Privacy Policy

(last updated 22 January 2022)

1. GENERAL

About us

Please read this Privacy Policy before using our website https://soajewelers.com (the “Service”) operated by State of Art Jewellery Designers LLC (“us”, “we”, or “our”). We are committed to providing you with the best service possible. Paramount to this is protecting and respecting your privacy and personal data which we are, and always will be, committed to doing.

The company is registered under Trade License CN-3820042 in the Emirate of Abu Dhabi, United Arab Emirates.

Why you should read this privacy policy

You should read this policy carefully because it sets out the basis on which any personal data we collect from you, or that you provide to us.

We encourage you to read the following information to fully understand our views and practices regarding your personal data and how we will treat it.

If you wish to contact us with any questions in relation to this policy or our privacy practices, you may contact us by emailing manager@soajewelers.com 

Updates

At all times, we keep our privacy practices and the terms of this policy under review to ensure your personal data is processed as securely as possible. This policy was last updated on the date given above.

2. INFORMATION WE MAY COLLECT FROM YOU

To provide you with the Services, we must collect, store, transfer, analyze and otherwise process certain of your personal data. This section of the policy explains what information we will collect about you and under what circumstances.

The personal data we process includes:

  • Personal data you may provide us if you create an Account

If you create an Account, you must provide your display name (username), email and/or mobile number. We will not be able to create your Account without this personal data. Please note that upon completion of this initial set-up, you will have access to your Account.

When preparing your Account, we may ask other information to build your profile, it will be used to create a more accurate picture of you as a customer of us and will enhance your user experience whilst operating the Services. Depending on the circumstances, we may be required to verify your identity.

  • Data related to your transactions

When you use our Services to make transactional purpose related to the Services, we collect information about the transaction, as well as other information associated with the transaction such as amount paid for products or services, merchant information.

Add value to, or remove money from, your Account: if you use our Services to add or remove value to or from your Account, we will collect personal data from you to facilitate the request. For example, if you use our Services to add value to your Account, we may collect personal data and other information including your Account ID and the amount added.
Send or receive gift cards: when you send or receive “gift cards” through the Services, we collect personal data such as your Account ID and the Account ID of the other Services user who is a party to the transaction.
Pay for items from our listed merchants: when you purchase items, such as a gift card, from one of our listed merchants, we will collect personal data about your transaction including your name and the merchant. The merchant may also provide us with certain other data related to the transaction.
Pay or request someone else to pay a bill: if you use our Services to pay a bill you are due to pay, or a bill for the benefit of someone else, or if you request another user pay a bill for you, we collect your Account number and certain personal data about the account holder to whom the bill is being paid to, such as name and account number.
Withdraw money: you can, depending on merchant capabilities, withdraw money from your Account at a merchant’s premises. If you choose to do this, we will collect personal data about your transaction including your name and the merchant. The merchant may also provide us with certain other data related to the transaction.

  • Marketing preferences

Based on your consent and marketing preferences, we may send you marketing communications such as emails. From this, we may collect further preferences from you based on how you interact and respond to our marketing communications. You have the right at any time to withdraw your consent by sending an UNSUBCRIBE notice to info@soajewelers.com at any time.

We use a booking form that requires your name and email to make an online appointment to visit us. We also use a pop-up form to request your name and email in case you would like us to get in touch with you.

We will never give or sell this information to any 3rd party as it only for us to communicate to you based on your booking or contact form submission.

  • Data from other users

We will collect your personal data, namely your email or mobile number and Account ID, when other users of the Services interact with you, for example when they send you a request for payment or when they add you to their payee list.

  • Query or complaint data

Should you wish to ask us a query, report an issue (for example with the website), or make a complaint about our Services, such personal data will also be added to your Account.

  • Data from service providers and automated decision making:

We use a third party to assist with verification checks. This site is protected by reCAPTCHA, to learn more visit Google’s Privacy Policy and Terms of Service.

  • Technical, usage and cookie data

We collect information about your use of the Services and/or Website, including how you use our Services and/or Website and how often you use our Services and/or Website. We do this to better understand how to provide the Services and our Website, what our users like about our Services and Website and what our users don’t like about the Services and Website. Such information may include, if applicable, your internet protocol (IP) address used to connect your device to the internet, your login information, browser plug-in types and versions, operating system and platform.

Our website utilizes Google Analytics to collect first-party cookies, data related to the device/browser, IP address and on-site/app activities to measure and report statistics about user interactions on the websites. Google uses Google Analytics data to provide the Google Analytics measurement service to us. Identifiers such as cookies and app instance IDs are used to measure user interactions with our site and/or apps, while IP addresses are used to provide and protect the security of the service, and to give us a sense of where in the world our site visitors come from. We may use the data collected by Google Analytics for site/app personalization or advertising purposes, including ads personalization. Google respects your privacy as found under Google Analytics Policy here www.google.com/analytics/policies and Google’s Privacy policy here https://www.google.com/policies/privacy

Our website utilizes the Conversion Tracking Pixel service of Facebook Inc. This tool allows us to follow the actions of users after they are redirected to our website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remain anonymous, thus we cannot see the personal data of any individual user. The collected data are saved and processed by Facebook. Conversion tracking allows Facebook and its partners to show you advertisements on and outside Facebook.

Custom Audience Pixel. A custom audience pixel provides a series of functions for transmitting application-specific events and user-defined data to Facebook. We use custom audience pixels to record information about the way visitors use our website. For this reason, each of our webpages contains a custom audience pixel. This pixel simply records information about your browsing session on our website, which it sends to Facebook along with a hashed version of the Facebook ID and the URL viewed. ‘Custom Audience from Your Website’ respects your privacy as found under Facebook’s Data Use Policy here https://www.facebook.com/policy.php

  • Device information

We may collect information about the device you use to access the Services and/or Website including the hardware model, the version you are using, the mobile network, and the time zone setting.

3. HOW WE USE YOUR PERSONAL DATA

In this section, we explain how we use your personal data and the reasons for such use, and we also explain the lawful grounds under certain data protection legislation that we rely on to do so. Please note we only ever process your personal data when it is lawful for us to do so.

We will not disclose, sell, share or in any way reveal your personally identifiable information to any other third party. All credit/debit cards detail and personally identifiable information will NOT be sold, shared, rented or leased to any third parties.

However, we may share information with governmental agencies or other companies assisting us in fraud prevention or investigation. We may do so when: (1) permitted or required by law; or, (2) trying to protect against or prevent actual or potential fraud or unauthorized transactions; or, (3) investigating fraud which has already taken place

3.1 To provide the Services and the Website

We process your personal data:

  • to verify your identity and create your Account;
  • to provide you with, and operate, the Services, including to initiate a payment, send or request gift cards, pay for an item, add value to an account, withdraw money from your account, or pay a bill;
  • to create an account connection between your Account and a separate third-party account or platform used to add value to your account;
  • to facilitate any exchange of messages between you and users using email and/or on social media messaging apps;
  • to perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes; and
  • to provide the Website.

We process your information for the purposes set out above on the following lawful grounds:

  • our legitimate interest in providing Services, operating and improving State of Art Jewellery Designers LLC, marketing our products and services to you and others and being as efficient as we can about complying with legal duties, obligations and regulations that apply to us and keeping our records up to date;
  • where it is necessary for the adequate performance of a Contract with you and to take steps requested by you prior to you entering into a Contract with us; and
  • compliance with legal obligations to which we are subject, for example in relation to carrying identity validation and other checks.

3.2 To perform obligations arising from the contract we have in place with you

We process your personal data:

  • to perform the purpose of the Terms of Use, namely to provide the Services to you.

We process your information for the purposes set out above on the following lawful ground:

  • where it is necessary for the adequate performance of a contract with you and to take steps requested by you prior to you entering into a contract with us.

3.3 To secure your Account and your money, and us and our Services

We process your personal data:

  • for anti-fraud and risk identification and management purposes. We use your personal data to comply with legal obligations relating to fraud and other financial crimes, and to ensure you, your personal data and your finances are protected; and
  • to verify activity, and to promote safety and security on and off our Services. Should we believe you have breached our Terms of Use, or are acting suspiciously, we may conduct an investigation to ensure you are not breaching the Terms of Use or breaking the law.

We process your information for the purposes set out above on the following lawful grounds:

  • given our legitimate interest in ensuring the safety and securing your Account, your money, our Services, us, our group companies, and any necessary third parties, and to secure us from harmful security related breaches;
  • where it is necessary for the adequate performance of a contract with you and to take steps requested by you prior to you entering into a contract with us;
  • compliance with legal obligations to which we are subject, for example in relation to money laundering; and
  • to protect yours or another individual’s vital interests, for example if we have to investigate harmful acts.

3.4 To communicate with you

We will process your personal data:

  • to communicate with you about your Account, including with respect to any potential fraudulent activity or any queries you have raised.

We process your information for the purposes set out above on the following lawful grounds:

  • our legitimate interest in ensuring the safety and securing your Account, your money, our Services, us, our group companies, and any necessary third parties;
  • where it is necessary for the adequate performance of a contract with you and to take steps requested by you prior to you entering into a contract with us; and
  • compliance with legal obligations to which we are subject, for example in relation to carrying identity validation and other checks.

3.5 To market to you

We will process your personal data:

  • to send you marketing materials, including in relation to other products and services provided by our group companies.

We process your information for the purposes set out above on the following lawful grounds:

  • if you provide is your consent to do so; and
  • in certain circumstances, given our legitimate interests in marketing our products and services to you and others.

3.6 To customize, improve and enhance our Services and/or Website

We will process your personal data:

  • to analyze your use of the Services so we can learn more about what you like or don’t like about our Services. We may also analyze your behaviour when using the Services to ensure you do not miss out on any offers or opportunities. In doing so, we will use the information we collect to communicate with you, for example, if you have not logged into the Website for a while or if you have not completed a transaction with one of our e-commerce merchants;
  • to respond to any of your queries; and
  • to improve and customize our Services and/or Website.

We process your information for the purposes set out above on the following lawful ground:

  • our legitimate interest in providing payment related Services and/or Website, operating and improving State of Art Jewellery Designers LLC and/or Website, marketing our products and services to you and others and being as efficient as we can about complying with legal duties, obligations and regulations that apply to us and keeping our records up to date.

4. SHARING YOUR PERSONAL DATA

We may share your personal data in the following scenarios only:

  • we may share your personal data with your consent;
  • we may share your personal data with other users who are using the Services to ensure you both receive the full benefit of the Services offered. You may also use our Services to share your own personal data with other users of the Services;
  • by providing personal data to form part of your public profile, any personal data displayed on the public profile will be visible by other users;
  • we may share your personal data with certain service providers, partners or group companies that facilitate and support us in providing the Services, including in relation to carrying out verification checks, remitting funds, processing transactions, and providing other functions. In certain circumstances, this will require us to share your full account and financial data, to the extent it relates to the Services, with a partner due to the degree of support they provide;
  • we may share your personal data with certain service providers or group companies to analyze the Services so we can improve and provide the best Services to you and others;
  • we may share your personal data if we are required to respond to law enforcement, officials, regulatory agencies and other lawful requests or legal processes, or to comply with a legal obligation to which we are subject;
  • we may share your personal data if we undergo a merger, acquisition or other form or reorganisation and pursuant to such, a third party will become the controller of your personal data; and/or
  • we may share your personal data with group companies if you request a good or service provided by one of our group companies, or if one of our group companies provides us with services which relate to the provision of Services to you.

In accordance with the laws of the UAE, we will store your transaction and other Account data within the UAE. Notwithstanding this, if we are required and permitted by law to transfer any of your personal data to a country outside that in which we collected it pursuant to the above listed circumstances, we will do so in accordance with the applicable data privacy legislation. The lawful requirements will depend on the flow of personal data, meaning it will depend on whether the sharing of personal data is cross-border and which countries are involved. At all times, we will ensure a similar degree of protection is afforded to your personal data outside the country in which you are based.

5. SECURITY OF YOUR PERSONAL DATA

We take your privacy very seriously and work hard to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place appropriate security measures to prevent this from happening.

In addition, we limit access to your personal data to those employees, volunteers, agents, contractors and other third parties (as listed above) who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

6. HOW LONG WE KEEP YOUR PERSONAL DATA FOR

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

With this in mind, we have determined that:

  • as required by applicable law, particularly those that relate to anti-money laundering, we will store your financial data for ten years from the date of the transaction, or longer if subject to the below retention period; and
  • upon cancelling your Account, we will store all data related to your Account, including personal data and transaction data, for up to five years from the date of cancellation before permanently deleting it.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation or other regulatory enforcement or action in respect of our relationship with you and/or your use of the Services.

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

7. YOUR RIGHTS

In certain circumstances and subject to certain jurisdictional restrictions, you may have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios. 
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
  • Withdraw consent at any time where we are relying on consent to process your personal data.
  • Complain to the appropriate regulator for any data protection issues. We would, however appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.

To exercise one of the above rights, please contact us at manager@soajewelers.com.

We may need to request specific information from you to help us confirm your identity and ensure you are able to exercise the right you wish to exercise. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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

8. THIRD PARTY LINKS

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. Our Services and Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins and/or applications and we are not responsible for their privacy statements. When you leave our App or Website, we encourage you to read the privacy policy of every website or application you visit or use.

9. Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Otherwise visitors to the website can download and extract any location data from images on the website.

We reserve the right to publish any modeling, repair, modification, and/or designing of your jewellery items we have produced or worked on unless you explicitly object to such.

CONTACT INFORMATION

If you no longer wish to receive any communication from us you may send us an unsubscribe notice request through to info@soajewelers.com with UNSUBSCRIBE as the subject and which channels of communication you wish to be removed from as the body (calls only / messages only / emails only / ALL).

ADDITIONAL INFORMATION

LEGAL

The jurisdiction for all legal matters will be litigated before the courts and judicial committees of the Emirate of Abu Dhabi in the United Arab Emirates, the nature of such matters deemed to the appropriate regulator for any legal issues and any action or proceeding including those arising from non-contractual disputes, controversy or claims. You agree that the courts of the United Arab Emirates shall have exclusive jurisdiction to hear, settle and/or determine any dispute, controversy or claim.

If such a claim may ever arise however, we would appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.