EU data protection law makes a distinction between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Pallotta, located at the address in the section entitled “Contact Us” below, is the controller with respect to information you provide through the Service.
INFORMATION WE COLLECT & YOU PROVIDE
We collect information you provide directly via the Service, including when you register an account, update your profile, access our content, make a purchase, participate in a sweepstake, contest, survey, or other promotion (“Promotion”), contact customer support, or apply for a job. We may use Service Providers (defined below) to collect this information.
The information we collect includes information that identifies you personally (whether alone or in combination). Some examples of information we collect include the following:
- Contact Data. We collect your first and last name, e-mail address, postal address, phone number, and other similar contact data.
- Credentials. We collect passwords and other information for authentication and account access.
- Demographic Data. We collect demographic information including your age, gender, and country.
- Payment Data. We collect data necessary to process your payment if you make a purchase, including your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.
- Profile Data. We collect your interests, favorites, wish lists, ring size preferences, and other profile data.
- Content. We collect the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide to customer support. For example, if you contact a customer service representative or jewelry consultant and provide information to the consultant or submit a request through our Service, we will use your information to respond to your request and to provide you with additional information that we believe may be helpful to you. We may also collect content such as photos, videos or other content that you submit to us.
You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
INFORMATION COLLECTED AUTOMATICALLY
Pallotta automatically collects information about your device and how your device interacts with our Service. We may use Service Providers to collect this information. Some examples of information we collect include the following:
- Service Use Data. We collect data about the features you use, the pages you visit, the e-mails and advertisements you view, the products you purchase, the time of day you browse, your referring and exiting pages, and other similar information.
- Device Connectivity and Configuration Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information.
- IP Address and Device Identifiers. Pallotta collects your IP address and other device identifiers, including your MAC address and mobile advertising identifiers. We collect this data for various purposes, including to assess, diagnose problems, and improve functioning of our Service, servers, and hosting providers as well as to analyze trends and traffic patterns, gather demographic information, track the date, time, and duration of each session within our website, prevent fraud, and customize our services and advertisements.
- Location Data We collect data about your device’s location, which can be precise (e.g., latitude/longitude data) or imprecise (e.g., location derived from an IP address or data that indicates a city or postal code level).
- Log Files. Our server logs automatically collect information, such as your IP address, your browser type and language, and the date and time of your visit, which helps us track users’ movements around our site and understand trends.
- Operational: Cookies are essential in order for you to use our Service, such as our shopping bag, as well as to access password-protected areas, such as your personal account.
- Analytics and Performance: Cookies collect information about how you use our Service and remember the choices you make (such as your language or location) to provide enhanced performance and more personalized experience.
- Customization: Cookies allow us to gather information on how our Service is being used so that we can provide content that is relevant to you.
- Social Networking: Cookies allow users to share our pages and content to third-party social networking sites.
For an updated list of cookies on our Service and your choices regarding them, please visit our Cookie List.
- Web Beacons. Pallotta also uses electronic images known as web beacons (also known as pixels) on the Service. When you access a website, video, e-mail, or advertisement that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from third parties that allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
- Location-Identifying Technologies. Location-aware technologies may be used to collect precise location data when you enable location-based services through your device. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.
Some information about your use of the Service and certain Third Party Services may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.
INFORMATION FROM OTHER SOURCES
- Data brokers from which we purchase demographic data to supplement the data we collect.
- Social networks when you reference our Service or grant permission to Pallotta to access your data on one or more of these services.
- Partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
- Advertising partners.
- Publicly-available sources such as open government databases or other data in the public domain.
For further information on Third Party Services, see the section entitled “Third Parties” below.
USE OF INFORMATION
We use information about you for our legitimate interests, including to:
- Manage our Service, including your registration, account, and transactions.
- Perform services requested by you, such as to process and fulfill your order, to respond to your comments, questions, and requests, and provide customer service.
- Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
- Prevent or take action regarding illegal activities, including suspected fraud.
- Monitor and analyze trends, usage, and activities.
- Conduct internal research on our users’ demographics, interests, behavior.
- Improve our marketing and promotional efforts, Service content and product, and service offerings.
- Develop and send you direct marketing, including advertisements and communications about our and third-party products, offers, promotions, rewards, events, and services.
We also use information about you with your consent, including to:
- Verify your eligibility and deliver prizes in connection with Promotions you have entered.
- Serve to advertise tailored to your interests on our Service and Third Party Services.
- Fulfill any other purpose disclosed to you and with your consent.
We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law.
SHARING OF INFORMATION
We share your information as follows:
- Service Providers. We share your information with third-party agents, contractors, vendors, and other service providers in connection with their work on our behalf (collectively “Service Providers”). For example, if we need to ship something to you, we must share your name and address with a shipping company. Examples of other third parties that we may share your information with include: web hosting companies, fulfillment companies (e.g., companies that fulfill product orders), loose diamond suppliers, jewelers, assemblers, data analysis firms, affiliates, third party consulting or marketing firms, and e-mail service providers. Additionally, if you use a credit card or other financing alternative to place an order with Pallotta, we will use a third party payment processor to process your information in association with the transaction. We may also share information with other companies and organizations for credit fraud protection and risk reduction. These third parties only receive your information if such information is needed to perform their function(s), and they are not authorized to use such information for any other purpose(s) other than the purpose(s) set forth by Pallotta. We only provide third-parties with the minimum amount of information necessary to complete the requested service, product or transaction. Notwithstanding the above, we may permit our Service Providers to use aggregate information which does not identify you or de-identified data for other purposes.
- Affiliates: We may share your information with our related entities including our parent and sister companies. For example, we may share your information with our affiliates for customer support, marketing, and technical operations.
- Business Partners: We may share your information with our business partners in connection with offering you co-branded services, selling or distributing our products, or engaging in joint marketing activities. For example, we may share information about you with a business partner for purposes of providing you with co-branded products or services that we may offer.
- Special Events: If you choose to participate in a special event (for example, a Promotion), Pallotta may share your information with those organizations participating in the applicable event. Typically, these third parties do not use your information for any other purpose other than to manage the event. In some cases, these third-party partners may send you promotional materials regarding their products and services. In these cases, you will be given the opportunity to opt-out, and not have your information shared with that third-party partner. By entering a Promotion, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
- Feedback, Testimonials and User Provided Content. If you provide feedback or testimonials on the Service or on Pallotta products or services, or provide other User Provided Content (such as photos or videos), we may post and share this feedback, testimonial or other User Provided Content, including your information, on the Service, with third party partners, or in marketing and promotional materials. We may, by our sole discretion, edit feedback, testimonials or user-provided content for length and content.
- Third Parties. We may share your information with third parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Service) and in connection with tailoring advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.
- Business Transfer. Your information may be disclosed as part of, or in connection with, any merger, sale of company assets, or acquisition, as well as in the event of an insolvency, bankruptcy or receivership, in which information would be transferred as one of the business assets of Pallotta.
- Security, Compliance with Law, and Fraud Protection. We may disclose your information as we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request. We also may share your information in order to investigate, prevent or take action regarding illegal activities, including suspected fraud, or as otherwise required by law. We may also share your information to protect the rights, property, life, health, security, and safety of us, the Service or any third party.
- Consent. We may share your information for any other purpose disclosed to you and with your consent.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law.
Pallotta does not knowingly collect personal information from children under the age of thirteen (13). In the event that Pallotta ever does so, we will strictly comply with the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and believe Pallotta has collected such information in a manner not permitted by COPPA, please contact us as set forth in the section entitled “Contact Us” below, and we will remove such data to the extent required by COPPA.
THIRD PARTY SERVICES
THIRD PARTY FEATURES
- Liking and Sharing. We may embed a pixel or SDK on our Service that allows you to “like” or “share” content on your Pallotta account through, Third Party Services, including social networks such as Facebook and Twitter. If you choose to engage with such a Third Party Service through our Service, we may collect any information you have authorized the Third Party Service to share with us (such as your user ID, billing information, public profile information, e-mail address, birthday, friends list, and other account and profile data). Likewise, if you choose to engage with such a Third Party Service through our Service or visit our Service while logged in to that Third Party Service on your device, the Third Party Service may receive information about your activities on our Service and be able to associate that information with information the Third Party Service already has about you.
ANALYTICS AND INTEREST-BASED ADVERTISING
Our Service contains Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third-party analytics provides, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide us with other services relating to a Service activity and internet usage. We also work with ad serving services, advertisers, and other third parties to serve advertisements on the Service and/or on Third Party Services. These third parties may use Tracking Technologies on our Service and Third Party Services (including in e-mails and advertisements) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Service and Third Party Services or third party devices after you have left the Service (“Interest-based Advertising”).
We may serve ads on Third Party Services, such as Facebook and Google, which are targeted to reach people (or similar people) on those services that have visited our Service or that are also identified in one or more of our databases (“Matched Ads”). This is done by matching common factors between our data and the data of Third Party Services. If we use Facebook Custom Audiences to serve Matched Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad and find out how to opt-out. We are not responsible for such Third Party Services’ failure to comply with your opt-out instructions.
REVIEW AND UPDATE OF ACCOUNT INFORMATION
You may access, update, or remove certain account information that you have voluntarily submitted to us through the Service. If you would like to update or revise information in your account, you may do so through your account or by contacting us as set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
TRACKING TECHNOLOGY CHOICES
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms.
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.
ANALYTICS AND INTEREST-BASED ADVERTISING
Some of the third parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit for website opt-out, aboutads.info/choices. In addition, some of these third parties may be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, please visit networkadvertising.org/choices/. If you are in the EU, please also visit the EU online choices page at http://www.youronlinechoices.com/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
To opt-out of receiving e-mail promotions from Pallotta, please follow the unsubscribe instructions in our promotional e-mail correspondence. Please note that opting out of promotional communication received from Pallotta does not affect our non-promotional communications with you, including those related to your account, orders placed with Pallotta, or our ongoing business relations.
YOUR EUROPEAN PRIVACY RIGHTS
If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do base on the consent you have provided to us.
To exercise any of these rights, contact us below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Despite the measures we take, transmission via the Internet is not completely secure and we cannot guarantee the security of your information at any time.