The website www.dtc.com is provided to you by DTC (“we”, “us” or “our”). DTC is the registered trading name of De Beers Global Sightholder Sales (Pty) Limited, a company incorporated in the Republic of Botswana, with address at PO Box, 329, Gaborone, Botswana and registered number CO2008/5689.
We are committed to protecting and respecting your privacy and we comply with data protection legislation and other applicable local laws.
This privacy policy (“Privacy Policy”) (together with our website terms of use (“Terms”)) applies to your use of the website and sets out the basis on which any personal information that we collect from you, or that you provide to us, will be processed by us. Please read this Privacy Policy carefully to understand our practices regarding your personal information and how it will be treated.
By visiting our website you agree to the terms of this Privacy Policy as may be amended from time to time.
1. INFORMATION WE MAY COLLECT FROM YOU AND HOW WE USE IT
Personal data is any information capable of identifying a natural person, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to their his or her physical, physiological, mental, economic, cultural or social identity. Data is considered personal when it enables anyone to link information to a specific person, even if the person or entity holding that data cannot make that link.
We may collect and process the following data about you:
Submitted information
We may collect information that you provide to us when you: (i) use our website; (ii) contact us using the “contact us” section of our website; (iii) report a problem with the website; or (vii) upload content to our website. This kind of information may include your name and email address, or other contact details such as a postal address and telephone number. In all these circumstances, the source of your personal data will be you. We use this information to facilitate the provision of services through the website, and to enable us to provide a good level of service.
Additional information
If you contact us with a complaint or query about the website, we will process your personal data in order to consider and respond to those queries and we may keep a record of that correspondence to ensure we provide a good service. The personal data that we process in order to respond to your communication will be the personal data that you provide to us, such as your name, contact details (e.g. email address and telephone number) and the content of your query. The source of your personal data will be you, however, we may also generate personal data internally, if this is needed to respond to your query.
Device information
We may collect information about the computer or device you use to access the website, including, where available, the device's unique device identifiers, operating system, for system administration purposes. We may associate this kind of device information with the Submitted and Additional Information referred to in the sections above for user services and system administration purposes and will treat the combined information as personal information in accordance with this Privacy Policy for as long as it is combined.
Log information
When you use the website, we may also automatically collect and store certain information in our server logs to get a better understanding of how people use the website, for system administration purposes, and to ensure we provide a good user experience and service. This type of information includes information about when, how, and what parts of the website you use, viewed and exit pages on the website, as well as date or time stamps.
In particular, our server automatically collects data about your server’s internet address when you visit us. This information, known as an ‘Internet Protocol’ address, or IP Address, is a number that is automatically assigned to your computer by your internet service provider whenever you are on the internet. When you request pages from our website, our servers may log your IP Address and sometimes your domain name. Our server may also record the referring page that linked you to us (e.g. another website or a search engine); the pages you visit on our website; the website you visit after you visit our website; other information about the type of web browser, related software and settings you are using; any search terms you have entered on the website or a referral site; and other web usage activity and data logged by our web servers. We use this information for internal system administration, to help diagnose problems with our server and to administer the website. Such information may also be used to gather broad demographic information, such as country of origin. Any or all of activities with regard to our website usage information may be performed on our behalf by our services providers.
Aggregated Data
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Special Categories of Personal Data
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Security and Fraud Prevention
We may use your personal information to ensure the security of your use of the website and our business, and for the purposes of preventing or detecting fraud or abuses of our services.
2. PURPOSES OF PROCESSING YOUR PERSONAL INFORMATION
We process your personal information in order to operate, maintain and provide you with the features and various functionalities of the services (including any additional functionalities you may have requested). We also process your personal information to provide user service and support. We will always indicate where the provision of certain information is voluntary and you will be able to withdraw your consent or exercise your rights in relation to this information at any time as described in this Privacy Policy.
We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do this. Typically, the legal basis will be one of the following:
- because it is necessary to fulfil a contract that we have in place with you;
- for our or our third parties’ legitimate business interests;
- your consent; orwhere the processing is necessary for compliance with our legal obligations.
If you would like to find out more about the legal basis for which we process personal data please contact us.
3. COOKIES AND SIMILAR TECHNOLOGIES
Our website uses cookies and technologies which are similar to cookies. To find out more about the cookies we use and how to manage your cookie settings, please see our Cookie Policy.
4. HOW LONG WE STORE YOUR PERSONAL DATA FOR
We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. We apply criteria to determine the appropriate retention period for different categories of personal information you provide us with. For example, we will keep information necessary to protect us in a legal claim, such as information relating to a contract, for the lifetime of the contract and up to seven years after. After this period it will be deleted or in some cases anonymised. Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information.
5. WHERE WE STORE YOUR PERSONAL DATA
We operate on a global basis. The information that we collect may be transferred to, and stored at, a destination outside the country in which it is collected, which may have less strict, or no data protection laws, when compared to those in your country. It may also be processed by staff operating outside the country in which it is collected who work for us or for one of our suppliers, for example in the provision of support services. By submitting your personal information, you consent to this transfer, storing or processing of your personal information.
Whenever we transfer your information outside of the country in which it is collected, we will take all steps reasonably necessary to ensure that appropriate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this Privacy Policy.
To this end:
- we ensure transfers within our group of companies (which means our subsidiaries, our ultimate holding company and its subsidiaries) (“Group”) will be covered by an agreement entered into by members of the Group which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred within the Group;
- where we transfer your personal data outside the Group or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal data. Some of these assurances are well recognised certification schemes like the EU/US Privacy Shield for the protection of personal data transferred from within the EU to the United States; or
- where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal data are disclosed.
You have a right to request more information using the email address in the “Contact Us” section of this Privacy Policy about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal data when this is transferred as mentioned above.
6. DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our Group.
We may disclose your personal information to third parties: (a) in the event that we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets; (b) if we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our users will be one of the transferred assets; or (c) if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request.
We may also disclose your personal information: (a) to enforce any part of this Privacy Policy and the Terms, or to investigate potential breaches; or (b) to protect the rights, property or safety of us or our users, or others.
We may share your information with our service providers and other third party partners who help us to operate the website, for example, website or database hosting companies, e-mail service providers, analytics companies, distribution companies, fulfilment companies and other similar service providers. Such parties may process information about you on our behalf to assist, for example, with the provision of support services.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. For example, we may disclose to our third party partners aggregate, anonymous data regarding user behaviour as a measure of interest in and use of our website. Such data may include overall patterns or demographic reports from which an individual cannot be identified.
7. SECURITY
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted via the website; any transmission is at your own risk.
8. ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS
We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the website and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by us and others to, among other things, analyse and track data, determine the popularity of certain content, deliver advertising and content targeted to your interest on the website and other websites and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioural advertising purposes, please visit www.aboutads.info/choices.
9. YOUR DATA PROTECTION RIGHTS
For website visitors located in the European Union, applicable data protection legislation provides certain rights in relation to your personal information. These include: the right to object to and / or withdraw consent to the processing of your personal information, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information. We will handle any request to exercise your rights in accordance with applicable law. If you wish to exercise any of these rights please refer to the “Contact Us” section of this Privacy Policy. You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. For the purposes of EU data protection law, the data controller in respect of your personal information is DTC.
10. CHANGES TO THIS PRIVACY POLICY
We may change this Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business. If we make changes, we will notify you by revising the date at the bottom of this policy and, in some cases, we may provide you with additional notice (such as by adding a statement to our website homepage or, where possible, sending you an email). We encourage you to review the Privacy Policy when you access the website to stay informed about our information practices and the choices available to you. The date this Privacy Policy was last updated appears at the bottom.
11. THIRD PARTY WEBSITES
You might find external links to third party websites on our website. This privacy notice does not apply to your use of a third party site.
12. CONTACT US
Questions and comments regarding this Privacy Policy should be sent to: [email protected].
Registered company name: De Beers Global Sightholder Sales (Pty) Limited, trading as DTC
Address: PO Box, 329, Gaborone, Botswana
Registered company number: CO2008/5689
DTC™ is used under licence by De Beers UK Limited.
This Privacy Policy was last updated on 31 March 2019.