Privacy Policy

Effective Date: August 27, 2025

jLjewelry (“Company”, “we”, “us”, “our”) operates the jLjewelry website and related online services (the “Service”). This Privacy Policy explains how we collect, use, disclose, and protect personal data when you visit our website, join a waitlist, contact us, or otherwise interact with our Service. More details about using the Service are available in our Terms of Use.

By using the Service, you acknowledge that you have read and understood this Privacy Policy.

Eligibility and Key Principles

Definitions

Scope

This Policy applies to:

• Visitors to our website and users of our Service;
• Individuals who contact us or submit forms (including waitlist, partnership inquiries, support requests);
• Individuals interacting with our marketing or commercial communications.

Personal Data We Collect

A. Information you provide

We may collect:

• Name
• Email address
• Phone number (if provided)
• Preferences for receiving marketing communications
• Information you submit through forms (e.g., messages, assets you want to borrow against, timeline)
• If applicable, your role/title and organization name (for partner inquiries)

B. KYC / verification data (where applicable)

If you choose to access services provided by licensed partners or participate in identity/asset verification flows, you may be asked to complete a verification process. This may include:

• Government-issued ID
• Proof of address
• Real-time facial scan / liveness check (if required by the verification vendor/partner flow)
• Other verification data specified on the relevant page or workflow

Note: Lending, where offered, is executed by licensed financial partners. jLjewelry provides infrastructure, workflows, and reporting.

C. Payments

If we offer paid products/services, payments may be processed by third-party payment providers. We do not store payment card details; payment processing is governed by the provider’s privacy policy.

Usage Data and Analytics

We may collect Usage Data such as:

• IP address
• Browser type and settings
• Internet service provider (ISP)
• Pages visited, exit pages, click interactions
• Date and time of visit
• Device and operating system information
• General location (e.g., country/region based on IP)

This data may be collected using tools like Google Analytics 4 (GA4), Microsoft Clarity, and similar analytics/session technologies.

Advertising & marketing cookies: We process marketing/advertising-related analytics only after you provide consent via the cookie banner (e.g., clicking “Accept Cookies”), where required by law.

How We Use Personal Data

We use personal data to:

• Operate, maintain, and secure the Service
• Respond to inquiries and provide customer support
• Improve site performance and user experience (analytics)
• Provide access to interactive features you choose to use
• Send updates, product news, and marketing communications (you can opt out at any time)
• Detect, prevent, and resolve technical or security issues
• Comply with legal obligations and enforce our rights

Legal Bases (GDPR / EEA)

If you are in the European Economic Area (EEA) or the UK/Switzerland, we process your data under one or more legal bases, including:

• Consent (e.g., marketing cookies, email updates where required)
• Contract / pre-contract steps (e.g., responding to a request, providing the Service)
• Legitimate interests (e.g., security, fraud prevention, service improvement), balanced against your rights
• Legal obligation (e.g., compliance, record-keeping)

If you have questions about the legal basis used for a specific processing activity, contact us (see “Contact”).

Disclosure of Personal Data

We may share personal data with:

• Service providers (hosting, analytics, CRM, security monitoring, form processing, support tools, marketing tools)
• Professional advisors (legal, accounting, audit) as needed
• Business partners and vendors that help facilitate Service-related workflows (e.g., verification, logistics, custody-related vendors), only as required and under appropriate safeguards

These parties may process data only under our instructions and for purposes described in this Policy.

A current list of key service providers may be provided upon request.

Legal and Regulatory Disclosures

We may disclose personal data to authorities or third parties if reasonably necessary to:

• Comply with applicable law or legal process
• Establish, exercise, or defend legal claims
• Investigate or prevent suspected fraud, security incidents, or violations
• Protect rights, property, or safety of users or others

We may also share data with your explicit consent.

Data Retention

We retain personal data only as long as necessary for:

• The purposes described in this Policy
• Legal, compliance, accounting, or reporting requirements
• Resolving disputes and enforcing agreements

Retention depends on the type of data, sensitivity, risk, and legal obligations. Technical/analytics data is typically retained for a limited period unless needed for security or legal reasons.

International Data Transfers

We may store or process data in countries other than where you live. When transferring personal data from the EEA to countries outside the EEA, we use appropriate safeguards such as:

• EU adequacy decisions (where applicable)
• Standard Contractual Clauses (SCCs)
• Other legally recognized transfer mechanisms

Data Security

We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or misuse. Access is limited to personnel and service providers who need it to perform their roles.

No internet transmission or storage system is 100% secure. If you believe your interaction with us is unsafe or suspect a breach, contact us promptly.

Marketing Communications

If you submit a form (e.g., waitlist or contact) you may receive communications about jLjewelry. You can opt out at any time by:

• Using the unsubscribe link in emails (when available), or
• Contacting us using the details below

We do not share your personal data with third parties for their own marketing purposes.

Your Rights (GDPR / EEA)

If you are in the EEA (and similarly in the UK/Switzerland), you may have the right to:

• Access your personal data
• Correct inaccurate data
• Delete your data (subject to exceptions)
• Restrict processing
• Object to processing
• Data portability
• Withdraw consent (where processing is based on consent)
• Lodge a complaint with a supervisory authority (e.g., ICO in the UK; FDPIC in Switzerland)

We may need to verify your identity before fulfilling requests. We typically respond within one month, unless the request is complex.

U.S. State Privacy Rights

If you are a U.S. resident, you may have rights under applicable state privacy laws, which can include:

• Access, correction, deletion
• Opt out of sale/sharing (we do not sell personal data)
• Opt out of targeted advertising (where applicable)
• Non-discrimination for exercising privacy rights

To exercise U.S. state rights, contact us at the email listed below. We may request information to verify your identity and authority (including for authorized agents).

Third-Party Links

Our website may link to third-party sites. We do not control and are not responsible for their privacy practices. Please review their policies before providing data.

Cookies

We and certain providers use cookies/pixels/tags to:

• Enable essential site functionality
• Analyze performance and usability
• Support optional features
• Measure marketing effectiveness (where permitted)

Types of cookies we may use:

• Strictly necessary cookies (required for core functionality)
• Performance cookies (analytics)
• Functionality cookies (preferences)
• Advertising cookies (remarketing/ads measurement, where enabled)

Cookie control: You can manage cookies via your browser settings. Disabling cookies may affect site functionality.

We may implement Google Consent Mode to respect your choices and, depending on consent status, collect data in aggregated/anonymized form for analytics continuity.

Do Not Track (DNT): We do not currently respond to DNT signals.

Changes to This Policy

We may update this Policy to reflect changes in law, business practices, or Service features. Updates will be posted here and may be communicated via a prominent notice where appropriate. Prior versions are available upon request.

Contact

To ask questions or exercise privacy rights, contact:

jLjewelry
Email: support@jljewelry.io