UmaUmi respects, and is committed to protecting, the privacy of our online visitors, and users of our mobile applications, and recognises the importance of protecting the information collected about them. To this end, we have established procedures that ensure your personal data is processed in a responsible manner.

This Privacy Policy informs you about the kind of data we collect and how; the purposes for which we collect and use it; your rights about and options concerning our use of your data; how your data is processed and with whom it may be shared; and for how long we store your information etc. Please read it carefully.

When we refer to ‘personal data’, 'data subject' or ‘processing’, we use the meaning of those terms as set out in the General Data Protection Regulation (EU) 2-16/679 or Data Protection Act 2018 (UK) (as applicable).

2. Who controls the data?

UMA and UMI Group LLC (EDRPOU code 38735011) and FOP Dorofeeva Yana (“UmaUmi”, “Company”, “us”, “our”, “we”), determine the purposes and means of the processing of your personal data. Carrying with its legal responsibilities, a data controller is legally responsible for the storing and use of personal information on computer or in manual files. UmaUmi does not employ a Data Protection Officer. Please refer to UmaUmi’s contact information below.

Our websites may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies for which we do not accept any liability. Please check these policies before you submit any personal data to their websites. 

3. What personal data is collected?

The way in which we collect and store information, including personal data, is dependent on how our website and related services are used. We do not collect any sensitive data about you.

3.1. Data we collect through your interaction with us

Various technologies may be used on our websites and our (mobile) applications in order to improve them, make them more user-friendly, efficient and secure. Such technologies may lead to personal data being collected automatically by us or by third parties on our behalf. Examples of such technologies include cookies, flash cookies and web analytics.

3.1.1. Click-stream data

When you visit our website, data is sent from your browser to our server. This data makes it possible for us to optimise our services and improve your experience on our websites and applications. The data is automatically collected and stored by us or by third parties on our behalf.

We may collect information about your computer for system administration purposes as well as to report aggregate information for internal marketing analysis reasons. This is data about our users' browsing actions and patterns and may include the following:

• Visitor’s IP address;
• Date and time of the visit;
• Referral URL (the site from which the visitor has been referred);
• Pages visited and user journey on our website;
• Information about the browser used (type, version, operating system, etc.).

3.1.2. Cookies

We use cookies on our website. Please read our Cookie Policy to find out more about our use of cookies and the privacy policies of the parties from which we use web analysis tools or of which we have integrated plug-ins on our websites.

3.1.3. Re-targeting Technologies

Our website and (mobile) applications use re-targeting technologies. Re-targeting technologies analyse your cookies and display advertisements based on your past websites behaviour. This enables us to advertise directly and personally to visitors who have already showed an interest in our products and/or shop via our partner websites.

We also work with companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect information about your visits to our websites or (mobile) applications, as well as your interaction(s) with our communications, including advertising.

3.2. Data you provide to us:

We process data about you which you have provided to us directly (for example, when you hold an UmaUmi account) or which we have been provided with from someone using our services (for example, by someone sending you a gift through the "send as a gift" service). This includes but is not limited to: 

• Personal data that identifies you as an individual – namely, your contact information, title, first and last name(s), wedding date, photographic image, billing address(es), postcode, date of birth, gender, telephone number, email address, credit and debit card information.
• Information provided by you at the time of registration for a UmaUmi Club account.
• Information provided when you create a Wish List, save your sizes, save designs, save your favourite stores, save your jewellery list.
• Information you provide when you enter a prize draw or similar activity.
• Information you provide to us via third parties such as Facebook and WeChat.
• Information that you upload to or share through our site by using our services.
• If you have created an online account with us: the preferences and interests stored in this profile (please see below for further information regarding these profiles).
• If you contact us, we may keep a record of your correspondence.
• If you contact us to report a problem with our site or for technical and/or customer support, we may keep a record of your correspondence or conversation.
• If you choose to respond to our surveys.

If you provide us with the personal data of another person, please make sure that you have the right to share this information with us before you do so.

4. How is the collected data processed and what for purposes?

Depending on your interactions with us, we may process your personal data in the following ways and for the following purposes: 

• Ensure that content from our site is presented on your computer in the most efficient manner.
• For purposes relating to your order; e.g. to notify you on the status of your order or delivery; to fulfil your requests, such as responding to a question regarding our products; to help you locate a store near you; to fulfil your order; to process your payment card and/or to provide you with customer service. We may use your data to assess your creditworthiness, for which we may use third parties.
• Verify your identity and to respond to any query you may raise with us; to process your request and provide you with the best service possible.
• Carry out our obligations arising from any contracts entered into between you and us.
• Allow you to participate in the interactive features of our service(s) when you choose to do so.
• Notify you about changes to our services, terms, conditions and policies, and/or other administrative information.
• Administer and maintain our records.
• Store any Wish List you may create and to allow you to share your Wish List with others.
• Allow you to participate in prize draws and similar promotions and administer such activities. Some of these activities have additional rules which could contain additional information about how we use and disclose your personal information.
• Customise content on our websites to provide you with personalised offers.
• Prevent and/or detect any misuse or fraud.
• With your permission, we may contact you directly through the details provided by you (e.g. postal services, email, text message, telephone or any other electronic means) for marketing, advertising and market research purposes. For example, this includes information related to UmaUmi products, e-commerce activities, special offers and promotions, as well as information on local store openings and activities. In order to be able to contact you with information that is of special interest to you, we may analyse and use information about your overall interaction with UmaUmi such as your shopping behaviour on our online store and in physical UmaUmi stores; your use of loyalty programmes; your ratings and reviews of products; your contact history with our customer service; your newsletter clicks/opening results; your website behaviour (web tracking); the types of newsletter you are subscribed to; your participation in promotions or events; and your interactions with and use of mobile applications. We may use your personal data for marketing, advertising and market research purposes. You can withdraw this consent at any time and exercise rights over your personal data, which are outlined in more detail in paragraph 7 below.

Even if you do not have an UmaUmi account, we may process your personal data to provide the "send as a gift" service if you choose to send an UmaUmi gift or if you are chosen by someone to be the recipient of an UmaUmi gift.

When you visit UmaUmi website, your personal data may also be processed in the following ways:

• Content, A/B testing and product browsing analytics;
• Traffic source analytics;
• Internal search analytics;
• Purchase analytics;
• Device analytics;
• Marketing re-targeting.

5. Legal basis and related purposes for processing

When you purchase an item in our online store, create an account with us, or enter into any other form of agreement with us, we will process your personal data necessary to enable us to fulfil that agreement. We may also process your personal data if you have a query or similar that precedes your decision to enter into an agreement with us and concluding that agreement. This legal basis is stated in Article 6(h 1)(, b) of the EU Personal Data Regulation (EU) 2016/679 (GDPR).

We may also process your personal data on the basis of GDPR Article 6( 1)(, f) unless our interests are outweighed by your privacy rights and statutory freedom. We have a legitimate interest in processing your personal data for marketing based on your preferences so that we can better customise our offerings to you—and ultimately offer products and services that better meet your needs and wishes. Additionally, we have a legitimate interest in processing your personal data for analytical purposes. Another legal basis on which we may process your personal data is consistent with your consent as permitted by GDPR Article 6(1)(a), for example, where you have given consent to receive our marketing newsletters by email. If we are required to by law, we will process your personal data to comply with that law in accordance with GDPR Article 6(1)(c). 

6. Disclosure of personal data

Treating your data with the utmost care and confidentiality is one of our core values. If required by law, your data may be disclosed to third parties. For example, we may disclose your information to the extent that we are duty-bound to disclose or share your personal data in order to comply with any legal obligation or the directions of the Court or any other body of competent jurisdiction, or in order to enforce or apply our privacy policy and other agreements; or to protect the rights, property or safety of UmaUmi, our employees, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

In addition, we employ service providers and data processors to process data on our behalf. These services include authentication, hosting and maintenance services, analysis services, e-mail messaging services, gift services, delivery services, handling of payment transactions, solvency, address and e-mail checks. These third parties are our data processors and may only process personal data to the extent necessary in order to deliver their services. Our data processors are contractually obliged to treat such information in the strictest confidence. They are prohibited from using the data in any other way than required. Necessary steps are taken to ensure that our data processors, including service providers and other processors working on behalf of UmaUmi, uphold and protect the confidentiality of your data.

Some of our data processors are situated outside the EU/EAA. Consequently, we will share your personal data with countries outside the EU/EEA. However, we will only provide this information on the basis of the recipient fulfilling the applicable legal requirements for such transfers.

Please note that any information you post or disclose through your interaction with UmaUmi (e.g. personal data in photos, stories, comments and videos that you post on our website, our pages on online or App platforms, or tag us in) will become public information and may be available to visitors to those platforms as well as to the general public.

7. Your rights

We provide numerous options, depending on the circumstances, in order to help you retain control over your data. These options may include displaying and editing your data online. It may also be possible to unsubscribe from services or delete user accounts or to receive information about the data held. In general, you have the rights listed in the following sub-headings. For more information about your rights over your data under data protection laws, please refer to guidance from the Information Commissioner’s Office.

7.1. The right to request access to your personal data

You are entitled to gain access to some of the personal data you provide to UmaUmi, and details of the information about you that we hold and process, including the purposes for which it is used. You can access your personal details by contacting us or logging on to your UmaUmi account on our website(s) and Clicking on “My Profile” or ”My Account”.

7.2. The right to amend and/or delete your personal data

You have the right to request correction, appendage, deletion or blockage of your stored personal data. If any of the information that you have provided us with has changed (e.g. if you change your contact details, or if you wish to cancel your UmaUmi account), you can easily edit your details on the "My Profile" or ”My Account” pages or contact us to amend and/or delete your personal data using any of the methods below. 

7.3. The right to restrict the processing of your personal data

In special circumstances, you have the right to restrict the processing of your personal data. 

7.4. The right to data portability

You have the right to receive your personal data (concerning you only) in a structured, commonly used and machine-readable format (“data portability”), and have the right to transit this data to another data controller.We are unable to guarantee your right to data portability, as it is dependent on the specific circumstances of the processing activity. 

7.5. The right to object to the processing of your personal data and to unsubscribe

You have the right to ask us not to process your personal data when processing is based on a legitimate interest pursued by UmaUmi, e.g. for marketing purposes. We will inform you in this privacy policy if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

Emails sent to you by UmaUmi containing newsletter or marketing content include the option to unsubscribe by following the instructions set out in the email. If you do not wish to receive emails from us, you can simply click on the unsubscribe hyperlink and we will stop sending you emails.

For all other types of messages you may receive from us, such as maintenance announcements or administrational notifications, the receipt of such can only be terminated by deleting your account. These messages are a mandatory part of user accounts and the related use of our websites and (mobile) applications. 

7.6. The right to withdraw your consent at any time

You are at any time entitled to withdraw your consent to our processing of your personal data. The withdrawal of consent shall, however, not affect the lawfulness of processing based on consent before its withdrawal.

If you wish to withdraw your consent to receiving promotional information and offers in general, including by post email, text message, telephone or any other electronic means, you may do so at any time contacting us. 

8. Retention of your personal data

UmaUmi will only retain your personal data for as long as is necessary for the purposes for which it is processed unless otherwise required by law, or required for the establishment, exercise or defence of legal claims. In addition, UmaUmi adopts the following retention and erasure policies applicable to the following processing activities:

9. The security of information and data integrity

We take appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised use, disclosure or access, in particular where processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse.

Where we have provided you with, or where you have chosen, a password that enables you to access certain parts of our site, you are responsible for ensuring this password remains confidential. We ask you not to share your password with anyone.

Unfortunately, transmission of information via the Internet is not wholly secure. Although we do our utmost to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is done so at your own risk. Once we have received your information, we employ strict procedures and rigid security measures to try to prevent unauthorised access. 

9.1. Third Parties

UmaUmi uses third party data processors to collect and process your personal data. Any data processors commissioned by UmaUmi will only process your personal data in accordance with UmaUmi’s instructions, will be bound by confidentiality obligations, data processing agreements and UmaUmi’s Privacy Policy, and are legally obliged to adhere to strict security procedures when handling personal data. 

9.2. Social Networks

Our website and mobile applications provide you with social plug-ins from various social networks. If you choose to interact with a social network, your activity on our website or mobile applications will also be made available to social media networks and related third parties.

If you have logged in to one of these social network sites during your visit to one of our websites or (mobile) applications, the social network site may add this information to your profile. If you interact with one of the social plug-ins, this information will be transferred to the social network site. If you do not want this data transfer, please log out of your social network site before using our website(s) or (mobile) applications. We cannot prevent this data collection and social plug-in information transfer. Please read carefully the privacy policies of your social networks for detailed information about their collection and transfer of personal data, your rights, and how you can achieve satisfactory privacy settings.

10. Consequences of non-disclosure of personal data

If you provide us with personal data on our websites or other channels, this is done on an entirely voluntary basis. If you choose not to provide the requested information, various customer benefits may not be available to you. In certain cases, only those who have submitted to us the required personal data are able to order products, use certain services and in other ways avail themselves of the activities and offers available on our website and mobile applications. It is not possible to provide some or all of the services of a UmaUmi Club membership for you to make a purchase on the UmaUmi website if you are unable to provide us with the required information. 

11. Contact Information

Should you have any questions or concerns about our privacy policy or the processing of your personal data, please feel free to contact us using our e-mail: sale@umaumi.com.

12. Complaints

Complaints should be submitted directly using our e-mail: sale@umaumi.com.

13. Changes to this policy

UmaUmi review this Privacy Policy in order to keep it up to date, to keep pace with new developments and opportunities relating to the Internet and to keep it compliant with privacy and data protection codes and legislation. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, may be notified to you by email.

Last updated: October 2022