MyAleph Jewelry LLC (“we,” “us,” or “MyAleph”) has created this privacy policy statement in order to demonstrate our firm commitment to your privacy. The following discloses our information gathering, use, and dissemination practices solely for the website located at myaleph.com (the "Site"). By using or accessing the Site, you signify your assent to our Privacy Policy.

1. Personal and Non-Personal Information We Collect:

Information You Provide: When using the Site, in order to utilize some of our services, you may choose to upload, or we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Information”). Personally identifiable information may include, but is not limited to:

• Name
• Email address
• Mailing/physical address
• Telephone number
• Credit card number
• Username
• Date of birth
• "Usage Data," which is data collected automatically, generated by either the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit).

We collect Personal Information from you when you choose to participate in our offers and programs or when you otherwise provide information directly to us, including when you register with us, purchase products, review products, participate in our interactive features, or otherwise interact with us on the Site. If you are under 18 years of age, please do not submit any Personal Information to us. If you are the parent or guardian of a person under 18 years of age who has provided Personal Information to us, please inform us at info@myaleph.com.

Non-Personal Information: In addition, we may also collect non-personally identifiable information, such as IP addresses (which identify your device), pages viewed, computer type, screen resolution, operating system version, Internet browser type and version, information collected through cookies, pixel tags, web beacons, and other technologies, and other data (“Non-Personal Information”). Because Non-Personal Information does not personally identify you, we may collect, use, and disclose Non-Personal Information for any purpose. Non-Personal Information will be retained only for so long as to fulfill a legitimate business need.

Aggregate Information: We may aggregate Personal Information so that the aggregated information does not personally identify you or anyone else, such as by using Personal Information to calculate the percentage of our customers who live in a particular area (“Aggregate Information”). In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined, and we may aggregate any information collected in a manner that does not identify any individual.

2. Use of Information:

Personal Information to Provide Services: We use Personal Information to process and fulfill any orders that you have placed, contact you about our products and services, personalize your experience with us including by presenting products or offers tailored to you, and allow you to use, communicate, and interact with others on our Site. This may include sharing information with third parties that provide us with services such as Site hosting, data analysis, payment processing, order fulfillment, infrastructure provision, information technology services, customer service, e-mail delivery services, credit card processing, auditing, training, and other similar services. These third parties may have access to Personal Information necessary to perform their functions but may not use it for other purposes.

Site and Marketing: We may use Aggregate Information to improve and enhance your experience on the Site and for our market research activities. For example, we may share Aggregate Information with unaffiliated third parties, such as business partners, site analytics vendors, manufacturers, distributors, and retailers, in an aggregate, anonymous form, which means that the shared information will not contain nor be linked to any Personal Information. We may also share your Personal Information with third-party service providers such as info@myaleph.com to improve our marketing and advertising activities.

As Necessary: We may disclose Personal Information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. Additionally, if we, or substantially all of our assets, were acquired by a third party, or if we go out of business or enter bankruptcy, user information will be considered an asset of ours and may be transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of user information may use your information per this Privacy Policy.

Mailing List: In order to maintain our mailing list, we may combine information you give us online along with information that is publicly available and/or provided by our third-party service providers or another company. We may also share your information with or lease information from other companies offering products or services that may be of interest to you. If you received our marketing materials and don’t know why, we may have received your information from another company. If you do not want to receive mailings or other marketing materials from us or if you do not want us to share your Personal Information with other companies, please contact info@myaleph.com

Distributors and Other Offers: We may at times share our customers’ email addresses with distributors, manufacturers, and/or other service providers that we believe will be of interest to the MyAleph audience. From time to time, we may give you the opportunity to opt-in to participate in special third-party offers that require us to share certain Personal Information with such third parties. We will disclose this anticipated sharing of Personal Information at the time we make such opportunities available to you. If you opt-in to participate in such an offer, we may disclose your Personal Information to such third parties for their direct marketing purposes. We recommend that you consult such third parties' privacy policies in advance if you wish to participate in these offers.

3. Data Retention Period: Data collected for the purposes outlined in section 1 will be retained by MyAleph for the time period necessary for the performance of a contract, with legal and conventional guarantees provided for, or in accordance with obligatory legal terms regarding the retention of data. Data collected for the purposes outlined in section 2 will be retained until the client revokes consent to process his/her personal data and in any event, with particular reference to data collected for the purposes outlined in section 2. When said consent is revoked or if the time limit for the retention of data collected for the purposes outlined in section 2 expires earlier, the data will be automatically erased or made permanently anonymous.

4. Email and Telephone Communications: We do use “browse abandon” and “cart abandon” tracking functions (if we have your email address and you visit our store, we will send you an email about the products you viewed or left in your cart). If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also contact you from time to time via telephone regarding customer service inquiries pertaining to your orders.

5. Cookies: “Cookies” are pieces of information that may be placed on your computer by a Site for the purpose of facilitating and enhancing your communication and interaction with that Site. We may use cookies to customize your visit to the Site and for other purposes to make your visit more convenient or to enable us to enhance our service. For example, cookies allow us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information. Cookies also allow us to keep track of items you add to your shopping cart. Many Sites use cookies for these purposes. There are several types of cookies, including, for example, browser cookies, session cookies, and persistent cookies. We use different types of cookies on our Site. We use cookies that allow customers and members to remain logged in to our Site, that keep track of items in your online shopping cart and user actions, and that recognize your Site preferences and user attributes. You may stop or restrict the placement of cookies on your computer or flush them from your browser by adjusting your web browser preferences, in which case you may still use our Site, but it may interfere with some of its functionality. We do not use cookies to retrieve personal information from your computer for purposes that are unrelated to the Site or your interaction with the Site.

6. Clickstream: As you use the Internet, a trail of electronic information is left at each Site you visit. This information, which is sometimes referred to as "clickstream data," can be collected and stored by a Site's server. Clickstream data can tell us the type of computer and browsing software you use and the address of the Site from which you linked to the Site. We may collect and use clickstream data as a form of Aggregate Information to anonymously determine how much time visitors spend on each page of our Site, how visitors navigate throughout the Site, and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Site and our services. Any collection or use of clickstream data will be anonymous and aggregate and will not intentionally contain any Personal Information.

7. Site Analytics: We may work with third-party service providers who use the technologies described in this section to conduct Site analytics to help us track and understand how visitors use our Site.

8. Security: The security of your Personal Information is very important to us. We attempt to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and MyAleph, or information stored on the Site or our servers, will be free from unauthorized access by third parties such as hackers, and your use of the Site demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Information. We store only the last four digits of your credit card number, and the full number, expiration date, and security code are transmitted to our payment processor in encrypted form. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with section 19 below.

9. Other Sites: Our Site may contain links to other Sites not maintained by MyAleph. Other Sites may also reference or link to our Site. The inclusion of a link on the Site does not imply endorsement of the linked Site by us. We are not responsible for the privacy practices of Sites operated by third parties that are linked to or integrated with our Site, nor for the privacy practices of third-party Internet advertising companies. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every Site that collects Personal Information.

10. Children’s Privacy: Protecting the privacy of children is especially important. Our Site is not directed to children under the age of 18, and we do not knowingly collect Personal Information from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Site at any time or in any manner. If we learn that Personal Information has been collected on the Site from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an account on the Site, then you may alert us at info@myaleph.com and request that we delete that child’s Personal Information from our systems.

11. Your California Privacy Rights: California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at info@myaleph.com

12. Changes to Privacy Policy: We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. When we make material changes to this Privacy Policy, we will provide you with notice as appropriate under the circumstances, such as by sending you an email or displaying a prominent notice on the Site. Your continued use of the Site following the posting of changes to this Privacy Policy constitutes your acceptance of such changes.

13. Contacting Us: If you have any questions about this Privacy Policy or our privacy practices, please contact us at info@myaleph.com.

14. Visitors From Outside The United States—Cross-Border Transfer: The Site is hosted in the United States. If you are visiting our Site from outside the United States, please refer to this Privacy Policy as other laws will apply. The European Commission has not determined that the United States ensures an adequate level of protection for Personal Information. The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and laws applicable in such jurisdictions. By providing us with Personal Information, you consent to the storage or processing of your Personal Information in the United States and acknowledge that the Personal Information will be subject to the laws of the United States, including the ability of governments, courts, or law enforcement or regulatory agencies of the United States to obtain disclosure of your Personal Information. By using the Site and/or providing personal data to us, you also consent to the transfer, storage, and processing of your information as described in this Privacy Policy. We will protect the privacy and security of Personal Information according to this Privacy Policy, regardless of where it is processed or stored.

15. General Data Protection Regulation (GDPR) Privacy Rights: Data Controller: MyAleph is the controller of your personal data provided to, or collected by or for, or processed in connection with, your use of the Site. Please see the “Cross-Border Transfer” section for more information about the transfer of your personal data to the United States or other countries.

Purposes of Processing and Legal Basis for Processing: If you are a resident of the European Economic Area (EEA), you have certain data protection rights. As explained above, we process Personal Information in various ways depending upon your use of our Site. We process Personal Information on the following bases: (1) with your consent; (2) as necessary to fulfill orders when you purchase products; and (3) as necessary for our legitimate interests in providing you with our products and services, enhancing our web services, conducting analytics, and delivering relevant advertising.

Your Rights Regarding Personal Information: The GDPR requires that we inform our EEA users about certain specific rights:

• The right to object, for legitimate purposes, to the processing of personal data.
• The right to request copies of your personal data held by us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
• The right to request that we delete or block your personal data without undue delay.
• The right to lodge a complaint with a supervisory authority.

Withdrawing Consent: If you wish to withdraw your consent, please contact us at info@myaleph.com. Please note that if you withdraw consent, we may not be able to provide or continue to provide certain services or marketing communications to you.

Objection and Requests for Copies: If you wish to:

• Object, for legitimate purposes, to the processing of personal data as provided under applicable law, or
• Request copies of your personal data held by us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible), please contact us at info@myaleph.com.

Requests for Deletion: If you wish to request that we delete your personal data, please contact us using the contact information detailed in section 19. We will promptly send you a response to ensure that the request was not made in error. We will respond to your request to delete your information within one month of receipt of your verification. Our response period may be extended by 60 additional days where necessary, taking into account the complexity and number of requests we receive. We may need to retain certain records, for example, those relating to open orders, payments, or customer service matters, for legal and accounting purposes.

EEA based individuals can learn more about their privacy rights and opt-out mechanisms at http://www.youronlinechoices.eu.

Lodging Complaints: You have the right to lodge a complaint about our data collection and processing actions with the supervisory authority in your country. For more information, please contact your local data protection authority in the EEA.

16. Existence of Automated Decision-Making: We may use automated decision-making processes to personalize the Site to enhance your shopping and consumer experience on our Site (for example, by recommending certain products to you) or, if you have opted into receiving promotional material from us, to send you personalized promotional emails. We do not believe any of these automated decision-making processes will produce legal effects concerning our users or similarly significantly affect our users.

17. Communications with MyAleph: By providing your email address to MyAleph, you expressly consent to receive emails from us. We may use email to communicate with you, to send information that you have requested, or to send information about other products or services developed or provided by us or by other third-party manufacturers, services, and/or distributors that MyAleph believes will be of interest to its audience. If you receive an unwanted email from us, you can simply reply and ask not to receive future emails. We also give you the option to remove your personal information from our list of active users completely. All unsubscribe or opt-out requests should be sent to us at info@myaleph.com, and we will process your request within a reasonable time after receipt. We are not responsible for removing your personal information from the lists of any third party who has been provided your information in accordance with this policy, such as a business partner.

18. Changes to the Privacy Policy: We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. When we make material changes to this Privacy Policy, we will provide you with notice as appropriate under the circumstances, such as by sending you an email or displaying a prominent notice on the Site. Your continued use of the Site following the posting of changes to this Privacy Policy constitutes your acceptance of such changes.

19. Contacting Us: If you have any questions about this Privacy Policy or our privacy practices, please contact us at info@myaleph.com. If you have any questions or comments about MyAleph or our products or have other customer service needs, please email info@myaleph.com for information on contacting our consumer service representatives.

This Privacy Policy was last updated on 6/16/23.