Data controller details
We are the data controller in relation to the processing of the personal information that you provide to us. Our contact details are as follows:
- Address: London Diamond Bourse, 100 Hatton Garden, London, England, EC1N 8NX.
- Email address: Help@davidashleys.com (please include “Personal Data Request” in your subject heading to ensure it receives the correct attention).
How we collect your information
Generally, the information we hold about you comes from the way you engage with us, for example by doing any of the following:
- through engaging with us via our website;
- purchasing a product and/or services from us;
- providing us with information in the course of registering as a subscriber;
- contacting us offline, for example by telephone, SMS, email or by post; and
- interacting with us using social media.
What we collect, legal grounds and purpose for processing
The types of personal data that we may collect, use, store and transfer about you are set out below, together with the legal grounds and purposes for processing:
|What we collect||Purposes and legal grounds|
|Contact information such as your name, email address, postal address and mobile or other telephone number.||
|Payment and account information (such as your payment card number, expiration date, security code and billing address)||
|Identification information contained in or provided to us as part of our customer ID checks. This includes details included in copy personal photo and residential ID documents we receive.||
|Technical data including internet protocol (IP) address, unique device identifier, location information, metadata, cookies and other information associated with other files stored on your device.||
Sharing your information
Please note that personal information we are holding about you may be shared with and processed by:
- regulators or other third parties for the purposes of monitoring and/or enforcing our compliance with any legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
- credit reference and fraud prevention agencies;
- any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
- other parties and/or their professional advisers involved in a matter where required as part of the conduct of the services;
- our own professional advisers and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
- credit financing companies (such as Klarna) if financing is requested by you as part of a purchase of goods and/or services from us;
- our service providers and agents (including their subcontractors) or third parties which process information on our behalf (e.g. internet service and platform providers, our bank, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, products, services and information you have requested; and
- another organisation to whom we may transfer our agreement with you or if we sell or buy (or negotiate to sell or buy) our business or any of our assets (provided that adequate protections and safeguards are in place).
Please note that we include links within our website to third party social media providers such as Facebook and Twitter, but we will not share your information with such providers without your consent.
We will not transfer personal data relating to you to a country which is outside the European Economic Area (EEA) unless:
- the country or recipient is covered by an adequacy decision of the Commission under GDPR Article 45;
- appropriate safeguards have been put in place which meet the requirements of GDPR Article 46 (for example using the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA); or
- one of the derogations for specific situations under GDPR Article 49 is applicable to the transfer. These include (in summary):
- the transfer is necessary to perform, or to form, a contract to which we are a party:
- with you; or
- with a third party where the contract is in your interests;
- the transfer is necessary for the establishment, exercise or defence of legal claims;
- you have provided your explicit consent to the transfer; or
- the transfer is of a limited nature, and is necessary for the purpose of our compelling legitimate interests.
- the transfer is necessary to perform, or to form, a contract to which we are a party:
Retention of personal data
- Unless we are required or permitted by law to hold on to your data for longer specific retention period (for example, by rules imposed by the Financial Conduct Authority), we will only hold your personal information on our systems for a period of 6 years from your last transaction with us.
- In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
- Where we no longer need your personal information, we will dispose of it in a secure manner.
Your rights in respect of your personal data
- You have certain rights under existing data protection laws, including the right to (upon written request) access a copy of your personal data that we are processing. From 25 May 2018, in accordance with the GDPR:
- you will have the following rights:
- right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one copy of the personal information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs); and
- right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete; and
- in certain circumstances, you will also have the following rights:
- right to erasure/“right to be forgotten: the right to withdraw your consent to our processing of the data (if the legal basis for processing is based on your consent) and the right to request that we delete or erase your personal information from our systems (however, this will not apply if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);
- right to restriction of use of your information: the right to stop us from using your personal information or limit the way in which we can use it;
- right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and
- right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or for marketing purposes.
- You have the right to unsubscribe from our marketing communications at any time by following the link in the footer of the last email you received from one of our brands (“Unsubscribe”) or by sending your request with detailed instructions to us (see contact details above in the “Data Controller details” section.
- If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: www.ico.org.uk.
Automatic decision making
We do not make decisions based solely on automated data processing, including profiling.
We keep your information protected by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:
- where appropriate, data is encrypted when transiting on our system or stored on our databases;
- we have implemented safeguards in relation to access and confidentiality in order to protect the information held within our systems; and
- we frequently carry out risk assessments and audits to monitor and review threats and vulnerabilities to our systems to prevent fraud.
However, while we will do our best to protect your personal information, we cannot guarantee the security of your information which is transmitted via an internet or similar connection. It is important that all details of any username, password and/or other identification information created to access our servers are kept confidential by you and should not be disclosed to or shared with anyone.
Last updated August 2020