Privacy Policy

Last Updated: August 8, 2023

Your privacy is very important to us. Ben Bridge Jeweler, Inc. (“Ben Bridge”) respects your concerns about maintaining privacy. Ben Bridge has adopted this Privacy Policy that applies to information we collect when you use our website www.benbridge.com and other sites or applications that are owned or operated by Ben Bridge, including Ben Bridge’s social media site(s) (each individually a “Site” and collectively the “Sites”), shop in our stores, attend an event, or otherwise interact with us as described below (collectively, the “Services”). We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the effective date above, and if we make material changes, we will provide you with additional notice (such as adding a statement to our website or sending you an email notification). We encourage you to review this Privacy Policy whenever you interact with us to stay informed about our information practices, how your personal information will be processed, and the choices available to you. This Privacy Policy is not, however, a contract and does not create any legal rights or obligations.

This Privacy Policy does not address or apply to information collected from employees or prospective employees within the context of their employment or prospective employment.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information. By accessing or using any Site, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. Certain Sites may be subject to additional terms and conditions which may also apply to your information. This Privacy Policy is subject to your agreement to our other Policies, as applicable.

NOTE REGARDING PANDORA STORES FORMERLY OPERATED BY BEN BRIDGE

Ben Bridge formerly owned and operated certain Pandora-branded franchise stores but transferred ownership of those stores to Pandora USA in March 2022. To the extent that you previously provided personal information to a Pandora store owned by Ben Bridge, the Pandora Jewelry Privacy Policy is now applicable.

THIRD-PARTY PARTNERS

For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to its collection, please visit our Cookie Policy.

GEOGRAPHIC SCOPE AND STATE-SPECIFIC DISCLOSURES

Please note that the Sites are directed towards users who reside in the United States. By using the Sites, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States.

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states. Please refer below for disclosures that may be applicable to you:

• If you are a resident of the State of California in the United States, please see see “ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES” for additional California-specific privacy disclosures.
• If you are a resident of the State of Nevada in the United States, please see below for Nevada-specific privacy disclosures.
• Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. We do not sell your covered information, as defined by Chapter 603A of the Nevada Revised Statutes. If you reside in Nevada, you have the right to submit a request to privacy@benbridge.com to opt out of the sale of covered information. Please include “Nevada Rights Request” in the subject line.

WHAT IS PERSONAL INFORMATION?

When we use the term “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you. The types of information we collect directly from you may include personal information such as your name, username, email address, postal address, phone number, birth date, payment method information, photographs, videos, social media handles, and any other information you choose to provide.

OUR COLLECTION OF PERSONAL INFORMATION

From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our services and, sometimes, we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction. We may link or combine your activities and information collected from you on our websites with information we have collected from you offline (e.g., in-store), information we receive from third parties, as well as information we collect automatically through tracking technologies (discussed below). This allows us to provide you with a personalized experience regardless of how you interact with us. Customer information you provide that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device is considered “personal information” under this Privacy Policy, as more fully described below. The personal information we collect may consist of the following:

• Contact and Profile Information. We collect personal information, such as your name, email address, password, telephone number, gender, zip code, and address when you create an account, sign up for a newsletter, request a transaction or make a purchase online or in-store, redeem or participate in a promotion, purchase or redeem a gift card or otherwise communicate with us. We collect any communications between you and us and any other information you provide to us. We also collect information about your use of our services, such as your orders, and similar activity. To advise you on product selection and better understand your product preferences, we may ask for demographic and biographical information such as your sizes.
• Payment and Transaction Information. We may collect information such as items purchased, date and time of your transaction, amount purchased, order details, whether you used a particular coupon or deal, and payment information, such as your credit/debit card (and associated security code) or gift card details, when you make an in-store or online purchase.
• Shopping History. For example, we may collect personal information about the items you viewed on our website, added to your cart, purchased or returned.
• Action/registration information you provide when you create an account, enter a promotion, or link your profile on a third-party site or platform with your registration account, such as your first name and surname, gender, date of birth, email address, username, password and other security information for authentication and access.
• Device, location and log information, such as, information about your device and location, such as IP address, location or provider. We may collect location through WiFi, wireless network triangulation and other methods or we may also approximate your location by your IP Address. We many also log access times, operating system, browser type and language, Internet Service Provider, and the web page you visited before navigating to our Services.
• Usage information and browsing history, such as, information about how you navigate within our services, your browsing history and which elements of our services you use the most.
• Transaction information you provide when you request information, contact Customer Service, or purchase a product or service from us, such as your postal address, email address, telephone number, and payment information.
• Information we obtain from a third party, such as a site or platform provider, about use of our applications on third-party platforms or devices.
• Location information, including location information provided by a mobile or other device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information.
• Activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences.
• Communications information. We collect and record communications information and content you provide when you sign-up to receive marketing emails or texts, and when you communicate with us to make an inquiry. For example, we collect and record information and content you provide to us over the phone, text, or online chat or when you communicate with us using any other service or communication method. This type of information includes your contact information, the date and time you contacted us, call recordings, the content of your communications, and your communication method. By communicating with us, you consent to our collecting and recording all information you communicate to and with us.
• Information We Infer. We may derive information or draw inferences about you based on the other personal information we collect about you. For example, based on your history of browsing for diamond bracelets on our Services, we may infer that you would be interested in purchasing a diamond bracelet.
• Analytics Data. This may include the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and objects you view, click or otherwise interact with (also known as “Clickstream Data”). We may collect analytics data or use third-party analytics tools such as Adobe Analytics and Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google's practices at http://www.google.com/policies/privacy/partners.
• Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, including your browser or device type, unique device identifier, and IP address.
• Information We Receive from Third-Party Sites You Connect to Our Services. Some parts of our services may allow you to login through a third party social network or authentication service such as Facebook. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site.
• Social Networks Through Your Interactions. When you interact with our services through various social media networks, such as when you “Like” us on Facebook or when you follow us or share our content on Facebook, Twitter, Snapchat, LinkedIn, Instagram or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third party websites and social media networks and services before linking or connecting them to our services.
• Information Provided by Others. From time to time, we may receive information about you from third parties and other users. For example, we may obtain information from our marketing partners or from third parties to enhance or supplement our existing user information. We may also collect information about you that is publicly available. We may combine this information with the information we collect from you directly.

COOKIES, WEB BEACONS, AND OTHER TRACKING DEVICES

Ben Bridge’s Sites also use a variety of cookies and other tracking devices to help us be more responsive to your needs and to deliver a more personalized online experience. For example, if you provide your zip code we may store it in a cookie and use it to remember your nearest Ben Bridge stores or if you click on one of our ads we may track what products you view or purchase from our website to evaluate the ad’s performance. We use web beacons or clear gifs (which are single pixel images) to help monitor how often a specific page or message is viewed. We may also use technologies, such as our own cookies, to provide you with personalized online display advertising tailored to your interests. To opt out of these ads, please click here.

ROLEX SECTION

While navigating on the Rolex section of our website, some cookies are controlled by ROLEX SA which applies the following Cookies Policy.

HOW WE USE PERSONAL INFORMATION

Ben Bridge uses the Personal Information that we collect about you:

• To provide you with information, products or services that you request from us, and to otherwise fulfill the purpose for which you provided the information.
• To process your registration for our services, purchases, transactions, and payments.
• To respond to your comments, questions, requests and to otherwise provide quality service to you and to tell you about opportunities we think may be of interest to you.
• Process and deliver contest or sweepstakes entries and prizes.
• To present and personalize the Sites and notify you of changes to a Site.
• To create, maintain, customize, and secure your account with us, including activities related to Investigating security incidents and preventing fraudulent transactions and other illegal activities;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To, unless you opt-out, send you marketing and promotional messages for special offers involving our own or our partner’s goods and services that may be of interest to you. To stop receiving these messages see “Choices and Control Over Your Information” section below.
• To send you important information regarding the services, such as certain changes to our terms, conditions, policies, and/or other administrative information. Because this information may be material to your use of the services, you may not opt out of receiving such communications.
• To attempt to detect and reduce fraud, credit risk, and other illegal activities or threats to safety, security, or integrity of the Sites or our other operations.
• To allow you to participate in interactive features on the Sites.
• To improve our Sites, services, product offerings, marketing and promotional efforts, and overall customer experience.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ben Bridge’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Ben Bridge about our customers or users is among the assets transferred.
• To personalize your experience and customize content on our services relevant to your interests, including but not limited to targeted offers and ads through our website, email, social media channels, third-party sites, or on other devices you may use.
• To operate, maintain, and provide to you the features and functionality of the products and services.
• To inform you of products, programs, services, and promotions that we believe may be of interest to you, including, without limitation, adding you to our email/mailing lists and permitting you to participate in sweepstakes, contests, and similar promotions (collectively, "Promotions").
• To evaluate your eligibility for certain types of Promotions, offers, products, or services that may be of interest to you.
• To help maintain the safety, security, and integrity of our service, technology assets, and business.
• For our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, enhancing the services, improving our services, identifying usage trends, and determining the effectiveness of our promotional campaigns, including to inform our machine learning for purposes such as user engagement.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations and enforce our corporate reporting obligations and our Terms of Use, or to comply with applicable laws.
• For our general business administrative, operations, and oversight purposes.
• To fulfill or complete any other purpose or function described to you when collecting your information.

HOW WE USE AND DISCLOSE PERSONAL INFORMATION

We may use and disclose any Personal Information that we collect or you provide to Ben Bridge in the following ways:

• To fulfill the purpose for which you provide it.
• To our subsidiaries and affiliates, in order to process your data for the same purposes or within the same activity as permitted under this Privacy Policy.
• To our agents, contractors, service providers and other third parties we use to support our business (such as shipping orders, completing credit checks, maintaining a Site, facilitating communication between you and Ben Bridge, etc.) for their use in completing services on our behalf.
• To enforce our Policies and other agreements, including for billing and collection purposes.
• We may share limited information with third parties with whom we partner to provide contests and sweepstakes, or other joint promotional activities. These partners will usually be clearly identified in the contest rules or promotional materials.
• Third Parties at Your Request: You may choose to share your activities on the services with your friends through email or on various social media networks.
• Online Advertising Partners. We also share personal information with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please read our Cookie Policy.
• The Public: When you provide feedback or post user content on our services (e.g., if you post a product review on our website or comment on our social media sites), your information (e.g., your first name and comments) may be displayed on our websites or on our social media pages. When you engage with us on social media, we may tag your social media account or the social media account of others (e.g., to give photo credit to another user).
• Service Providers. We share personal information with third-party vendors, consultants and other service providers who perform functions or services on our behalf and under our instructions to make our services available to you. For example, this may include vendors and providers who engage in marketing or advertising activities or provide mailing or email services, tax and accounting services, auditing and compliance, fraud prevention, infrastructure provisioning, analytics services, IT services, product fulfillment, and web hosting.
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
• in connection with the establishment, exercise, or defense of legal claims;
• to comply with laws or to respond to lawful requests and legal process;
• to protect the rights and property of Ben Bridge, our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
• to detect, suppress, or prevent fraud;
• to reduce credit risk and collect debts owed to us;
• to protect the health and safety of us, our customers, or any person; or as otherwise required by applicable law.
• To any other party if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Ben Bridge, our customers or others. This includes sharing information with other entities for fraud protection and credit risk reduction.
• For any other purpose disclosed by us when you provide the information.
• With Your Consent or At Your Direction: In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you consent to or direct such sharing.
• We may use or disclose any non-individually identifiable information (including aggregated information) about our users that we collect and any information other than Personal Information without restriction.
• We may combine the Personal Information we collect with other information we possess to verify, update or complete the information we have about you from time to time.

SOCIAL SHARING FEATURES

The Services may offer social sharing features or other integrated tools, such as a Facebook “Like” button, which let you share actions you take on the Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these features.

CHOICES AND CONTROL OVER YOUR INFORMATION

Profile and settings: You may update your account information and adjust your account settings by logging into your account. Please note that changes to your settings may require some time to take effect.

How to control your email preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. You may also be able to adjust certain communications preferences by logging into your account or by contacting us at privacy@benbridge.com or by calling 1-888-448-1912. We make every effort to promptly process all unsubscribe requests. Note: removal from our e-mail marketing list will not prevent you from receiving confirmation messages for orders you place or other information you request on a Site. Although we will promptly begin removing your name from our e-mail marketing lists after receiving your request, for a limited period of time you may still receive messages from us for that had been initiated prior to your name being removed. Online advertising and tracking. Please see Cookie Policy to learn more about how we work with third party partners to collect data through tracking technologies for various purposes, including analytics and advertising, and to understand your choices.

If at any time you would like to request access to or change any Personal Information that you have provided to Ben Bridge, please contact us at privacy@benbridge.com or by calling 1-888-448-1912. Please include your full name, street and email address, and telephone number in any message to ensure we can identify all of your information that we collected. If you would like to delete Personal Information you have provided to Ben Bridge, please fill out the CCPA Data Subject Request form. We may not accommodate a request to change or remove information if we believe it would violate any law or legal requirement or cause the information to be incorrect.

LINKS AND THIRD PARTY CONTENT

Our Sites may contain links to other web sites or applications. We are not responsible for the privacy practices or the content of other web sites.

In addition, we may allow third-party advertisers to place ads or other content on our Sites. These third-party advertisers may use cookies or similar tracking technologies to help present the advertisements to you or to help measure the effectiveness of their advertisements. Some advertisers may track your device(s) to attempt to serve ads based on your visits to the Sites and other websites on the Internet. The use of such technologies is subject to the privacy policies of the third-party advertisers and is not covered by this Privacy Policy. As a result, if you respond to any such third-party advertisers by clicking on the advertisements and/or visiting their websites or the websites of any other third party, be sure to evaluate their privacy policies before providing them any of your information. To opt-out of a third party’s use of cookies; you must visit such third party’s website and follow its specified opt-out procedures or block all cookies. You can opt out of some, but not all, third-party advertiser cookies and other tracking devices by visiting the following pages: (1) the Network Advertising Initiative opt-out website, located at www.networkadvertising.org/managing/opt_out.asp and (2) http://www.aboutads.info/choices/. You may block all cookies by following the instructions applicable to your browser at https://www.aboutcookies.org/how-to-manage-and-delete-cookies.

CHILDREN'S PERSONAL INFORMATION

The Sites are not intended for children under 14 years of age. No one under age 14 may provide any Personal Information to or through any Site. Ben Bridge does not knowingly collect personal information from children under 14. If you are under 14, do not use any of the Sites. If Ben Bridge learns that it has collected or received any personal information from a child under 14 other than in accordance with law, Ben Bridge will delete that information. If you believe we might have any information from or about a child under 14, please contact us at privacy@benbridge.com or by calling 1-888-448-1912.

DATA SECURITY

We have implemented commercially appropriate measures intended to secure your Personal Information from unauthorized access, use, alteration and disclosure in conformance with industry standards. The Ben Bridge website serves all pages over secure HTTPS. Your credit card information and other shopping information is transmitted to us in an encrypted format so that it cannot be compromised or disclosed between the sending and our receipt of the information. Note that we are not responsible for devices, applications, or other programs located on your device or connection which may intercept your information (such as a “keylogger”). Unfortunately, the transmission of information via the internet is not completely secure. Although we strive to protect your Personal Information, we cannot guarantee the security of your personal information that is transmitted to our Site. Any transmission of Personal Information is at your own risk.

The safety and security of your information also depends on you. Where you have a password for access to certain parts of a Site, you are responsible for keeping this password confidential. You may not share your password with anyone.

UPDATES TO THIS PRIVACY POLICY

Ben Bridge may update this policy from time to time. By your continued use of our Sites after we make changes, you are deemed to accept those changes, so please review this Privacy Policy periodically for updates. All changes shall be effective from the date of publication unless otherwise provided.

CONTACT US

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to privacy@benbridge.com. Alternatively, inquiries may be addressed to:

Ben Bridge Jeweler, Inc.,

P.O. Box 1908,

Seattle, WA 98111,

Attn: General Counsel