JAMES ALLEN PRIVACY POLICY

Last Updated: September 22, 2024

This privacy policy (the “Policy”) describes how James Allen (“James Allen”, “we”, “our”, or “us”) collect, use, and disclose consumers’ personal information, including information collected in our retail locations and through our website https://www.jamesallen.com/ (“Website”) (and all other websites, mobile sites, services, applications, platforms and tools where this Policy appears or is linked) (collectively, the “Services”).

To the maximum extent permitted by law, by providing personal information to us (by any means, whether in a store, in correspondence, via our Website, phone or otherwise) you consent to our use of the personal information you provide in accordance with this Policy. If you do not agree with this Policy or our practices, please do not use our Services.

1. Sources of Information We Collect

When information identifies or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, we refer to it as “personal information” or “personal data.”

There are several ways we may obtain personal information about you, including through (A) information you provide to us directly; (B) information that we automatically collect; and (C) information we receive from third parties. This includes data that identifies you personally whether directly (i.e., your name) or indirectly (i.e., information associated with the device you use online). For further information on the personal information we collect, please refer to the Notice at Collection above.

A. Information You Provide

We collect personal information about you, as described in the Notice at Collection above, via the Services, including online, offline, at our retail locations and by telephone.

B. Information Automatically Collected

Whenever you visit our online Services, we and our third-party advertisers and service providers (see Section 2.B below for more detail), may use a variety of technologies such as cookies and similar technologies to automatically or passively collect certain information about your online activity.

We may link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you for the purposes described in the Notice at Collection above, and to let us know, for example, whether you have opened an email we sent to you. While you can change your cookies settings in your browser, without cookies, you may not be able to use all of the features of our Website.

C. Information Collected From Third-Party Sources

We collect information about you from ad networks, data companies, data brokers, and other third- party sources with whom you may not have a direct relationship, and that help us provide ads and services that target your interests. The information collected includes, for example, your demographic information, media consumption, previous purchases, shopping habits, loyalty program information, lifestyle preferences, or information to validate or update the information we collect from or about you.

D. Aggregate or Deidentified Information

We may aggregate or deidentify any personal information we collect. We may share the aggregated or de-identified information with our business partners and service providers, and we may use such information for our own purposes. We will maintain and use de-identified information in de-identified form and will not attempt to re-identify that information.

2. Information We Disclose

A. Disclosure of Information by You

We offer you many ways to find, enjoy, and share content, including by filling out surveys, reviewing and rating products or services, inquiring about or purchasing products or services, participation in online communities, “liking” or “sharing” our content to your social media accounts.

Any personal information you disclose on publicly-facing areas of our Services, or to publish on our Website or on other third-party websites (e.g., social media channels) becomes public information. Please exercise caution when disclosing or allowing us to process and/or publish you personal information in these public areas.

B. Disclosure of Information by Us

We sell or share the categories of personal information identified in the Notice at Collection above:

• With vendors and advertising partners, including social media platforms, who help us reach you with ads that are tailored to your interests, as described under “Interest-Based Advertising Choices” below.
• With analytics partners, who help us understand your use of our Services.
• With our affiliates and subsidiaries for business, operational, promotional, and/or marketing purposes.
• To partners in co-branded relationships such as advertisers that provide products and services or rewards programs. We may share information with these third parties if you participate in a co-branded, co-sponsored, or jointly presented promotion, contest, survey, voting feature, "refer a friend promotion", or service.

We disclose the categories of personal information identified in the Notice at Collection above:

• To service providers that provide business, professional or technical support functions for us (including fulfilling and shipping orders), help us operate the Services, help us send commercial or marketing communications, or administer activities on our behalf. Under applicable law, service providers are defined as a person that processes personal information on behalf of a business and that receives from or on behalf of the business consumer's personal information for a business purpose pursuant to a written contract.
• With our affiliates and subsidiaries for business, operational, promotional, and/or marketing purposes.
• If we are required to do so by law or court order, to enforce or apply our Terms of Use (or other document or contract related to our services) or if we believe in good faith that such release is necessary or appropriate to protect the rights, property, or safety of our company, customers, affiliates (i.e., brands with common ownership, interest, or control), or others or for fraud prevention or detection purposes.

In addition, we may aggregate or deidentify personal information and use or disclose the aggregated/de-identified information for marketing, analytics, and other purposes. Finally, we may disclose personal information in connection with the sale, transfer, acquisition, merger, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change or ownership or control by James Allen or any affiliated company (in each case, whether in whole or in part).

3. Interest-Based Advertising Choices

We collect information about your use of the Services through cookies, pixels, log files, or other similar technologies (our cookie notice is available here) to review or improve the usage and operations of our Website, to analyze trends and track users’ movement around the Website, to administer the Website and to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this last purpose from third-party websites on which our ads are served. You may see our ads on third-party websites or apps because we use third-party ad networks to serve our ads.

The networks use this information to show you advertisements that may be tailored to your individual interests. The information our ad networks may collect on our behalf includes data about your visits to websites that serve our advertisements, such as the pages or advertisements you view and the actions you take on the websites (e.g., if you click the ad). This data collection takes place both on our Website and other online Services, and on third-party websites that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts.

To learn more about interest-based advertising, and to opt out of the use of your information for such advertising by the Digital Advertising Alliance (DAA) participating companies, please visit http://optout.aboutads.info .

To opt out from the use of information about your online activities for interest-based advertising by Network Advertising Initiative (NAI) member companies, please visit http://optout.networkadvertising.org .

To opt-out from the use of information about your online activities for interest-based advertising by European Interactive Digital Advertising Alliance (EDAA) participating companies, please visit: http://www.youronlinechoices.eu/ .

To opt-out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.

The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available here, and the Google Privacy Policy, available here. If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout/.

You can also control how some information is collected through your browser or mobile device. You can adjust your browser settings to limit or block certain cookies, but this may prevent us from storing your preferences and may make some features of the Services inoperable. Refer to your browser’s help menu for further details. On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising. You may need to set these preferences on each browser or device you use.

4. Other Choices About the Use of Your Personal Information

You can unsubscribe from receiving James Allen's marketing communications by following the "Unsubscribe" link provided in our emails. If you receive marketing communications from one or more brands or affiliates, you should opt-out individually from each of the affiliates from which you are receiving brand-specific marketing communications. Opting out of such communications does not affect our communication with you via telephone or email regarding your orders, customer support or service transactions.

5. How We Protect Personal Information

We use technical, administrative, and procedural measures to help protect your personal information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

6. Children’s Privacy

We are committed to protecting the privacy of children. The Services are not directed to children and we do not knowingly collect any personal information from children. For the purposes of the GDPR, we do not intend to offer information society services directly to children. If a child under the age of 16 has provided us with personal information online, we ask that a parent or guardian please contact us, and we will take reasonable steps to delete personal information provided by the child. We do not knowingly sell or share the personal information of anyone under 16 years of age.

7. Links to Third Party Sites and Services

Our Website and online Services contain links to third party websites (including social networks and related plugins) operated by individuals or companies unrelated to us. Please be aware that we are not responsible for the privacy practices of such third-party websites. We provide links to these websites for your convenience only, and you access them at your own risk. We recommend that you review the privacy policies and terms of use posted on such third-party websites before using them.

Our Website and online Services may also offer you the ability to interact with plugins from social media sites, which may allow us and/or the social media site to receive data from or about you. In some cases, we may know that you clicked on a social plugin, such as a Twitter Follow button, or receive other information from the social media sites. Similarly, if you have previously provided personal information to a third-party operating a plug-in on this Website or another of our online Services, then that third-party may recognize you on our Website or other online Services. Your use of social network plugins is subject to each social media site’s own privacy policy, so please read that site’s policies carefully to understand its practices. As with linked sites, we have no control over and are not responsible for the information that is collected, stored, or used by social network plugins.

8. Retention of Personal Information

We keep personal information as long as reasonably necessary or relevant to achieve the purpose described in this Policy. We also keep personal information as otherwise required by law. What this means in practice will vary between different types of information, and when we consider our approach we take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, fraud prevention, for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and potential or actual disputes, litigation, or investigations.

9. Your State-Specific Privacy Rights

The following rights, which may be subject to certain exemptions or derogations, apply to residents of California, Colorado, Connecticut, Virginia, and Utah:

• Right to Know: You have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.

• Right to Portability: You have the right to access your information in a portable format.
• Right to Delete: You have the right to delete personal information that we have collected from you. Note that there are some reasons we will not be able to fully address your request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, for our internal purposes, or to comply with a legal obligation.
• Right to Correct: You have the right to correct inaccurate personal information that we may maintain about you, subject to appropriate verification.
• Right to Opt-Out of the Sale or Sharing of Personal Information:You have the right to opt-out of the “sale” or “sharing” of your personal information, as such terms are defined under state privacy law. This means that, if you opt out, going forward, we will not sell or share your personal information with such third parties to use for their purposes, including cross-context behavioral advertising, unless you later direct us to do so.
• Right to Opt-Out of Targeted Advertising:You have the right to opt-out of targeted advertising. Opting out does not mean that you will stop receiving ads, it just means that those ads will not be targeted based on your personal information.
• Right to Appeal:If we deny your request, and you wish to appeal, you may appeal our decision.

Use and Disclosure of Sensitive Personal Information: To the extent that we collect information which is considered "sensitive personal information" as that term is defined under applicable privacy law, we limit our use or disclosure of the sensitive personal information for permitted business purposes.

Please note that, where permitted under applicable law, we may decline a request if we are unable to verify your identity (or an agent’s authority to make the request) and confirm the personal information we maintain relates to you.

How to Submit a Request

If you want to submit a request, please contact us by email at service@jamesallen.com, by phone at +1 877-826-9866. When processing your request, we may request additional information about you or your interactions with James Allen to confirm or verify your identity or for security purposes before we can respond to your requests. To exercise your right to opt out of the sale or sharing of personal information (including to opt out of targeted advertising), please click on the Do Not Sell or Share My Personal Information link which also is on our website footer or email us at service@jamesallen.com.

Alternatively, you can use certain preference signals to exercise your sale and sharing opt-out right automatically with all businesses that you interact with online, including James Allen. If you enable a browser-based opt-out preference signal, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of personal information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each browser or profile.

Nevada residents may send an email to service@jamesallen.com to submit a verified request to direct us to stop the sale of your covered information.

We value your privacy and will not discriminate in response to your exercise of your privacy rights.

Agent Requests

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you have authorized them to act on your behalf or must demonstrate they have power of attorney pursuant to applicable probate law. James Allen retains the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent is prohibited from using a consumer’s personal information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer’s requests, for verification, or for fraud prevention.

10. Additional Notice to EEA and UK Residents

For residents of the European Economic Area and United Kingdom, James Allen is the controller responsible for processing your personal data.

10.1 Legal Basis for Processing:Applicable law in certain jurisdictions requires us to set out the “legal basis” that we rely on to collect and use your personal information. Where applicable, the legal bases upon which we rely on in order to collect and use your personal information are as follows:

• Consent: We may collect, use, and disclose your personal information on the basis of the consent that you provide us at the point of information collection or disclosure. You have the right to revoke your consent at any time.
• Contractual Necessity: We may collect and use certain personal information where it is either necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. This may include personal information used to provide you with our products and related services and related transaction information.
• Compliance with a Legal Obligation: We are subject to various legal requirements in the jurisdictions in which we operate, and we may use, disclose, and retain your personal information if necessary for us to comply with a legal obligation arising under an applicable law to which we are subject.
• Legitimate Interests: We may collect and use your personal information to the extent necessary to carry out our legitimate interests (or those of a third party), provided that such interests do not outweigh your interests or fundamental rights and freedoms. For example, we may collect and use your personal information in reliance on a legitimate interest in managing our relationship with you; conducting and managing our business; providing you with customer support; conducting market research; developing and enhancing our Services as well as our products and services; detecting and preventing fraud and other harmful activities; and monitoring and maintaining the security of our data, systems, and networks.

10.2 Privacy Rights and Requests: Under applicable law, you may have certain rights in relation to your personal information, including:

• Right to Access: You have the right to request access to, or copies (and transmission) of, the personal information we hold about you and the purposes for which we are using it.
• Right to Rectify: You have the right to correct inaccurate personal information that we have collected from and maintain about you, subject to appropriate verification.
• Right to Erase: You have the right to erase personal information pertaining to you. We will assess any deletion request after verifying your identity and work to respond within one calendar month, and let you know if we need additional time.
• Right to Object: You have the right to object to processing the personal information we process, under certain conditions.
• Right to Restrict: You have the right to restrict the processing of your personal information.
• Right to Data Portability: You have the right to receive the data we have collected from you. Under certain conditions, you may request that we transfer your personal information to another organization, or directly to you.
• Right to Lodge a Complaint: You have the right to file a complaint with the supervisory authority in your jurisdiction. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution. You can exercise your rights by contacting us at service@jamesallen.com.

At any time, you may request or assert any of the rights above by emailing us at service@jamesallen.com. If you believe there has been a violation of your privacy rights, please contact us or the supervisory authority.

You may also have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

10.3 Additional Information Regarding Transfers of Personal Information

A. Internal transfers: Transfers within the Signet Jewelers Family of Companies will be covered by an internal processing agreement entered into by members of the Signet Jewelers Family of Companies (an intra-group data processing agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred to.

B. External transfers:.Where we transfer your personal information outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your personal information. When James Allen engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission. James Allen also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.

11. Modifications to this Policy

Any changes we may make to our Privacy Policy will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy. If you do not agree or consent to these updates or changes, do not continue to use our Services. If we make a material change to this Privacy Policy, we will provide notice to you as required by law (e.g., by email or other means).

In addition to this Privacy Policy, there may be specific campaigns or promotions which will be governed by additional privacy terms or policies. We encourage you to read these additional terms or policies before participating in any such campaigns or promotions as you will be required to comply with them if you participate.

13. Branded Credit Card Privacy Policy

This Policy does not govern the collection or use of the information provided in connection with our branded credit cards. We notify our charge account holders of our privacy practices annually, or as otherwise required by law. If you have one of James Allen's branded credit cards, a separate privacy policy provided to you describes collection, use, and protection of information about you and your account.

14. Notice of Financial Incentive

We may offer financial incentives to promote our products and services. These may include:

• Discounts, coupons, and special offers when you sign up for our email list, refer a friend, participate in a marketing promotion or sweepstakes, send your videos, or create an account.
• Points programs, where you earn points for certain purchases that can be redeemed for discounts, coupons, or other benefits.

We may ask you to provide personal information in connection with these promotions, including the following personal information: your first and last name, email address, phone number, birthday and gender; we may also ask you to record a video of you and share it with us. Because we may collect personal information, this may be interpreted as a “financial incentive” program under California law or a “bona fide loyalty program” under Colorado law. James Allen uses this information for the purposes described above under the section titled “Notice at Collection” including for targeted advertising. James Allen may share your personal information with third parties as described in Section 2.B above (“Disclosure of Information by Us”) including data analytics providers, advertising technology vendors, and social media platforms. Participation in any financial incentive is optional. You may withdraw from the program at any time by emailing service@jamesallen.com. To stop receiving our coupons or discounts in your email, you may unsubscribe from our emails by clicking the “unsubscribe” button at the bottom of any such email. To stop receiving our coupons or discounts via text message, please text “STOP” to our text messages or contact us at service@jamesallen.com.

If you ask us to delete your personal information, we will not be able to provide you with access to these programs. We have valued the personal information collected and used as being equal to the value of the discount code or financial incentive offered, and the calculation of the value is based upon a reasonable and good-faith estimate often involving the consideration of (i) the categories of personal information collected (e.g., email address and/or phone number, as applicable), (ii) the value of the discount offered, and (iii) the value of the total purchase (excluding taxes and fees). The disclosure of the value described herein is not intended to waive, nor should be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards. We reserve the right to change our financial incentives in the future and the goals thereof.

Please note that we may provide additional terms that apply to a particular financial incentive. If applicable, those terms will be presented to you at sign up.

15. How to Contact Us

If you have any questions or concerns about this Policy or the practices described herein, you may contact us at service@jamesallen.com or by mail to 135 W 50th street, New York, NY 10020, USA or by phone at (301)631-1414.

For specific issues relating to this Policy, please contact our Data Protection Officer at dpo@jamesallen.com.