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PRIVACY POLICY

Effective Date: January 31, 2020

Robbins Brothers Jewelry, Inc. ("Robbins Brothers") is strongly committed to your right to privacy and takes steps designed to secure the privacy of the personal information we obtain. The intent of this privacy policy ("Privacy Policy") is to fully disclose our privacy practices to you. We will only use your personal information obtained through our Services in accordance with this Privacy Policy. We encourage you to read our Privacy Policy to understand the types of information we collect and how this information is used.

This Privacy Policy applies to all personal information collected about you when you do any of the following (collectively, the “Services”): (i) visit Robbins Brothers stores, (ii) communicate with us during any written, electronic, and oral communications, or (iii) access or use our website currently located at https://www.robbinsbrothers.com (the "Site"), features or content owned or operated by Robbins Brothers that link to this Policy.

Use of this Site is subject to our Terms of Use, which you can view here: https://www.robbinsbrothers.com/terms-conditions (“Terms of Use”) and this Policy. Please read the Terms of Use and this Privacy Policy carefully before you use our Services. By using our Services, you consent to the collection and use of your information as described in our Terms of Use and this Privacy Policy. If you do not agree with our Terms of Use and this Privacy Policy, please do not use our Services.

We reserve the right to change, add or remove all or part of our Privacy Policy at any time. Any changes to our Privacy Policy will be reflected on this page so that you are always aware of the information we collect and how we use it. Your continued use of our Services following the posting of changes to this Privacy Policy means you accept such changes. Any material changes in the way we use personal information will be described in future versions of this Privacy Policy. Of course, you may always submit concerns regarding our Privacy Policy or our privacy practices by using our Contact Form. We will attempt to respond to all reasonable concerns or inquiries within two business days of receipt.

As part of this Privacy Policy, we address the following:

  • • PERSONAL INFORMATION WE COLLECT
  • • COOKIES AND OTHER TRACKING TECHNOLOGIES
  • • HOW WE USE YOUR PERSONAL INFORMATION
  • • SHARING AND DISCLOSURE OF PERSONAL INFORMATION
  • • OUR SECURITY MEASURES
  • • THIRD-PARTY WEBSITES
  • • INFORMATION ABOUT MINORS
  • • YOUR CHOICES
  • • CALIFORNIA PRIVACY RIGHTS
  • • CONTACT US

1. PERSONAL INFORMATION WE COLLECT

In general, you can use our Services without telling us who you are or revealing any personal information about yourself. Personal information means any information that may be used to identify an individual including, but not limited to, name, personal or billing address, email address, phone number, credit card or debit card information, age and any other information that itself identifies or, when tied to the above information, may identify you as a specific individual. In certain jurisdictions, Internet Protocol (IP) address or unique device identification numbers may be considered personal information. We also collect browser and session data, IP addresses and/or unique device identification numbers, depending on the type of browser or device that you use to access our Site.

a) Information You Provide to Us

We collect information you give us in the following ways:

• Order-Related Information – Robbins Brothers collects personal information when you place an order for the purchase of products on the Site or in one of our stores. Personal information we collect when you place an order is used to confirm and process your order, detect and prevent credit fraud or identity theft, provide you with information regarding your order, respond to your requests regarding your order, and to contact you if necessary.

• Your Requests – We also collect personal information through the Site to respond to your requests for information. Robbins Brothers uses online forms on which you are asked to provide your contact information. This information is used to respond to your requests for certain information regarding us and our products and services.

• Site Registration – We ask you to register before allowing you to use certain features of our Site, such as our wish list and contact form. As part of the registration process, we may ask you to provide information, such as your name, address, phone number, email address, wedding date or dates of other special occasions. Registration information is needed to track and verify compliance with the Terms of Use applicable to the Site, as well as with federal, state and local laws.

• Online Resources and Features – We collect personal information to allow you to use certain resources and online services available on our Site, including, for instance, to create and maintain wish lists, gift registries and personalized websites. Through this Site, you may provide information related to your wedding or special occasion, including dates and places of the rehearsal, wedding and reception, name, address and phone number of wedding guests, and information relating to your gift registry and honeymoon.

• Marketing Communication – We may also use personal information we collect through the Site to tailor your experience at our Site, to show you content that we think you might be interested in, and to display the content according to your preferences. We may use your contact information to send you information and promotional materials about us and some of our partners (unless you choose not to receive such communications as described below).

• Contests – Robbins Brothers will periodically sponsor contests to give you the opportunity to win prizes. Your participation in these contests is entirely optional. Information we collect for such contests can include contact information and demographic information.

• Online Surveys – Robbins Brothers values the opinions and comments from all of our users, so we frequently conduct surveys. Your participation in these surveys is entirely optional. Information we collect in online surveys will include general information on the use of our site and other demographic information, such as age and income bracket. Survey participants are anonymous unless otherwise stated in the survey.

b) Information About Your Use of Our Services

We may collect information about your use of the Services. For example, we may collect:

• Device information – When you connect to our Site, we record information concerning your use of the Site, such as the name of your Internet service provider, your IP addresses, your hardware model, other unique device identifiers, information on the type of operating system (e.g., Windows Vista) and browser software (e.g., Microsoft Internet Explorer and Mozilla Firefox) you are using, and the Internet address of any referring website and the Internet address of the website from which you linked directly to our Site. We use such information for diagnostic and statistical purposes and to administer the Site.

• Usage Information – Site usage information, such as the time you access the Site, regarding traffic patterns and Site usage. This information is used to analyze and improve this Site and to provide Robbins Brothers customers with a better user experience.

• Cookies – We may also use “cookies” to store your preferences to make your use of the Site more productive. Please see the next section to learn more about our usage of the cookies and other tracking technologies.

2. COOKIES AND OTHER TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to track your activity on our Services. Cookies are small pieces of information that are stored by your browser on your computer's hard drive. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.

a) How We Use Cookies

Generally, we use first-party and third-party cookies for the following purposes: to support and improve the Site, to diagnose problems with our servers and for system administration, to send you communications about Robbins Brothers, its products and services, and those of its partners, to help gather aggregated demographic information, to better understand how you go through our Site so that we may tailor your experience at our Site, to understand whether you have visited our Site previously, to help us determine whether you came to our Site from a particular Internet link or banner advertisement, and to help you save and retrieve passwords and other information and preferences you use on our Site.

Cookies cannot and will not be used by us to retrieve any personal information about you from your computer that you have not previously and voluntarily provided to us. However, cookies may also be received when you link to our partners' sites, and we do not have control over how they use this information.

b) Types of Cookies on Our Services

We use the following types of cookies on our Services:

• Strictly Necessary Cookies – These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.

• Functional Cookies – We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.

• Performance or Analytic Cookies – These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies.

• Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.

c) Google Analytics

Robbins Brothers uses Google Analytics to collect information about the effectiveness of our Services. Google Analytics uses "cookies", text files stored on your computer, to learn about how people use our Site. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service: http://www.google.com/analytics/terms/us.html/ and the Google Privacy: http://www.google.com/policies/privacy/. You can learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You can prevent your information from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

d) Other Tracking Technologies

To see how our Site is performing we sometimes use conversion pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page (e.g. a thank you page once you have completed the procedure for subscribing to one of our services or have completed one of our forms). We also use web pixels to analyze usage patterns on our Site. The use of a pixel allows us to record that a particular device, browser, or application has visited a particular webpage.

e) Your Choices

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. However, some of the features on our Site will not function if you do not accept cookies. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below:

• First-Party Cookies - You can enable, disable or delete our cookies through the browser you are using to access our Services. To do this, follow the instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of our Services and parts of the Services may not work properly for you. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.

• Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers.

• Targeted Advertising. You can also opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://optout.aboutads.info/) or the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1). In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads.

f) Do Not Track

Some browsers have incorporated Do Not Track (“DNT”) preferences, but our Services do not respond to DNT signals at this time because we do not track your activities across the internet and off of our Services.

3. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal information as described in this Privacy Policy or as disclosed to you prior to such processing taking place.

a) To Provide You Our Services

We will use your personal information to provide information or perform Services that you request. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable information to the third party providing the information or performing applicable Services. Your information may be available or provided to third-party service providers and contractors (such as the Site webmaster) that are contractually obligated to protect your information as disclosed in this Privacy Policy.

b) For Internal Use

We will use your personal information for the purposes of furthering our business, including analyzing your information and other uses. We may monitor how our users use our Site including without limitation search terms entered, pages visited and documents viewed. This information may be stored with an IP address. This information is used solely for purposes of enabling us to provide you with a personalized Site experience. Aggregated forms of this data may also be used for research purposes in order to develop new products and identify future features and functions to develop for the Site.

c) To Provide You with Service-Related Communications

We will send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information about policy updates, confirmations of your account actions or transactions, security updates or tips or other relevant transaction-related information. We process your contact information to send you such communications. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services.

d) To Provide Customer Support or Respond to You

We collect any information that you provide to us when you contact us, such as with questions, concerns, feedback, disputes or issues. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.

e) To Enforce Compliance with Our Terms and Agreements or Policies

When you access or use our Services, you are bound to our Terms of Use and this Privacy Policy. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. We also process your personal information to: investigate, prevent or mitigate violations of our internal terms, agreements or policies; enforce our agreements with third parties and business partners; and, as applicable, collect fees based on your use of our Services. We cannot perform our Services in accordance with our terms, agreements or policies without processing your personal information for such purposes.

f) To Ensure the Security of the Services

We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information. We cannot ensure the security of our Services if we do not process your personal information for security purposes.

g) To Maintain Legal and Regulatory Compliance

Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws or as necessary to manage risk as required under applicable law. Without processing your personal information for such purposes, we cannot perform the Services in accordance with our legal and regulatory requirements.

h) To Engage in Marketing Activities

Marketing lets us grow our community and update you about new products and services. We process your contact information or information about your interactions on our Services to: send you marketing communications and keep you updated about our products and services; provide you with information about events, training sessions or other materials; and deliver targeted marketing to you. See Cookies and Other Tracking Technologies section of this Policy for more information about tracking techniques we use for our marketing campaigns).

4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

a) Service Providers

We may provide your personal information, including financial information, to our service providers, subcontractors or agents in order for them to perform their services on our behalf. These services may include, but are not necessarily limited to, digital marketing optimization, image management, credit or debit card processing, order processing and fulfillment, credit verification and credit fraud protection, market research and promotions management. We only provide your personal information to the extent relevant to the services being provided by each such service provider. Each provider is required to protect confidential information received on behalf of Robbins Brothers, and is obligated to use your personal information only for the purpose of providing Site services or as otherwise consistent with this Privacy Policy.

b) Our Business Partners

We may make personal information (excluding credit card information) available to our business partners whose products or service we think may interest you. If you do not wish to receive such promotional communications from our business partners, see "The choices you have about the use of your information" below.

c) Third Parties

We may share anonymized and non-personal information (such as cookies, IP addresses and aggregated information) with third parties who are not our service providers, including for example, for marketing and promotional purposes, but this information will not be shared along with your personal information or in a manner that would personally identify you.

d) Mergers and Acquisitions

Robbins Brothers may disclose the information obtained through our Services as part of a merger, acquisition or other sale of its assets or business. Robbins Brothers will use commercially reasonable efforts to notify you (which you agree may consist solely of a posting on the Site) in the event information about you is transferred and becomes subject to a different privacy policy.

e) To Maintain Legal and Regulatory Compliance

We may disclose your information if required to do so by law, court order, as requested by other government or law enforcement authorities, or in the good faith belief that disclosure is otherwise necessary or advisable, including (without limitation) when we have reason to believe that disclosing the information is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

i) Public Postings to the Site

In various locations of the Site, you may publicly post videos, pictures and information about you, your engagement, wedding or honeymoon, and other personal information about yourself. Please remember that any information that you choose to post on the Site becomes public information and is not governed by this Privacy Policy. This public information may be collected and otherwise used by others. You should exercise caution when deciding to publicly disclose your personal information.

5. OUR SECURITY MEASURES

Robbins Brothers uses commercially reasonable physical, electronic and managerial procedures to maintain the confidentiality of the personal information we collect online. Our Site and servers are protected using standard industry practice. We review and update web security and security procedures regularly.

Personal information you provide to us when registering on the Site or when placing orders through the Site is transmitted using SSL (Secure Socket Layer) encryption. SSL is a widely used coding system that lets your browser automatically encrypt or scramble data before you send it to us. Registrations and purchases will not be permitted if your browser does not accept SSL encryption. Only authorized personnel from Robbins Brothers and its service providers can decode this information and such personnel will only do so in accordance with our or their Privacy Policy.

You may also have choices to limit third party access to your personal information. When you register for certain online services, you may have the opportunity to restrict third party access to personal information you disclose as part of such online service. For instance, if you register for online registry, you may select whether you wish to make your online registry available to your guests via a password. If you do not elect to make your registry available only via password (or if you create a registry that does not provide this option), anyone visiting our website will be able to search for your registry or other online services by using first and/or last names and wedding dates (and on some pages, city or state).

Despite the security measures we take to protect your information, please be aware that the security of communications sent over the Internet, including email, is subject to many factors outside of Robbins Brothers' control and that no data transmission over the Internet can be guaranteed to be 100% secure. Robbins Brothers does not guarantee that the personal information you submit to us will be free from unauthorized third-party intrusion.

6. THIRD-PARTY WEBSITES

Please be aware that on our Site we may have advertisements and links to other websites that may collect personal information about you. This Privacy Policy does not cover the information practices or policies of such websites. We are not responsible for the privacy practices of third party sites. We encourage you to read the privacy policies of all such sites, as their policies may be materially different from our Privacy Policy. This Privacy Policy applies solely to information collected by Robbins Brothers.

7. INFORMATION ABOUT MINORS

This Site is a general audience Site. Robbins Brothers’ content is neither directed toward minors nor children who are under the age of 18. We do not knowingly collect personal information from children under the age of 18 without parental consent. If Robbins Brothers’ or its Internet service providers become aware that a minor or a child under the age of 18 has provided us with personal information without the parental consent, that information will be deleted from our databases. Parents who have questions about personal information that may have been submitted by a child under the age of 18 should email us at privacy@robbinsbrothers.com.

8. YOUR CHOICES

We provide you the following rights:

a) Opt-Out

As a user, customer, or contest entrant you will occasionally receive email updates from us about material changes to our Site, special offers from us and our business partners, new Robbins Brothers services and other noteworthy news items about us and our business partners. We hope you will find these updates interesting and informative. Of course, if you would rather not receive them, use the "Remove" link in the email or follow any other specific instructions in the email. Our Site also provides you the opportunity to opt-out of receiving such communications from us by emailing privacy@robbinsbrothers.com . In other words, if you don't want us or our partners to send you emails about our or their business, just let us know. However, Robbins Brothers reserves the right to limit registration to the Site to those who will accept emails and to those who will provide the requested information. Also, we may continue to contact you via email or other means for marketing, administrative or informational purposes regarding any orders you place or other transactions you conduct through the website.

b) Deletion, Access and Rectification

At any time, you can delete, view and/or update your personal profile information contained in your account(s) on the Site by emailing privacy@robbinsbrothers.com . However, even if you request that we delete or change some personal information in our registration database, it may still be stored on our, or other third-party databases (including those kept for archival purposes).

9. CALIFORNIA PRIVACY RIGHTS

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the Personal Information categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we process (“Personal Information”) about your when you use our Services:

• identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;

• protected classifications, such as gender;

• commercial information such as records of products or services purchased, obtained, or considered by you;

• Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;

• your geolocation, to the extent you have configured your device to permit us to collect such information;

• audio recordings of your voice to the extent you call us, as permitted under applicable law; and

• inferences about your preferences, characteristics, behavior and attitudes.

We generally do not collect biometric, employment or education-related information. For more information about the Personal Information we collect and how we collect it, please refer to sections 1 and 2 above.

We collect your Personal Information for the business purposes described in sections 2 and 3. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.

The following activities are considered “business purposes” under the CCPA: auditing related to a current interaction with the consumer and concurrent transactions, and auditing compliance with laws and other standards; detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, verifying customer information; repairing errors that impair existing intended functionality; Internal research for technological development; verifying or maintaining the quality or safety of, and improving, upgrading, or enhancing, a service or device that is owned, manufactured by, manufactured for, or controlled by the company.

The categories of third parties with whom we may share your Personal Information are listed in section 4 above.

Privacy Rights

If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our network systems. To assert your right to know or your right to delete your Personal Information, please contact us at privacy@robbinsbrothers.com or by phone at (800) 821-7689 . To verify your identity, we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

• Right Against Discrimination – You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.

• Right to Know – You have the right to request in writing: (i) the categories of personal information we have collected about you, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual. You have the right to request a copy of the specific Personal Information we collected about you during the 12 months before your request.

• Right to Delete – You have the right to request us delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.

• Right to Opt-Out of Selling – If you are a California resident, you have the right to opt out of the “sale” of your personal information to “third parties.” Sale is defined very broadly. The law defines “sale” more broadly than you might think. It doesn’t just include the exchange of data for money. Instead, it covers any transfer of personal information to a “third party” in exchange for “other valuable consideration.” We do not sell your personal information. However, in 2019, we were sharing identifiers about you with our business partners in such a way that, under the CCPA, may be defined as selling.

Shine the Light Law

We will not share any personal information about you with outside third-parties for their direct marketing purposes to the extent prohibited by California law, unless you agree otherwise as authorized by your prior written consent. California residents have the right to request information from Robbins Brothers regarding the manner that we may share personal information with affiliated companies and third parties for their direct marketing purposes. To find out what and how we share such information, you may send us an email request at privacy@robbinsbrothers.com or mail a request to: Privacy Officer, Robbins Brothers 1300 W. Optical Drive, Suite 200, Azusa, CA 91702 and receive the following information:

• The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year, if any;

• The names and addresses of the third parties who received information for their direct marketing purposes; and

• Examples of the products and services subject to the third-parties’ direct marketing programs, if the nature of the third parties’ business cannot be determined from their names.

10. CONTACT US

If you have any questions about this Privacy Policy and our personal information processing practices, please email your questions to: privacy@robbinsbrothers.com.