PRIVACY POLICY & COOKIES

De Beers Group Industry Services WEBSITE PRIVACY NOTICE
Our Site (“Our Site”) is operated by IIDGR UK Limited ("Company", “we” or “us” or “our”). We are registered in England and Wales under company number 08597754 and have our registered office at 20 Carlton House Terrace, London, SW1Y 5AN, UK. We are committed to protecting and respecting your privacy and we comply with data protection legislation and other applicable local laws.

The Company is a member of the De Beers Group of Companies ("Group"). The Group is made up of different legal entities, including:

• DeBeers Diamond Jewellers Limited
• De Beers Auction Sales Belgium NV
• De Beers UK Limited
• Forevermark Italy S.r.l.
• Forevermark Limited (UK)
• Forevermark NV
• Forevermark Marketing (Shanghai) Limited
• Element Six (UK) Limited
• Element Six AB
• Element Six B.V
• Element Six GmbH
• Element Six Limited
• Element Six Limited (Ireland)
• Element Six Technologies Limited

You can find out more about our Group at www.debeersgroup.com or by contacting us using the information in the contact us section.

This privacy notice (together with our Terms and Conditions which can be found here: https://www.debeersgroupservices.com/terms-conditions and any other documents referred to in it) sets out how we will use any personal data which you provide through our Site. Please read it carefully before you proceed. Unless you have carefully reviewed and completely understand all the contents in this privacy notice, you will not be entitled to access or use Our Site or any services therein.

Updates
We may amend this privacy notice from time to time to keep it up to date with legal requirements and the way we operate our business, and will place any updates on this webpage. Please regularly check these pages for the latest version of this notice.  If we make fundamental changes to this privacy notice, we will seek to inform you by notice on our Site or email where possible.  This privacy notice was last updated on 4 February 2019.  

Third Party Websites
You might find external links to third party websites on our Site. This privacy notice does not apply to your use of a third party site. We are not responsible for the privacy practices of such third party websites.
 
WHAT PERSONAL DATA WE COLLECT AND WHEN AND WHY WE USE IT

In this section you can find out more about the types of personal data we collect when we collect personal data how we use personal data the legal basis for using personal data

 
When we collect personal data
Personal data is any information capable of identifying a natural person, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to their his or her physical, physiological, mental, economic, cultural or social identity.  Data is considered personal when it enables anyone to link information to a specific person, even if the person or entity holding that data cannot make that link.
We collect personal data about you collectively ("you") if you register with or use our Site or request our services.
Our Site is not intended for children and we do not knowingly collect data relating to children.

If you request our services

• If you engage our services through our Site, we will process your personal data in order to provide you with relevant training courses.
• The personal data that we process to do so will be the personal data that you provide to us, such as your name and your contact details (such as your email address).
• The source of your personal data will be you, however, we may also generate personal data internally if this is needed to manage the training courses.  You hereby authorize us to generate personal data for such purpose.

If you contact us using the enquiry form on our Site

• If you contact us using the enquiry form, we will process your personal data in order to consider and respond to those queries.
• The personal data that we process to do so will be the personal data that you provide to us, such as your name, your contact details (such as email address) and the content of your query.
• The source of your personal data will be you, however, we may also generate personal data internally if this is needed to respond to your query. You hereby authorize us to generate personal data for such purpose.

 
Cookies

• If you visit our Site, we use cookies to understand who has seen which webpages, to determine how frequently particular pages are visited and to determine the most popular areas of our Site.
• Cookies will collect personal data about you. The personal data that is collected by these cookies is internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site.
• The source of this personal data will be you, gathered by the cookie.  For further information, please see the Cookies section below.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Legal basis for using your personal data
We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do this. This may be because:

• we need to use your personal data to perform a contract or take steps to enter into a contract with you; and/or
• we need to use your personal data for our legitimate interest as a commercial organisation. In all such cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the Legal Rights section below; and/or
• we need to use your personal data to comply with a relevant legal or regulatory obligation that we have; and/or
• We have your consent to using your personal data for a particular activity. 

In particular:

What we use your information for	Legal basis for using personal data	Legitimate interests legal basis
To register your account	Performance of a contract	Not applicable
To manage our relationship with you which will include: (a) notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	Performance of a contract   Legitimate interests	To keep our records updated and to study how individuals use our products/services
To consider and respond to queries that you submit using the "contact us" section of our Site	Legitimate interests	The management of our business
To manage our Site and improve your user experience	Legitimate interests	To ensure the effective operation of our Site.   To ensure that content from our Site is presented in the most effective manner for you and for your computer.   If you review or download information on our Site, we track the visit to give us information about which part of the site is frequented.

If you would like to find out more about the legal basis for which we process personal data please contact us.

COOKIES
A cookie is a small text file containing small amounts of information which is downloaded to / stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website.
Cookies help us remember information about your visit to our Site, like your country, language and other settings. They can also help us to operate our Site more efficiently and make your next visit easier. Cookies can allow us to do various other things, as explained further in our Cookie Policy which you can access by clicking on the link below. 

For more information about how our cookies work and information about how to manage your cookie settings please visit our Cookie Policy.

Sharing Personal Data Others

In this section you can find out more about how we share personal data: within Company with third parties that help us provide our products and services; and government organisations and agencies, law enforcement and regulators

We share your personal data in the manner and for the purposes described below:

• within the Group, where such disclosure is necessary to provide you with our products or services or to manage our business;
• with Ridgeway (our digital agency), Mailgun Technologies, Inc (our email delivery service provider) and other third parties who help manage our business and deliver our services;
• with government organisations and agencies, law enforcement, supervisory authorities and regulators, which may include the Information Commissioner's Office or the Cyberspace Administration of China, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies; and
• we may share in aggregate, statistical form, non‑personal data regarding the visitors to our Site, traffic patterns, and website usage with our partners, affiliates or advertisers.

Where appropriate, the third parties set out above have agreed to confidentiality restrictions and use any personal data we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us.

If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets.

HOW WE PROTECT AND STORE YOUR INFORMATION
Security

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

While we have implemented reasonable technical and organisational precautions to protect the security and integrity of personal data provided to our Site, due to the inherent nature of the internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. We maintain physical, electronic and procedural safeguards to protect your Personal Data.
You agree to (a) immediately notify us of any unauthorised use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session. It is your responsibility to control the dissemination and use of your password, control access to and use of your account, and notify us when you desire to cancel your account on this Site. To the extent permitted by law, we are not responsible or liable for any loss or damage arising from your failure to comply with this provision.

We will not be liable for disclosure of your information due to errors or unauthorised acts of third parties during or after transmission.

We recommend that you change your password every three months. If you are using a public computer (e.g. at a library), or a shared computer, we urge you to log out of your account and our Site altogether, and quit the browser application before you leave the computer. This will help prevent others from accessing your account and any personal information.

In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavour to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.

Storing your personal data

We will store your personal data for as long as is reasonably necessary for the purposes for which it was collected, as explained in this privacy notice. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner. In some circumstances we may store your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting  requirements.

In specific circumstances we may store your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.

LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal data. Click on the links below to learn more about each right you may have:

To access personal data

You have a right to request that  we provide you with a copy of your personal data that we hold and you have the right to be informed of; (a) the source of your personal data; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal data  may be transferred.

To rectify / erase personal data

You have a right to request that  we rectify inaccurate personal data. We may seek to verify the accuracy of the personal data before rectifying it.
You can also request that we erase your personal data in limited circumstances where:

• it is no longer needed for the purposes for which it was collected; or
• you have withdrawn your consent (where the data processing was based on consent); or
• following a successful right to object (see right to object section); or
• it has been processed unlawfully; or
• to comply with a legal obligation to which the Company is subject.

To the extent permitted by law, we are not required to comply with your request to erase personal data if the processing of your personal data is necessary:

• for compliance with a legal obligation; or

• for the establishment, exercise or defence of legal claims

Right to restrict the processing of your personal data 

You can ask us to restrict your personal data, but only where:

• its accuracy is contested, to allow us to verify its accuracy; or
• the processing is unlawful, but you do not want it erased; or
• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal data following a request for restriction, where:

• we have your consent; or
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.

Right to transfer your personal data

You can ask us to provide your personal data to you in a structured, commonly used, machine‑readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

• the processing is based on your consent or on the performance of a contract with you; and
• the processing is carried out by automated means.

Right to object to the processing of your personal data

You can object to any processing of your personal data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection,  we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to object to how we use your personal data for direct marketing purposes

You can request that  we change the manner in which we contact you for marketing purposes.

You can request that  we not transfer your personal data  to unaffiliated third parties for the purposes of direct marketing or any other purposes.

Right to obtain a copy of personal data safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal data  is transferred outside of the European Union.

We may redact data transfer agreements to protect commercial terms.

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time. 

If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal data to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request. 

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

CONTACT US
The primary point of contact for all issues arising from this privacy notice is our Data Protection Team. The Data Protection Team can be contacted in the following ways:

Email address: dataprotection@angloamerican.com

Telephone number: +44 (0)20 7968 8888

Postal address: 20 Carlton House Terrace, London, SW1Y 5AN

If you have any questions, concerns or complaints regarding our compliance with this privacy notice, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact our Data Protection Team. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

To contact your data protection supervisory authority

You have a right to lodge a complaint with your local data protection supervisory authority (i.e. the regulatory authority in your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority.
 
De Beers Group Industry Services Website Cookie Policy
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to Our advertisers. This is statistical data about Our users’ browsing actions and patterns, and does not show personal details that identify you.
 
For the same reason, We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies are small pieces of information sent by a web server to a web browser which allow the web server to recognise the web browser. They help Us to improve Our Site and to deliver a better and more personalised service. They enable Us:

• To estimate Our audience size and usage pattern.
• To store information about your preferences, and so allow Us to customise Our Site according to your individual interests.
• To speed up your searches.
• To recognise you when you return to Our Site.

You can control how your browser handles cookies received from websites. You can choose to refuse all cookies, or to be prompted before a cookie is saved to your hard drive, or to only accept cookies from certain websites that you designate. Information on deleting or controlling cookies is available at www.AboutCookies.org. By refusing to accept cookies from Us, you may not be able to use some of the features and functionality available on Our Site.

Here is a list of the cookies on Our Site and what they are used for:

Cookie Name	Purpose	Type of cookie
cookiesViewed	On initial load Cookie Policy loads in, if user closes this window (and therefore accepts cookie policy) this cookie is stored so as to not show the message again
ASP.NET_SessionId	General purpose platform session cookie, used by sites written with Miscrosoft .NET based technologies. Usually used to maintain an anonymised user session by the server.	Session
ga	This cookie is used to distinguishes unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years.	Persistent & First Party Cookie
gat	This cookie is used to distinguishes unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years.	Persistent & First Party Cookie
_hjid	Hotjar cookie. This cookie is set when the customer first lands on a page with the Hotjar script. It is used to persist the random user ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.	Session
_hjIncludedInSample	This cookie is associated with web analytics functionality and services from Hot Jar. It uniquely identifies a visitor during a single browser session and indicates they are included in an audience sample.	Session

 
Our server automatically collects data about your server’s internet address when you visit Us. This information, known as an Internet Protocol address, or IP Address, is a number that’s automatically assigned to your computer by your internet service provider whenever you’re on the internet. When you request pages from Our Site, Our servers may log your IP Address and sometimes your domain name. Our server may also record the referring page that linked you to Us (e.g., another website or a search engine); the pages you visit on Our Site; the website you visit after Our Site; the ads you see and/or click on; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on Our Site or a referral site; and other web usage activity and data logged by Our web servers. We use this information for internal system administration, to help diagnose problems with Our server, and to administer Our Site. Such information may also be used to gather broad demographic information, such as country of origin and internet service provider. Any or all of activities with regard to Our Site usage information may be performed on our behalf by our services providers.