Gemfields appreciates that protection of your privacy is very important to you. This Privacy Notice sets out the data which Gemfields collects about you and how Gemfields uses your personal data. This Privacy Notice applies to our website at https://gemfields.com/ (the Website) and to any other dealings which we may have with you.

22 June 2018

Gemfields Limited (a UK registered company, with company number 05129023) of 1 Cathedral Piazza, London, SW1E 5BP (Gemfields, we or us) is the data controller in respect of your personal data.

We collect the following information from you:

Information you give us:

Information that you provide to us by filling in forms on the Website (such as the “Contact Us” page) or by dealing with us or our representatives by telephone, e-mail, in person or otherwise. This information will include:

• your name;
• your email address;
• your address;
• phone number;
• your company or organisation; and
• the subject and substance of any message or query you send to us.

It is important that any personal data we retain about you is accurate. Please keep us informed if your personal data changes at any point during your relationship with us by emailing us at info@gemfields.com.

Information we collect about you:

We and our service providers collect various pieces of technical information, each time you visit the Website. This information will include details on the Website traffic and other commercial information. We do not pass these statistics onto other parties.

We and our service providers collect your personal data for the following purposes:

In respect of your user experience:

• to review and improve your online experience with the Website;
• to respond to enquiries you place with us, either via the Website, telephone or via e-mail;
• to improve the Website to ensure that content is presented in the most effective manner for you and for your computer;
• to assist you with any future interactions with Gemfields;
• to let you know of any products, services and events which we feel may be of interest to you; and
• to allow you to participate in interactive features of our service.

In respect of technical and administrative matters:

• to notify you about changes to our business practices, services or to the Website;
• to administer the Website and for our internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to keep the Website safe and secure; and
• to measure or understand the effectiveness of advertising which we serve to you and others, and to deliver relevant advertising to you.

We rely on the following legal basis for processing your Personal Data:

It is necessary for the purposes of the legitimate interests pursued by us (for example, operating and making available the Website, and providing you with information about our operations and services, particularly in connection with responding to any enquiries and notifying you of any events which we feel may be of interest to you).

Gemfields will share your personal data with the following third party recipients or categories of recipients:

• other Gemfields staff in locations around the world;
• our third party suppliers who help us maintain the Website and support our business e.g. our hosting provider, Website developers, marketing agencies and our IT support team;
• law enforcement, regulatory bodies and fraud prevention agencies, to comply with our legal obligations or to help tackle fraud or investigate any breach of the Website terms and conditions or this Privacy Notice;
• other Gemfields group company members; and any prospective buyer of our business or assets.

Data transfers

If we intend to transfer your personal data outside of the European Economic Area, it is to Gemfields group companies and third party recipients.

Data retention and storage

We will keep your personal data for as long as we have a commercial relationship with you or to comply with our legal obligations and any contractual obligations we might be subject to. After this period, we will delete your personal data in a safe and secure manner. Your personal data is held within the UK, regardless of the location in which the data was collected.

Cookies

The Website uses cookies (a cookie is a piece of software that is stored on your computer or device by your web browser which allows the website to remember your preferences). Most browsers are automatically set to accept cookies but usually you can alter the settings of your browser to prevent automatic acceptance. If you chose not to accept cookies, you will still be able to use most of the features on our website. However, if you do experience any problems or have any questions then please contact us at info@gemfields.com.

We use cookies to, amongst other things, review how you use the Website and to see how you browse its pages. This information allows us to improve and maintain the Website and our service to you.

For detailed information on the cookies we use and the purposes for which we use them, please see our Cookies Policy.

Your rights

You have the general right to request from us:

• access to your personal data;
• rectification or erasure of your personal data;
• restriction of processing concerning you or to object to our processing of your personal data; or
• the right to data portability.

If you wish to stop receiving any emails from us, you may unsubscribe from these emails at any time by clicking on the “Unsubscribe” link in the emails or by emailing us at info@gemfields.com.

If you wish to exercise any of these rights, please contact us by emailing info@gemfields.com.

You also have the right to complain to the Information Commissioner’s Office about the manner in which we process your personal data.

Third Party links to the Website.

This Website may include third party links (for instance social media sites). Clicking on these links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party links and are not responsible for their privacy statements or for what happens to you after you leave this Website. When you leave this Website, we encourage you to read the privacy notice of every other website you visit.

Updates to this Privacy Notice

From time to time we may need to update this Privacy Notice to ensure that it remains up to date. If we make significant changes, we will make that clear on the Website or by some other means of contact such as email, so that you are able to review the changes before you continue to use the Website.

Please refer to the date at the top of the Privacy Notice to make sure that you are looking at the latest version.