True Diamonds (together with its parent company and subsidiaries, if any, “TRUDIA LLC.”) operates the True Diamonds website (the “Site”) and related mobile applications and software (collectively with the Site, the “Service”), which enable people to create and subscribe to content channels and access exclusive audio clips, videos, photos, and direct events (collectively, “Content”) all in real time. The Content is available for free or at premium with discretion to share and subscribe.
Children The Service is not intended for or directed to persons under the age of 13, and we will not knowingly collect information from such persons. Any person who provides information to us through registration or in any other manner on the Site or the Service represents to True Diamonds that they are 13 years of age or older. If we learn that a child under 13 has submitted personal information to us, we will attempt to delete the information as soon as possible. If you believe that a child has provided us with personal information, please contact us at firstname.lastname@example.org.
Collection of Information “Personally Identifiable Information” means any information which can be used to identify an individual, and may include, but is not limited to, name, email address, postal or other physical address, title, or occupation.
We may collect the following Personally Identifiable Information from you when you register for or use the Service: name, email, phone number, credit card payment information, other payment information, and billing address.
We may collect information when you register to join the Service by logging into an account that you already have with certain third-party social networking sites (“SNS”) (including, but not limited to, Facebook and Twitter) via the Service. By connecting to the Service with SNS, you give us permission to access, store and use your information from the SNS, including, but not limited to, your Personally Identifiable Information, any information that you have permitted the SNS to share with us, any information you have made public in connection with that service, any interests that are not hidden and mutual friends that you may have in common with other users. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Service.
We also automatically receive and record information on our server logs from your browser, including without limitation your IP address, cookie information (as described below), and the page(s) you request.
We also reserve the right to anonymously track and report a userʼs activity inside the Site and mobile applications.
Some of the pages on the Site may contain “cookies.” A cookie is a small data file that may be sent to your Web browser and stored on your computer. This allows our server to “recognize” you when your computer visits the Site in the future. Most Web browsers can be configured to not accept cookies, or to notify you if a cookie is sent to you. In some instances, True Diamonds may collect non-Personally Identifiable Information (aggregate or demographic data) through cookies.
- Information Use True Diamonds uses Personally Identifiable Information for several general purposes: to provide you with product and service information, demos, and news regarding the Service, to support the products and services offered on or through the Service, to fulfill your subscription requests, to process your payments including credit checks and collection, to notify you of technical updates or changes in policy, or We may use non-Personally Identifiable Information such as demographic data to analyze and develop our marketing strategy and further improve the Service and our other products and services.
You also may have the option to import your personal contacts (including email addresses of friend lists via SNS) to the Service so that you can find your friends on the Service, and your friends can find you on the Service.
Information Sharing and Disclosure
We may share the information in your True Diamonds account (including your Personally Identifiable Information) with the SNSs that you have linked to your account. These third parties have access to your Personally Identifiable Information only for this purpose (unless the SNS has received your Personally Identifiable Information independently of the Service) and not for other purposes.
Third Party Privacy Policies
You should also be aware that if you submit information to “comments feeds” and similar public communications channels, through the Service or otherwise, then such information becomes public information, meaning that you risk losing any privacy rights you might have with regards to that information. Such disclosures may also increase your chances of receiving unwanted communications from third parties.
Access You may correct, amend, or delete your Personally Identifiable Information by editing your profile on the Site or emailing us at email@example.com.
We are committed to protecting Personally Identifiable Information from loss, misuse, disclosure, alteration, unauthorized access, and destruction. True Diamonds takes reasonable precautions to safeguard the confidentiality of Personally Identifiable Information. We protect the security of your Personally Identifiable Information during transmission to us by using Secure Sockets Layer (SSL) software, which encrypts the information you input. While we strive to protect your Personally Identifiable Information, we cannot ensure the security of the information you transmit to us in all cases.
International Transfers Personally Identifiable
Information collected on or through the Service may be stored and processed in the United States or any other country in which True Diamonds or its affiliates, subsidiaries or agents maintain facilities, and by using the Service, you consent to any such transfer of information outside of your country.
Effective date: October 22, 2018
Thank you for using True Diamonds! We take your privacy extremely seriously and would like to describe how we collect, use and protect your information when you access our website(s), products, services and applications (collectively, the “Services”).
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. TRUDIA LLC. (“True Diamonds”) will be the controller of your Personal Data processed in connection with the Services.
Note that we may also process Personal Data of our customersʼ end users or employees in connection with our provision of Services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
What Personal Data Do We Collect From You?
We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
- Personal Contact Details: Full Name, Address, E-mail Address, Phone Number, Birthday Date, Country & City of Residence
- Purpose for Prospects: We process this type of Personal Data in order to market our Services to potential customers who have requested demonstrations of our Services.
- Legal Grounds: We process this type of Personal Data based on the consent you expressly grant to us at the time we collect such Personal Data.
- Purpose for Customers: We process this type of Personal Data in order to create an account for you and to provide you our Services.
- Legal Grounds: We process this type of Personal Data for our legitimate interests in providing the Services and associated support.
- Other Personal Details: Type of Browser, page and/or feature selection, certain cookie information, Device type, Device ID, IP Address and associated Location Data
- Purpose: We process this type of Personal Data in order to provide you our Services.
- Legal Grounds: We process this type of Personal Data for our legitimate interests in providing the Services and performing web analytics to improve the Services and understand how our customers interact with the Services.
How and With Whom Do We Share Your Data?
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
- Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services) Social media services (if you interact with them through your use of the Services)
- Third party business partners who you access through the Services (e.g. third party applications)
- Other parties authorized by you
- We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).
- We also share Personal Data when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
- Protect us, our business or our users, for example to enforce our Terms of Service, prevent spam or other unwanted communications and investigate or protect against fraud
- Maintain the security of our products and services
If we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as you have an open account with us and for 6 months after you close your account. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally. However, user signup data (your name, your email address, and the fact that you were a True Diamonds user) may be retained in third- party analytics services beyond closure of your account, unless you request that your data be deleted.
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device which may include “cookie” information. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. Note that in the past, True Diamonds used cookies with longer expiration times. Delete your cookies to get the new cookies.
What Security Measures Do We Use?
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. For example, True Diamonds is continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction or alteration. Some of the safeguards we use to protect Personal Data are firewalls, data encryption, and information access controls.
Personal Data of Children
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email firstname.lastname@example.org.
Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by accessing your account settings.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by accessing your account settings.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about True Diamonds’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data
The Services are hosted and operated in USA, specifically, hosted in Oregon and operated from USA, through True Diamonds and its service providers. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to True Diamonds in USA and will be hosted on servers in USA, and you authorize True Diamonds to transfer, store and process your information to and in the USA and possibly other countries.
What If You Have Questions Regarding Your Personal Data?
If you have any questions about this GDPR Privacy Notice or our data practices generally, please contact us using the following information:
Name: TRUDIA LLC.
South Ozone Park, New York
Email address for contact: email@example.com