This is the privacy policy of HStern (Jewellery) Limited, a company registered in England and Wales (company number 00804975) whose registered office is at York House, Empire Way, Wembley, Middlesex, HA9 0FQ.

We are committed to protecting and respecting your privacy. This privacy policy explains what personal information we collect and how we will use it.

We may collect personal information about you as follows:

• If you fill in forms on our website, we will collect your contact details and the other information you provide in the form.

• If you contact us by any other means (e.g. email or telephone), we may keep a record of that contact and the information you provide us at that time.

• If you instruct us to provide products or services to you, we will process the limited information which is required to provide those products or services including contact details; financial data; and transaction data, including details about the products we have sold you or services we have provided and payments received from you.

• We may collect personal data relating to third parties in the course of providing products or services to our customers, including contact details of relevant suppliers.

• If you ask to be added to our marketing database, we will collect your name, email address and your preferences as to the types of marketing information you would like to receive from us. The emails that we send you may contain tracking facilities, which may include the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity and other data relevant to the production of an enhanced user experience.

• If you apply for employment or work with us, we will collect a range of information relating to you which is outlined in more detail in our candidate privacy notice.

Our website uses Google Analytics, a web analysis service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyse how users navigate the site. The information generated by the cookies about your use of the website will be transmitted to and stored by Google on its servers. You can find more information on Google’s privacy policy and the technology used by Google at www.google.com/analytics.

Our site may use cookies and tracking technology in order to gather information that helps us understand how the site is being used. A cookie is a small file, which is placed on your computer's hard drive with permission. Cookies allow web applications to respond to you as an individual by remembering information about your preferences, tracking the sites you visit, etc. By doing so, cookies help sites customize your visit and tailor its operations to your needs, likes and dislikes, etc. A cookie does not give us access to your computer or any information about you, other than the data you choose to share with us. The default setting on most web browsers is to automatically accept cookies, however, you can usually modify your browser setting to decline cookies if you wish (although this may prevent you from taking full advantage of the website).

Our website may, from time to time, contain links to other websites (including external social media platforms and/or adverts) which may be of interest to you. If you follow a link, please note that the other website will have its own privacy policy and you should check this before you submit any personal information to that website. We are not responsible for the content of other websites or their use of your personal information.

This website may also use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

• If you visit our website, we will use information about your visit to help us make our website experience as user-friendly for as many visitors as possible on the basis that we have a legitimate interest to do so.

• If you fill in forms on our website, or contact us by any other means, we use the information you provide to respond to your enquiry or contact you on the basis that we have a legitimate interest to do so.

• If you instruct us to provide products or services, we will use the information you provide to carry out our contractual obligations to you and to fulfil any legal obligations arising from your instructions. We may also use it to notify you about changes in our organisation on the basis that this is compatible with our original use of your information.

• We may contact you on occasion with information if you are a customer or contact of the company or a person who we reasonably believe would be interested in receiving that particular communication. This may include news about launches, seasonal greetings and invitation to HStern exclusive events. Any such communications are tailored and considered and as far as is possible not intrusive. They are sent on the basis that we have a legitimate interest in doing so, namely to grow our business, to inform our marketing strategy and to improve our offering to you.

• If you ask to be added to our marketing database, we will use the information you provide to send you information about our organisation, products and services in accordance with your stated preferences. Any information obtained via the tracking of marketing emails is used to refine future email campaigns and supply you with more relevant content based around their activity. We will do this on the basis that you have consented to us processing your personal information in this way. You can stop receiving marketing information from us at any time as these communications provide easy ways to unsubscribe or update your preferences.

We will not use your personal information for any purpose not explained in this privacy policy and/or the privacy notices that apply to candidates and our staff members.

Some of the information you provide to us will be transmitted electronically, e.g. information provided via our website or by email. We would remind you that information transmitted via the internet is not completely secure and although we will do our best to protect any information transmitted in this way, we cannot guarantee its complete security.

We have put in place appropriate security measures to prevent your personal data being accidently lost, accessed or used in an unauthorised way, altered or disclosed. Being a member of a global group of companies and selling products under the same brand we may store some of your data on secure servers located outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to your personal data or shall seek your express informed consent. The HStern group has put in place a data processing agreement between our various corporate group members which incorporates the safeguards required by Article 46(1) of the General Data Protection Regulations.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We may disclose your personal information to third parties if we are under a duty to disclose or share it in order to comply with any legal obligation (for example our auditors, our insurers, professional advisers, couriers and tax and custom authorities) or with your consent.

We may transfer limited amounts of your personal data to other companies within the HStern group to enable us to fulfil our contract with you and/or in our legitimate interests as part of leadership reporting and business development. This may involve transferring your data outside the European Economic Area (EEA). Please see above regarding the safeguards we have put in place to ensure the security of your data whenever it is transferred outside the EEA.

We will keep your personal information for the following periods of time, subject to our email data retention policy:

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you would like to communicate with us about any of the rights mentioned above, or if you have any other queries about the matters mentioned in this privacy policy, please contact us using one of the following options:

• Website: www.hstern.net

• E-mail: client.service@hstern.com.br

• Post: Rua Visconde de Piraja, 490 – 5º. Andar

• Phone: +55 21 2106 0000

You have the right to complaint to the relevant national data authority about the way in which we collect and use your personal data.

This policy is effective from 25 May 2018. We may change this privacy policy from time to time by updating this webpage.