Privacy Policy
See also Terms of Sale, Terms of Use, Refund Policy & Cookie Policy
PRIVACY AT A GLANCE
We collect information about you to process your order, manage your account, respond to your queries, ensure the continuity of our business and, if you agree, send you information about our products and offers tailored to your interests and preferences.
We will share your information with our service providers and our affiliates for the purposes above, as well as with regulatory authorities where required by law. We will not share your personal information for marketing purposes with any other organisation.
To learn more about your rights and how we use your personal information, please read our detailed Privacy Notice below.
1. INTRODUCTION
Welcome to Graff’s Privacy Notice. Graff respects your privacy and is committed to protecting your personal information and making sure you understand our privacy practices. This Privacy Notice describes the personal information we collect through our website www.graff.com (“Site”), how it is used, and your choices regarding this information.
2. WHO IS GRAFF?
Graff Diamonds Japan KK (referred to as “Graff”, "we", "us" or "our" in this Privacy Notice) is the data controller and responsible for your personal information.
If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us using the details set out below:
Graff Diamonds Japan KK
3-3-1 Ginza, Chuo-ku, Tokyo 104-0061
clientservices.jp@graffjapan.com
3. WHY DO WE USE YOUR PERSONAL INFORMATION AND WHAT BASIS DO WE RELY ON?
We may process your personal information for the purposes below and based on the following legal bases:
| Purpose | Basis for processing |
|---|---|
| Purchasing process and delivery of products which includes taking and handling orders, deliver products and communicate with you about your orders. | Necessary for the performance of our contract with you. |
| Managing payments for the services we provide you which includes billing process where you purchase a product through our website. | Necessary for the performance of our contract with you. |
| Service Relationship which includes managing your account, providing customer support and communicating with you about our products and about your engagement with us, such as changes in our terms. | Necessary for the performance of our contract with you. |
| Communicating with you at your request to provide you with information of our products or solve your enquiries before purchasing any of our products. | Necessary for taking steps prior to entering into a contract with you. |
| Ensuring proper administration of our business which includes keeping appropriate records, resolving complaints and managing our business relationships and opportunities. | Necessary for our legitimate interest pursued by us or our service providers acting on our behalf or by a third-party insofar as such interests do not pose a high risk to your rights and freedoms. Our legitimate interest is ensuring the continuity of our service. |
| Preventing, detecting and fighting fraud or other illegal or unauthorized activities which includes monitoring operations, user activity and networks for fraud prevention and crime detection purposes. | Necessary for our legitimate interest pursued by us or our service providers acting on our behalf or by a third-party insofar as such interests do not pose a high risk to your rights and freedoms. Our legitimate interest is preserving the security of our service. |
| Sending marketing communications about our services, products and our organisation. | Where you signed up for our newsletter or other content, we will send you relevant information based on your consent. Where consent is not required, as you are an existing customer who purchased a similar product in the past, we may send you marketing communications based on our legitimate interest pursued by us insofar as such interests do not pose a high risk to your rights and freedoms. Our legitimate interest would be promoting our business and to provide you with offers of relevant services and products. Please note that we will include an unsubscribe link in all our email communications, which removes you from receiving further communications. |
| Profiling activities to make sure the commercial communications you receive are relevant to you and tailored to your preferences and expectations. | Based on your consent. |
| To establish, exercise or defend legal claims in suspected or actual legal proceedings. | Necessary for compliance with applicable laws and regulations. |
| To provide any requested information to the tax, regulatory, anti-money laundering or any other relevant authorities or public bodies, where required to do so, as well as any processing of your personal information in connection to specific legislation, statutory codes of practice and other legal or tax related obligations. | Necessary for compliance with applicable laws and regulations. |
| To ensure your safety and for the prevention and detection of crime, CCTV is in operation during your visit to any of our retail outlets. Please be aware that if we are requested to provide CCTV images of you or any other personal information relating to you by the police or any other regulatory or government authority investigating suspected illegal activities, we are obliged do so. | Necessary for our legitimate interest pursued by us or our service providers acting on our behalf or by a third-party insofar as such interests do not pose a high risk to your rights and freedoms. Our legitimate interest would be to ensure the safety and security of our facilities, employees and visitors against theft and vandalism. |
4. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We may only disclose your personal information in accordance with the Act on the Protection of Personal Information (referred to as “APPI”) and for the above-stated purposes, to the following parties:
· Third-party service providers acting on our behalf and that provide services such as website hosting, data analytics and information technology assistance. We have appropriate contracts in place that define the legitimate use and sharing of personal information in accordance with this Privacy Notice and oblige such service providers to only process personal information that is necessary for the performance of the contract or are required by the APPI.
· Graff affiliates, subsidiaries and/or divisions (referred to as “Affiliates”). We may disclose your personal information to the Affiliates based on your consent to our Website Terms of Use.
· Regulatory authorities, as required by the APPI, for the purposes of including, without limitation to, responding to any governmental or regulatory authority request, cooperating with law enforcement investigations and mutual assistance, or upon receipt of any court order.
· Parties including prospective or actual buyers or seller in the event of a merger, acquisition, or other reorganization or sale or disposition of all or any portion of our business and/or assets, including disposition in bankruptcy.
- We may share information that has been anonymized or aggregated without limitation.
5. DO WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE OF YOUR COUNTRY?
We do not usually send your personal information to the Affiliates outside Japan unless it is strictly necessary for the purposes stated in this Privacy Notice. When we do send personal information to the Affiliates outside Japan, we have in place adequate safeguards to do so. We may send your personal information to the Affiliates outside Japan based on your consent to our Website Terms of Use.
6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
Your personal information will be stored in accordance with applicable laws and kept for as long as needed to carry out the purposes described in this Privacy Notice. How long we keep your personal information will depend on:
· what type of product or service we are providing for you;
· how long laws or regulations say we must;
· what we need for fraud and other financial crime prevention;
· what we need to lend responsibly;
· other legitimate business reasons (for example because we need to respond to a complaint or legal claim).
7. YOUR RIGHTS
In certain circumstances, you may exercise the rights available to you under the APPI as follows:
· If you wish to request disclosure, correction, addition, deletion of your personal information.
· You may ask us to erase, or cease the processing (including cease the disclosure to third parties) of, your personal information.
You can exercise your rights at any time by contacting us using the contact details included in this Privacy Notice.
We respond to all requests we receive from users in accordance with the APPI. We may ask you to provide proof of identity before we can answer the above requests. In some cases, we may reject requests for certain reasons (for example, if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another individual).
8. WHAT COOKIES AND SIMILAR TECHNOLOGIES DO WE USE?
Please see our Cookies Policy for more information on what cookies we use, why we use them and how you can better control their use through your browser and other tools.
9. CONTACT US
If you have questions regarding your privacy and rights, please let us know how we can help.
· Email: data@graff.com (globally) or clientservices.jp@graffjapan.com (in Japan)
· Postmail: 3-3-1 Ginza, Chuo-ku, Tokyo 104-0061
13. CHANGES TO THIS PRIVACY NOTICE
We reserve the right to change this Privacy Notice from time to time. If we make any changes, the updated Privacy Notice will be posted with a revised effective date.
Effective date: March 2021