Version number: 1.0

Effective date: 01/02/23

1. Who are we?

1. We are MTL 18 Ltd trading as “White House Diamonds”. For privacy queries, you can contact us at info@whitehousediamonds.co.uk. Other contact details are on our website. 

2. What’s the point of this policy? 

1. It tells you what to expect when we collect personal information from users of our website and services. Please only use them if you are completely happy with this policy. 

2. Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies. 

3. Might the policy change?

1. Yes. We will take reasonable steps to give you notice of the new version.

4. What do we collect? 

1. Information which you upload to our service or otherwise give us such as:

• your name and contact details;

• account information such as your username and password;

• details about your transactions with us;

• information that you include in reviews or that you otherwise provide for display on our service and/or in communications with us including surveys and feedback; and

• contact or other information which you give or allow us to use for newsletters or other marketing.

2. Automated information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the site from which you arrived at our service, details of your activity with date / time stamps including pages you visited and your searches / transactions.  

3. The following information about you may be provided to us by other people:

• Limited billing information sent to us by our payment provider for verification purposes e.g., your name, email address and billing address.

5. What’s our reason / legal basis for collecting the information?

1. Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract. This applies to information such as initial enquiries and to account, contact and transaction information. 

2. Because it’s in our “legitimate interests”, e.g., sending you marketing communications about our similar products/services, managing and improving our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to information such as contact details, automated usage data as well as to reviews and similar information you display on our service and to surveys and feedback.

3. Because you’ve specifically agreed on our service (e.g., by selecting a consent box). This may apply to contact or other information that you specifically agree to us using for certain kinds of marketing. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.  

6. How long do we keep personal information? 

1. We will generally hold your information for our default standard retention period of six years after the end of our contract/relationship with you, but we may delete it earlier/later as set out below or in our terms and conditions.

2. We will keep your information that we use for email newsletters or other marketing until you tell us to stop sending you such messages.

3. We will generally keep automated browsing information for up to 26 months.     

4. Even if our contract/relationship with you is over, we will continue to display reviews posted by you until you either ask us to remove them or, if applicable, you take them off the originating site.

7. To whom do we send or make available your personal information? 

1. To other people who supply us with services, e.g., delivering goods, website hosting and management, payment, customer service, email distribution, e-commerce, online advertising, analytics, social media etc. 

2. To other Internet users if you include your personal information in a public action on our service, e.g., in a review.

3. To regulators, the police and other law enforcement or official authorities to help deal with fraud and abuse and/or comply with legal requirements and/or to protect us or others.

4. To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.

5. To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.

8. Do we send your information outside the UK?

1. Your personal information (e.g., name, username, contact details, IP address, browsing information) is transferred to companies outside the UK (generally to the US) that provide us with hosting, e-commerce, analytics, advertising, email distribution, social media and other services. Where this happens, we will ensure that there is a legal basis to do so, for example under contracts with standard contractual clauses sanctioned by the Information Commissioner that are designed to provide adequate safeguards for your personal information. 

2. We may need to send your contact information to delivery companies outside the UK, to enable us to deliver goods to you. 

9. What rights do you have? 

1. If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete it or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g., marketing).

2. You may also have the right to object to use of your personal information in certain circumstances.

3. If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO).

4. For more information about your rights, visit the ICO’s website: www.ico.org.uk.

10. What about cookies?

1. We and/or other companies use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your web browser.  Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Some are session temporary “session” cookies that remain in the cookie file of your browser only until your browser is closed. Whereas persistent cookies stay for longer (depending on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete existing cookies, visit: www.allaboutcookies.org. Our site’s functionality will be limited if you configure your browser to reject cookies.

2. We ourselves may place the following types of cookies:

   Type of cookie [“—“ = Purpose]

   Logged-in status — Assess whether you are logged in to our site

   “Remember me” — Remember you and speed up your login when you return to our site

   Authentication — Identify and authenticate you to help you move easily through the site 

   Preferences — Store information about the preferences you’ve selected (e.g., favourites, currency, wish-lists) and personalise the site

   Shopping cart — Remember contents of your cart and related preferences

   Affiliate — Track whether you have visited us from websites affiliated with us so we can pay affiliates and assess the effectiveness of the affiliate links

   Security — Provide security-related features to protect our site, for example to help stop fraudulent logins

   Cookie notice — Store your response to our cookie notice

3. Companies which provide us with a service also place cookies. Some of these cookies (e.g., from Google) may involve certain information, such as your name and contact details and/or the IP and web address of the page you’re visiting, being sent to the company concerned. Below is a summary of the kinds of cookies used together with details about who places them and where you can go to get more information and to opt out (where possible):

• Analytics cookies: These kinds of cookies recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and where the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily. These cookies are provided by:

• Squarespace: We use functional, analytics and performance cookies from our website provider. See here for more information.

• Google Analytics (“GA”). More information:

• Google’s overview of GA data practices and safeguarding

• how to specifically opt out from GA cookies

• Google’s use of its partners’ data