- Gemconsult understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our websites, Gemconsult and its affiliated websites will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
What is personal data:
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Where and how we collect data:
We would like to inform you of (i) the general categories of personal data that we may process, (ii) the purposes for which we may process personal data, and (iii) the legal bases of the processing.
We may process:
- Data about your use of our Sites (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics, our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving Our Sites.
- your account data (“account data“). The account data may include your name, email address and IP address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our sites, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you (or your employer) and us and/or taking steps, at your request, to enter into such a contract.
- information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is legitimate interests, namely offering services to relevant potential customers.
- information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your IP address, your job title or role, your contact details, and information contained in communications between us and you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is the performance of a contract between you (or your employer) and us and/or taking steps, at your request, to enter into such a contract.
- information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
- information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our Sites will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
- your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice and the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks and the protection and assertion of our legal rights, your legal rights and the legal rights of others.
- In addition to the specific purposes for which we may process your personal data set out in this section, we may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Please do not supply any other person’s personal data to us, unless we prompt you to do so. Please note that our sites and services are targeted at persons over the age of 18. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
What we do with your data:
Nothing evil, we promise. If you’ve consented to receiving updates and promotions from us, we’ll send you a regular newsletter with free content and might email you once in a while with some Gemconsult promotions. These emails can sometimes be automated and customised based on your web behaviour, your job title and interests. If you happen to be part of the target audience for our premium services we might also send you an email or give you a call about this.
How long and where we store your data:
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods: up to three years after your last activity on our website or interaction with one of our emails.
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on whether you are qualifies as a potential user of our services or reader of World Luxury Jewellers. Notwithstanding the other provisions in this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We do not share your data with external third parties. Except to the following third parties to supply certain products and/or services These may include payment processing, delivery, sales, marketing (including sending newsletters) and website analytics. In some cases, those third parties may require access to some or all of your personal data that we hold.
Google Analytics: anonymised website analytics – based in the EEA and US
MailChimp: email marketing – based in the US
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in section ‘How long and where we store your data’. If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in section ‘How long and where we store your data’. In addition to the above, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. The way you can do this is set out in the heading ‘How Can I Access My Personal Data?’.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us to find out more.
- The right to be forgotten, e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
How can I access my personal data:
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent via email here. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How can I control my personal data:
In addition to your rights under the GDPR, in the section ‘Your Rights’, when you submit personal data via our ites, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
Can I withhold information?
You may access our sites without providing any personal data at all. However, to use all features and functions available on our Sites you may be required to submit or allow for the collection of certain data.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on our sites. We recommend that you check this page regularly to keep up-to-date.
Who we are (the data controller):
Our sites are owned and operated by Greathouse Advisory BV.
Our legal details: Greathouse Advisory BV, with company number BE 0732697517 and registered office in region of Antwerp – Belgium. You can contact us via our contact page.