UNI Luxury Group Limited and UNI Luxury USA INC are the authorized users and distributors of
(available at https://www.uni.diamonds and as
may be made available through U.N.I's mobile application) ("Platform"), a professional diamond
business trading Platform developed and owned by U.N.I Technologies Ltd ("U.N.I Technologies").
Group Limited, UNI Luxury USA INC, U.N.I Technologies Ltd and their respective affiliates,
subsidiaries and related entities shall hereinafter be referred to as: "U.N.I" or "we" or "us"
We, at U.N.I, put great efforts in making sure that we secure your personally identifiable information and use it properly.
The summary of this policy will give you a quick and clear view of our practices. Please take the time to read our full policy.
The Personally Identifiable Information That You Provide Us – We receive and store any
enter on our Platform or give us in any other way, including your usability and activity
other information you provide before registering as a user to the Platform, or during our KYC
you register with the Service and/or go through our KYC procedure we will need, inter alia, your
name, entity type, date of incorporation, principal business address, nature of business,
countries in which business is transacted, details of key persons, shareholders and officers
names, positions, nationalities, ownership percentage (with respect to shareholders)) and such
information as further elaborated in our KYC form. In addition to the registration and KYC
details, you may
be required to provide payment and full bank account details, financial information such as your
turnover, reference customers, and additional information as may be required by anti-money
and counterterrorism regulations and such other applicable regulatory obligations. We may also
ask for your
email and/or phone number in order to contact you, subject to the terms of this policy. Please
note that we
may also receive any personally identifiable information that you provide when contacting us. Read More
Sources of the Personally Identifiable Information That We Collect – Most of the
collect comes directly from you. Subject to your consent, we also collect and share information
Malca-Amit group companies as part of our KYC procedures in order to, inter alia, cross-verify
information you provide us and receive such other information which we deem necessary in order
you eligibility to receive the Services (such as blacklisting, transaction history, etc.).
applicable law, we may also collect information from other third parties and databases,
including under such
cases where we are required do to so under applicable anti-money laundering and counterterrorism
which we are subject. Read
The Personally Identifiable Information That You Upload – You may upload content with
identifiable information. Please use caution and do not upload personally identifiable
information of others
without their appropriate consent. Read More
What Do We Do With Personally Identifiable Information? We use the information we collect
to determine you eligibility to receive the Service and Service level, to enable, provide and
Service, to execute and collect proceeds for the transaction in the Service, to study and
functionality of the Service and users' experience, to make it better, continue developing it
us, our customers and the Service from misuse and law violations.
Sharing Information with Others – We do not sell, rent or lease your personally
information. We will share your personally identifiable information with service providers and
parties, if necessary to fulfill the purposes for collecting such information and deliver the
Any such third party will commit to protect your privacy as required under applicable law and this policy. We may also use service providers, for example, to provide support and send email and mobile messages. We will transfer information if we change our corporate structure, and we will share the information with our affiliated entities (e.g. subsidiaries or future parent or sister companies of U.N.I), who will be subject to this policy. Read More
Disclosure of Information to Authorities – We will obey orders and other lawful
authorities to disclose information.
Aggregated and Analytical Information – Aggregated data is not identifiable. We use it
Your Choice – You may opt-out of our mailing lists and exercise further opt-out rights.
Accessing Your Personally Identifiable Information - At any time you can request access
personally identifiable information.
Your EU Data Subject Rights – If we process your personal data when you are in the EU,
apply to our processing in relation to your rights as a data subject under EU data protection
Data retention – We retain data to provide the service and for legitimate and lawful
further explained in the data retention section of the policy.
Transfer of Data Outside your Territory – We use multi-regional cloud-based services and
technologies, including those of third parties, to store and process data.
Information Security – We implement systems, applications and procedures to secure your
identifiable information, to minimize the risks of theft, damage, loss of information, or
access or use of information.
notice at the Platform.
Incorporation to the Terms of Service - This policy is an integral part of the U.N.I and
and/or Loan Agreement entered into between you (or any entity affiliated to you) and us.
We receive and store any information you enter on our Platform or give us in any other way,
usability and activity information, information you provide during our KYC procedures or
calls, digital chat or any other means of communication.
If you register with the Service and/or go through our KYC procedure we will need, inter alia, your entity name, type, date of incorporation, principal business address, nature of business, specification of countries in which business is transacted, broker/dealer license number, diamond exchange or burse member name and number, details of key persons, shareholders and officers (including name, positions, nationalities, ownership percentage (with respect to shareholders), and such other information as further elaborated in our KYC form.
In addition to the registration and KYC details, you may be required to provide payment and full bank account details, and additional financial and other information, as may be required by U.N.I including, but not limited to, anti-money laundering (AML) and counterterrorism regulation and such other applicable regulatory obligations.
Should you execute transactions through the Platform, we may also receive your payment transaction details from the payment service provider that processed your payment.
When you contact us, or when we contact you, we will receive, store and process any personally identifiable information that you provide us.
Most of the information we collect comes directly from you. Inter alia, we collect information
when you go
through our KYC procedures, when your register and use our Service, etc.
Subject to your consent, we also collect and share information from and with Malca-Amit group companies, including Malca-Amit Ltd. and any parent, subsidiaries and sister companies thereof, as part of our KYC procedures in order to, inter alia, cross-verify the information you provide us and receive such other information which we deem necessary in order to determine you eligibility to receive the Services (such as blacklisting, transaction history, etc.).
Subject to applicable law, we may also collect information from other third parties and databases, including under such cases where we are required do to so under applicable anti-money laundering and counterterrorism laws to which we are subject.
The content you upload to the Service, whether such content relates to you or to third parties,
content originated from your own device or from a third party device, be it a computer, mobile
or any other device, including any data, text, graphic, audio and audio-visual files, may
Please use caution when uploading the content and avoid any involuntary disclosure of your personally identifiable information or disclosure of others' personally identifiable information without their consent.
We use the personally identifiable information we collect and receive to determine you
receive the Service, to provide the Service to you and to other users, to enable, perform and
Service's tools and features, to enhance users' experience with the Service, to study and
functionality of the Service and users' activities, to provide support, to measure Service
provide automatic updates of new versions of the Service, to maintain the Service, to make it
better and to
continue developing the Service.
We will use your email address and mobile phone number to contact you when necessary, to send you reminders and to provide you information and notices about the Service. We may include commercial and marketing information about our Service.
Subject to applicable law, we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook and Google, to generate leads, drive traffic to our Platform or otherwise promote our Service. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you. The social media platforms with which we may share your personal data are not controlled or supervised by U.N.I. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider. Please note that you may, at any time, ask U.N.I. to cease processing your data for these direct marketing purposes by sending an e-mail to firstname.lastname@example.org.
We obey the law and expect you to do the same. If necessary, we will use your personally identifiable information to enforce our terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity theft and any other misuse of the Service, and to take any action in any legal dispute and proceeding.
We do not sell, rent or lease your personally identifiable information. We will share your
identifiable information with service providers and other third parties, if and to the extent
fulfill the purposes for collecting such information and deliver the Service to you. Any such
will commit to protect your privacy as required under applicable law and this policy.
Inter alia, we may share your personally identifiable information with third party providers involved in any of the following services associated with our Service: inspection and diamond certificate verification, autonomous diamond gemological examination, video filming and imaging of the diamonds, diamond mark-to-market appraisal, diamond digital certificate issuance, safe storage of the diamonds, insurance (as and where applicable), marketing and international promotional campaigns of diamonds, diamond industry tradeshows participation, delivery of diamonds and payment charging and collection services, subscription processing, data analysis, marketing, promotion and advertising services, e-mail services, hosting services and costumer services.
We only share the minimum data needed for data processors to perform the services for which they were contracted.
You may opt-out from any advertising communications by following the unsubscribe instructions in our marketing communication or by sending an e-mail to email@example.com. For more information about you opt-out options please refer to our "Choice" chapter in this policy.
We share your payment transaction details with the payment services providers, to process and verify your payments. We may use a service provider to manage our email, push notification and mobile messages transmission.
We may also share your personally identifiable information with our affiliates. This means companies within the U.N.I. group and includes subsidiaries, sister-companies and parent companies, subject to the terms of this policy.
Additionally, you are aware and agree that in the case of a merger, acquisition or any other structural change we may require to transfer your personally identifiable information to another entity, as part of the structural change, provided that the receiving entity will comply with this policy.
We will need to disclose personally identifiable information in response to lawful requests by
authorities, including to meet national security or law enforcement requirements.
We use standard analytics tools. The privacy practices of these tools are subject to their own
policies and they use their own cookies or similar technologies (such as tokens) to provide
(for further information about cookies, please see the 'Cookies' section in this policy).
We use anonymous, statistical or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from such information that we or others can associate specifically to you.
We will share your personally identifiable information only subject to the terms of this policy, or subject to your prior consent.
At any time, you can unsubscribe our mailing lists or newsletters, by sending us an opt-out
request to: firstname.lastname@example.org.
At any time, you can exercise your following opt-out options: (i) object to the disclosure of your personally identifiable information to a third party, other than to third parties who act as our agents to perform tasks on our behalf and under our instructions, or (ii) object to the use of your personally identifiable information for a purpose that is materially different from the purposes for which we originally collected such information, pursuant to this policy, or you subsequently authorized such use. You can exercise your choice by contacting us at: email@example.com.
We request and collect personally identifiable information that we need for the purposes that we describe in this policy. Following the termination or expiration of the Service, we will stop collecting any personally identifiable information from or about you. However, we will store and continue using or making available your personally identifiable information according to our data retention section in this policy.
If you find that the information associated with you is not accurate, complete or up-to-date,
us the necessary information to correct it.
At any time, you can contact us at: firstname.lastname@example.org. and request to access the personally identifiable information that we keep about you. We will ask you to provide us certain credentials to make sure that you are who you claim to be and will make good-faith efforts to locate your personally identifiable information that you request to access.
Under your right of access, you can obtain confirmation from us of whether we are processing personally identifiable information about you, receive a copy of that data, so that you could:
verify its accuracy and the lawfulness of its processing;
request the correction, amendment or deletion of your personally identifiable information if it is inaccurate or if you believe that the processing of your personally identifiable information is in violation of the applicable law. We will use judgement and due care to redact from the data which we will make available to you, personally identifiable information related to others.
If EU data protection laws apply to the processing of your personal data by U.N.I., then the following terms apply: U.N.I. Technologies Ltd. is the data controller in relation to the processing of the personal information that you provide to us when you use our Services. Our registered address is 21 Tuval St., Ramat Gan, Israel. Where U.N.I. processes your personal data as a data controller, then we process your personal data for the following lawful grounds:
In addition to your rights under other sections in this policy, you have the following rights:
A summary and further details about your rights under EU data protection laws, is available on
Commission's website at:
Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will ask you further questions to understand the nature and scope of your request.
If we need to delete your personal data following your request, it will take some time until we completely delete residual copies of your personal data from our active servers and from our backup systems.
If you have any concerns about the way we process your personal data, you are welcome to contact our privacy team at:email@example.com. We will investigate your inquiry and make good-faith efforts to respond promptly.
We retain different types of personally identifiable information for different periods,
depending on the
purposes for processing the information, our legitimate business purposes as well as pursuant to
requirements under the applicable law. Unless otherwise determined in accordance with applicable
personally identifiable information is kept for no longer than necessary for the purposes for
which it is
being processed in accordance with this policy.
For example, we may need to keep the information about the payment transactions that you made for several years due to tax related requirements, for accounts settling, record keeping, archiving and legal issues.
We will maintain your contact details, to help us stay in contact with you. At any time before or after the termination of your account, you can contact our privacy team at: firstname.lastname@example.org and request to delete your contact details. Note that we may keep your details without using them unless necessary, and for the necessary period to the extent required in order to comply with legal obligations. We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.
We use multi-regional cloud-based services to store and process data. From time to time, we will
operational decisions which will have an impact on the sites in which we maintain personally
information. We make sure that our data hosting service providers, provide adequate
If you are a resident in a jurisdiction where transfer of your personally identifiable information to another jurisdiction requires your consent, then you hereby provide us your express and unambiguous consent to such transfer. You can contact our privacy team at: email@example.com for further information about data transfer.
Cookies are small files that a web server sends to a user's device, when the user browses
device removes session cookies when you close your browser session. Persistent cookies last for
periods. You can view the expiry date of each cookie, through your browser settings.
We may use both types. We may use persistent cookies or similar technologies (such as tokens) to remember your log-in details and make it easier for you to log-in the next time you access the Service. We may use this type of cookies and Session Cookies for additional purposes, such as content adjustability, in order to facilitate the use of the Service's features and tools.
Every browser allows you to manage your cookies preferences. You can block or remove certain cookies or all of them through your browser settings. Please bear in mind that blocking or removing cookies will influence your user experience with our Service. For example, disabling or blocking our cookies will require you to re-enter your log-in details, or even prevent you from using features of the Service.
We and our hosting services implement systems, applications and procedures to secure your
identifiable information, to minimize the risks of theft, damage, loss of information, or
access or use of information.
These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Service will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
We do periodical assessments of our data processing and privacy practices, to make sure that we
this policy, to update the policy when we believe that we need to, and to verify that we display
properly and in an accessible manner.
If you have any concerns about the way we process your personally identifiable information, you are welcome to contact our privacy team at: firstname.lastname@example.org, or write to us at: U.N.I Technologies Ltd., 21 Tuval St., Ramat Gan, Israel. We will investigate your query and make good-faith efforts to resolve any existing or potential dispute with you.
From time to time, we will update this policy and post a revised policy with an updated
effective date. A
notice of updates will be communicated to the Platform's users by a notification through the
through other communication means, subject to U.N.I's discretion.
Continuing to use the Service after the new policy takes effect means that you agree to the new policy. Note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required by law.
applicable, the Consignment Agreement and/or Loan Agreement entered into between you (or any
affiliated to you) and us.
Please contact our Privacy Team at: email@example.com for