PRIVACY POLICY

Latest Update: October 8, 2021

Spence Diamonds Ltd. (“Spence Diamonds”) is committed to respecting your privacy through the protection of your personal information, as further described below. We want to provide you with value added service on an ongoing basis and to establish a long-lasting relationship with you that will grow and change to meet your needs.

Spence Diamonds’ privacy policy (“Privacy Policy”) applies to information collected, processed or stored by us, as further described below, including through our website spencediamonds.com (the “Website”).

The Website is intended for users in the legal age of jurisdiction in Canada. By providing personal information through the use of the Website, you understand and consent to the collection, maintenance, processing of such information within Canada.  Creating an account with false information is a violation of our Website Terms and Conditions.

Spence Diamonds may update this Privacy Policy from time to time. Please read the Privacy Policy carefully to understand our views and practices regarding your personal information and how we will treat it. If you do not agree with any part of this Privacy Policy or our Website Terms and Conditions, please do not use or access our services (the “Services”).

1. Objectives of this Privacy Policy

This Privacy Policy explains how Spence Diamonds Ltd (“Spence Diamonds”) will collect, use, and disclose your personal information – including when you:
• Use our websites or our mobile applications (collectively, the “Online Platforms”)
• Sign up to join our marketing lists and newsletters from Spence Diamonds
• Apply for an employment opportunity including a job
• Participate in Spence Diamonds’ activities, initiatives, games, contests, polls, forms and/or surveys
• Purchase a product(s)
• Use our social media channels or other engagement applications, including but not limited to Facebook, Instagram, etc.
• Communicate with us
(together, the “Purposes”).

The Privacy Policy aims to assist you in understanding how we collect, use, and safeguard the personal information that you provide to us and to assist you in making informed decisions when communicating with us and receiving news or related content from us.

2. What’s in this Privacy Policy?

This Privacy Policy covers the following topics:

• Privacy Statement Updates
  • Meaning of Personal Information
  • Personal Information We Collect
  • How We Use Your Personal Information
  • How We Share Your Personal Information
  • Opting Out of Communications
  • How We Use Certain Technologies
  • Links to External Services
  • Retention of Personal Information
  • Protecting Your Personal Information
  • Your Rights
  • Withdrawing Your Consent
  • How to Contact Us

3. Privacy Statement Updates

This Privacy Policy describes the way that Spence Diamonds will, subject to applicable legal requirements, adhere to all relevant federal and provincial legislative privacy requirements. This Privacy Policy may be updated or modified from time to time by Spence Diamonds to account for the introduction of new technologies, business practices, stakeholder needs and applicable laws and regulations.

4. What is Personal Information?

Personal information is information about an identifiable individual and could include, for example, name, home address, phone number, personal e-mail address or other personal information about such identifiable individual.

5. What Personal Information Do We Collect?

Form of Consent

Generally, we obtain your consent to collect, use or disclose personal information. Consent can be provided electronically or it can be implied where the purpose for collecting, using or disclosing your personal information would be considered obvious and you voluntarily provide personal information for that purpose. Consent may also be implied where we give you notice and a reasonable opportunity to opt-out of having your personal information being used, and you do not opt-out. Subject to certain , you can withhold your consent for Spence Diamonds to use your personal information in certain ways – and you can do so by contacting us at [email protected]. Your decision to withhold your consent to certain uses of personal information may restrict our ability to provide particular Purposes, services or functionality.

Categories of Personal Information that We May Collect

• Electronic and Geolocation Data: When you visit our Online Platforms, we may collect information such as your IP address, device type, time zone, and geolocation (if this function is enabled). This information is collected automatically through cookies and similar tools to enable our Online Platforms to function effectively, to fix bugs, or to ensure the security of our Online Platforms. Please refer to section 11 for more information about cookies.
• Usage and Analytics Data: We collect information such as time spent on the Online Platforms, pages visited, links clicked, language preferences, and pages that led or referred you to the Online Platforms. We collect this information to understand Online Platform usage, whether there are bugs, and to generally improve our Online Platforms. Please refer to section 11 for more information about cookies.
• Communication Data: The Online Platforms may allow you to provide us with your e-mail address, location, and language of preference, so we may send you information and updates about Spence Diamonds. For individuals who otherwise interact with us, whether in person, by phone or e-mail, through social media or otherwise (including individuals who might be interested in acquiring our products or services, who sign-up to receive newsletters or other communications, or who respond to surveys and questionnaires), we may collect information that you provide to us during these interactions.
• Newsletter and Marketing Data: If you subscribe to receive our newsletter from our Online Platforms, we collect your first and last names, e-mail and location. We also collect information through cookies to conduct targeted advertising on social media platforms.
• Employment Application:  If you apply for a position of employment, we may collect information to evaluate your application, including your name, contact information, resume and cover letter.
• Contests: From time to time, Spence Diamonds may run co-sponsored promotional contests, content, programs and initiatives. If you provide a completed registration form or otherwise engage with any of our co-sponsored content, programs, or initiatives, we may disclose the information that you disclosed to us, including your name, address and e-mail address to the applicable co-sponsor for the purposes of fulfilling your prize. Additionally, activities of participants may be photographed, distributed, and used by Spence Diamonds for promotional purposes in any medium or form and without any compensation.

If you enter a contest including our Online Platforms, or via a third-party partner or contest co-sponsor we may collect your name, contact information, and other information as part of the contest to administer the contest and for other purposes that may be identified in the contest rules.

• Social Media Data: Spence Diamonds may use social media as an extension of its presence on the web. Social media accounts of Spence Diamonds are public and are not hosted on Spence Diamond’s servers. Before engaging with us on social media platforms, we recommend that you read the privacy policies of these third-party service providers and those of any applications that you use to access them. Information obtained from those third-party services depends on your settings and privacy policies for such third-party platforms and accounts, which are not controlled by Spence Diamonds and are not subject to our current Privacy Policy. We strongly recommend that you check your privacy settings on such third-party platforms and understand the terms of applicable third-party privacy policies.

6. How Do We Use Your Personal Information?

Some of the purposes for which Spence Diamonds may collect, use, and disclose your personal information are:

• To facilitate communication with you
• To grant you/enable you to access certain special features, services or areas of our Online Platforms
• To process any of your requests for information
• To advise and administer of special promotions such as participation in contests, content, programs, initiatives, games, surveys, forms, and polling
• To administer the “Share or Hint” function of our Online Platforms to e-mail an item to a friend
• To announce special events
• To provide an enhanced user experience

By signing up to take part in programs or initiatives that we may initiate, or to receive online and/or e-mail communications, we may use the information that you provide to operate and facilitate such programs, initiatives and communications.

7. Who Do We Share Your Personal Information With?

To administer services and operations, certain personal information may be shared with, or accessed by, authorized third-party service providers, such as e-commerce providers, payment card processers, telephone and technical support providers, data storage and processing service providers. Your personal information will be provided to such third-party service providers only to enable the proper administration of such services and operations.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, 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 the terms of the agreements for our products and services; (e) to protect our rights, operations or property; and (f) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

9. How Can You Opt-Out of Our Marketing Communications?

Spence Diamonds is committed to meet the requirements of Canada’s Anti-Spam Legislation, including through any commercial electronic messages sent by the Spence Diamonds to you and/or your friend. You may “Unsubscribe” from receiving any such applicable communications from Spence Diamonds at any time and your electronic address will be removed from our databases. Please click on a Spence Diamonds delivered email to your inbox and click “Unsubscribe” at any time.

10. Personal Information of Children

Spence Diamonds is strongly committed to protecting the online privacy of children under the age of 18. Parents and legal guardians are strongly recommended to monitor the use of the internet by their children.

11. How Do We Use Certain Technologies in Our Services?

What technologies do we use?

Similar to many other companies, our website uses cookie technology to make your use of our website more convenient. A cookie is a text file that enables our website to store information about your general activities on the website, such as the date and time of visits, pages viewed, time spent, and websites visited just before and just after our website. Personal information about your visits to, and use of, the website is used on an aggregate basis, which means that it is used for statistical purposes to assist us in enhancing your online experience, or to evaluate the materials that we may carry on the website, it is done in aggregate with all web visits not in isolation of your specific web visit. Notably, we use Google Analytics, which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the collected data to track and monitor the use of our services. This data is shared with other Google services. In addition, the cookie will store your e-mail address, which is your unique identifier, so that, on return visits, the website will be able to match you to your identity in the database. This is an opt-in feature that will only be made operational if you choose to do so. Web beacons (also called “clear GIFs” or “pixel tags”), which are small strings of code that are placed in a web page or in an e-mail message, may be used in conjunction with cookies to track activity on our website. Since they are used in combination with cookies, if you disable cookies, the web beacons will only detect an anonymous website visit.

Do we use cookies for targeted advertising?

Our Online Platforms may also use services to advertise on third-party websites to previous visitors to our Online Platforms (e.g. Google AdWords, Facebook Conversion Pixel, and Twitter remarketing). Third-party vendors use cookies to serve ads based on someone’s past visits to our Online Platforms. For example, after browsing our website, you may receive related ads on Facebook. This is known as interest-based advertising. In such a case, any data collected by Spence Diamonds will be used in accordance with this Privacy Policy and, for those other platforms, through their respective privacy policies.

How you can manage your cookie preferences

If you choose to disable cookies associated with our Online Platforms, this may affect your use of those platforms and your ability to access certain features. You can also use WebChoices, which is a browser-based tool for opting out of interest-based advertising. AdChoices provides additional solutions and explanations to block and control cookies, as well as plug-ins to retain opt-out cookie preferences, even if you delete your cookies. Depending on the browser that you are using, different instructions are applicable. In the list below, click on the browser that you use to find out more information:

Google Chrome
Firefox
Safari
Microsoft Edge 

12. Links to Other Sites

Our website may contain links to other websites, applications or digital products that are not operated by Spence Diamonds. Spence Diamonds has no responsibility for, control over, or liability for those websites or internet resources, or their collection, use, and disclosure of your personal information. We recommend that you refer to the privacy policy and terms of use contained in any linked site that you choose to go to and that you familiarize yourself with that website’s terms and conditions of use.

13. How Long Do We Retain Your Personal Information?

Spence Diamonds will retain your personal information only for as long as it is necessary to fulfill the identified purposes, or a legal or business purpose in accordance with this Privacy Policy.

14. How Do We Protect Your Personal Information?

Spence Diamonds endeavour to maintain appropriate procedural and technological measures as well as storage facilities to prevent any unauthorized use or disclosure of your personal information. Spence Diamonds takes commercially reasonable efforts to protect any personal information that is provided to it. We cannot, however, guarantee the security of any personal information that is provided to us in an e-mail or in online form while it is being transmitted to us because the internet is a potentially unsecure method of information transfer. Any such transmission is at your own risk.

15. What Are Your Rights Regarding Your Personal Information?

The law provides you with rights over your personal information, notably the right to access and rectify the personal information that we have on you if it is incorrect, incomplete, invalid or ambiguous.

Request to Access

If you have any questions about :

• collection, use, or disclosure of your personal information by Spence Diamonds or
• if you simply want to know whether we have any of your personal information on file or
• if you want to access information that we have collected about you

you may reach us at [email protected] and we will respond to your requests for access in accordance with applicable privacy legislation and this Privacy Policy. In the event that we refuse access to you, reasons for our refusal will be provided upon your request. For example, your request could be refused because it may include information about other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

Request to Correct

We will make reasonable efforts to ensure that your personal information is accurate and complete. You may request corrections or changes to your personal information in order to ensure its accuracy and completeness. A request to correct your personal information must be sent by email to [email protected] and provide sufficient detail to identify the personal information and achieve the correction being sought. If such personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any third party to which we may have disclosed the personal information previously in accordance with this Privacy Policy.

16. How to Withdraw Your Consent to the Use and Disclosure of Your Personal Information?

At any time you may withdraw your consent to our use and disclosure of certain personal information by notifying us in writing through . Please note that your withdrawal request may take up to 30 days to implement. Also note that withdrawing your consent may preclude us from providing you with certain information or may prevent your use of certain features and functionalities of our Online Platforms or other Purposes.

17. Questions or Concerns

If you have any questions or concerns regarding our collection, use, and disclosure of your personal information or about this Privacy Policy, you may contact our Privacy Officer at the following e-mail address: [email protected]