please be aware that some features of the Services may not function properly or may be slower if you disable cookies.

Industry opt-outs

Google provides tools to opt out of certain Google Analytics data collection at https://tools.google.com/dlpage/gaoptout and of Google Display Advertising at https://www.google.com/settings/ads.

Many of the companies we work with to provide interest-based advertising participate in the Digital Advertising Alliance (“DAA”) and the Network Advertising Initiative (“NAI”). To opt out of interest-based advertising from participating companies, please visit https://www.aboutads.info/choices and https://www.networkadvertising.org/choices/ for website opt-outs, and https://www.aboutads.info/appchoices for mobile opt-outs. Opting out through these links only means that the selected participants should no longer deliver interest-based advertising to you; it does not mean those participants will stop processing your information for advertising purposes, or that you will not receive interest-based advertising from other companies.

These opt-outs apply only to the specific browser or device from which you opt out. We are not responsible for the effectiveness of opt-outs offered by other entities.

Email communications

You can unsubscribe from promotional emails by following the unsubscribe instructions at the bottom of any such email, or by emailing us at info@naturaldiamonds.com with “UNSUBSCRIBE” in the subject line. Please note that you cannot opt out of transactional messages necessary to provide the Services.

Changes to this Cookie Policy

We may update this Cookie Policy from time to time. When we do, we will revise the “Effective” date at the top of this page. Where required, we will obtain your renewed consent to material changes.

Other Privacy Policy sections

Links to Other Sites

We provide links to websites or resources outside of our Services for your informational purposes only. These other sites may send their own cookies to you, collect data or solicit personal information from you. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of any of your personal information that you provide or is collected by such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites.

Security

We have adopted physical, technical, and administrative safeguards to help protect against theft, loss, misuse, and unauthorized access to or disclosure of the information we collect and receive. However, please note that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your personal information.

Children’s Privacy

We do not knowingly collect information from children under the age of 18 on the Services.  If you are under the age of 18, please do not provide any personal information to us.  If you believe we have gathered your information in a manner inconsistent with this Privacy Policy, contact us at info@naturaldiamonds.com.

California Shine the Light

California residents are entitled once, per calendar year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year.  To exercise a request, please write us at the email or postal address set out in “Contact Us” below and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity. We do not share personal information with third parties for their own direct marketing purposes.

Processing of personal data relating to data subjects located in the European Union

Any processing of personal data of data subjects who are in the European Union (‘EU’) is governed by the applicable legislation on the protection of personal data, including the General Data Protection Regulation 2016/679 (‘GDPR’) and the relevant national legislation, where the processing activities are related to the offering of goods or services to such data subjects.

• Pursuant to the applicable data protection legislation, we would like to inform you of the legal basis for processing your personal data (i), the place of data processing (ii), the data retention period (iii) the rights you have relating to the personal data we hold about you (iv) and the contact details of our Representative in the EU (in addition to the above-mentioned information regarding the categories of data processed, the purposes of data processing, and information regarding data sharing). Legal basis for data processing

** **We are only authorized to use and process your personal data if one of the following conditions is met:

• The use of your personal data is necessary for the performance of a contract you have entered into with us or to take the necessary measures to enter into this contract at your request.

• We have your free and explicit consent to use your personal data for a specific purpose (for example, by signing up to our newsletter).

• Your personal data are used in line with our legitimate interests and in accordance with your interests and rights (for example, collecting and saving your IP address in order to secure our website).

• We are legally required to process and communicate certain data to the competent authorities.

• Place of data processing

Since our host servers are located in the United States of America, your personal data are transferred outside the European Economic Area (EEA)/ European Union (EU).

In order to guarantee the same level of protection as that in force under the GDPR, we have framed the transfer of your personal data by one of the mechanisms provided for in Chapter V of the GDPR.

• Data retention period

We will only retain your information to the extent necessary to achieve the objectives specified in this Privacy policy.

Given that the need to retain data depends on the type of data and the purpose of the processing, retention periods may vary considerably. Here are the criteria we go by to determine retention periods:

• How long do we need the data to provide the service requested?

• Have we established and announced a specific retention period?

• Have we obtained consent to extend the retention period?

• Are we subject to a legal, contractual or other obligation?

As soon as we no longer need your data and are no longer legally required to retain them, we permanently delete them or, if this is not possible, we anonymize them in our system.

• Rights of data subjects

You have certain rights relating to the personal data we hold about you:

• Right to be informed: You have the right to be informed, no later than when your data are collected, about the processing we carry out, your rights relating thereto and the exercise of these rights. This being the case, we have drawn up this Privacy Policy.

• Right of access: You have the right to view the information concerning you and to obtain a copy of the information we hold.

• Right of rectification: If your personal data have changed, you may ask us to rectify, supplement or delete any out-of-date, incorrect or incomplete data we hold about you.

• Right of erasure: Under certain circumstances, you have the right to have the personal data that we hold about you erased, for example where such personal data are no longer necessary for the purposes for which they were collected or where you have withdrawn your consent and there is no other legal basis for the processing.

• Right of restriction: Under certain circumstances you have the right to request the limitation of the processing of your personal data. We may thus temporarily and/or partially stop the processing that is carried out. You may definitively stop a specific processing operation or all processing operations carried out by us on your personal data by appealing to the right to object.

• Right to object: If you do not agree with the way in which we process certain personal data on the basis of our legitimate interest, you have the right to object. We will accept this objection, unless our interests prevail over your rights and freedoms.

• Right of portability: Under certain circumstances you have the right to request that personal data that you personally provided to us – in a structured, commonly used and digital form – be forwarded to you so that you can store them for personal (re)use, or to forward such personal data directly to another data controller, to the extent that it is technically possible for us to do so.

Please note that in certain circumstances provided for by law, we may deny access to your information or not accept your request where we are permitted to do so by applicable data protection legislation.

To exercise the aforementioned rights, send us a written and dated request:

• By e-mail: [info@naturaldiamonds.com ]

We ask that you clearly state the right you want to invoke, which processing you wish to object to or restrict, or which consent you wish to withdraw.

In case of reasonable doubts, we may request additional information necessary to confirm your identity.

When you exercise your rights, you will not be charged unless we consider it to be a patently unfounded or excessive request. However, we may ask you to pay a reasonable sum not exceeding our copying costs for any request for an additional copy.

For any request relating to your rights, we will respond to your request within one month. Nevertheless, this period may be extended to two months if the request proves to be complex and/or due to the number of requests that we have to deal with. If this period is extended, we will inform you of this by telling you the reason for this decision.

If you feel that the processing of your personal data does not comply with the applicable legislation and/or that we did not act on your request, you have the right to lodge a complaint with the Belgian Data Protection Authority, Rue de la Presse, 35, B-1000 Brussels, T: +32 (0)2 274 48 00; F: +35 (35)2 274 48 35; contact@apd-gba.be https://www.autoriteprotectiondonnees.be/.

• Representative in the EU

We have appointed a Representative in the European Union.

The contact details of the Representative are the following:

• email: info@naturaldiamonds.com

Any questions that you may have regarding the protection of your personal data can be directed to our Representative.

Changes to Our Privacy Policy

We may modify this Privacy Policy from time to time. We recommend that you revisit this Privacy Policy periodically to ensure that you are aware of our current privacy practices, although we may also elect to notify you by e-mail or by posting something on some or all of our Services.  Your continued use of the Services following the posting of changes will mean you accept the Privacy Policy and any changes.

Contact Us

Any questions that you may have regarding this Privacy Policy should be directed to info@naturaldiamonds.com.