Last Updated: November 27, 2019
Personal data we collect
Newsletters. If you wish to sign up to receive our newsletter with information about our products and offers, we will ask you to provide your email address.
Shop. We collect information about the products you wish to order. When you place an order with us, we collect information such as your name, your contact information, billing information, and shipping information. We will also collect your free text ordering notes if you choose to share those with us.
Inquiries. You can send us your inquiries through any of our contact methods. In such a framework, we may ask you to provide information such as your name, email address, country of origin, the topic of your inquiry, and the text of your message.
You do not have a legal obligation to provide any of the above information to us. However, you will not be able to sign up for our newsletter, to place an order on our Website, or to submit inquiries, without providing the requested information.
When you visit our Website, we may collect specific data about your visit and use of the Website and your interaction with our email messages and newsletters. Analytical data we collect includes your IP address, the general location corresponding to your IP address, time and date of access, type of browser used, language used, links clicked, and the web pages you accessed.
How and why we use personal data
If you sign up to receive our newsletter, we would then process your email address to send you our periodic marketing newsletter.
If we collect your contact information in the course of an order you place, we will allow you to refuse or opt-out of our newsletter at any time by sending an email to firstname.lastname@example.org. As long as you have not opted-out, we will send you these promotional communications.
If you order a product, we will process your order information to fulfill your order, charge you for the purchase price and fees, keep you informed about the status of your order, and ship the products you ordered to the shipping address you specify. We process your data for accounting and financial record-keeping purposes. We may also process your data to adapt the Website and its content to users’ preferences, to better understand the market demand in which we operate and for reporting and business planning purposes.
If you submit an inquiry to us, we will use the information you provide in your request or question to process, handle, and contact you about the inquiry.
We use analytics data to improve the Website and the content on the Website, our email communications, and the products we offer to customers. We also use the analytics data to adapt the Website and its content to users’ preferences. Finally, we will use the analytics data to understand the market in which we operate and for reporting and business planning purposes.
How we share personal data
We will share your personal data with our service providers (such as PayPal, credit processing companies, Amazon AWS, MailChimp, and other Online Virtual Hosting services), who assist us in performing certain business-related functions. These include payment processing, mailing information, maintaining databases, hosting services, internal website operations fulfillment, and shipping of your order. These companies are authorized to use your data only as necessary to provide their specific relevant services to us and not for their purposes. We do not sell your data to third parties.
We will share your personal data if we are required to disclose it by a judicial, governmental, or regulatory authority.
We will share your data to enable structural change if we reorganize our business, merge, consolidate or resolve to operate in any different framework or legal structure or entity, for example, due to a merger or acquisition.
We will share your data if we need to act immediately to protect the personal safety of our customers or the public.
How we transfer personal data internationally
We may transfer the data we collect from you to our relevant service provider (as identified elsewhere herein) in France.
We may transfer some data from within Europe to Israel. The European Commission recognizes Israel as having adequate protection of personal data. If we transfer your data from within Europe to other jurisdictions outside of Europe, we will do so using appropriate safeguards consistent with those determined by the EU Commission.
Automatic data collection tools
Cookies are text files that include a small amount of data we store on your computer, tablet, or smartphone when you use the internet and visit our website. It allows us or a third party to recognize you. We use both Session Cookies and Persistent cookies as described below.
Session cookies data is read by a website you visit, during the session of your visit. Session cookies expire when you close your browser. Persistent cookies data is read by a website you visit when you return to revisit it. A persistent cookie remains on your computer until it expires, or you delete your cookies.
We use the Cookiebot add-on to provide you with more detailed information about the cookies we use, their origin, purpose, and expiration dates. It also enables you to control the use of marketing cookies, preference cookies, and statistics cookies.
You can, at any time, enable or disable individual categories of cookies. However, you cannot disable the ‘necessary’ cookies because the website cannot operate without them. By enabling cookies, you give your consent to collect the data for the cookie purpose.
Note to Yrusha: An excellent tool for managing cookies and consents is Cookiebot. It’s not free, but it is excellent for GDPR compliance. The essential elements for GDPR compliance are the existence of a notice explaining about the cookies, a systematic and readable display of the cookie-types used (Cookiebot does this automatically), and the ability to manage opt-ins properly (also a feature of Cookiebot, although you need to configure which cookies are opt-ins and which are opt-outs for user control).
Necessary cookies are those that are strictly necessary for the functioning of our Website. Our Website cannot operate properly without these cookies. You can block or receive an alert about these cookies by setting your browser configuration. Still, some parts of our Website may not function properly without these cookies.
Preferences cookies are those that remember your choices when you use our Website and allow the site to react by reflecting your preferences.
Statistics cookies help us to discern how you and others interact with our Website by collecting data that does not directly identify you.
Marketing cookies track your use of our Website and allow us to tailor content, both on and off the Website, that we believe is relevant to you.
Our Website contains links to social networks such as Facebook and YouTube. Please be aware that we are not responsible for the privacy practices of such other platforms. We encourage you to read the privacy statements of each platform you chose to engage with.
We implement safeguards to reduce the risks of damage, loss of data, and unauthorized access or use of data we collect and maintain. However, these measures do not guarantee absolute information security. Therefore, although we take reasonable precautions and make an appropriate effort to secure your data, you cannot expect that the Website will be immune to information security risks.
We keep your personal data for the duration of our business relationship with you, interacting with you as a customer, to the extent permitted by applicable laws. We may still keep your data for as long as necessary to administer our business, our bookkeeping requirements, resolve disputes, establish and defend legal claims, and enforce our agreements. When we no longer need your data, we will delete it from our systems (using reasonable means) and records or take steps to anonymize the data.
You have the right to:
Access your personal data that we process and have about you and receive a copy of it.
Rectify incorrect, inaccurate, or incomplete personal data we have about you.
If you are a resident of the EU or UK, you have the following additional rights to:
Object to the processing of your personal data for marketing purposes or for our other legitimate interests. However, we may override your objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise or defense of legal claims. At any time, you can also object to our processing of your personal data for direct marketing (newsletter) purposes, by simply opting out of our newsletters.
Restrict the processing of your personal data for the duration we require to verify its accuracy, in the event that you allege an error in such data. You have the right to restrict the processing of your personal data if you consider it an unlawful processing. You can also restrict the deletion of your data if you need it for the establishment, exercise, or defense of legal claims. You can also request the restriction of the processing during the time we review your objection to our legitimate interest.
Erase your personal data when it’s no longer needed. For example, when you withdraw your consent to our newsletters, you have the right to ask us to erase your data relating to that. However, we may still process your personal data if we need to in order to comply with a legal obligation, or if we are subject to do so under the law, or for the establishment, exercise, or defense of legal claims.
Data Portability You have the right to receive a copy of the personal data that you provided to us in a structured, commonly used, and machine-readable format and to send that information to other businesses. Where technically feasible, you also have the right to have your personal data transmitted directly from us to another business you designate.
If you wish to exercise any of these rights, contact us at: email@example.com
We have the right to ask for reasonable evidence to confirm your identity before we provide you with the data. Where we are not able to provide you with the data that you have requested, we will explain the reason for our inability to do so.
Additional information for users in the EU
Yrusha Jewels Ltd. is the data controller for the personal data we collect through our Website and the products offered on our Website. Our registered address is at P.O. Box [Insert P.O. Box] (c/o [inset name]), [Insert address], Israel, postal code [Insert postal code]. You can contact us by email at: firstname.lastname@example.org.
Our European representative, for this Policy, is ____________. If you are within the European Economic Area, you may contact our European representative at the following address: ____________.
The legal basis for our collecting and processing your product preferences is our legitimate business interest of offering you products that are suitable to your interests.
The legal basis for our collecting and processing your email is to send you newsletters is your explicit consent to receive such commercial communications.
The legal basis for our collecting and processing your order information for fulfillment, billing, and shipping is the performance of the contract for sale of the product to you.
The legal basis for processing your inquiry information is our legitimate interest in responding to your question or request.
The legal basis for keeping your order information for Website adaptations, and business planning, is our legitimate business interest in enhancing our Website and our business development and planning.
The legal basis for processing analytics information about you is our legitimate interest in managing our Website and our business development and planning.
The legal basis for sharing your data with others if you breached our terms is our legitimate interest in protecting ourselves from abuses.
The legal basis for disclosing your data to a judicial, governmental, or regulatory authority is our compliance with our legal obligation to do so.
The legal basis for sharing your data to enable a structural change of Yrusha Jewels Ltd. is our legitimate business interests in our business continuity, or the legitimate interest to consummate such transaction.
We designed this Website to serve people above the age of 18. We do not knowingly collect personal data of children who are under the age of 16 through our Website. If you are under the age of 18, you should not use our Website.
Subject to applicable law, you have the right to complain to your local data protection authority. If you are in the EU, you can complain to the supervisory authority, in particular in the Member State of your residence, place of work, or place of an alleged infringement of the GDPR. For a list of data protection authorities in the EU, click here.
In France, this is the Commission Nationale de l’Informatique et des Libertés (CNIL)
3 Place de Fontenoy
75334 PARIS CEDEX 07
Tel. +33 (0)220.127.116.11.22
Fax: +33 (0)18.104.22.168.00