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TrueFacet, LLC. ("TrueFacet," "we," "us," or "our") welcomes you. We're really excited that you have decided to access and use our website located at www.TrueFacet.com ("Site").

This Privacy Policy sets forth TrueFacet's policy with respect to personally identifiable information and other information that is collected from Site visitors and Registered Users. By using the Site, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use. If you have any questions or comments about this Privacy Policy or our use of your personally identifiable information, please contact us at privacy@truefacet.com.


1. Personal Data

We collect personally identifiable information from you when you voluntarily provide such information, such as when you create an account and become a Registered User (for example, name, email address, and payment information) or when you otherwise contact us with inquiries or respond to one of our surveys (such information is collectively referred to herein as "Personal Data"). We do not collect any Personal Data from you when you use the Site unless you provide us with the Personal Data voluntarily. When you voluntarily submit your Personal Data to us, you are giving us your consent to the collection, use, and disclosure of your Personal Data as set forth in this Privacy Policy.

2. Other Information

We may collect additional information (collectively, the "Other Information"). Such Other Information may include:

a. From You. Additional information that you voluntarily provide to us, such as characteristics of your jewelry and watch items (including without limitation details regarding shape, weight, color, clarity, retail value, and appraisal) hobbies, personal interests, household income range, gender, marital status, occupation, product and service preferences, and other information that does not identify you personally.

b. From Your Activity. Information that we automatically collect when you use the Site, including, without limitation:

  • IP address, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, sections of the Website visited, etc.;
  • Information about a mobile device, including universally unique ID ("UUID"), Platform type and version (e.g., iOS or Android), carrier and country location, hardware and processor information (storage, chip speed, camera resolution, NFC enabled, and network type (Wi-Fi, 2G, 3G, 4G); and
  • Activity and usage information occurring via the Site, including search information; when you search on our site, we store the search terms and the visited pages so that we can continuously improve the quality of our search results.

c. From Cookies. Information that we collect using "cookie" technology. Cookies are small packets of data that a website stores on your computer's or mobile device's hard drive so that your computer will "remember" information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Site. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser's documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Site may not function properly.

3. Transaction Information

We collect and retain information regarding our transactions with you processed via the Site (such information, "Transaction Information").



We may share Other Information about your activity on the Site with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Site and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable us, and these third-party advertisers, to recognize a browser's cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.



If you have provided us Personal Data, you may access, review, and make changes to your Personal Data through your account. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the "unsubscribe" link located on the bottom of any TrueFacet marketing email. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to your transactions with us.


The information that we collect about you may be used by us or by third parties we engage in any manner and for any purpose permitted by law. This may include combining your personally identifiable information, such as your email address, with information that does not identify you personally, such as your IP address, device ID, a unique cookie placed or recognized on your browser, or information associated with such non-personally identifiable information, such as information about your browsing history, whether collected on this site or a third-party site. We, or third parties we engage, may use this combined information to send you relevant marketing, including by email, about our products or services or the products or services of third parties. To Opt-Out from these services, please go to (http://www.aboutads.info/choices) opt-out from third party cookies, http://www.aboutads.info/appchoices to opt-out from use of their mobile device ID for some interest based advertising.

We use the Personal Data, the Other Information, and the Transaction Information (collectively, the "Information") to process your transactions, provide and improve the Site and our services, solicit your feedback, inform you about our products and services and those of our third-party marketing partners, and administer our rewards and promotional programs. Also, we may share Information as described below.

  • To administer our rewards and promotional programs, we may share your Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
  • In an ongoing effort to better understand our users, Site, and services, we might analyze the Information in aggregate form in order to operate, maintain, manage, and improve our services and/or Site. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe the Products, the Site and our business to current and prospective business partners and to other third parties for other lawful purposes.
  • We may from time to time share Information with other companies who may provide you information about the products and services they offer. However, to the extent required by law, you will be given the opportunity to opt-out of such sharing.
  • We may employ other companies and individuals to perform functions on our behalf. Examples may include providing processing payments for Products purchased through the Site, marketing assistance, information technology support, and customer service. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
  • With your permission, third-party applications or services may access your Information.
  • We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
  • As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
  • If you choose to participate in a special event (for example, a promotion, contest, or sweepstakes), TrueFacet may share Information with those organizations participating in the applicable event. Unless we tell you otherwise in connection with a special event, these third parties do not use your Information for any other purpose other than to manage the event. We may authorize trusted partners to send you information about products and services that may be of interest to you.
  • To the extent permitted by law, we may also disclose the Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing the such information is necessary or advisable, for example, to protect the rights, property, or safety of TrueFacet or others.


We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.


It is important to note that the Site and its servers are operated in the United States. If you are located outside of the United States, please be aware that any Personal Data you provide to us will be transferred to the United States. By using the Site and by providing us Personal Data, you hereby consent to this transfer and our use of the Information in accordance with this Privacy Policy.


We do not knowingly collect Personal Data from children under the age of 13 through the Site. If you are under 13, please do not give us any Personal Data. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Data through the Site without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us, please contact us, and we will endeavor to delete that information from our databases.


Under California Civil Code Section 1798.83, California residents who have an established business relationship with TrueFacet may choose to opt out of our sharing their Personal Data with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Data to third parties for the direct marketing purposes, please contact us as set forth below.


The Site may contain links to External Sites. TrueFacet has no control over the privacy practices or the content of any such External Site. As such, we are not responsible for the content or the privacy policies of those External Sites. You should check the applicable third-party privacy policy and terms of use when visiting any External Site.


TrueFacet reserves the right to make changes to this Privacy Policy at any time. If TrueFacet makes a material modification to this Privacy Policy, it will notify you by: (i) sending an email to the address associated with your account (TrueFacet is not responsible for your failure to receive an email due to the actions of your ISP or any email filtering service; therefore, you should add TrueFacet.com to the list of domains approved to send you email (commonly known as your "whitelist")); or (ii) displaying a prominent announcement above the text of this Privacy Policy for thirty (30) days, with (i) or (ii) being deemed sufficient notification, of such changes. After notice of a modification to this Privacy Policy has been posted for 30 days, the notice may be removed. If you choose to continue using the Site, you agree that by doing so you will be deemed to accept the new Privacy Policy.


Please recognize that if you submit any User Content through the Site, such User Content and all information contained therein, including, without limitation, any Personal Data, it will be made available to other users of the Site and to the general public and will not be subject to the terms of this Privacy Policy. Please carefully consider the information contained in any User Content and do not provide any Personal Data in any User Content, unless you are comfortable with the terms of this Section.


Email communication that you send to us via the email links on the Site may be shared with a customer care representative, employee or the expert that is most likely to be able to address your inquiry. If you provide Personal Data in your email, it will be used only for the purposes of answering your email. From time to time we may send you site-related emails, such as a welcome email when you register with the Site.


When you invite a friend to join the Site, your circle (network of friends) or your group, we will automatically send your friend an email invitation on your behalf. We will not use your friend's email address for any other purpose. Similarly, when you email a message using the Invite a Friend function, the email addresses are used to facilitate the email communication and are not retained by us.


At various places on the Site you will be given the option to receive recurring event sales newsletters and to set alerts and reminders. You can unsubscribe from newsletters by clicking on the unsubscribe link. You can manage your alerts through your account. How to Contact Us If you have questions about this Privacy Policy, please e-mail us at privacy@truefacet.com. You may also write to us at TrueFacet LLC, 36 West 47th Street, Suite 603, New York, NY. 10036.