YOUR PRIVACY AND SECURITY AT HELZBERG DIAMONDS

Effective: January 1, 2021

When making a personal and meaningful purchase, you shouldn't have to worry about your privacy. That's why Helzberg's Diamond Shops LLC. (“Helzberg”) has adopted this Privacy Policy to protect the information you provide to us, either in-store, offline, or in connection with your use of this site, www.helzberg.com and other sites or applications that are owned or operated by Helzberg, including Helzberg’s mobile application(s) and social media site(s) (each individually a “Site” and collectively the ”Sites”). Review this Privacy Policy to understand the measures we take to ensure your privacy.

This Privacy Policy does not apply to information collected from employees or prospective employees within the context of their employment or prospective employment.

Please read this policy carefully to understand our policies and practices regarding your information. By accessing or using any Site, you agree to this Privacy Policy. Certain Sites may be subject to additional terms and conditions which may also apply to your information. This Privacy Policy is subject to your agreement to our Terms and Conditions of Use (“Terms of Use”), as applicable.

At Helzberg, we collect customer information to try and make your online shopping experience stress-free and enjoyable. Customer information that you provide which identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device is considered “personal information” under this Privacy Policy, as more fully described below. The personal information we collect may consists of the following:

• Name and contact data, such as, first and last name, email address, postal address, phone number, and other similar contact data
• Payment information, such as, payment card number (credit or debit card), and the security code associated with your payment instrument, if you make a payment
• Action/registration information you provide when you create an account, enter a promotion, or link your profile on a third-party site or platform with your registration account, such as your first name and surname, country of residence, gender, date of birth, email address, username, password and other security information for authentication and access;
• Device information, such as, information about your device, such as IP address, location or provider
• Usage information and browsing history, such as, information about how you navigate within our Services, your browsing history and which elements of our Services you use the most
• Transaction information you provide when you request information, contact Customer Care, or purchase a product or service from us, such as your postal address, email address, telephone number, and payment information;
• Information we obtain from a third party, such as a site or platform provider, about use of our applications on third-party platforms or devices;
• Location information, including location information provided by a mobile or other device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information;
• Activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences; and
• Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, including your browser or device type, unique device identifier, and IP address.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Helzberg’s Sites also use a variety of cookies and other tracking devices to help us make our site more responsive to your needs and deliver a more personalized online experience. For example, if you provide your zip code we may store it in a cookie and use it to remember your nearest Helzberg Diamonds stores or if you click on one of our ads we may track what products you view or purchase from our website to evaluate the ad’s performance. We use web beacons or clear gifs (which are single pixel images) to help monitor how often a specific page or message is viewed. We may also use technologies, such as our own cookies, to provide you with personalized online display advertising tailored to your interests. To opt out of these ads, please click here.

The primary ways in which we collect your Personal Information through the Sites includes:

• Directly from you when you purchase a product on a Site, Store, or when you complete or enter any forms, promotions, contests, or messages through a Site or Store.
• Directly from you when you request to receive marketing and promotional messages. To stop receiving these messages see “Opt-Out and Unsubscribe”.
• Directly from you when you publish or post any User Generated Content (as defined in the Terms of Use) on a Site.
• Our servers, logs and other technologies automatically collect system/device and usage information to help us administer, protect and improve our Services, analyze usage and improve users’ experience.
• We automatically gather information about where you go on a Site and certain information about your device (such as your IP address or device ID when not associated with personally identifiable information). This information helps us improve and manage our business operations, determine which areas of the Sites are most visited, and provide a quality online shopping experience by recognizing and delivering more of the features, services and products you prefer.
• We collect information using analytics tools, including when you visit our sites and applications or use our applications on third-party sites or platforms.
• We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we validate postal or email address information using third party services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it.
• In our relationship with clients or prospects, partners and suppliers, they also provide us with business contact information (such as name, business contact details, position or title of their employees, contractors, advisors and authorized users) for purposes such as contract management, fulfillment, delivery of products and services, provision of support, invoicing and management of the services or the relationship.

We may combine the Personal Information we collect with other information we possess to verify, update or complete the information we have about you from time to time.

Helzberg uses the Personal Information that we collect about you:

• To provide you with information, products or services that you request from us.
• To process purchases, transactions, and payments.
• To present and personalize the Sites and notify you of changes to a Site.
• To create, maintain, customize, and secure your account with us.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To, unless you opt-out, send you marketing and promotional messages for special offers involving our own or our partner’s goods and services that may be of interest to you. To stop receiving these messages see “Opt-Out and Unsubscribe”.
• To attempt to detect and reduce fraud, credit risk, and other illegal activities or threats to safety, security, or integrity of the Sites or our other operations.
• To allow you to participate in interactive features on the Sites.
• To improve our Sites, services, product offerings, marketing and promotional efforts, and overall customer experience.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Helzberg’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Helzberg about our customers or users is among the assets transferred.
• For our general business administrative, operations, and oversight purposes.
• To fulfill or complete any other purpose or function described to you when collecting your information.

We may disclose any Personal Information that we collect or you provide to Helzberg:

• To fulfill the purpose for which you provide it.
• To our subsidiaries and affiliates, in order to process your data for the same purposes or within the same activity as permitted under this Privacy Policy.
• To our agents, contractors, service providers and other third parties we use to support our business (such as shipping orders, completing credit checks, maintaining a Site, etc.) for their use in completing services on our behalf.
• To, unless you opt-out, third parties to improve our marketing programs and the marketing programs of other retailers. These disclosures may constitute sales or sharing under certain state laws. To prevent this sharing of information see “Opt-Out and Unsubscribe”.
• To enforce our Terms of Use and other agreements, including for billing and collection purposes.
• To a buyer or other successor in the event of a merger, reorganization, dissolution or other sale or transfer of some or all of Helzberg's assets in which personal information held by Helzberg is among the assets transferred.
• To display any User Generated Content in accordance with our Terms of Use.
• To comply with any court order, law or legal process, including responding to any government or regulatory request.
• To any other party if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Helzberg, our customers or others. This includes sharing information with other entities for fraud protection and credit risk reduction.
• For any other purpose disclosed by us when you provide the information.
• For any other purpose with your prior consent.
• We may use or disclose any non-individually identifiable information (including aggregated information) about our users that we collect and any information other than Personal Information without restriction.

We may combine the Personal Information we collect with other information we possess to verify, update or complete the information we have about you from time to time.

We provide you the opportunity to ‘opt-out’ of receiving certain electronic marketing and promotional messages from us, or from our sharing or sale of your information with other retailers for marketing purposes. If you wish to opt-out or unsubscribe from these marketing messages then you should follow the unsubscribe instructions in the applicable message (see below for SMS unsubscribe). You may also email or call Customer Care at 1-800-435-9237. Note: removal from our e-mail marketing list will not prevent you from receiving confirmation messages for orders you place or other information you request on a Site. Although we will promptly begin removing your name from our e-mail marketing lists after receiving your request, for a limited period of time you may still receive messages from us for that had been initiated prior to your name being removed. If you wish to opt-out of having your information shared with other retailers for marketing purposes, use the “Privacy Opt-Out” link at the bottom of every page on this site.

You may receive marketing and promotional messages (SMS and MMS) from Helzberg if you provide your mobile number and opt-in to receive such messages. If your device or carrier does not support MMS alerts, you will receive a SMS alert. For more information and support reply HDHELP to 88769; or email or call 1-800-435-9237. To cancel and unsubscribe you can either reply HSTOP to 88769; or email, or call 1-800-435-9237. Standard text messaging and data rates apply.

If at any time you would like to request access to or change any Personal Information that you have provided to Helzberg, email or call Customer Care at 1-800-435-9237. Please include your full name, street and email address, and telephone number in any message to ensure we can identify all of your information that we collected. We may not accommodate a request to change or remove information if we believe it would violate any law or legal requirement or cause the information to be incorrect

Our Sites may contain links to other web sites or applications. We are not responsible for the privacy practices or the content of other web sites.

We may allow third-party advertisers to place ads or other content on our Sites. These third-party advertisers may use cookies or similar tracking technologies to help present the advertisements to you or to help measure the effectiveness of their advertisements. Some advertisers may track your device(s) to attempt to serve ads based on your visits to the Sites and other websites on the Internet. The use of such technologies is subject to the privacy policies of the third-party advertisers and is not covered by this Privacy Policy. As a result, if you respond to any such third-party advertisers by clicking on the advertisements and/or visiting their websites or the websites of any other third party, be sure to evaluate their privacy policies before providing them any of your information. To opt-out of a third party’s use of cookies; you must visit such third party’s website and follow its specified opt-out procedures or block all cookies. You can opt out of some, but not all, third-party advertiser cookies and other tracking devices by visiting the following pages: (1) the Network Advertising Initiative opt-out website, located at www.networkadvertising.org/managing/opt_out.asp and (2) http://www.aboutads.info/choices/. You may block all cookies by following the instructions applicable to your browser at http://www.aboutcookies.org/page-1.

The Sites are not intended for children under 13 years of age. No one under age 13 may provide any Personal Information to or through any Site. Helzberg does not knowingly collect personal information from children under 13. If you are under 13, do not use any of the Sites. If Helzberg learns that it has collected or received any personal information from a child under 13 other than in accordance with law, Helzberg will delete that information. If you believe we might have any information from or about a child under 13, email or call Customer Care at 1-800-435-9237.

We have implemented commercially appropriate measures intended to secure your Personal Information from unauthorized access, use, alteration and disclosure in conformance with industry standards. Any orders, including payment and Personal Information submitted as part of an order, are encrypted using SSL technology on our server. Note that we are not responsible for devices, applications, or other programs located on your device or connection which may intercept your information (such as a “keylogger”). It is our policy to not send sensitive information, such as a credit card number, via email. Unfortunately, the transmission of information via the internet is not completely secure. Although we strive to protect your Personal Information, we cannot guarantee the security of your personal information that is transmitted to our Site. Any transmission of Personal Information is at your own risk.

The safety and security of your information also depends on you. Where you have a password for access to certain parts of a Site, you are responsible for keeping this password confidential. You may not share your password with anyone.

Please note that the Sites are directed towards users who reside in the United States. By using the Sites, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States. While some of these countries may not offer the same level of privacy protection as your own, we commit to uphold the privacy protections as explained in this policy.

Under various data protection laws and as outlined within this notice, you have rights we need to make you aware of. We will honor your rights under applicable data protection and privacy laws. You have the following rights under European laws and may have similar rights under the laws of other countries and states.

• Right of data subject access: The right to make a written request for details of your personal information and a copy of that personal information
• Right to rectification: The right to have inaccurate information about you corrected or removed.
• Right to delete: The right to have certain personal information about you erased, delete, randomized, or de-identified.
• Right to opt out of marketing: You can manage your marketing preferences by unsubscribe links found in the communications you receive from us or by visiting the applicable preference center.
• Right to opt out of having your data sold.
• Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in usable and readable format

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by law or as a necessity of the services provided, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request:

• Call us at 1-800-435-9237.
• Contact us via email

Only you or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

These rights are not absolute, and they do not always apply in all cases. In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we cannot comply with your request, whether in whole or in part, we will explain why.

Helzberg may change this policy from time to time. By your continued use of the Site after we make changes, you are deemed to accept those changes, so please review the policy periodically for updates.

For questions or comments about this privacy policy and our privacy practices please visit our Contact Us page.