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This policy was published on September 28, 2024, and will take effect on  September 28, 2024. 

 

We at Linto's Diamond Dreams LTD (“we”, or “us”) recognize the importance of privacy and confidentiality of personal information.

 

lintodiamonddreams.com (“Linto's Diamond Dreams LTD” or, the “Platform”) is a jewerlies product platform which connects and facilitates sales and purchases of precious jewerlies to consumer buyers (or “Buyers”).

 

This Privacy Policy sets out the ways in which we collect, use and disclose information in connection with the operation of the Platform, including personal information about you, Platform users, visitors and representatives. This Privacy Policy also applies to the use of the Platform via your mobile device.

 

For users located in the EU/EEA/UK and other countries, you may be entitled to additional rights or disclosures, please see the EU/EEA/UK Privacy Policy and General Policy Page respectively for information about your privacy rights under certain US state laws, which is incorporated into this policy.

 

This policy applies to our registered buyers (“Buyers”), those who purchase items on our platform without an account (“Guests”) and anyone else who visits our Sites or uses our Services (together with our Buyers and Guests, “you” and “your”). If you are not a registered Member or a Guest, please see our Non-Member Privacy Policy for further information about how we may collect and use your information, available here.

 

This policy does not apply to the practices of third parties that you may choose to share information with when you use the Services. Please note that the collection and use of your information by these third parties is subject to their own privacy policies and terms. You should understand the privacy and security practices of any third party before you share information with them.

 

K. VISITORS FROM THE UNITED STATES

This section of our Privacy Policy contains information required by certain U.S. state data privacy laws.  If you reside in California, Nevada, Colorado, Connecticut, Utah, or Virginia, this section applies to you and supplements the rest of our Privacy Policy above. Please refer to the state in which you reside to learn more about additional terms and rights that may apply to you.

If you are a registered buyer based in the United States, the data controller of your personal information is Linto's Diamond Dreams LTD. Your data will be stored in the United States. For contact details, please see section P. HOW TO CONTACT US below.

 

Information Pertaining to Children

Our Platform is not directed to and we do not intend to, or knowingly, collect, or solicit personal information online from users under the age of 18, nor children under the age of 13. We do not knowingly collect personal information from children under the age of 13 or have any reasonable grounds to believe that children under the age of 13 are accessing or using our Platform. If you believe that a child under 13 may have provided us personal information, please contact us using the contact details provided under section P. HOW TO CONTACT US below.

 

California residents

This section supplements the description of our information collection and sharing practices described above under section A. COLLECTION OF INFORMATION and provides certain disclosures to California residents whose personal information we process pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA").

Collection of Personal Information. During the preceding 12 months, we have collected, used, and/or disclosed the categories of personal information described above in section A. COLLECTION OF INFORMATION.

The personal information that we collect, or have collected in the preceding 12 months, falls into the following categories of personal information, as enumerated by the CCPA:

•   Identifiers, such as your name, postal address, email address, user account name, and IP address;

•   Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your contact information;

•   Commercial information, such as transaction information and purchase history;

•   Internet or network activity information, such as your browsing history and interactions with our Platform;

•   Geolocation data, such as your approximate location;

•   Audio, electronic, visual, and similar information, such as your records of your support requests and interactions with our customer support service; and

•   Inferences drawn from any of the above personal information to create a summary about you, for example of your preferences and characteristics.

In limited circumstances, we may also collect sensitive personal information as defined in the CCPA, such as account log-in information.

We may obtain the categories of personal information listed above from the categories of sources described above in section A. COLLECTION OF INFORMATION above.

Use of Personal Information. The business purposes for which we collect and handle personal information is described above in section B. USE OF PERSONAL DATA above.

Disclosure of Personal Information. We disclose or share personal information in the ways described above in section C. DISCLOSURE OF PERSONAL DATA, including by allowing third parties that provide us analytics and advertising services to collect information through cookies and other similar technologies.  

The CCPA defines a "sale" as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration, and "sharing" includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, like many websites, we may "share" (as defined in the CCPA) certain identifiers (i.e., IP address and online identifiers), usage data, and inferences to advertising networks, data analytics providers, operating systems and platforms, and social networks, including in the context of our use of certain cookies, pixel tags, and other similar tools and technologies. We do so in order to improve and evaluate our advertising campaigns and better reach customers and prospective customers with more relevant ads and content.

The types of personal information that we may share include unique identifiers (e.g., cookies and similar technologies), device information, geolocation data, commercial data, behavioral data, and inferences.

To the extent that the use of cookies and other tracking technologies to disclose certain personal information to third parties to display targeted or personalized advertisements to you constitutes a "sale" or "sharing" of personal information under the CCPA, you may opt out of such cookies at any time by adjusting your cookie choices in our Cookie Preferences on our Platform to adjust your cookie choices.

We do not "sell" or "share" sensitive personal information, nor do we "sell" or "share" any personal information about individuals who we know are under sixteen (16) years old.

You can opt out of any future sale of personal information by using the contact details provided under section P. HOW TO CONTACT US below.

California Privacy Rights. If you are a resident of California, you have the following rights under the

CCPA, subject to certain limitations and exceptions under applicable law:

•   Know and Access: You have the right to request to know and access the following information covering the 12 months preceding your request:

-       the categories of personal information we have collected about you;

-       the categories of sources from which your personal information was collected;

-       the business or commercial purposes for collecting, "selling" and/or "sharing" your personal information;

-       the categories of third parties to whom we have disclosed, "sold" or "shared" personal information about you; and

-       the specific pieces of personal information we have collected about you.

You have the right to receive your personal information in a portable and commonly used format.

•   Correct: You have the right to request that we correct any of your personal information that we have collected from you that is inaccurate.

•   Delete: You may have the right to request that we delete certain personal information we have collected from you.

•   Opt-out of the selling or sharing of your personal information: You have the right to request that a business not "sell" or "share" your personal information with a third party, as those terms are defined under the CCPA. As described above, we use cookies and other tracking technologies to make available certain personal information to third parties to display targeted or personalized advertisements to you. To the extent that such practice may constitute a "selling" or "sharing" of personal information under the CCPA, you may opt-out of such "selling" or "sharing" at any time by using our Cookie Preferences on our Platform to adjust your cookie choices.

•   Limit the use and disclosure of sensitive personal information: We do not use or disclose "sensitive personal information" (as defined by the CCPA) for the purpose of inferring characteristics about you, or in any way that would require a right to limit under the CCPA. As a result, we do not offer an ability to limit the use or disclosure of sensitive personal information.

•   Non-Discrimination: You have the right not to be discriminated against because you exercise your rights under the CCPA. We shall not discriminate against you for exercising any of your above rights, for example, we will not charge you different prices or provide different quality of services to you for exercising your CCPA rights unless those differences are related to your information or otherwise permitted by law.

California Shine the Light Law. Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer's personal information with third parties for their own direct marketing purposes, without their approval. For inquiries regarding our disclosure policy, please use the contact details provided under section P. HOW TO CONTACT US below.

Do Not Track. California Business and Professions Code Section 22575(b) (as amended effective January 1, 2014) permits our customers who are California residents to be informed as to how we respond to Web browser "Do Not Track" settings. As 'Do Not Track' is a standard that is currently being developed, we do not take actions to respond to 'Do Not Track' settings, and instead we adhere to the standards set out in this Privacy Policy. If you would like to find out more about Do Not Track you may find the following link useful: http://www.allaboutdnt.com/ .

 

Nevada residents

Under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online.  As discussed above, we share your information with certain third parties that we believe can provide you with offers and promotions for products and service of interest to you and in the other ways described above.  We do not believe that our sharing in this regard would qualify as a sale under Nevada law. Nonetheless, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to record your preference to opt out by using the contact details provided under section P. HOW TO CONTACT US below. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

 

Colorado residents

The Colorado Privacy Act ("CPA") and its implementing regulations define "consumer" as a Colorado resident who is acting in an individual or household context only and does not include residents acting in a commercial or employment context. If you are a Colorado "consumer", you may have the following rights concerning your personal data, subject to certain limitations and exceptions under applicable law:

•   Access: You have the right to request to confirm whether we are processing personal data about you and to access such personal data.

•   Data Portability: You have the right to obtain your personal data in a portable and readily usable format.

•   Correction: You have the right to request that we correct inaccuracies in the personal data we have collected about you, taking into account the nature of the personal data and the purposes of processing your personal data.

•   Deletion: You have the right to request to delete certain of your personal data.

•  Opt-out of Data Processing for purposes of Targeted Advertising; Sales to Third Parties; and Profiling: We do not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under the Colorado Privacy Act. As described above, we do not sell personal data to third parties for money, nor for the purpose of profiling in connection with decisions that produce legal or similarly significant effects. However, we do process personal data for the purpose of displaying targeted or personalized advertisements to you, if you instruct us to do so. You have the right to opt out of the processing of personal data for personalized advertising purposes at any time by changing your cookies choices via our Cookie Preferences on our Platform.

•   Appeal: You have the right to appeal a refusal to take action on your request. You must ask us to reconsider our decision within 45 days after we send you our decision. We will endeavor to respond to your appeal within 60 days of such an appeal, including a written explanation of the reasons for the decision, and any action taken or not taken in response to the appeal.

 

Connecticut residents

The Connecticut Data Privacy Act ("CtDPA") defines "consumer" as an individual who is a resident of Connecticut. If you are a Connecticut "consumer", you may have the following rights concerning your Personal Information, subject to certain limitations and exceptions under applicable law:

•   Access: You have the right to request to confirm whether we are processing personal data about you, and to access such personal data.

•   Data Portability: You have the right to obtain your personal data in a portable and readily usable format.

•   Correction: You have the right to request that we correct inaccuracies in your personal data.

•   Deletion: You have the right to request to delete the personal data provided by you or obtained about you.

•   Opt-out of Data Processing for purposes of Targeted Advertising; Sales to Third Parties; and Profiling: As described above, we do not sell personal data to third parties for money, nor for the purpose of profiling in connection with decisions that produce legal or similarly significant effects. We may process personal data for the purpose of displaying targeted or personalized advertisements to you, if you instruct us to do so. You have the right to opt out of the processing of personal data for personalized advertising purposes at any time by changing your cookies choices via our Cookie Preferences on our Platform.

•   Appeal: You have the right to appeal a refusal to take action on your request. You must ask us to reconsider our decision within 45 days after we send you our decision. We will endeavor to respond to your appeal within 60 days of such an appeal, including a written explanation of the reasons for the decision, and any action taken or not taken in response to the appeal.

 

Utah residents

The Utah Consumer Privacy Act ("UCPA") defines "consumer" as an individual who is a resident of Utah acting in an individual or household context only and does not include residents acting in a commercial or employment context. If you are a Utah "consumer", you may have the following rights concerning your personal data, subject to certain limitations and exceptions under applicable law:

•   Access: You have the right to request to confirm whether we are processing personal data about you, and to access such personal data.

•   Data Portability: You have the right to obtain your personal data in a portable and readily usable format.

•   Deletion: You have the right to request to delete the personal data provided by you or obtained about you.

•  Opt-out of Data Processing for purposes of Targeted Advertising and Sales to Third Parties: As described above, we do not sell personal data to third parties for money, nor for the purpose of profiling in connection with decisions that produce legal or similarly significant effects. We may process personal data for the purpose of displaying targeted or personalized advertisements to you, if you instruct us to do so. You have the right to opt out of the processing of personal data for personalized advertising purposes at any time by changing your cookies choices via our Cookie Preferences on our Platform.

 

Virginia residents

The Virginia Consumer Data Protection Act ("VCDPA") defines "consumer" as a Virginia resident who is acting in an individual or household context only and does not include residents acting in a commercial or employment context. If you are a Virginia "consumer", you may have the following rights concerning your personal data, subject to certain limitations and exceptions under applicable law:

•   Access: You have the right to request to confirm whether we are processing personal data about you, and to access such personal data.

•   Data Portability: You have the right to obtain your personal data in a portable and readily usable format.

•   Correction: You have the right to request that we correct inaccuracies in your personal data.

•   Deletion: You have the right to request to delete the personal data provided by you or obtained about you.

•   Opt-out of Data Processing for purposes of Targeted Advertising; Sales to Third Parties; and Profiling: As described above, we do not sell personal data to third parties for money, nor for the purpose of profiling in connection with decisions that produce legal or similarly significant effects. We may process personal data for the purpose of displaying targeted or personalized advertisements to you, if you instruct us to do so. You have the right to opt out of the processing of personal data for personalized advertising purposes at any time by changing your cookies choices via our Cookie Preferences on our Platform.

•   Appeal: You have the right to appeal a refusal to take action on your request. You must ask us to reconsider our decision within 45 days after we send you our decision. We will endeavor to respond to your appeal within 60 days of such an appeal, including a written explanation of the reasons for the decision, and any action taken or not taken in response to the appeal.

 

Making US Privacy Rights Requests

If you are a resident of one of the above U.S. states and would like to exercise any of your rights described above, please submit your rights request by using the contact details provided under section P. HOW TO CONTACT US below. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of the Platform.

Please note that the rights described above are not absolute, and where an exception under applicable law applies, we may be entitled to refuse requests in whole or in part.

In certain states (such as California), an authorized agent may submit a rights request on your behalf. If you use an agent, we may require you to provide the agent with signed permission to submit a request, require that you verify your identity directly, or otherwise require you to confirm you have provided the authorized agent with permission.

 

We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period (up to a total of 90 days) in writing. You may submit a request as frequently as you would like, but we are not required to respond to requests to provide personal information to you more than twice in any 12-month period.

 

L. VISITORS FROM BRAZIL

This section applies if you are based in Brazil. The controllers of the personal data are Linto's Diamond Dreams LTD. Your data will be stored in the United States. For contact details, please see section P. HOW TO CONTACT US below. The personal data processing activities performed by us under the Platform for the Brazilian market, which includes any processing activity (i) carried out in Brazil, (ii) aimed at offering or providing goods or services or processing data of individuals located in Brazil, or (iii) collected in Brazil; users of the Platform in Brazil are carried out in accordance with the laws of Brazil, including the Marco Civil da Internet, Federal Law No. 12.965/2014 ("MCI") and the General Data Protection Law, Federal Law No. 13.709/2018 ("LGPD").

We process the categories of personal information described in Section A of our Privacy Policy. Depending on the services you use, this may include your identifiers (e.g. IP addresses, date and time of access to the Platform, and email addresses), business and internet or other electronic network activity information. It may also include inferences we draw from other information we collect.

 

Legal Basis for Data Processing

We process personal information for the purposes set out in this Privacy Policy observing legal bases set out in the LGPD. Our legal basis for processing your personal information will depend on the personal information in question and the specific context in which we collect it, but will include when it is:

•   necessary for the performance of the contract between you and Linto's Diamond Dreams LTD (for example, to provide the services requested by you and to identify and authenticate you so that you can use the Platform).

•   necessary to comply with legal requirements (for example, to comply with applicable accounting rules and make required disclosures to law enforcement authorities);

•   necessary to achieve our legitimate interests or those of third parties;

•   based on your consent;

•   necessary for the regular exercise of rights in judicial, administrative and arbitration proceedings;

•   necessary for the protection of life and limb or of the data subject and third parties;

•   used for credit protection purposes;

•   used for other cases foreseen in the LGPD or applicable legislation.

If we collect and use your personal information based on our (or a third party's) legitimate interest, that interest will generally be to operate our Platform and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate business interest, for example in responding to your inquiries, improving our Platform and services, conducting marketing, or for the purpose of ensuring the security of our Platform and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information). In some cases, it may be necessary for you to provide us with personal information for processing as described above in order for us to provide you with all of our services and for you to use all of the features of our Platform.

If you have questions or need more information about the legal basis on which we collect and use your personal information, please contact us using the contact information provided in section P. HOW TO CONTACT US below.

 

Your Rights

You have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided in section P. HOW TO CONTACT US below:

•   The right to access your personal data and confirm the existence of processing.

•   The right to correct, update or request anonymization, blocking or deletion of your personal information.

•   The right to object to the processing of your personal information where it is based on our legitimate interests or in case of non-compliance with LGPD or applicable law.

•   The right to ask us, in some situations, to restrict the processing of your personal information or to request portability of your personal information.

•   The right to cancel marketing communications we send you at any time. You may exercise this right by clicking on the "unsubscribe" or "unsubscribe" link in marketing e-mails that we have sent to you. To unsubscribe from receiving other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact information provided in section P. HOW TO CONTACT US below.

•   If we collect and process your personal information with your consent, you have the right to withdraw your consent at any time and request deletion of your personal data. Withdrawing your consent will not affect the lawfulness of any processing carried out prior to your withdrawal, nor will it affect processing of your personal information carried out on a legal basis other than consent.

•   The right to request a review of decisions based solely on automated processing, which may affect your interests.

•   The right to petition the National Data Protection Authority - ANPD about our collection and use of your personal information.

•   The right to request portability of your personal data to another service provider;

•   The right to request information about with whom your personal data has been shared.

We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. If you are aware of changes or inaccuracies in your information, you must inform us of such changes so that our records can be updated or corrected.

To exercise your rights, you or your authorized legal representative may contact us using the contact details provided in section P. HOW TO CONTACT US below. Once we receive your request, we may verify it by requesting sufficient information to confirm your identity, including requesting that you verify information about your use of the Platform.

 

M. VISITORS FROM MEXICO

This section applies if you are based in Mexico. The data controller of your personal information is Linto's Diamond Dreams LTD, located at 51 Bras Basah Road, #01-21 Lazada One, Singapore 189554. For contact details, please see section P. HOW TO CONTACT US below.

 

Legal Basis for Data Processing

Your consent is the basis for Linto's Diamond Dreams LTD to process your personal data, unless the processing is required by law. In that case your consent would not be required.

 

Use of Personal Data

Except for “Sending and serving tailored marketing and advertising that we believe will be of interest to you” and “Help you find people you may know who are also using Linto's Diamond Dreams LTD”, which are secondary purposes, the rest of the processing purposes listed above in Section B. USE OF PERSONAL DATA are considered primary purposes.

 

If you do not want your personal data to be processed for secondary purposes and you do not want to receive our marketing and advertising communications, please click on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. You can also opt-out from those communications in the Settings Section of the Platform.

 

Disclosure or Sharing of Personal Information

Your consent is required to transfer your personal data to “our business partners” and to “actual or potential buyer” mentioned above in Section C. DISCLOSURE OR SHARING OF PERSONAL INFORMATION of this Privacy Policy. With your consent to this Privacy Policy, you consent the data transfers mentioned in this paragraph.

 

Linto's Diamond Dreams LTD does not require your consent to disclose or share your personal information with the rest of the recipients mentioned in Section C. DISCLOSURE OR SHARING OF PERSONAL INFORMATION of this Privacy Policy. 

 

Your Rights

You have the following rights regarding your personal information: i) access; ii) rectification; iii) cancelation; iv) objection; v) revoking your consent; vi) limit the use or disclosure of your personal information.

 

If you want to exercise any of the rights previously mentioned please contact us using the contact details provided under section P. HOW TO CONTACT US below. Your request must include: (i) Linto's Diamond Dreams account ID or registration email or phone number; and (ii) a description of the personal data which is intended to be exercised. We verify your identity when you access to our services by login-in to our services or through the email address registered in your account. Data subject requests sent by email must come from the email registered in your account, so we can verify your identity.

 

We will respond to any complete request within 20 days. The response will indicate whether the request is admissible. If it is admissible, we will make the determination within 15 days from the date you communicate the response. The deadlines may be extended in accordance with the applicable law. If you exercise your right of access, we will provide digital documents.

 

N. INTERNATIONAL TRANSFERS OF PERSONAL DATA

In connection with providing the services through our Platform, we will store your personal data processed through the Platform in the United States, Russia, Germany, China and/or Singapore, depending on the country you are located in, mainly for back up and data center storage. These countries have data protection laws that may have different provisions to the laws of your country. There will also be international transfers of your information among the above-mentioned countries. Where the transfer is not subject to an adequacy decision or regulations, we take appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and we implement appropriate measures to ensure your personal information will remain protected in accordance with this Privacy Policy and applicable laws. The safeguards we use to transfer data in case of both our group companies and third party services providers for personal information originating from the EEA and UK are the European Commission's Standard Contractual Clauses, and the UK Addendum (as applicable). A copy of the relevant clauses can be obtained by contacting us using the contact details provided under section O. HOW TO CONTACT US below.

 

O. LANGUAGE

If there is any conflict between the English version and another language version of this Privacy Policy, the English version shall prevail.

 

P. HOW TO CONTACT US

Contact information of the Data Protection Officer: contact@lintodiamonddreams.com.