2024 UNI all rights reserved
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UNI Luxury Group Limited and UNI Luxury USA INC are the authorized users and distributors of
UNI.Diamonds
(available at https://www.uni.diamonds and as
may be made available through U.N.I's mobile application) ("Platform"), a professional diamond
business to
business trading Platform developed and owned by U.N.I Technologies Ltd ("U.N.I Technologies").
UNI Luxury
Group Limited, UNI Luxury USA INC, U.N.I Technologies Ltd and their respective affiliates,
parent companies,
subsidiaries and related entities shall hereinafter be referred to as: "U.N.I" or "we" or "us"
or "our".
We, at U.N.I, put great efforts in making sure that we secure your personally identifiable
information and
use it properly.
This policy explains our privacy practices for processing your personally identifiable
information as a
user of our services through the Platform, through ancillary services related to the Platform
and through
other registration or contact channels, including our know-you-client ("KYC"), your Platform
onboarding
processes, your diamond inventory uploading to the Platform and diamond validation, certificate
verification, non-lab-grown cross-check, gemology inspection, appraisal details and periodic
value update,
call centers, sales man, customer support, storage and safekeeping at Malca Amit, logistic
delivery,
insurance, collection, payment balance settlement and other procedures and policies
(collectively:
"Service"). We will process your personally identifiable information subject to the terms of
this privacy
policy.
The summary of this policy will give you a quick and clear view of our practices. Please
take the time
to read our full policy.
The Personally Identifiable Information That You Provide Us – We receive and store any
information you
enter on our Platform or give us in any other way, including your usability and activity
information and
other information you provide before registering as a user to the Platform, or during our KYC
procedures. If
you register with the Service and/or go through our KYC procedure we will need, inter alia, your
entity
name, entity type, date of incorporation, principal business address, nature of business,
specification of
countries in which business is transacted, details of key persons, shareholders and officers
(including
names, positions, nationalities, ownership percentage (with respect to shareholders)) and such
other
information as further elaborated in our KYC form. In addition to the registration and KYC
details, you may
be required to provide payment and full bank account details, financial information such as your
annual
turnover, reference customers, and additional information as may be required by anti-money
laundering (AML)
and counterterrorism regulations and such other applicable regulatory obligations. We may also
ask for your
email and/or phone number in order to contact you, subject to the terms of this policy. Please
note that we
may also receive any personally identifiable information that you provide when contacting us. Read More
Sources of the Personally Identifiable Information That We Collect – Most of the
information we
collect comes directly from you. Subject to your consent, we also collect and share information
with
Malca-Amit group companies as part of our KYC procedures in order to, inter alia, cross-verify
the
information you provide us and receive such other information which we deem necessary in order
to determine
you eligibility to receive the Services (such as blacklisting, transaction history, etc.).
Subject to
applicable law, we may also collect information from other third parties and databases,
including under such
cases where we are required do to so under applicable anti-money laundering and counterterrorism
laws to
which we are subject. Read
More
The Personally Identifiable Information That You Upload – You may upload content with
personally
identifiable information. Please use caution and do not upload personally identifiable
information of others
without their appropriate consent. Read More
What Do We Do With Personally Identifiable Information? We use the information we collect
and receive
to determine you eligibility to receive the Service and Service level, to enable, provide and
maintain the
Service, to execute and collect proceeds for the transaction in the Service, to study and
analyze the
functionality of the Service and users' experience, to make it better, continue developing it
and protect
us, our customers and the Service from misuse and law violations.
Read More
Sharing Information with Others – We do not sell, rent or lease your personally
identifiable
information. We will share your personally identifiable information with service providers and
other third
parties, if necessary to fulfill the purposes for collecting such information and deliver the
Service to
you.
Any such third party will commit to protect your privacy as required under applicable law
and this
policy. We may also use service providers, for example, to provide support and send email and
mobile
messages. We will transfer information if we change our corporate structure, and we will share
the
information with our affiliated entities (e.g. subsidiaries or future parent or sister companies
of U.N.I),
who will be subject to this policy.
Read More
Disclosure of Information to Authorities – We will obey orders and other lawful
requirements by
authorities to disclose information.
Read More
Aggregated and Analytical Information – Aggregated data is not identifiable. We use it
for legitimate
business purposes.
Read More
Your Choice – You may opt-out of our mailing lists and exercise further opt-out rights.
Read More
Accessing Your Personally Identifiable Information - At any time you can request access
to your
personally identifiable information.
Read More
Your EU Data Subject Rights – If we process your personal data when you are in the EU,
further terms
apply to our processing in relation to your rights as a data subject under EU data protection
laws.
Read More
Data retention – We retain data to provide the service and for legitimate and lawful
purposes, as
further explained in the data retention section of the policy.
Read More
Transfer of Data Outside your Territory – We use multi-regional cloud-based services and
technologies, including those of third parties, to store and process data.
Read More
Cookies - We use cookies to make it easier for you to log-in and to facilitate Service
activities.
Read More
Information Security – We implement systems, applications and procedures to secure your
personally
identifiable information, to minimize the risks of theft, damage, loss of information, or
unauthorized
access or use of information.
Read More
Dispute Resolution – Contact us at: privacy@uni.diamonds or
write us for every request and complaint. We will make good-faith efforts to resolve any
existing or
potential dispute with you.
Read More
Changes to this Privacy Policy – We will update our policy from time to time after giving
proper
notice at the Platform.
Read More
Incorporation to the Terms of Service - This policy is an integral part of the U.N.I and
www.uni.diamonds Terms of Use as available at: Terms of Use and, if applicable, the Consignment
Agreement
and/or Loan Agreement entered into between you (or any entity affiliated to you) and us.
Read More
Contact Us – Please contact our Privacy Compliance Team at: privacy@uni.diamonds for further information.
Read More
We receive and store any information you enter on our Platform or give us in any other way,
including your
usability and activity information, information you provide during our KYC procedures or
customer support
calls, digital chat or any other means of communication.
If you register with the Service and/or go through our KYC procedure we will need, inter
alia, your
entity name, type, date of incorporation, principal business address, nature of business,
specification of
countries in which business is transacted, broker/dealer license number, diamond exchange or
burse member
name and number, details of key persons, shareholders and officers (including name, positions,
nationalities, ownership percentage (with respect to shareholders), and such other information
as further
elaborated in our KYC form.
In addition to the registration and KYC details, you may be required to provide payment and
full bank
account details, and additional financial and other information, as may be required by U.N.I
including, but
not limited to, anti-money laundering (AML) and counterterrorism regulation and such other
applicable
regulatory obligations.
Should you execute transactions through the Platform, we may also receive your payment
transaction
details from the payment service provider that processed your payment.
When you contact us, or when we contact you, we will receive, store and process any personally
identifiable
information that you provide us.
Most of the information we collect comes directly from you. Inter alia, we collect information
when you go
through our KYC procedures, when your register and use our Service, etc.
Subject to your consent, we also collect and share information from and with Malca-Amit
group
companies, including Malca-Amit Ltd. and any parent, subsidiaries and sister companies thereof,
as part of
our KYC procedures in order to, inter alia, cross-verify the information you provide us and
receive such
other information which we deem necessary in order to determine you eligibility to receive the
Services
(such as blacklisting, transaction history, etc.).
Subject to applicable law, we may also collect information from other third parties and
databases,
including under such cases where we are required do to so under applicable anti-money laundering
and
counterterrorism laws to which we are subject.
The content you upload to the Service, whether such content relates to you or to third parties,
whether such
content originated from your own device or from a third party device, be it a computer, mobile
phone, tablet
or any other device, including any data, text, graphic, audio and audio-visual files, may
include personally
identifiable information.
Please use caution when uploading the content and avoid any involuntary disclosure of your
personally
identifiable information or disclosure of others' personally identifiable information without
their consent.
We use the personally identifiable information we collect and receive to determine you
eligibility to
receive the Service, to provide the Service to you and to other users, to enable, perform and
execute the
Service's tools and features, to enhance users' experience with the Service, to study and
analyze the
functionality of the Service and users' activities, to provide support, to measure Service
activity, to
provide automatic updates of new versions of the Service, to maintain the Service, to make it
better and to
continue developing the Service.
We will use your email address and mobile phone number to contact you when necessary, to
send you
reminders and to provide you information and notices about the Service. We may include
commercial and
marketing information about our Service.
Subject to applicable law, we may use certain limited personal information about you, such
as your
email address, to hash it and to share it with social media platforms, such as Facebook and
Google, to
generate leads, drive traffic to our Platform or otherwise promote our Service. These processing
activities
are based on our legitimate interest in undertaking marketing activities to offer you products
or services
that may be of interest to you. The social media platforms with which we may share your personal
data are
not controlled or supervised by U.N.I. Therefore, any questions regarding how your social media
platform
service provider processes your personal data should be directed to such provider. Please note
that you may,
at any time, ask U.N.I. to cease processing your data for these direct marketing purposes by
sending an
e-mail to privacy@uni.diamonds.
We obey the law and expect you to do the same. If necessary, we will use your personally
identifiable
information to enforce our terms, policies and legal agreements, to comply with court orders and
warrants,
and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation,
infringements,
identity theft and any other misuse of the Service, and to take any action in any legal dispute
and
proceeding.
We do not sell, rent or lease your personally identifiable information. We will share your
personally
identifiable information with service providers and other third parties, if and to the extent
necessary to
fulfill the purposes for collecting such information and deliver the Service to you. Any such
third party
will commit to protect your privacy as required under applicable law and this policy.
Inter alia, we may share your personally identifiable information with third party
providers involved
in any of the following services associated with our Service: inspection and diamond certificate
verification, autonomous diamond gemological examination, video filming and imaging of the
diamonds, diamond
mark-to-market appraisal, diamond digital certificate issuance, safe storage of the diamonds,
insurance (as
and where applicable), marketing and international promotional campaigns of diamonds, diamond
industry
tradeshows participation, delivery of diamonds and payment charging and collection services,
subscription
processing, data analysis, marketing, promotion and advertising services, e-mail services,
hosting services,
costumer services and relationship management, Platform engagement tracking and enhancement thereof.
We only share the minimum data needed for data processors to perform the services for which
they were
contracted.
You may opt-out from any advertising communications by following the unsubscribe
instructions in our
marketing communication or by sending an e-mail to privacy@uni.diamonds. For more information about you
opt-out
options please refer to our "Choice" chapter in this policy.
We share your payment transaction details with the payment services providers, to process
and verify
your payments. We may use a service provider to manage our email, push notification and mobile
messages
transmission.
We share your personally identifiable information with Mixpanel, an analytics service company, for the purpose of tracking and enhancing Platform usage. We also share your personally identifiable information with Zoho, an online CRM service provider, for management of customer relationship.
We may also share your personally identifiable information with our affiliates. This means
companies
within the U.N.I. group and includes subsidiaries, sister-companies and parent companies,
subject to the
terms of this policy.
We will report or block any content that you upload (which may incorporate personally
identifiable
information), if we believe, in our sole discretion that such content is against the Terms of
Use, or
illegal or abusive or may violate any third-party rights.
Additionally, you are aware and agree that in the case of a merger, acquisition or any
other structural
change we may require to transfer your personally identifiable information to another entity, as
part of the
structural change, provided that the receiving entity will comply with this policy.
We will need to disclose personally identifiable information in response to lawful requests by
public
authorities, including to meet national security or law enforcement requirements.
We use standard analytics tools. The privacy practices of these tools are subject to their own
privacy
policies and they use their own cookies or similar technologies (such as tokens) to provide
their service
(for further information about cookies, please see the 'Cookies' section in this policy).
We use Google Analytics and we will use additional or other analytics tools, from time to
time, to
learn about how users use the Service, in support of our Service-related activities and
operations. For
further information about the Google Analytics privacy practices, please read their Privacy
Policy at:
http://www.google.com/analytics/learn/privacy.html.
We use anonymous, statistical or aggregated information and will share it with our partners
for
legitimate business purposes. It has no effect on your privacy, because there is no reasonable
way to
extract data from such information that we or others can associate specifically to you.
We will share your personally identifiable information only subject to the terms of this
policy, or
subject to your prior consent.
At any time, you can unsubscribe our mailing lists or newsletters, by sending us an opt-out
request to: privacy@uni.diamonds.
At any time, you can exercise your following opt-out options: (i) object to the disclosure
of your
personally identifiable information to a third party, other than to third parties who act as our
agents to
perform tasks on our behalf and under our instructions, or (ii) object to the use of your
personally
identifiable information for a purpose that is materially different from the purposes for which
we
originally collected such information, pursuant to this policy, or you subsequently authorized
such use. You
can exercise your choice by contacting us at: privacy@uni.diamonds.
We request and collect personally identifiable information that we need for the purposes
that we
describe in this policy. Following the termination or expiration of the Service, we will stop
collecting any
personally identifiable information from or about you. However, we will store and continue using
or making
available your personally identifiable information according to our data retention section in
this policy.
If you find that the information associated with you is not accurate, complete or up-to-date,
please provide
us the necessary information to correct it.
At any time, you can contact us at: privacy@uni.diamonds. and
request to access the personally identifiable information that we keep about you. We will ask
you to provide
us certain credentials to make sure that you are who you claim to be and will make good-faith
efforts to
locate your personally identifiable information that you request to access.
Under your right of access, you can obtain confirmation from us of whether we are
processing personally
identifiable information about you, receive a copy of that data, so that you could:
verify its accuracy and the lawfulness of its processing;
request the correction, amendment or deletion of your personally identifiable information
if it is
inaccurate or if you believe that the processing of your personally identifiable information is
in violation
of the applicable law. We will use judgement and due care to redact from the data which we will
make
available to you, personally identifiable information related to others.
If EU data protection laws apply to the processing of your personal data by U.N.I., then the following terms apply: U.N.I. Technologies Ltd. is the data controller in relation to the processing of the personal information that you provide to us when you use our Services. Our registered address is 21 Tuval St., Ramat Gan, Israel. Where U.N.I. processes your personal data as a data controller, then we process your personal data for the following lawful grounds:
In addition to your rights under other sections in this policy, you have the following rights:
A summary and further details about your rights under EU data protection laws, is available on
the EU
Commission's website at:
https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
Note that when you send us a request to exercise your rights, we will need to reasonably
authenticate your
identity and location. We will ask you to provide us credentials to make sure that you are who
you claim to
be and will ask you further questions to understand the nature and scope of your request.
If we need to delete your personal data following your request, it will take some time until we
completely
delete residual copies of your personal data from our active servers and from our backup
systems.
If you have any concerns about the way we process your personal data, you are welcome to contact
our privacy
team at:privacy@uni.diamonds. We will investigate your
inquiry and
make good-faith efforts to respond promptly.
We retain different types of personally identifiable information for different periods,
depending on the
purposes for processing the information, our legitimate business purposes as well as pursuant to
legal
requirements under the applicable law. Unless otherwise determined in accordance with applicable
law,
personally identifiable information is kept for no longer than necessary for the purposes for
which it is
being processed in accordance with this policy.
For example, we may need to keep the information about the payment transactions that you
made for
several years due to tax related requirements, for accounts settling, record keeping, archiving
and legal
issues.
We will maintain your contact details, to help us stay in contact with you. At any time
before or after
the termination of your account, you can contact our privacy team at: privacy@uni.diamonds and request to delete your
contact details.
Note that we may keep your details without using them unless necessary, and for the necessary
period to the
extent required in order to comply with legal obligations. We will keep aggregated
non-identifiable
information without limitation, and to the extent reasonable we will delete or de-identify
potentially
identifiable information, when we no longer need to process the information.
We use multi-regional cloud-based services to store and process data. From time to time, we will
make
operational decisions which will have an impact on the sites in which we maintain personally
identifiable
information. We make sure that our data hosting service providers, provide adequate
confidentiality and
security commitments.
If you are a resident in a jurisdiction where transfer of your personally identifiable
information to
another jurisdiction requires your consent, then you hereby provide us your express and
unambiguous consent
to such transfer. You can contact our privacy team at: privacy@uni.diamonds for further information about
data transfer.
Cookies are small files that a web server sends to a user's device, when the user browses
online. Your
device removes session cookies when you close your browser session. Persistent cookies last for
longer
periods. You can view the expiry date of each cookie, through your browser settings.
We may use both types. We may use persistent cookies or similar technologies (such as
tokens) to
remember your log-in details and make it easier for you to log-in the next time you access the
Service. We
may use this type of cookies and Session Cookies for additional purposes, such as content
adjustability, in
order to facilitate the use of the Service's features and tools.
Every browser allows you to manage your cookies preferences. You can block or remove
certain cookies or
all of them through your browser settings. Please bear in mind that blocking or removing cookies
will
influence your user experience with our Service. For example, disabling or blocking our cookies
will require
you to re-enter your log-in details, or even prevent you from using features of the Service.
We and our hosting services implement systems, applications and procedures to secure your
personally
identifiable information, to minimize the risks of theft, damage, loss of information, or
unauthorized
access or use of information.
These measures provide sound industry standard security. However, although we make efforts
to protect
your privacy, we cannot guarantee that the Service will be immune from any wrongdoings,
malfunctions,
unlawful interceptions or access, or other kinds of abuse and misuse.
We do periodical assessments of our data processing and privacy practices, to make sure that we
comply with
this policy, to update the policy when we believe that we need to, and to verify that we display
the policy
properly and in an accessible manner.
If you have any concerns about the way we process your personally identifiable information,
you are
welcome to contact our privacy team at: privacy@uni.diamonds, or
write to us at: U.N.I Technologies Ltd., 21 Tuval St., Ramat Gan, Israel. We will investigate
your query and
make good-faith efforts to resolve any existing or potential dispute with you.
From time to time, we will update this policy and post a revised policy with an updated
effective date. A
notice of updates will be communicated to the Platform's users by a notification through the
Platform or
through other communication means, subject to U.N.I's discretion.
Continuing to use the Service after the new policy takes effect means that you agree to the
new policy.
Note that if we need to adapt the policy to legal requirements, the new policy will become
effective
immediately or as required by law.
This policy is an integral part of the Terms of Use as available at: https://www.uni.diamonds/terms
and, if
applicable, the Consignment Agreement and/or Loan Agreement entered into between you (or any
entity
affiliated to you) and us.
Please contact our Privacy Team at: privacy@uni.diamonds for
further information.
2024 UNI all rights reserved