This privacy policy sets out how MBHL Limited (“MBHL”) through our Bring Diamonds website (the “Website”) uses and protects any information that you give us when you use this website.

MBHL is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

In line with GDPR, this policy is effective from the date on which this website went live. We will update you with any changes to our privacy policy.

We understand the importance of GDPR and our role as a custodian of the data you have provided to us either as an interested person or as a user of this website.

Here is a simple summary of the content of this policy. It falls into two parts.   

Interested Parties:

• We will only collect your data if you want us to, that includes providing us your details as part of a business discussion.

• We act as a data controller for data we collect.

• We don’t do everything ourselves, we use other sub-processors such as Wild Apricot as part of our data processing.

• When it comes to removing yourself from communications from MBHL (whether directly or through the Website), you can unsubscribe at any time, and if you aren’t a member of the Website or user of the Website, we will remove your information from our records.

• We do collect cookies.

• If you wish us to remove your data, or wish to make a subject access request, please let us know by contacting us at info@bringdiamonds.com

Our Users:

• We act as a data processor for our users.

• We don’t do everything ourselves, we use other sub-processors such as Wild Apricot and Etsy as part of our operations and data processing.

The Legal Bit

Introduction:

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your sensitive information and how we will deal with it. For the purposes of the Data Protection Act (‘the DPA’) and the EU General Data Protection Regulation (‘the GDPR’), sensitive information includes what is defined as your ‘personal data’.

By visiting www.bringdiamonds.com (the ‘Website’) you accept and consent to the practices described in this Privacy Notice including the processing of your personal data in accordance with this policy.

In this Privacy Notice, we seek to abide by the letter and spirit of the guidelines laid out by the UK Information Commissioner’s Office in the document ‘Privacy Notices, Transparency and Control’.

Who We Are

We are MBHL Limited (“MBHL”), a company registered in Scotland with Company Number SC619204 and our registered office is at 7 Hopetoun Crescent, Edinburgh EH7 4AY.

We are registered with the Information Commissioner’s Office under Registration Number 00014934120, registered 02.11.20 and you can view more details of our registration by going to the ICO website.

For the purposes of the DPA and in line with the GDPR, MBHL is the Data Controller. If you register to be a member of the Website then we will also as a Data Processor on your behalf. If you have any concerns about the way we use your information or any questions about this Privacy Notice, please let us know.  We can be contacted via email at info@bringdiamonds.com, or you can write to us at the address above.

What we do with your information

We Will Use Your Information To:

• Communicate with you for the purpose of furthering our mutual, business
• Send you information about the services that we offer and other related topics;
• Collect feedback about our services; and
• Send you information about the services we provide by other agreed means.

We may compile statistics about user trends on our Website, which are used by third party organisations to understand how users interact with businesses, brands and one another online and to advise about these things. These statistics are drawn from a dataset which does not contain any information from which you can be identified.

• If you have provided us with your contact details as part of initial or ongoing business discussions, we will continue to process your information on the legal basis of legitimate interests.

• If you have previously signed up to receive marketing information from us by signing up to the website, we will continue to process your information on the legal basis of legitimate interests.

Wherever we have used the legal basis of legitimate interests, we have carried out a Legitimate Interests Assessment to document this legal basis.

Information we collect from you

We Will Collect And Process The Following Information About You:

• Information you give us – this is information about you that you give us by filling in forms on our website or by corresponding with us by phone, email or otherwise. 
• We only request from you the minimum data required for you to use our service.
  

The information we require from you to sign up to our membership area will include your first name and an email address. We do not collect store payment details, our partner takes payments and processes this information. See their privacy policy here.

Where we hold and what we do with your information

Cross-Border Transfers of Personal Data:

Your personal data may be transferred to and stored on servers at Wild Apricot’s hosting provider, Amazon Web Services (AWS), in the United States.  The European Commission has recognised Canada (commercial organisations) as providing an adequate level of data protection.  The data protection and privacy laws of the United States may not be as comprehensive as the laws in your country.  For example, personal data transferred to the United States may be subject to lawful access requests by federal and state authorities in the United States.  AWS participates in the EU-U.S. Privacy Shield principles and the Swiss-U.S. Privacy Shield principles regarding the collection, use, sharing and retention of personal data from the European Economic Area and Switzerland, as described in the EU-U.S. Privacy Shield certifications and Swiss-U.S. Privacy Shield certifications of AWS.  Click  here  for more information concerning such certifications of AWS. 

We will never share your user information with third parties for promotional purposes.

We store some client data electronically using Google Drive. If you want to learn more about Google’s service and how they handle your data you can visit their website here.

If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

What we do to ensure the security of your personal information

We take the security of your personal data very seriously. Our approach to information security is evolving and is reviewed periodically.

We have policies and practices in place that not only ensure our compliance under the DPA but also the GDPR, including training and adequate procedures put in place for any staff that handle or have access to sensitive information.

Your rights regarding your personal information

We may contact you via email with updates about the inventory that we offer or any changes that we have made to our website.

You can opt in or out at any time by clicking the ‘Unsubscribe’ link in our emails. 

Our website may, from time to time, contain links to and from the websites of members and to others of interest to our business. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we are not responsible or liable for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Your Rights

You have the right to find out about what information we hold about you. You can exercise that right by contacting us and we will send you any request for information in a suitable electronic form within 20 working days.

To make a request for information please contact info@bringdiamonds.com and a member of our team will be in touch.

If your personal data is incorrect then you have the right to rectify this information and ensure that it is accurate and up to date.  In this case please contact us at the email address above and a member of the team will rectify this on your behalf.

You have the right ‘to be forgotten’ and to have your personal identifiable information permanently deleted from our systems.  Again, if you would like to exercise this right then please contact us at info@bringdiamonds.com

There will be no charge made for reasonable electronic access to your information, your right to rectification or for your right to be forgotten from our systems.

How long we hold your information for

At MBHL we have procedures in place to review every 12 months what personal data we hold. If you have not interacted with us or accessed our services during this or the subsequent period then we will delete your personal data from our systems, but will send you an email first informing you of our intention to do so.

Changes to this Privacy Notice

Any changes we may make to our Privacy Notice in the future will be posted on this page. The new terms may be displayed on-screen and you will be required to read and accept them to continue your use of our services.

Our Cookie Policy

If you’d like to manage your use of cookies or completely turn off cookies then you can find out how to do so by using the link here. Please note that if you do limit or block cookie use on our website the functionality of the Website may be affected.

Our website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site. By continuing to browse the Website, you agree and consent to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

As part of our overall approach to privacy and transparency, this section describes what cookies are in the context of our web and mobile interfaces, and what their use means to you. At the end, we’ve included some links to help you research cookies and their impact, and how you can use your web browser to control the way it manages cookies.

We use the following types of cookies:

• Strictly necessary cookies –these are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-payment system.

• Analytical/performance cookies – these allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies –these are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies –these cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose but these cookies will contain no information capable of identifying you personally to us.

You can find more information about the individual cookies we use and the purposes for which we use below:

GOOGLE ANALYTICS

We use Google Analytics to understand general trends about our content and traffic sources; for example, where users come from, which pages are most popular, which sites provide most traffic, how our marketing efforts impact the number of visits we receive.

Google’s statement about privacy can be found here.

FACEBOOK BUTTON

We use Facebook button to allow you to share details of our site with your friends and other Facebook users.

Facebook’s statement about privacy relating to their Connect feature is here and also here.

INSTAGRAM BUTTON

We use an Instagram button to allow you to share details of our site with your friends and other Instagram users.

Facebook’s statement about privacy relating to their Connect feature is here.

LINKEDIN BUTTON

We use a LinkedIn button to allow you to share our platform and the services we offer with your connections. LinkedIn’s information about privacy can be found here.

Contact the Information Commissioner if there is a problem

If you consider we have not addressed your problem, you can contact the UK Information Commissioner’s Office for assistance. Further information can be found here.