Privacy Policy

Royal Age Platform Privacy Policy

Last Revised: April 20, 2020

SHI Sapphire Holdings International (Royal Age) Inc. (“Royal Age”, “Company”, “we” or “us”) respects the privacy of the users of its Platform (available at [LINK TO PLATFORM]) (“User” or “you”) and is committed to protecting the personal information that its Users share with it. We believe that you have a right to know our practices regarding the information we may collect, process and use when you use our Platform.  

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in the TOU, to which this Privacy Policy is incorporated by reference.

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email to [customer support email] (the “Support Email”) and we will make an effort to reply within a reasonable timeframe.

 

  • Your Consent (PLEASE READ CAREFULLY!)

 

BY ENTERING INTO, CONNECTING TO, ACCESSING AND/OR USING THE PLATFORM, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY”), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS AND/OR USE THE PLATFORM.  

FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US.

 

  • Which information we may collect on our Users?

 

We may collect two types of data and information from our Users:

    1. The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from which we have collected Non-personal Information. Non-Personal Information is any unconcealed information which is available to us automatically while Users are using the Platform. Non-personal Information which is being gathered consists of technical information and behavioral information, including, but not limited to, the User’s operating system, type of browser, screen resolution, browser and keyboard language, Flash version, the User’s ‘click-stream’, the activities of the User on the Platform (such as purchase of Products), the period of time the User visited the Platform, etc.
    2. The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature. Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User.
  • Users of the Platform automatically provide their IP address (or Mac Address, if applicable) mainly for enhancing the User’s experience and for geolocation and security purposes as well as other identifiers assigned to their devices and/or web-browsers, such as Identifier for Advertising (IDFA). 

  • The Personal Information is collected from the details the User provides when opening an Account, which consist of the User’s full name, e-mail address, mobile phone-number and shipping address. 

  • Personal Information may be collected from the details the User may provide us while contacting us via the Support Email.

  • In order to facilitate payments via Online Payment Processors (e.g. Paypal or Stripe), you will be required to provide a credit card number and other related billing information. We will not store such information on our servers, and it will be kept with the applicable Online Payment Processor. We only keep token information that such Online Payment Processors provide us with, and such information is strictly secured.

We will not collect any Personal Information from you without your approval which is obtained, inter alia, through your active acceptance to the TOU and the Privacy Policy. 

 

  • How Do We Collect Information on Our Users? 

 

There are two main methods we use: 

      1. We collect Non-personal Information through your use of the Platform. In other words, when you are using the Platform we are aware of it and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below.

      2. We collect Personal Information which you provide us voluntarily. We collect Personal Information required to operate the Platform when you register and open a User Account by completing our registration form, and when you purchase Products via your Account.

 

  • What are the Purposes of the Collection of Information? 

 

Non-personal Information is collected in order to:   

  • Enhance the User experience on the Platform;
  • Create statistical information and learn about the preferences of Users and general trends on the Platform (e.g. understand which Products are more popular than others); 
  • Keep the Platform secured and for prevention of fraud; and
  • Improve, develop and upgrade the Platform and our services.

Personal Information is collected in order to:   

  • Verify the User’s identity when s/he signs in to the Account;
  • Enable the operation of the Platform, including the purchase of Products, and to advise the Suppliers to which address to deliver these Products;
  • Be able to contact Users for the purpose of providing them with technical assistance and collect feedback regarding the Platform and/or the Products;
  • Allow us to contact Users with proposals and tailored information regarding our products, events, offers, services, features, enhancements, special offers, upgrade opportunities, and events of interest etc. (including by way of newsletter);
  • Keep the Platform safe and secured and for prevention of fraud;
  • Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Platform; and
  • Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails. 
  • Determine general geolocation information (i.e., country) from which the User’s computer is connected to the Internet in order for us to know the general location of our Platform’s Users as well as in order to safeguard our Platform.
  • Enable payment through third party Online Payment Processors. As mentioned above, we do not collect and store credit card or other financial information.
  • Provide Users with updates concerning the status of their Product order.
  • Provide Users with updated information regarding our offerings and new services.

 

  • Sharing Information with Third Parties

 

In the event a User purchases Products via our Platform, Royal Age will share with the applicable Supplier the name, phone and shipping address of the User, in order to allow the Supplier to deliver the Products to the User and/or provide services related to the Products.

Additionally, Royal Age may disclose Personal Information to a third party only in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User’s support requests; (e) to respond to claims that any content available on the Platform violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of Royal Age, its Users, or the general public; (h) when Royal Age is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (i) to collect, hold and/or manage your Personal Information through Royal Age’s authorized third party service providers (for example, [Amazon] cloud services), as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (j) to enable payment through Online Payment Processors; (k) pursuant to your explicit approval prior to the disclosure; or (l) cooperate with third parties for the purpose of enhancing the User’s experience. 

For avoidance of doubt, Royal Age may transfer and disclose Non-personal Information to third parties at its own discretion. 

 

  • Advertisements 

 

Users may receive advertisements and commercials from third party advertisers and/or our authorized service providers and/or vendors. By clicking the advertisements or commercials you may be transferred to a website of an advertiser or receive any other messages, information or offers from the advertiser and/or from others. Note that if you click on any of these advertisements, these advertisers may use Local Storage including without limitation cookies and other web-tracking technologies (such as tracking pixel agent or visitor identification technology, etc.) to collect data regarding advertisement performance, your interaction with such ads and our Platform and your interests (which may include, non-personal and/or Personal Information (such as, device and network information, unique identifiers, gender, age and location) about you) in order to serve you advertisements and for the legitimate business interests of such third parties ad networks. We recommend that you review the terms of use and privacy policy of any advertiser with which you are interacting before doing so. Their privacy policy, not ours, will apply to any of those interactions.

All the information contained in such advertisements and commercials belongs solely to the advertisers and the Company makes no warranties or representations in respect of such, whether or not the Company has control over such advertisements or commercials and these are provided on an “AS IS” basis. In any event, the Company will not be liable for any damage or loss incurred to you as a result of or in connection with such advertisements or commercials. The Company, advertisers and/or related third-parties may be entitled to certain shares of the earnings for such advertisements and/or commercials. You agree, acknowledge and consent that no right, title or interest is or shall be granted to you in any way with respect to any revenue share whatsoever in relation thereto.

 

  • Modification or Deletion of Personal Information

 

If for any reason you wish to modify, update and/or revise your Personal Information you may do so in the settings of your Account. In order to delete your Personal Information completely please send us your request to our Support Email and we will make reasonable efforts to delete any such Personal Information pursuant to any applicable privacy laws. 

Note that unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, all as permitted under any applicable privacy laws.

Aggregated and/or anonymous information derived from your use of Platform may remain on our servers indefinitely.

 

  • Cookies & Local Storage

 

When you access or use the Platform, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools or technologies which store certain local information on your device (“Local Storage”) which may enable us, inter alia, to recognize your device from those of other Users of the Platform, to improve the Platform’s performance, to deliver a better and more personalized service according to the User’s individual interests and the device or browser used, to track Users’ use of the Platform, to gather information about the Users’ approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics, to develop our Platform and to serve targeted advertisements.  

Such information is locally stored in the User’s device. We and/or our authorized third party service providers may access such information. We and/or our authorized third party service providers may use both session cookies (which expire once you close the web-browser) and persistent cookies (which stay on the User’s device until s/he deletes them). Such Local Storage used by the Platform may store non-personal information (such as the different pages viewed by a User within the Platform) as well as User persistent identifier, which will be collected in accordance with the terms specified herein. 

Most devices and browsers will allow you to erase cookies from your device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, your experience of the Platform may be limited. Please note that unless you block the acceptance of cookies, the Platform will utilize cookies upon your use of the Platform. If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the Platform from placing further cookies on your device unless and until you adjust your settings as described above.  For detailed instructions regarding the blocking of cookies, please refer to your browser ‘help’, ‘tool’ or ‘edit’ section or see http://www.allaboutcookies.org/manage-cookies. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers:

It is possible to opt-out of having your browsing activity within the Platform recorded by performance cookies. Please note that we use Google Analytics, as our service provider in order to track Users’ activities on the Platform, including by use such services’ persistent cookies. Google provides a browser add-on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout. 

 

  • International Data Transfer 

 

In order to provide the Platform, we may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.

 

  • Direct Marketing 

 

You hereby agree that we may use the contact details you provided us with (including, without limitation, e-mail address) for the purpose of providing you commercial and/or non-commercial materials related to our current and/or future products and services. You may withdraw your consent by sending a written notice to our Support Email, or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you. 

 

  • Security 

 

We take a great care in implementing and maintaining the security of our Platform and our Users’ Personal Information. The Personal Information is hosted on [AWS] which provides advanced security features. Royal Age employs industry standard procedures to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information.  Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. ROYAL AGE SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.    

 

  • Third Party Software/Service 

 

While using the Platform we may be using third party software and/or service, in order to collect and/or process the information detailed herein. Such software includes without limitation, Google Analytics, which privacy policy is available at http://www.google.com/intl/en/analytics/privacyoverview.html and Amazon cloud services which privacy policy is available at: http://aws.amazon.com/privacy/. Please read such third party service providers’ terms of use and privacy policies to understand their privacy practices. 

 

  • Third Party Websites

 

While using the Platform you may encounter links to third party websites. Please be advised that such third party websites are independent from the Platform, and we assume no responsibility or liability whatsoever with regards to privacy matters or any other legal matter with respect to such third party websites. We encourage you to carefully read the privacy policies and the terms of use of such websites.

 

  • Minors

 

The Platform is intended for Users over the age of sixteen (16). Therefore, Royal Age does not intend and does not knowingly collect Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Platform. If we learn that we collected Personal Information from children under the age of sixteen (16) we will delete that information as quickly as possible. Please contact our Support Email if you have reasons to suspect that we collected Personal Information from children under the age of sixteen (16) and will delete that information as quickly as possible.

 

  • Changes to the Privacy Policy 

 

The terms of this Privacy Policy will govern the use of the Platform and any information collected therein. Royal Age reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the Platform and/or we will send you an e-mail regarding such changes to the e-mail address that you provided in the registration form. Such substantial changes will take effect seven (7) days after such notice was provided on our website or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Platform after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.



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