PRIVACY POLICY

• INTRODUCTION
• LEGAL BASIS
• POLICY STATEMENT
• WHAT WE COLLECT
• USAGE
• DISCLOSURE
• INTERNATIONAL TRANSFERS
• DATA SECURITY
• HOW LONG

Privacy Policy

Fergus James values the privacy of our customers – we collect data to enhance the customer experience and security.  The privacy policy informs users what information is collected, why we need this information and how we use the information to enhance the user experience. 

Introduction

Fergus James are a luxury bespoke designer and manufacturer of fine jewellery. We are dedicated to utilizing policies, procedures and practices that protect and regard users privacy in compliance with the EU General Data Protection Regulation (“GDPR”) guidelines. Fergus James, owned by Diamond Rocks Trading DMCC, is registered in the DMCC Free zone Dubai, United Arab Emirates and for the purposes of the Data Protection Act 1998 and GDPR, the data controller is Fergus James.

At certain times, Fergus James gathers and uses information about users to enhance the website user experience, in order to make our site more user-friendly.  The Privacy Policy communicates what types of data we collect along with how it is used and stored in a safe, secure environment.  Fergus James gathers information from website users, or anyone who has had any contact with the organization including, but not limited to, walk-in customers, suppliers, affiliates, business contacts and employees.

The Fergus James privacy policy applies to all our website users, staff, business suppliers contacts and associates.  The Policy is drafted to ensure that:

• The personal data rights of our customers, staff and business associates are recognized and protected
• Personal Data is processed in compliance with GDPR
• Fergus James are mindful of our responsibilities and requirements when processing Personal Data
• Fergus James is well protected against data breach

By using our website www.fergusjames.com users accept and consent to the processes outlined in the policy.

Legal Basis For Data Collection

There are a number of various reasons that the law allows the collection and processing of personal data.

• Consent:

A good example of consent within business is when you sign up for marketing emails. By ticking that you agree to receive those promotional emails, you are agreeing to allow that company and its processor to use your data for outreach and marketing purposes. By unsubscribing, you revoke that consent.

• Contractual Obligations:

 We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.

• Legal Compliance:

We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.

• Legitimate Interest:

We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests.

 

Policy Statement

Fergus James only save and use information in situations where the user has given their consent.

We aim to comply with all relevant data protection legislation such as the GDPR and do our best to:

• Comply with the Data Protection Legislation and adhere to general data protection principles if applicable.
• Be as transparent as possible with regards to how data is gathered, processed and used as well as giving users an option to opt in/out of offering information.
• Be vigilant with suppliers and partners to ensure that their data protection processes, standards and modus operandi works to the both external legal standards as well as our own internal standards and protocols.
• Respond appropriately to users wishing to change the way we use their data for marketing/service delivery purposes
• Securely store, guard and protect all data provided to Fergus James by not disclosing any of this information to any suppliers or 3^rd parties without the users consent.
• Ensure that all Fergus James staff have read and understand the companies data protection policy as well as the importance of data protection
• Ensure that any complaints with regards to data protection are dealt with as swiftly as possible.

 

 

Information we collect from you

Fergus James collect, use and store information of website users in order to fulfill contractual obligations as well as to improve and enhance the website users personal fine-jewellery buying experience.

Users provide Fergus James with formation through a variety of different mediums including, but not limited to:

• Browsing the website
• Over the telephone
• Over email
• Filling in forms or ticking boxes
• Personal meetings in our showrooms

The information given to us includes, but is not limited to:

• Website user data
• Telephone number
• Email address
• Personal name/address/work location
• Financial information (if applicable)

Additionally, we also use Google Analytics to gather technical information that helps us to improve the effectiveness of the users shopping experience on our website.  This, for example, includes browser information and geographic location, as well as phone type, time spent on website and the number of pages visited.

Cookies

Fergus James website, www.fergusjames.com uses Cookies to enhance the individual experience of each user.  Our Cookie policy explains this in more detail.  To find out more about how to manage cookies on your browser please contact your browsers help pages.

 

Information we receive from other sources

Fergus James may have access to specific information if you have had any sort of interaction with us in the past, whether that is through services we provide or through our social media outlets.

We may also work with certain third parties that you may have authorized to share your information with us. These businesses may include, but are not limited to; business partners, subcontractors, payment services, ad networks, analytics providers, search engine providers, credit reference agencies. We will only receive information from the listed businesses if it is necessary.

At times we also collect, use and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data may come from your personal data, but is not considered personal data in law as this data does not directly or indirectly reveal your identity. If we connect the aggregate data to your personal data, we will be sure to treat the data as personal data, which will be used in accordance with this privacy policy, if it can be traced back to you.

Fergus James does not collect any unique categories of personal data – such as race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic, biometric data, or criminal convictions and offences.

If personal data is required and you fail to provide the necessary data when requested, we may not be able to start and perform the contract that we have attempted to enter with you. If we cannot proceed, we may have to cancel the service you have with Fergus James, but we will be sure to notify you if this is the case.

 

How we use your information

Fergus James will only use your personal data when the law permits us to. We will use your personal information:

• to carry out our obligations that come from any contracts entered into between you and us or to take steps at your request before entering into any contracts;

• to comply with any legal obligations to which we are subject; or

• where it is necessary for our legitimate interests, including for the purposes of preventing fraud, excluding where such interests are overridden by your interests or fundamental rights.

Examples of how we may use your data include but are not limited to:

• Providing you with information, products and services that you request from us.
• Providing you with information about other goods and services that we offer that are similar to those you have already purchased, enquired about, or that we would recommend.
• Administer www.fergusjames.com and for internal operations such as troubleshooting, data analysis, testing, or for research purposes.
• Improving www.fergusjames.com in order to ensure that content is presented in the most effective manner for you and your computer.
• Developing and test the products and services we provide you with.
• Allowing you to interact with features of the service.
• Helping us keep www.fergusjames.com safe and secure.
• Measuring the effectiveness of advertising served to you.
• Processing payments.

Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending direct marketing communications to you via email.

 

Marketing

Fergus James is constantly strives to provide you with relevant choices regarding certain personal data uses, particularly around marketing and advertising.

At times we may use your identity, contact details, usage data and marketing preferences to form a perspective on what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

If you have requested information from us, purchased goods or services from us or provided us with your details when you entered a competition or registered for a promotion, you will receive marketing communications from Fergus James. You can ask us, or third parties, to stop sending you marketing messages at any time by contacting us at any time.  Please email us at info@fergusjames.com

If you choose to opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

Fergus James will only use your personal data for the purposes for which we collected it, unless we reasonably feel that we need to use it for another reason and that reason is compatible with the initial purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us info@fergusjames.com

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis, which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where permitted by law.

Disclosure of your information

We may share your personal data with trusted third parties, for example business partners or for fraud management.

We may share your data with:

• Google Analytics based in the USA
• Crazy Egg, an analytics software provider based in the USA
• Paypal – a payment provider based in USA
• Fraud prevention agencies

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Many of our external third parties, including Salesforce and Google Analytics, are based outside the European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside the EEA to the USA, for example.

If this is necessary, we have procedures in place to ensure that this data receives the same process as we follow for the EEA. We will treat the information the same as we would for EAA companies under the stipulations of this Privacy Notice.

Data security

Fergus James has the taken appropriate security measures to prevent your personal data from being accidentally lost, used, altered or accessed in an unauthorised way. In addition, we also limit access to your personal data to those employees, agents, contractors and other third parties on a need-to-know basis. They will only be able to process your personal data on our instructions.

However, the transmission of information from the Internet is never 100% secure. Although we will always do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach immediately, where we are legally required to do so.

How long will we keep your data?

Fergus James will only retain your personal information for as long as is necessary to carry out the purpose for which it was collected. This may include for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may make your personal data unidentifiable for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.