Privacy Policy

Last updated April 2019

This website is owned and operated by The Other Jewelry Company, LLC. We respect your privacy and understand that you have a right to know why we collect your personal information and what we do with it. This Privacy Policy applies to information we collect through our Sites (as defined below) as well as information we collect offline.

This Privacy Policy is divided into four main parts, which you can visit by clicking on the links below:

Part 1 is applicable to all visitors to our Sites.
Part 2 applies only to residents of the United States of America.
Part 3 applies only to residents of California, USA.
Part 4 applies only to residents of the European Union or the United Kingdom.

PART 1 – INFORMATION FOR ALL VISITORS TO OUR SITE

PURPOSE OF THIS PRIVACY NOTICE

This policy describes the type of information we may collect from you and/or that you may provide us when you visit and/or use this website and/or any of our mobile applications (individually or collectively, “Sites”). “You/your/user(s)” means you as a user of our Sites, including any information, tools and services available from the Sites, conditioned upon your acceptance of all the terms, conditions, policies and notices stated here, which you accept by continuing to utilize the Sites.

By accessing the Sites, you acknowledge this Privacy Policy and agree to be bound by the terms hereof, the Terms of Service, and any other terms or policies set forth on the Sites. If there is anything you do not understand please email any inquiry to info@ninarunsdorf.com. If at any time you do not agree to this Privacy Policy, please do not use the Sites or provide us with any personal information.

Changes to this Privacy Policy. We reserve the right to change or update this Privacy Policy by posting such changes or updates to the Sites. Amendments to this Privacy Policy will be posted at this URL and will be effective when posted. It is your responsibility to review any such changes or updates and to check the Sites regularly to be sure you understand all terms and conditions, agreements and policies of the Sites and are in compliance with them. You can tell if this Privacy Policy has changed by checking the last modified date that appears at the top of this Privacy Policy. Your continued use of the Sites following the posting of any amendment, modification or change shall constitute your acceptance thereof.

IMPORTANT INFORMATION ABOUT US

The Other Jewelry Company LLC is the data controller, which means we determine the purpose and means of collecting and using your personal information. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below:

Full name of legal entity: The Other Jewelry Company LLC

Email address: info@ninarunsdorf.com

Postal address: 20 East 69th Street, Suite 3A, New York, NY 10021

YOUR SECURITY

We strive to keep your Personal Information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access. All payment transactions will be handled through our third party payment processor, and we will not have access to your credit card number or other such financial data.

Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Sites, any transmission of Personal Information is at your own risk. We cannot guarantee that such information will not be intercepted by third parties and we will not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third-party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for circumvention of any privacy settings or security measures contained on the Sites.

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with jewelry or other products). In this case, we may have to cancel the order you have with us, but we will notify you if this is the case at the time.

INFORMATION WE COLLECT

Personal Information

We collect various information that identifies you as a person (“Personal Information”) when you provide the information to us, such as:

Contact Information: contact details including name, email, telephone number and shipping, billing address
Account Information: login and account information, including unique user ID and password
Identity Information: personal details including gender, date of birth and purchase history
Payment Information: payment or credit card information
Marketing Preferences: personal preferences including your wish list as well as marketing preferences
Recruitment Information: employment and education history and other information that you provide to us if you apply for employment with us through our Site

If you are interested in how we use the various types of Personal Information, please see How We Use The Information We Collect.

Automated Information

We collect information through automated means when you visit our Sites (“Automated Information”) such as:

the IP address of the device you use to connect to the internet (which may include information about your geographic location)
the unique identifiers of your device
your browser characteristics
your device characteristics
your operating system
your language preferences
the URLs through which you were referred to our Site
information on actions taken by you on our site
dates and times of your visits to our Site
the pages you accessed on our Site

HOW WE COLLECT PERSONAL INFORMATION

We collect Personal Information directly from you when you provide it to us. This typically occurs when you:

Sign up for our email list
Place an order with us online
Buy a product at any of our retail locations
Send us an email or other communication
Join any of our social networking sites
Register for an account with us
Participate in our promotions, surveys, and/or contests

HOW WE COLLECT AUTOMATED INFORMATION AND USE OF COOKIES

We collect Automated Information automatically as you navigate through our Site as explained further below.

We may collect information, which may include certain Personal Information data such as your IP address, from your browser when you use our Sites. We use a variety of methods, such as cookies and pixel tags to collect this information, which may include your (i) IP-address; (ii) unique cookie identifier, cookie information and information on whether your device has software to access certain features; (iii) unique device identifier and device type; (iv) domain, browser type and language, (v) operating system and system settings; (vi) country and time zone; (vii) previously visited websites; (viii) information about your interaction with our Sites such as click behavior, purchases and indicated preferences; and (ix) access times and referring URLs.

Most web browsers automatically accept cookies. If you do not wish to have cookies on your system, you can set your browser to refuse them. Please review the specific instructions from your browser in order to do this. However, please note that not accepting cookies may make certain features of our Sites unavailable or difficult to view or use.

In some of our email messages we may use a “click-through URL” linked to content on our Sites. When you click one of these URLs, you will pass through our web server before arriving at the destination web page. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our Sites. If you prefer not to be tracked through our emails, simply avoid clicking text or graphic links in the email.

Third parties may also collect information via our Sites through cookies, third party plug-ins and widgets in order to deliver our targeted advertisements to you across the Internet.

Our web server may collect clickstream information such as the address (or URL) of the web site that you came from before visiting the Sites, which pages you visit on the Sites, which browser you used to view the Sites and any search terms you may have entered on our site, among other things. The Sites may also use other technologies to track which pages our visitors view. Only some payment processing information is collected by us. We may also use one or more third party payment processors. We do not want you to send us your credit card or bank account information by email or other means except where requested as part of the checkout process. Please review the terms of use and privacy policies of the third party payment processor prior to providing Personal Information to them.

HOW WE USE THE INFORMATION WE COLLECT

Whenever we use your Personal Information, we will always rely on a lawful basis (reason) for doing so. In particular, we will rely on one of the reasons listed below. Most commonly we will use your Personal Information in the following circumstances:

Where you have asked us to do so, or consented to us doing so;
Where we need to do so in order to perform a contract we have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation.

Here are some examples about how we may use the information we collect about you and the lawful basis upon which we rely on to do so:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To manage your registration to our Sites and/or our services, including: ● Registering you as a new customer ● Authenticating users ● Updating and maintaining the accuracy of information about our customers ● Provide the materials, goods and/or services we offer and/or you request	Name, email, phone (optional), shipping address and billing address	Performance of a contract with you
To deliver our Sites, including: ● Presenting our Site to you ● Notifying you of any changes to our Site or our business	Registration information, technical information, usage information and marketing and communications information.	Necessary for our legitimate interests (to deliver the Site)
To process and deliver your order including: ● Completing your purchase transactions, fulfill your orders, keep you informed about the status of our goods and services and your orders ● Collecting and recovering money owed to us	Registration information, financial and billing information	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: ● Asking you to leave a review or take a survey ● Enabling you to participate in features such as seminars, sending and receiving invitations, surveys, reviews, blogs or forums, or to participate in special initiatives and to communicate with you about them ● Sending you notices of a transactional, administrative or relationship nature or as required by law ● Alerting you to any issues with products or product recalls	Registration information.	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Registration information and technical information.	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	Registration information, technical information, usage information and marketing and communications information.	Necessary for our legitimate interests (to grow our business and to inform our marketing strategy)
To further our marketing and communications strategy, which will include: ● Identifying your product and service preferences, so we can notify you of new or additional products, services, and promotions that might be of interest to you ● Communicating with you by email, text message, app notifications, or other means about our company, our products, or other information that we believe may be of interest to you ● Conducting market research and to customize offers ● Sending you our electronic communications, including our newsletters and our company announcements, alerts, notices and updates ● Communicating with you about our products, our company, and other information that we believe may be of interest to you	Registration information, technical information, usage information and marketing and communications information.	Necessary for our legitimate interests (to develop our products/services and grow our business)
To use data analytics, to: ● improve our website, products/services, merchandise selections, marketing, customer relationships and experiences ● analyze the use of our products and services and information about visitors to the Sites to enhance our marketing efforts	Technical information and usage information.	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Provide others with your Personal Information for the limited purposes described in this Privacy Policy	Registration information, usage information and marketing and communications information.	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation

SHARING PERSONAL INFORMATION WITH THIRD PARTIES

We are committed to maintaining your trust and we want you to understand when and with whom we may share Personal Information and information collected about you. We do not sell your Personal Information to any third parties, and we do not share your Personal Information with any third parties except as set forth herein.

Sharing Personal Information with our business partners. We may disclose your Personal Information to outside individuals and/or companies that help us bring you the products and services we offer and to create, operate, and maintain our Sites. For example, we may work with third parties to: (a) manage a database of customer information; (b) assist us in distributing e-mails; (c) assist us with direct marketing and data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service; and (g) provide other services designed to assist us in developing and running our Sites and maximizing our business potential. We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us.

Sharing Personal Information with corporate entities in our group, or if we sell our business. If we seek investors or go through a business transition, including but not limited to, a merger, acquisition by another company, or a sale of all or a portion of our assets, your Personal Information may be shared as part of the negotiation of the transaction and will likely be among the assets transferred in the event of a sale or partial sale of our assets.

Sharing Personal Information with law enforcement, the court, or regulators. We may disclose your Personal Information when legally required to do so, to cooperate with law enforcement investigations or other legal proceedings, to protect against misuse or unauthorized use of the Website, to limit our legal liability and protect our rights or to protect the rights, property or safety of Users of this Website or the public.

TARGETED ADVERTISING AND REMARKETING

You may see advertisements for our products on other websites and mobile applications because we work with third party advertisers to engage in remarketing and retargeting activities. Through our relationships with these advertisers, we can target messaging to our users by interest-based, demographic, contextual, and other means. These third party advertisers track your online activities over time and across websites and mobile applications by collecting information through automated means, including through the use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites and mobile applications that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites or apps. This data collection takes place both on our Sites and on third-party websites and mobile applications that participate in the advertising networks. This process also helps us track the effectiveness of our marketing efforts. Some third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offer a single location to opt out of ad targeting from member companies (www.networkadvertising.org). If you are a California resident, you may ask us to refrain from sharing your information with certain of our affiliates and other third parties for their marketing purposes. See the “Notice for California Residents” section below for additional information.

LINKS TO AND FROM OTHER WEBSITES

Our Sites may contain links to websites operated by third parties, or you may have come to our Sites using a link found in another website. This does not mean that we endorse these websites or the goods or services they provide. We do not make any representations or warranties about any website that may be linked to the Site. Such other websites are independent from us, and we have no control over, or responsibility for, their information, products or activities. Our privacy practices may differ from those of these other websites. If you provide Personal Information at one of these third party websites, you are subject to the privacy policy of the operator of that website, not our Privacy Policy. Please make sure you understand the other website's privacy policy before providing such website with any Personal Information.

YOUR CHOICES ABOUT HOW WE USE YOUR INFORMATION AND OPTING

We have mechanisms by which you can control your information:

Tracking: You can set your browser to refuse some or all cookies or to alert you when cookies are being sent. Please visit your specific browser’s instructions for doing this.
Promotional Offers: If you do not wish to receive our promotional offers, you may opt-out by checking the relevant box when we collect your information, logging into your account to update your preferences, clicking on the “unsubscribe” link found in emails we send to you, or sending us an email request to info@ninarunsdorf.com. Please note that you may NOT opt out from receiving emails from us directly related to a product purchase.

You may opt out of: (a) receiving email communications such as email newsletters and promotional emails by following the instructions provided at the bottom of each email, clicking the “unsubscribe” button at the bottom of emails we sent you; and/or (b) receiving promotional email communications and newsletters by emailing us at info@ninarunsdorf.com and including the word “UNSUBSCRIBE” in the subject text. Please allow up to ten (10) business days for changes to your email preferences to take effect. During that time, you may continue to receive email communications from us that were already in process. Opting out of receiving our communications will not affect your receipt of service-related communications, such as payment confirmations and delivery status updates, as we must be able to communicate with you regarding your purchases.

Opting out of online and mobile website advertising. You can opt out of Internet-based and mobile advertising on your mobile device by visiting TRUSTe’s Ad Preference Manager, currently available here.

Our products and services may use Google Analytics Advertising Features and its associated tracking technologies to help display our ads you see on other sites, and to help us manage and optimize our online advertising efforts. To opt out of Google Analytics Advertising Features, visit Google’s Ad Settings page, currently located here. Website users can also access the Google Analytics Opt Out Browser Add-on, currently located here. We may also work with Facebook and Apple to provide analytics in connection with our Sites, including our mobile applications. For more information about Facebook’s privacy practices, click here, and for Apple’s privacy policy, click here.

You may opt out of receiving online behavioral or internet based advertising by using the tools located at the Digital Advertising Alliance’s consumer choice page, currently available here or the Network Advertising Initiative (NAI) opt out tool currently available here.

When using the ad industry opt out tools described above, note that: (a) if you opt-out we may still collect some data about your online activity for operational purposes (such as fraud prevention), but it will not be used by us for the purpose of targeting ads to you; (b) if you use multiple browsers or devices you may need to execute this opt out on each browser or device; and (c) other ad companies’ opt-outs may function differently than our opt-out, and we have no control over the practices of any third-parties. We do not make any representations or warranties about such opt-out services. Such services are independent from us, and we have no control over, or responsibility for their performance.

You can opt out of accepting cookies or disable them from your browser. The “Help” function on most browsers contains information on how you can set your browser to notify you before accepting cookies, or can disable them entirely. If you opt out of cookies, you will not be able to take advantage of various features of the Sites that are available to other users. For example, we may use cookies to recognize you by name when you return to this site so you don’t have to login again and provide your password each time.

Registered users who have provided their cell phone number to us may remove it from within their personal profile settings. If you prefer not to receive text or wireless promotional communications on your mobile device, you can opt out by replying STOP to any text you receive from us.

You may ask us to delete your Personal Information from our system, however, because we archive and keep track of past transactions, you cannot delete information associated with past transactions or archived information on the Sites. Please also update your Personal Information if it changes.

Registered users may terminate their registration at any time, for any reason, by contacting us. You understand it may be impossible to delete Personal Information entirely because of backups and records of deletions. If you wish to cancel your account on the Sites or delete your Personal Information previously provided to us, you may do so in your account section of the Sites or send your request to us at info@ninarunsdorf.com and include the words “DELETE ME” in the subject line with your specific request in the body of your communication.

If you do not receive a response from us to any emails you send to us within ten (10) business days, please send us another email as your original email may not have been received.

DISCLOSURE FOR LEGAL PURPOSES

You hereby authorize us to disclose any of your Personal Information pursuant to judicial and administrative proceedings and to law enforcement or government agencies if we believe the disclosure is necessary or appropriate. You also authorize us to disclose Personal Information if we believe the disclosure is necessary or appropriate in the event of an investigation of improper or illegal conduct in connection with the Sites, such as fraud, misrepresentation, intellectual property infringement, or other activity that may put us at risk for liability.

CHILDREN

We do not permit persons under 16 years of age to use the Sites, and we do not knowingly collect, use or disclose Personal Information from anyone under 16 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian's consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 16, we will make reasonable efforts to delete such information from our records.

CONFIDENTIAL INFORMATION

We do not want you to send to us any confidential or proprietary information through email or otherwise. Any information, materials, suggestions, ideas or comments sent to us will be considered non-confidential, and by submitting the same to us, you are giving us the absolute right to use, modify, reproduce, transmit, display and distribute the information for any purpose whatsoever, with no payment or other compensation to you. However, we will not use your name unless we are required by law to identify the source of the materials, information, suggestions, ideas or comments, or unless we first obtain your permission.

PART 2 – INFORMATION APPLICABLE TO US RESIDENTS ONLY

Disputes

This Privacy Policy will be interpreted in accordance with the laws of the State of New York and the United States of America, without regard to its conflict-of-law provisions. By visiting the Sites, you agree that, except as otherwise specified herein, the laws of the State of New York without regard to principles of conflict of laws, will govern any dispute of any sort that might arise between us or any of our affiliates regarding your visit and use of the Sites.

We and you agree that in the event of any dispute, the party wishing to address the dispute must contact the other party in writing, including by e-mail, and advise the other party of the dispute in reasonable detail as well as informing the other party of the remedy being sought. We may send you notices via the email address or physical address you provide to us, and all notices to us shall be sent to the email address info@ninarunsdorf.com and include the words “DISPUTE NOTICE” in the subject. The parties shall then make a good faith effort to resolve the dispute before resorting to more formal means of resolution. In the event that the dispute is not resolved through this procedure, the party raising the dispute may proceed to mandatory arbitration as set forth below.

Arbitration

ANY AND ALL DISPUTES BETWEEN YOU AND US WILL BE RESOLVED BY BINDING ARBITRATION. YOU HEREBY AGREE TO GIVE UP YOUR RIGHT TO GO TO COURT to assert or defend your rights under this Privacy Policy, except for matters that may be taken to small claims court. Your rights will be determined by a neutral arbitrator, NOT a judge or jury. You agree that any dispute arising out of or relating to this Privacy Policy, including with respect to the interpretation of any provision of this Privacy Policy or other agreements between you and us, or concerning the performance or obligations of you and us, shall be resolved by mandatory and binding arbitration submitted to JAMS in accordance with its Commercial Arbitration Rules at the request of either us or you pursuant to the following conditions:

Place of Arbitration Hearings. Unless you elect to conduct the arbitration by telephone or written submission, an in-person arbitration hearing will conducted at a JAMS facility in your area or at a JAMS facility in New York, New York.
Selection of Arbitrator shall be made pursuant to JAMS’ Streamlined Arbitration Rules & Procedures or JAMS’ Comprehensive Arbitration Rules & Procedures, depending on the amount of the claim as specified herein.
Conduct of Arbitration. The arbitration shall be conducted by a single neutral arbitrator under JAMS’ Streamlined Arbitration Rules & Procedures. For claims exceeding $5,000.00, the arbitration shall be conducted under JAMS’ Comprehensive Arbitration Rules & Procedures Subject to the applicable JAMS procedure, the arbitrator shall allow reasonable discovery in the forms permitted by the Federal Rules of Civil Procedure, to the extent consistent with the purpose of the arbitration. The arbitrator(s) shall have no power or authority to amend or disregard any provision of this section or any other provision of these Terms of Service, except as necessary to comply with JAMS’ Policy on Consumer Arbitrations Pursuant to Pre-Dispute Clauses Minimum Standards of Procedural Fairness. The arbitration hearing shall be commenced promptly and conducted expeditiously. If more than one day is necessary, the arbitration hearing shall be conducted on consecutive days unless otherwise agreed in writing by the parties.
Findings and Conclusions. The arbitrator(s) shall, after reaching judgment and award, prepare and distribute to the parties written findings of fact and conclusions of law relevant to such judgment and award and containing an opinion setting forth the reasons for the giving or denial of any award. The award of the arbitrator(s) shall be final and binding on the parties, and judgment thereon may be entered in a court of competent jurisdiction.
Costs and Fees. You will be subject to a filing fee, set by JAMS, to initiate the arbitration. To the extent permitted by JAMS procedures, each party shall bear its own costs and expenses and an equal share of the arbitrators’ and administrative fees of arbitration, and we will remain responsible for its share of costs, expenses and fees plus any costs, expenses and fees required under JAMS procedures.
Litigation. The Federal Arbitration Act and federal arbitration law apply to these Terms. Either party also may, without waiving any remedy under these Terms, seek from any court having jurisdiction any interim or provisional relief that is necessary to protect the rights or property of that party, pending the establishment of the arbitral tribunal (or pending the arbitral tribunal’s determination of the merits of the controversy).

Class-Action Waiver

Any arbitration, claim or other proceedings by or between you and us shall be conducted on an individual basis and not in any class action, mass action, or on a consolidated or representative basis. You further agree that the arbitrator shall have no authority to award class-wide relief or to combine or aggregate similar claims or unrelated transactions. You acknowledge and agree that this agreement specifically prohibits you from commencing arbitration proceedings as a representative of others. If for any reason a claim proceeds in court rather than in arbitration, each party waives any right to a jury trial. Any claim that all or part of this Class Action Waiver is unenforceable, unconscionable, void, or voidable may be determined only by a court of competent jurisdiction and not by an arbitrator.

PART 3 – INFORMATION APPLICABLE TO CALIFORNIA RESIDENTS ONLY

NOTICE TO CALIFORNIA RESIDENTS

This section is only applicable to you if you are a resident of California.

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit an email request to the email address info@ninarunsdorf.com and include the words “CALIFORNIA PRIVACY” in the subject line, and you must put the statement “Your California Privacy Rights” in the body of the request and state the name of our specific website with respect to which you are requesting the information as well as your name, street address, city, state, and zip code.

In addition, please note the following:

Users can visit the Sites anonymously;
We will add a link to this Privacy Policy on our home page, or at a minimum, on the first significant page after entering the Sites;
Our Privacy Policy link includes the word “Privacy” and can be easily be found on the page specified above;
Users will be notified of any privacy policy changes on our Privacy Policy page;
Users can change their Personal Information by emailing us or by calling us;
Some Internet browsers include the ability to transmit “Do Not Track” signals that give you control over the collection and use of web browsing information. Because uniform standards for “Do Not Track” signals have not yet been adopted, we do not process or respond to such signals in users’ web browsers at this time; and
We allow the collection of users’ behavioral tracking by third parties. We do not authorize the collection of Personal Information on the Sites by third parties.

PART 4 – INFORMATION APPLICABLE TO EUROPEAN UNION & UNITED KINGDOM RESIDENTS ONLY

This section is only applicable to you if you are a resident of the European Union or the United Kingdom

If you are located in the European Union, our processing of your Personal Information (also known as “Personal Data” under European law) is governed by the General Data Protection Regulation (EU) 2016/679 (the “GDPR”). If you are located in the United Kingdom, our processing is governed by the GDPR and the Data Protection Act 2018 (the “DPA”).

As part of our obligations under GDPR and the DPA, we are required to inform you about our use of your Personal Information. Much of the information we are required to provide is covered elsewhere in this Privacy Policy. However, there are some important aspects which differ, depending on the data protection laws that apply where you live. If the information in another part of this Privacy Policy contradicts the information in this EU section, please note that this EU section will apply if you are an EU resident. The EU section will cover the following points:

Marketing and sharing your Personal Information;
International transfers;
How long we keep your Personal Information; and
Your rights as a data subject.
What to do if you wish to make a complaint

Marketing. We may use your Personal Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased good or services from us and you have opted out of receiving that marketing. We will get your express opt-in consent before we share your Personal Information with any third party for marketing purposes.

International Transfers. We are a US company, and therefore our service and most of our service providers may be based outside of the European Economic Area (the “EEA”). Your Personal Information will likely be transferred outside of the EEA. We make this transfer: to perform our contract with you, deliver our Site to you or provide you with any services thereunder; or where you have explicitly consented to the proposed transfer.

By submitting your Personal Information, you agree to this transfer, storing or processing. If you would like more information about how the mechanism via which your Personal Information is transferred, please contact info@ninarunsdorf.com.

Data Retention. We will hold your Personal Information on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances, you can ask us to delete your Personal Information: see below for more information.

YOUR RIGHTS

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Your Right of Access: You may, at any time, request access your Personal Information that we hold (you may have heard of this right being described as a "subject access request"). Please note that this right entitles you to receive a copy of the Personal Information that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that Personal Information lawfully. It is not a right that allows you to request Personal Information about other people, or a right to request specific documents from us that do not relate to your Personal Information. You can exercise this right at any time by writing to us by contacting us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure: You may, at any time, request that we correct Personal Information that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase Personal Information if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”). Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase Personal Information when asked to do so; if for any reason we believe that we have a good legal reason to continue processing Personal Information that you ask us to erase we will tell you what that reason is at the time we respond to your request. You can exercise this right at any time by contacting us and telling us that you are making a request to have your Personal Information rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing: Where we process your Personal Information on the basis of a legitimate interest (see the table above which explains how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid. You may also ask us to stop processing your Personal Information (a) if you dispute the accuracy of that Personal Information and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your Personal Information (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims. Please note that if for any reason we believe that we have a good legal reason to continue processing Personal Information that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it. You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability: Where you wish to transfer certain Personal Information that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format. If you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to object to processing: You may object to processing of your Personal Information where we rely on legitimate interest for processing that Personal Information. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

Your Right to stop receiving communications: Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications). Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by contacting us and telling us which communications you would like us to stop sending you.

Your Right to object to automated decision making and profiling: You have the right to be informed about the existence of any automated decision making and profiling of your Personal Information, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Your right to lodge a complaint with your supervisory authority: You may also lodge a complaint to the supervisory authority about the way we process your Personal Information. In the United Kingdom, the relevant regulatory authority is the Information Commissioner’s Office of the United Kingdom (https://ico.org.uk/). We would however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us in the first instance.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We will notify you if this is the case.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. It might take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.