Privacy Shield Notice

R2Net, Inc. (“R2Net”, “We” or “Our”), a company that owns R2Net Ltd. (“R2Net Ltd.”), has certified with the EU-U.S. Privacy Shield with respect to the Personal Data (defined below) that (i) We receive from Customers (defined below), Service Users (as defined below) or from R2Net Ltd. (“R2Net Ltd.”), and/or that (ii) We collect from, and/or Process about, on behalf or in the benefit of, the Customers and/or R2Net Ltd., all in the context of providing the Service (as defined below) to Customers or Service Users.

R2Net complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, processing, and retention of Personal Data transferred to the United States. R2Net has certified to the Department of Commerce that it adheres to the Privacy Shield Principles and Our Privacy Shield certification will be available here.

If there is any conflict between the terms in this Privacy Shield Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Our certification, please visit Privacy Shield.

1. DEFINITIONS.

   “Customer(s)” means prospective, current, or former customers, or clients of R2Net and/or R2Net Ltd.

   “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

   “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

   “Service User(s)” means prospective, current, or former users of R2Net’s and/or R2Net Ltd.’s Service (as defined below) or any part thereof.

2. SCOPE.

   R2Net's participation in the Privacy Shield applies to the Personal Data subject to EU data protection law that (i) R2Net receives from Customers, its Service Users or from R2Net Ltd., and/or that (ii) R2Net collects from, and/or Processes about or on behalf or in the benefit of, the Customers or R2Net Ltd., all in the context of providing the Service.

3. PURPOSES OF DATA PROCESSING.

   R2Net and R2Net Ltd. are online bridal jewelry retailers with cutting edge Diamond Display Technology, which own and operate a website, that includes an online jewelry shopping platform and related (collectively and each separately, the “Service(s)”).

   R2Net will Process the Personal Data it receives from R2Net Ltd. and/or Customers and/or Service Users, for the purposes of providing the Service to Customers and Service Users. We may, without limitation, access the Personal Data to assist R2Net Ltd. with providing the Service, to perform contracts or agreements with Customers and/or Service Users, and facilitate transactions via the Service, including with respect to processing order, shipping items, providing support and maintenance, correcting and addressing technical or service problems, contacting Customers and/or Service Users, complying with applicable laws, regulations and orders from public authorities or courts, and/or for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedures.

4. ONWARD TRANSFERS OF PERSONAL DATA.

   Subject to Section 6 below, We will not transfer Personal Data originating in the EU to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of protection to the Personal Data as required by the Principles of the EU-U.S. Privacy Shield Framework. We may transfer Personal Data to cloud service providers (collectively "Processors") who need the information in order to provide services to or perform activities on Our behalf. In cases of onward transfer to third parties of Personal Data received pursuant to the EU-U.S. Privacy Shield, R2Net is potentially liable.

   The above mentioned Processors and the description of the services that they provide and/or the activities that they perform are set out in the table below:

   Service/Activity
   Business, professional and technical support vendors (including, customer support)
   IT and the Website
   Cloud services
   Marketing tools
   Shipping companies
   Payment processors

   
   
5. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA.

   Data subjects have the right to access Personal Data about them, and in some cases to limit use and disclosure of their Personal Data. If you would like to request access to your Personal Data which We have processed, please contact: service@jamesallen.com and provide your name, contact information and observe the required formalities under applicable law.

6. REQUIREMENT TO DISCLOSE.

   R2Net may be required in certain circumstances to disclose Personal Data in response to lawful requests by courts or public authorities, including to meet national security or law enforcement requirement.

7. PRIVACY SHIELD INDEPENDENT RECOURSE MECHANISM.

   In compliance with the Privacy Shield Principles, R2Net commits to resolve complaints about Our collection or use of your Personal Data. EU individuals with inquiries or complaints regarding Our Privacy Shield policy should first contact R2Net at: service@jamesallen.com or by postal mail sent to: James Allen Corporate Office 135 W 50th St., 4th Floor. New York, NY 10020.

   R2Net has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles to JAMS, a non-profit alternative dispute resolution provider located in the United States to assist with the complaint resolution process. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint. The services of JAMS are provided at no cost to you.

8. U.S. FEDERAL TRADE COMMISSION ENFORCEMENT.

   R2Net is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) to ensure compliance with the EU-US Privacy Shield Principles outlined in this notice.

9. ARBITRATION.

   Under certain conditions, more fully described on the Privacy Shield website, you may also be able to invoke binding arbitration when other dispute resolution procedures have been exhausted.