Last Updated January 2024

Introduction

Welcome to Don Roberto Jewelers, Inc.’s (the “Company”, “us” or “we”) Privacy Policy (the “Policy”). In this Policy, we explain what information we collect, how we use and protect your information, with whom we may share it and the rights that you may have in connection with it. By providing information to us (by any means, whether in our stores, on our Website or otherwise), you consent to our use of the information you provide in accordance with this Policy. This Policy is incorporated into our Website Terms & Conditions. This Policy applies to our website https://donrobertojewelers.com/ (the “Website”), our stores and corporate activities related to our products, and services such as customer service, and repairs and collections. When required under applicable laws, additional policies disclosed to you at the time of collection may also apply. This Policy does not apply to employees or applicants for employment with the Company. For disclosures related to collection of information in connection with employment or applications for employment see DRJ’s Employee/Applicant Privacy Policy.

How to Contact Us

If you have any questions about this Policy or if you have a disability that prevents you from accessing this Policy electronically in this format and require it to be provided in an alternate format (e.g., audio, large print), you may contact us by sending an e-mail to [email protected] or writing to: 

Attn:  Compliance Department
205 Avenida Fabricante
San Clemente, CA 92672

Categories of Personal Information We Collect 

 Depending on how you interact with us, we collect one or more of the following categories of Personal Information. We have provided examples of when and why we collect the categories below and we do not necessarily collect all of the below categories of information from you.

Sources of the Personal Information We Collect From You 

Information you provide directly to us

When you visit our stores, or contact us via phone, email or in person, for any reason including customer service inquiries and repairs, or if you fill out or submit forms over our Website we may collect any of the Categories of Personal Information listed above directly from you. 

Information we collect passively over our Website

When you visit the website, we collect identifiers, such as your IP address or online identifiers and Internet or similar network activity, such as information about your interactions with our websites, mobile applications, emails, or advertisements. IP address, the type of browser or device that you are using, referring and exit pages, domain and other system settings and operating system; Information regarding how you interact with the Website including the date and time of your visits, webpages visited, and links clicked. For example, we use Google Analytics, an analytics tool that helps us understand how visitors use our Website. To learn more about Google Analytics’ data practices, please visit Google’s support page.   

Cookies and Trackers

When you visit our Website, we automatically collect information that is linked to your computer or device but does not directly identify you. We use cookies and pixel tags to collect such activity information. Cookies are small text files used to collect information and pixels are transparent images that allow us to understand how users interact with our Website. You can prevent cookies from being set on your device by changing the settings in the browsers you use. Note that if you do block cookies, some site functionality may not work properly. You can learn more about cookies and how they work at www.allaboutcookies.org.  

Information we collect from third parties

In connection with a credit application: credit reports from credit reporting agencies, information about debts from bankruptcy courts or information from references you have provided to us, who we contact in connection with a credit application.

Under applicable laws, some personal information, like your social security number, may be considered “sensitive” personal information when used for certain purposes described in the law. We use your social security number to consider your for financing and service your credit account with us, but we do not use this information for purposes other than to provide you services. Accordingly, we do not provide a “Limit the Use of My Sensitive Personal Information” link on our website. Note that Information in your credit report or credit file may be subject to additional applicable laws, including the Fair Credit Reporting Act.

Video Surveillance

When you visit our stores, we also collect video footage of your visit via our security cameras. 

How We Use the Information We Collect

We use the information you provide us:

• To facilitate your purchases and provide the services you request; 

• To confirm and track orders; 

• To respond to your inquiries and/or requests; 

• For fraud monitoring and security;

• To administer promotional surveys and provide you with the relevant products or services (for example, to deliver a prize you may have won in a contest);

• To send you information or materials via email about products, offers and news we think might interest you. This information may relate to products, offers and news of the Company or its licensees or selected commercial partners;

• To verify and respond to consumer requests regarding their information;

• To send you information regarding changes to our terms and policies;

• For other purposes disclosed at the time of collection or otherwise compatible with the above and applicable law.

We use information that we collect automatically from our Website:

• To administer, maintain and improve our Website;

• To understand how you found out about us and what services and products may interest you so we can improve our products and services and deliver to you the type of content, features and promotions that you are most relevant to you;

• To understand the demographics of our Website visitors;

• To perform website traffic, e-commerce and other trend analyses;

• For fraud monitoring and prevention and other security purposes.

Additional Uses

Additionally, we may use your information as we believe to be necessary or allowed: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being illegal, unethical, or legally actionable.

Disclosure and Transfer of Your Information 

The categories of information described in the section above “Information We Collect” may be disclosed to the categories of third and for the specific business purposes described in this section. 

We do not sell your information and we do not share your information with third parties for cross-contextual behavioral advertising (i.e., targeted advertising). However, we may disclose your information to the categories of recipients and for the business purposes described as follows:

• Our vendors and service providers: We use a variety of vendors and service providers that help us with our business activities such as maintaining our Website, email and document management, shipping, payment processing, physical security, managing our marketing and customer relationships and providing our products and services to our customers. We require these companies and individuals to use your information only as necessary to provide their services to us. 

• Credit reporting agencies: For the purpose of providing you credit, we may disclose information about your credit account or from your credit application as required by applicable law or in connection with providing updated information associated with your credit file.

• Insurance agencies: We may disclose information to our insurance partners in connection with your application for insurance that we offer or when you make any claims on an insurance policy purchased through us.

• Business transfers: We may disclose information as part of or in connection with a corporate merger, consolidation, sale of assets, bankruptcy or other corporate change.

• Legal requirements: We may also disclose your information when we reasonably believe it is required by law, subpoena or other legal process, including to meet national security or law enforcement requirements, as well as to honor user access rights, as applicable.

• Protection of rights: We may disclose information to protect our rights, privacy, safety or property, including our employees, contractors and agents, when we are required or permitted to do so by law.

• At your request: We may disclose information to a third party with your consent to do so.

• Fraud detection: We may disclose information when we believe in good faith that it is necessary to investigate fraud.

Data Retention

We apply different retention periods depending on the type of personal information collected and the purposes we use it. We will keep your information for as long as is necessary to fulfill the purposes for which the information was collected. We may be required to retain personal information to comply with our legal obligations or protect against fraudulent, deceptive, or illegal activity. The retention periods for personal information are determined by the purposes for which we need to use the information. Generally, we retain personal information for as long as an applicable law requires us to, or until legal obligations that require us to retain personal information have ended.

Security

The Company has taken steps to implement appropriate technical and organizational measures to help protect your information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. 

Your Rights and Choices

You may have certain rights in relation to your information under applicable laws. You are not obligated to provide us with your information. However, if the information is necessary to process your order, reply to your requests or answer your questions, we may not be able to assist you without it.  

We will process your request to the extent required and permitted by applicable laws. We may ask you for additional information to verify your identity. We reserve the right to deny or restrict fulfillment of your request in certain cases, such as when your access to data places another individual’s privacy rights at risk, or the continued processing or your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.

You may opt out of promotional communications at any time by following the unsubscribe instructions included in the communications we send you or by contacting us via email at [email protected].

You can set your browser to not accept cookies, but this may limit certain functionalities on the Website. 

How to opt out depends on the type of browser and/or device you are using. We have not implemented global privacy controls because we do not sell your information and we do not share your information for cross-context behavioral advertising (i.e., for targeted advertising).

If you reside or are located in certain jurisdictions, you may have rights and protections regarding the collection, processing, sharing and use of your information under local law. If you are a California resident, please see below.

For California Residents

The California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.) applies to the collection, use, and disclosure of “personal information” collected from California residents (as those terms are defined by the CCPA). The CCPA requires us to disclose to California consumers the categories of personal information (as defined in the CCPA) we collect, our business and commercial purposes for collecting, using,  selling or sharing such personal information, the categories of sources from which we collect personal information, the categories of personal information we have disclosed or sold for a business or commercial purpose in the preceding 12 months and the categories of third parties with whom we share personal information. We have provided these disclosures in this policy in the sections above. 

In addition to the further details described throughout this Policy: 

• We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

• The information we have collected about you in the past 12 months is described in Categories of Personal Information We Collect.

• In the past 12 months, we have used your Personal Information for the business purposes described in How we use the information we collect.

• We have disclosed the following categories of personal information described in Categories of Personal Information We Collect in the preceding 12 months to the following categories of recipients:

• We disclose Identifiers, Internet or Other Network Activity, Geolocation Data, Commercial Information and Inferences to our service providers, including our website analytics providers.

• We disclose Payment Information to our service providers who process payments.

• When necessary, we disclose Video Surveillance information to law enforcement and to our services providers that provide security services to us.

• We disclose personal records as defined in the California Customer Records statute to credit reporting agencies.

Under the CCPA, you, or an authorized agent acting on your behalf, have the right to: (i) know what personal information we have collected about you and to request access to your personal information and request additional details about our information practices, (ii) request deletion of your personal information, (iii) correct your personal information, (iii) opt out of the “sale” or “sharing” of your personal information (as those terms are defined by the CCPA), (iv) limit the use of your sensitive personal information, and (v) to not be discriminated against for exercising any of your rights under the CCPA. As we have explained in this privacy policy, we do not “sell” or “share” your personal information and only use sensitive personal information for the purposes set out in this privacy policy, which are permitted uses under CCPA. If you submit a request to exercise your rights, we may ask you to provide certain information to compare against our records in order to verify your identity and respond to your requests. If we believe that your request is fraudulent, we may take additional steps as necessary to verify your identity. We may also request that you sign a declaration under the penalty of perjury. There may be circumstances under which we are not required to or are unable to respond to your requests. When that occurs, we will explain to the reasons that we are not able to respond to your request.

Making a verifiable consumer request does not require you to create an account with us. We value your privacy and will not discriminate against you in response to your exercise of your privacy rights. We will endeavor to respond to your requests within 45 days following receipt of your request, after proper verification, unless we need additional time, in which case we will let you know.

For more information or to exercise your rights with respect to your personal information collected under this policy, please email [email protected] or call us at (877) 240-4041. 

Do Not Track

Some browsers have a “Do Not Track” feature. 

Data Transfers

The Company is based in the United States, and our stores are in the United States in the state of California. The Website is intended for use by individuals located in the United States. If you access the Website from outside the United States, you do so on your own initiative, at your sole risk and you are responsible for compliance with applicable laws.

When you access this Website, you understand and acknowledge that we may transfer, process and store information about you in the United States. By providing us with your information, you consent to the transfer to, and to the processing and storage of your information in countries outside of your country of residence, which may have different data protect laws than those in the country in which you reside.

Links to Other Websites

This Policy applies to our Website, our stores and corporate activities related to our products and services such as customer service, repairs and collections. As a convenience to you, the Website may contain links to other sites that may provide useful information or link with other platforms. The Company does not control these third-party sites and is not responsible for their privacy practices or content. You should refer to the privacy statements of such third-party sites to find out how they collect and use your information. 

Children

The Company does not knowingly collect or sell any information from or about children under the age of sixteen. If you believe that we have received information of a child, please contact us at [email protected]

Changes to This Policy

We may update portions of this Policy from time to time and will alert you that changes have been made by indicating on the Policy the date it was last updated. You can find the date of the last update at the top of the Policy. When you visit this Website, you are accepting the current version of this Policy as posted on the Website at that time. We recommend that you re-visit this Policy on occasion to learn of any changes.