PRIVACY POLICY

Fedoma Inc. (“Fedoma”, “we”, “us”, “our”)recognize the importance of your personal information. This Privacy Policy setsout how Fedoma uses and protects information that it collects from itscustomers, visitors and users (collectively, the “Users”) through, or inassociation with, its website with a homepage located at www.Fedomajewellery.com(the “Site”), its products and services that may be offered from time to timevia the Site, its related social media sites, or otherwise through Users’interactions with Fedoma (the Site, products, services, and social media pages,collectively, the “Services”). By accessing the Services, using features of theServices, and/or submitting information to Fedoma, you are bound by all termsand conditions in the Terms of Use at https://www.fedomajewellery.com/pages/terms-of-use (the “Terms of Use”) and this PrivacyPolicy.


INFORMATION WECOLLECT

Information you provide: When you register an account or complete atransaction through the Services, we collect some “Personal Information” (thatis, any information that can be directly or indirectly associated with you),such as your name, title, email address, phone number, address, billinginformation and other similar information. You may also provide us with certainPersonal Information of other people (e.g., if you are sending a gift tosomeone else).

Device Identifiers: When you access the Services by or througha device, we may access, collect, monitor and/or remotely store one or more“device identifiers”. Device identifiers allow us to uniquely identify yourdevice and are used to enhance the Services (including sending updates andinformation from the Services). A device identifier may also be used inconjunction with other Personal Information.

Analytics: When you access our Services, we may collect information(either directly or using third party services) using logging and cookies whichcan sometimes be correlated with Personal Information. We use this informationto monitor and analyze use and interest in the Services. See the section on“Service Providers” for more detail in this respect.

Log data: As with most website and technology services delivered overthe Internet, our servers automatically collect information when you access oruse our Services and record it in log files. This log data may include theInternet Protocol (IP) address, the address of the web page visited beforeusing the Services, the purchases that you make, the products you view, browsertype and settings, the date and time the Services were accessed, informationabout browser configuration and plugins, language preferences and cookie data.

Cookie Information: A cookie is a text file stored locally ona User’s device by the User’s web browser, which enables the browser toremember passwords, orders, preferences, and other information when visiting awebsite. We use cookies and similar technologies such as pixel tags and webbeacons that help us collect certain usage data about you (such as yourpreferences and to process shopping cart items) (“Usage Data”), which maybecome Personal Information due to direct association with you. The Servicesmay also include cookies and similar tracking technologies of third parties,which may collect information about you via the Services and across other sitesand online services, including social media platforms. Our use of cookies andsimilar technologies such as pixel tags and web beacons is generally foroperational purposes, website performance purposes, enhancing functionality ofthe Services and advertising. For more details about how we use thesetechnologies, please see the section on “Service Providers” below.


USE OF INFORMATION

We generally use information that we collect forthe purposes of fulfilling our contractual obligations to you, in furtheranceof our legitimate interests in operating the Services and our business and/orwhere you have consented to such usage.

More specifically, Fedoma uses PersonalInformation:

To provide, update, maintain and protect theServices and our business. Thisincludes use of Personal Information to support delivery of the Services,prevent or address service errors, security or technical issues, analyze andmonitor usage, trends and other activities or at your request. Fedoma may useyour email address or phone number to send you notices (including any noticesrequired by law, in lieu of communication by postal mail). If you correspondwith Fedoma by email, we may retain the content of your email messages, youremail address and our responses.

As required by applicable law, legal process orregulation. Fedoma may incertain instances be compelled by law to process your Personal Information inorder to comply with a binding order. We will only do so to the extentreasonably required by that order.

To communicate with you by responding to yourrequests, comments and questions. If you contact Fedoma, Fedoma may use your PersonalInformation to respond.

To send emails and other communications. Fedoma may send you service, technical andother administrative emails, messages and other types of communications. Fedomamay also contact you to inform you about changes in our products, and importantnotices, such as security and fraud notices.

For billing, account management and otheradministrative matters. Wemay need to contact you for invoicing, account management and similar reasons,and we use account data to administer accounts and keep track of billing andpayments.

To investigate and help prevent security issuesand abuse.

For marketing purposes. Fedoma may use the information we collect,including Personal Information, to market our products and services to new andexisting customers, and to understand our audience. Fedoma may also use yourPersonal Information to send you marketing messages and may provide suchinformation to third parties to send you information about our products andservices. If you are in the EEA we will only do so if you have opted in toreceive such communications. If you don’t want to receive these messages, youcan opt out by following the instructions in the message or by contacting us asprovided at the end of this Privacy Policy.


INFORMATION SHARINGAND DISCLOSURE

Fedoma may share, transfer and/or disclose yourPersonal Information to or with third parties in order to provide the servicesor products requested by you, and under the following circumstances:

  • Fedoma shares certain Personal Information with itsshipping company, credit card processing company, payment serviceprovider(s), email service provider(s) and other third parties necessaryin order to fulfill an order placed through the Services. These thirdparties are prohibited from using your Personal Information for promotionalpurposes.
  • Fedoma may share Personal Information and otherinformation we collect with our Service Providers and other third partiesin connection with our marketing and business development efforts.
  • Fedoma shares certain information that is traditionallynot considered Personal Information (such as device, analytics, and usagedata) for purposes of better understanding the usage of the Services byUsers and improving on that experience.
  • Fedoma reserves the right to disclose PersonalInformation: as permitted or required by law; when Fedoma believesdisclosure is necessary to protect our rights or to comply with a legalprocess; and/or in the event it is necessary to prevent, investigate ortake action regarding unlawful, illegal or suspicious activities thatviolate the Terms of Use or this Privacy Policy.
  • Fedoma may transfer Personal Information to a buyer orother successor in the event of a merger, divestiture, restructuring,reorganization, dissolution, or other sale or transfer of some or all ofour assets, whether as a going concern or as part of bankruptcy,liquidation, or similar proceeding, in which Personal Information held by Fedomaabout Fedoma’s Users is among the assets transferred.

 

All information voluntarily shared by youthrough forums, comments, or blog posts is publicly available and your usernamemay be visible by other Users. Fedoma is not responsible for any informationyou submit that can be read by other Users and can be used to send youunsolicited information by other Users.

Fedoma may, from time to time, choose to postcertain Personal Information about a User for promotional or Service-relatedpurposes; prior to posting said information, Fedoma will obtain the User’sconsent via email.


RETENTION OF DATA

Fedoma will retain your Personal Information foras long as is reasonable or appropriate for the purposes set out in thisPrivacy Policy. We will also retain and use your Personal Information to theextent necessary or reasonable to comply with our legal obligations (forexample, if we are required to retain your data to comply with applicablelaws), resolve disputes, and enforce our legal agreements and policies.

Fedoma will also retain Usage Data for internalanalysis purposes. Usage Data is generally retained for a shorter period oftime, except when this data is used to strengthen the security or to improvethe functionality of our Service, or we are legally obligated to retain thisdata for longer time periods.


TRANSFER OF DATA

Your information, including PersonalInformation, may be transferred to — and maintained on — computers locatedoutside of your state, province, country or other governmental jurisdictionwhere the data protection laws may differ from those in your jurisdiction.

If you are located outside the United States,please note that we transfer data, including Personal Information, to theUnited States and process it there.

By using the Services, you understand andacknowledge that your Personal Information will be transferred to and processedin the United States, which may have different data protection rules than inyour country.

Fedoma will take steps reasonably designed totreat your Personal Information securely and in accordance with this PrivacyPolicy, as further described below.


YOUR DATA PROTECTIONRIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European EconomicArea (EEA), you have certain data protection rights. Fedoma aims to takereasonable steps to allow you to correct, amend, delete, or limit the use ofyour Personal Information.

If you wish to be informed about what PersonalInformation we hold about you, and/or if you want it to be removed from oursystems, please contact us using the contact information set out below.

In certain circumstances, you have the followingdata protection rights:



  • Request access to your Personal Information (commonly known as a "data subject accessrequest"). This enables you to receive a copy of the PersonalInformation we hold about you where we are the data controller and tocheck that we are lawfully processing it.
  • Request correction of the Personal Information that wehold about you. This enables you to haveany incomplete or inaccurate information we hold about you corrected,though we may need to verify the accuracy of the new information youprovide to us.

  • Request erasure of your Personal Information.This enables you to ask us to delete or remove PersonalInformation where there is no good reason for us to continue to processit. You also have the right to ask us to delete or remove your PersonalInformation where you have successfully exercised your right to object toprocessing (see below), where we may have processed your informationunlawfully or where we are required to erase your Personal Information tocomply with local law. Note, however, that we may not always be able tocomply with your request for erasure for specific legal reasons, whichwill be explained to you, if applicable, at the time of your request.

  • Object to processing of your Personal Information Where we are relying on a legitimate interest (orthose of a third party) and there is something about your particularsituation which makes you want to object to processing on this ground, asyou feel it impacts on your fundamental rights and freedoms. You also havethe right to object where we are processing your Personal Information fordirect marketing purposes. In some cases, we may demonstrate that we havecompelling legitimate grounds to process your information which overrideyour rights and freedoms.

  • Request restriction of processing of your PersonalInformation. This enables you to askus to suspend the processing of your Personal Information in the followingscenarios: (a) if you want us to establish the information's accuracy; (b)where our use of the information is unlawful but you do not want us toerase it; (c) where you need us to hold the information even if we nolonger require it as you need it to establish, exercise or defend legalclaims; or (d) you have objected to our use of your information but weneed to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your Personal Information toyou or to a third party. Wewill provide to you, or a third party you have chosen, your PersonalInformation in a structured, commonly used, machine-readable format. Notethat this right only applies to automated information which you initiallyprovided consent for us to use or where we used the information to performa contract with you.

  • Withdraw consent at any time where we are relying onconsent to process your Personal Information. However, this will not affect the lawfulness ofany processing carried out before you withdraw your consent. If youwithdraw your consent, we may not be able to provide certain services toyou. We will advise you if this is the case at the time you withdraw yourconsent.

 

You have the right to complain to a DataProtection Authority about our collection and use of your Personal Information.For more information, please contact your local data protection authority inthe European Economic Area (EEA).

If you wish to exercise any of the rights setout above, please contact us using the contact details below.

You will not have to pay a fee to access yourPersonal Information (or to exercise any of the other rights). However, we maycharge a reasonable fee if your request is clearly unfounded, repetitive orexcessive. Alternatively, we may refuse to comply with your request in suchcircumstances.

We may need to request specific information fromyou to help us confirm your identity and ensure your right to access yourpersonal information (or to exercise any of your other rights). This is asecurity measure designed to ensure that Personal Information is not disclosedto any person who has no right to receive it. We may also contact you to askyou for further information in relation to your request to speed up ourresponse.


CALIFORNIA PRIVACYRIGHTS

California residents, see our California PrivacyNotice for more information about certain legal rights.


NEVADA PRIVACYRIGHTS

Nevada law permits our Users who are Nevadaconsumers to request that their personal information not be sold (as definedunder applicable Nevada law), even if their Personal Information is notcurrently being sold. Requests may be sent to support@Fedomajewellery.com andare free of charge.


CHILDREN’S PRIVACY

Our Service is not intended for anyone under theage of 18.

We do not knowingly collect personallyidentifiable information from anyone under the age of 18. If you are a parentor guardian and you are aware that your child has provided us with PersonalInformation, please contact us. If we become aware that we have collectedPersonal Information from children without verification of parental consent, wetake steps to remove that information from our servers.


PROTECTING YOURINFORMATION

Fedoma implements security measures designed tomaintain the security of your Personal Information. These security measures areimplemented both during transmission of Personal Information and once received.The security of your Personal Information is important to us. Certain sensitiveinformation submitted, such as credit card information, is encrypted usingsecure layer technology (SSL). However, no method of safeguarding informationis completely secure. While we use measures designed to protect PersonalInformation, we cannot guarantee that our safeguards will be effective orsufficient. In addition, you should be aware that Internet data transmission isnot always secure, and we cannot warrant that information you transmitutilizing the Services is or will be secure.


THIRD PARTIES

In some instances the Services might containlinks to other third party sites and services. When you access these othersites or services, you are leaving the Services. Fedoma is not responsible orliable for the activities on, security or privacy practices of, or content onthird party sites. We encourage you to read the privacy statements posted oneach such third party site or service.


SERVICE PROVIDERS

We may employ third party companies andindividuals to facilitate the Services and our provision of products andservices through the Site, to provide the Services on our behalf, to performservices related to the Services (as discussed above), to assist us inanalyzing how our Services are used, and to assist us with business developmentand marketing efforts related to the Services (“Service Providers”).

These Service Providers may have access to yourPersonal Information only to perform these tasks on our behalf.


COMMUNICATIONSOPT-OUT

You may opt out of receiving marketing or othercommunications from us at any time by following the opt-out link or otherunsubscribe instructions provided in any email message received, or bycontacting us using the contact information provided below. If you wish to optout by sending us an email to the address provided below, please include“Opt-Out” in the email’s subject line and include your name and the emailaddress you used to sign up for communications in the body of the email. Notethat, even if you opt out of receiving marketing communications from Fedoma, wewill still send you order confirmations and other non-marketing relatedmessages.


EDIT OR DELETEACCOUNT

If your personally identifiable informationchanges, you may correct, update, or amend your account by making the desiredchanges on the account profile page found after you log-in at www.Fedomajewellery.com.If you wish to delete/remove or deactivate your account on the Site, pleasecontact us using the information provided below.


CHANGES TO PRIVACYPOLICY

Fedoma may amend or update from time to timethis Privacy Policy in its sole discretion and without prior notice. Any suchamendments or updates will be effective upon our posting of the revised PrivacyPolicy. Your continued use of the Services following our posting of any revisedPrivacy Policy will constitute your acknowledgement and acceptance of theamended Privacy Policy.


EFFECTIVE DATE

This policy was last modified July/2020.