GDPR

This edition is valid from 01/05/2023.

This notice on the protection of personal data describes the method of collection and further processing of personal data by Eden gems s.r.o., IČO: 17982600, which is the exclusive owner of the sale of Adda jewelry in the Czech Republic.

The term personal data must include all information relating to identified or identifiable persons.

Section I of this privacy notice describes generally how Eden gems processes personal data. Part II contains specific provisions for specific uses (such as online commerce, newsletter and banner ads) and Part III contains specific provisions for customer programs.

If you provide Eden gems with personal information about other people, such as the recipient of a gift, you will only provide this information to Eden gems if you have permission to do so under applicable data protection laws and only if the person concerned has consented to you providing her personal data to Eden gems for the purposes for which the data is collected and to process her personal data in accordance with our privacy notice.

DECLARATION

We declare that, as the administrator of your personal data, we fulfill all legal obligations required by applicable legislation, in particular the Personal Data Protection Act and the GDPR, and therefore that:

we will process your personal data only on the basis of a valid legal reason, namely legitimate interest, fulfillment of a contract, legal obligation or consent, we fulfill the information obligation according to Article 13 of the GDPR even before starting the processing of personal data, we will enable and support you in applying and fulfilling your rights under the Personal Data Protection Act and the GDPR.

I. GENERAL PROVISIONS

1. ADMINISTRATOR, COMMISSIONER FOR THE PROTECTION OF PERSONAL DATA

Each website (including online stores and mini-websites for special offers), each social media presence on multimedia portals, chatbots and each application of Eden gems (each WEBSITE) has its own administrator within Eden gems with respect to the collection of personal data in accordance with the General Data Protection Regulation (GDPR) in the EU (or equivalent provisions under applicable data protection laws). Unless otherwise stated on the WEBSITE (according to circulation, conditions of use, etc.) or below in parts II and III, the company Eden gems, ID 17982600, is the administrator of the online stores www.addagems.cz.

Eden gems has not appointed a data protection officer pursuant to Article 37 of the GDPR, other than Eden gems.

HOW TO CONTACT EDEN GEMS

If you wish to exercise any of your rights relating to newsletter subscription, data access or deletion, please contact our customer care team who will be happy to answer any questions you may have.

Any questions or complaints about our privacy policy or the processing of personal data can also be addressed to the group's privacy team at edengems.cz@gmail.com.

2. PROCESSING OF PERSONAL DATA

Eden gems collects and processes personal data

registered users of the addagems.cz WEBSITE;

of users registered on the WEBSITE (for example, if the user creates a user account);

persons who purchase and receive / benefit from Eden gems products and services;

potential and current parties interested in Eden gems products and services;

recipients of the Adda newsletter;

survey participants in research campaigns and opinion polls conducted by Eden gems;

participants in courses, seminars and other training organized by the Eden gems company;

users of the WI-FI network provided in Eden gems stores and other locations;

registered participants of Eden gems' customer loyalty programs (CUSTOMER PROGRAM) (collectively, CUSTOMERS).

CUSTOMERS' personal information is generally collected directly by Eden gems during use of the WEBSITE as well as at Eden gems stores or events or through direct communication such as email, telephone or other means. Personal data may also be collected indirectly, for example by independent processors, such as PARTNERS of Eden gems (as defined below, including wholesalers, resellers, retailers, suppliers and other business partners such as customer service providers). Eden gems also collects data when the CUSTOMER making the purchase does not match the person benefiting from the purchase, or when the purchase is shipped to another person (for example, as a gift), based on a third-party recommendation (for example, a recommendation from the CUSTOMER's family or friends). or through further obtaining additional information from third-party data sources (for example, social media).

In particular, the following categories of personal data are processed by Eden gems:

• personal data and contact information, including but not limited to first and last name, maiden name, address, domicile, telephone number, email address, age, date of birth, gender, marital status, relatives, emergency contact, pictures;
• data related to orders and purchases, including but not limited to payment information, credit card and other payment information (in accordance with other laws and regulations), billing and delivery addresses, products and services ordered and purchased, information, inquiries and complaints that relating to products and services, or including corresponding concluded contracts, for example, warranty claims, after-sales services, repairs, customer care and services, withdrawal and disputes;
• data in connection with the marketing of products and services, including, but not limited to, information regarding the newsletter and other communication channels, consent or non-consent to participate, invitations to participate in events and special events (unless they are part of a customer loyalty program), further including preferences and interests and customer segmentation information;
• data related to the use of the WEBSITE, including, but not limited to, the IP address and other user identification (for example, username on social media, MAC address of a smart phone or computer, cookies), further including the date and time of the visit to the WEBSITE, pages visited and content and referring websites;
• communications data including, but not limited to, preferred means of communication, correspondence and communications with Eden gems (including records of communications);
• data that has been collected as part of the Customer Program, including but not limited to membership numbers, access codes (including passwords), preferred language, gift certificate numbers, date and duration of membership, payment information of the CUSTOMER or potential third party, including information relating to the recipient of the data , the number of visits to the WEBSITE, purchase history, products obtained (all WEBSITE accounts, activities and events for which the CUSTOMER must register using his own personal data and thereby enter into a contract with Eden gems shall be considered a customer program for the purposes of these policies, except for traditional customer loyalty programs); together then CUSTOMER DATA.

In addition, Eden gems collects:

• data of users of the WEBSITE who are not registered with Eden gems (VISITOR), but may include personal data for example from social media (VISITOR DATA), the provisions of this notice regarding data collected from the CUSTOMER in connection with the use of the WEBSITE apply accordingly, i when identification of the visitor by Eden gems is not usually possible;
• information relating to employees and other individuals who act on behalf of wholesalers, sellers, retailers, suppliers and other business partners of Eden gems (hereinafter natural persons referred to as PARTNERS, their data as PARTNER DATA), including but not limited to contact details, information about their function, information about previous contact with these individuals, data related to marketing activities (for example, receipt of a newsletter), information related to business transactions, requests, offers, tenders, terms and contracts, information related to the professional or other interests of these individuals.

With regard to the framework of their business relationship, CUSTOMERS are required to provide certain CUSTOMER DATA necessary for the creation of a contractual relationship and the fulfillment of related contractual obligations, or if required by law. Without this information, Eden gems will usually not be able to enter into or fulfill the contract with the corresponding CUSTOMER. This also applies analogously to PARTNERS DATA regarding the data of wholesalers, sellers, retailers, suppliers and other business partners of Eden gems; in principle, contracts cannot be concluded and processed without information about their employees or other contacts. As each access to the WEBSITE is logged, connection data (such as IP address) will always be recorded. This is done automatically during use and cannot be turned off for individual VISITORS, CUSTOMERS or PARTNERS.

3. PURPOSE OF PROCESSING AND LEGAL REASONS

3.1. PURPOSE OF PROCESSING

In accordance with applicable law, Eden gems may process CUSTOMER DATA for lawful purposes, including but not limited to the following:

in connection with the services offered, the conclusion of contracts (for example, purchases), the performance of contracts (for example, purchase contracts and contracts related to participation in customer programs and events), the maintenance and development of customer relationships, communications, customer service and support, promotions, advertising and marketing (including newsletter and sending advertising materials);

administration of WEBSITE users and other activities involving CUSTOMERS, operation and improvement of the WEBSITE (including providing functions that require identifiers or other personal data) and other IT systems and identity verification;

the protection of CUSTOMERS, employees and other individuals and the protection of data, secrets and assets of Eden gems or entrusted to it and the security of Eden gems' systems and sites;

complying with legal and regulatory requirements, including Eden gems' internal rules, enforcing and exercising legal rights and claims, defending against legal claims, legal action, complaints, combating abuse, engaging in legal investigations and dealing with and responding to inquiries from public authorities;

sales or acquisitions of business divisions, companies or parts of companies and other corporate transactions and transfers of CUSTOMER DATA related thereto; and

for other lawful purposes where such processing is obvious from the circumstances or is notified at the time of collection (collectively, CUSTOMER DATA PROCESSING PURPOSE).

3.2. LEGAL REASONS FOR PROCESSING

Eden gems uses CUSTOMER DATA for the PURPOSE OF PROCESSING CUSTOMER DATA based on the following LEGAL GROUNDS:

performance of contracts;

compliance with Eden gems' legal obligations;

the consent of the CUSTOMER (only with regard to processing based on a specific request, which can be revoked at any time, for example, receiving an information newsletter for which the CUSTOMER has registered)

The legitimate interest of Eden gems, including but not limited to

the purchase and delivery of products and services, also in connection with individuals who are not direct contractual partners (for example, individuals receiving a gift);

advertising and marketing activities;

effective and efficient customer support, contract maintenance and other communication with CUSTOMERS outside of contract processing;

understanding the behavior of the CUSTOMER, his activities, problems and needs, market study;

effective and efficient improvement of existing products and services and development of new products and services;

the effective and efficient protection of CUSTOMERS, employees and other individuals and the protection of data, secrets and assets of Eden gems or entrusted to it and the security of Eden gems' systems and sites;

maintaining and ensuring the efficient and effective organization of business operations, including the secure, efficient and effective operations and successful further development of websites and other IT systems;

reasonable requirements and development of company management;

successful sales and acquisitions of business units, companies or parts of companies and other corporate transactions;

compliance with legal and regulatory requirements and internal rules of Eden gems;

issues related to protection against fraud, misdemeanors and criminal acts and also including investigations in connection with such misdemeanors or other wrongdoing, further including the handling of complaints and actions conducted against the Eden gems company, cooperation in legal proceedings and with public authorities, including lawsuits, execution and defense against lawsuits.

In conjunction with applicable data protection laws, Eden gems may process VISITORS' DATA for the purposes of maintaining and developing the WEBSITE (including providing features that require identifiers or other personal data), for statistical analysis regarding the use of the WEBSITE, and to combat abuse, for the purposes of judicial investigation or proceedings and to answer questions from public administration bodies. VISITORS' DATA will be processed in accordance with the principles set out for CUSTOMER DATA above.

In accordance with applicable laws on the protection of personal data, Eden gems may process PARTNER DATA for the purpose of concluding and fulfilling contracts and other business relationships with PARTNERS, promotions, advertising and marketing, communication, invitation to events and participation in events for PARTNERS, joint organizations activities, compliance with legal and regulatory requirements and internal regulations of Eden gems, further including the enforcement and use of legal rights and claims, defense against legal claims, lawsuits, complaints, combating abuse, participation in legal investigations and proceedings and responding to inquiries from public authorities administration, further for the purpose of selling or acquiring business units, companies or parts of companies and other business transactions and related transfers of PARTNER DATA. PARTNER DATA will be processed in accordance with the principles set out for CUSTOMER DATA above.

4. DATA TRANSFER AND ACCESS

In accordance with applicable laws on the protection of PERSONAL DATA, Eden gems may transfer CUSTOMER DATA, VISITOR DATA and PARTNER DATA to the following categories of third parties that process PERSONAL DATA in accordance with the purpose of data processing on behalf of Eden gems or for their own purposes:

• service providers (within Eden gems and also external), including processors;
• wholesalers, resellers, retailers, suppliers and other business partners;
• customers of Eden gems;
• local, national or foreign authorities;
• the media;
• the public, including visitors to the Eden gems WEBSITE and social media;
• industry organizations, associations, organizations and other committees;
• acquirers or parties engaged in the acquisition of business units, companies or other parts of Eden gems;
• other parties to potential or actual legal proceedings;
• other companies of the Eden gemsI group (collectively THIRD PARTIES).

5. DATA RETENTION

In general, Eden Gems stores personal data only for the time necessary for the purposes for which the personal data is processed. Regardless of this general principle, Eden gems may process personal data for a longer period of time based on the following rules and obligations: Eden gems retains personal data for as long as Eden gems is (i) obliged to do so (by contract, law or other provisions) or (ii) as it has a higher interest (for example, an interest for reasons of evidence in case of complaints, documenting compliance with certain legal or other requirements, in the interest of non-personal analysis). Other rules are reserved, with regard to the anonymization or pseudonymization of personal data according to applicable law.

For the contract related to CUSTOMER DATA and PARTNER DATA (including business records and communications), the rule is that Eden gems retains personal data as long as the contractual obligation lasts and for a period of ten years after the termination of the contractual relationship, unless (i) applies in individual cases a shorter or longer statutory retention obligation, (ii) if retention is not required for documentation reasons or another valid reason based on applicable law or (iii) if data deletion is not required earlier (for example, for the reason that the data is no longer required or is required , for Eden gems to delete the corresponding data).

The rule for operational data containing CUSTOMER DATA, VISITOR DATA or PARTNER DATA (for example logs, records) is that Eden gems retains personal data for a period of 3-12 months.

6. COOKIES, GOOGLE ANALYTICS AND SOCIAL NETWORK PLUG-INS

Eden gems uses cookies on its WEBSITE. Cookies are a widely used technique that makes it possible to identify the user's browser of WEBSITES that the user stores and makes available on demand. Eden gems uses session cookies, which are automatically deleted when the user closes the WEBSITE, and which allow the server to establish a stable connection with the user (so, for example, the contents of the shopping cart are not lost) if the user is still browsing the WEBSITE. However, Eden gems also uses permanent cookies, which are only deleted after the period defined for each WEBSITE. Persistent cookies allow certain settings (such as language) to be stored for several sessions and enable automated login. The User agrees to the use of persistent cookies through the use of the WEBSITE and the corresponding functions (for example, language settings and automated login). The user can block or delete the use of cookies in his browser, but this action may interfere with the use of the website.

In accordance with applicable law, Eden gems may install code in the newsletter and other marketing emails to determine whether the recipient has opened the email or downloaded the images contained therein. However, the recipient can block this feature in their email application. In any case, the recipient consents to the use of this technology by receiving newsletters or other marketing emails.

In the event that Eden gems places third-party advertisements on the WEBSITE (for example, banners) or places its own advertisement on a third-party website, the cookies of a company specializing in the use of such advertisements may be used. Eden gems will not disclose personal information to such companies, i.e. these companies can only place a persistent cookie on users of the WEBSITE to recognize those users and do so in the sole interest of Eden gems. This enables Eden gems to place advertisements targeted at these individuals on external third-party websites (for example, in conjunction with products that these individuals have shown interest in in the online store). Eden gems will not disclose personal data to external website operators.

Eden gems uses Google or similar services on its WEBSITE. These applications are third-party services that allow Eden gems to measure and analyze the use of its WEBSITES. The provider of these services can be based in any country in the world (in the case of Google Analytics operated by Google Inc., it is the USA, www.google.com). The service provider uses persistent cookies for these applications. Eden gems will not disclose any personal data to the service provider (which also does not store any IP address). However, the Service Provider may monitor the user's use of the WEBSITE and combine this data with data from other websites monitored by the same Service Provider that the User has visited, and the Service Provider may use these findings for its own needs (for example, to control advertising). The service provider knows the identity of the user who registered with the service provider. In such case, the processing of personal data will be the responsibility of the service provider and the data will be processed in accordance with the personal data protection and privacy laws and the personal data protection policies of the service provider (for Google, see policies.google.com/privacy). The service provider will provide data about the use of the WEBSITE to Eden gems.

In addition, Eden gems may use social media network plug-ins on its WEBSITE, such as Facebook, Twitter, YouTube, Google+, Pinterest or Instagram. By default WEBSITE plugins are disabled. The user can thus choose whether he wants to activate them. Should the user do so, the social media providers can establish a direct connection with the user during his visit to the WEBSITE, which allows the provider to be aware of the user's visit and can analyze the relevant information. The subsequent processing of personal data will be carried out under the responsibility of the social media provider, according to the laws on the protection of personal data and privacy and according to the privacy policy published on the website (for example www.facebook.com/; www.twitter.com/; www.youtube. com/; www.google.com/; www.instagram.com/.

7. RIGHTS OF CUSTOMERS, VISITORS AND PARTNERS

Any affected individual, including any CUSTOMER, VISITOR and PARTNER, may request information from Eden gems as to whether their data is being further processed. In addition, they have the right to request the correction, destruction or restriction of personal data concerning them, as well as to object to the processing of personal data. If the processing of personal data was based on consent, the relevant individual can withdraw his consent at any time. In EU and EEA countries, the data subject may, in certain cases, have the right to receive data generated during the use of online services in a structured, common, machine-readable format that enables further use and transfer. Requests in this regard must be forwarded to the point of contact (see paragraph 1 above). Eden gems reserves the right to limit the rights of relevant individuals in accordance with applicable laws, such as not to make available exhaustive information or not to delete data.

In the event that Eden gems makes an automated decision with respect to a specific individual that may have a legal impact on that individual or may materially affect that individual in a similar manner, that individual has the right to communicate with the administrator of Eden gems in accordance with applicable law and request consideration of the decision or request a prior evaluation by the administrator. In such a case, the individual concerned may no longer be able to use certain automated services. The individual will be informed about this as follows or separately in advance.

Any affected individual may also file a complaint.

8. CHANGES TO THE PRIVACY NOTICE

Eden gems reserves the right to change this privacy notice at any time without notice or notification. The latest version published on the Eden gems WEBSITE always applies. If the privacy notice forms part of the contract with CUSTOMERS and PARTNERS, Eden gems may inform them of the update or additions by e-mail or other appropriate means. Changes are considered accepted if no objection is filed within 30 days of notification. In the event of objections, Eden gems will be able to freely and exceptionally terminate the contract with immediate effect.

II. SPECIAL PROVISIONS

The following provisions are in addition to the general provisions in Part I and relate to certain activities of Eden gems. In the event of any disagreement, the following provisions shall prevail.

NEWSLETTER AND ADVERTISING BANNERS

Eden gems may send newsletters or other commercial communications in connection with its products and services to CUSTOMERS and PARTNERS. In accordance with applicable laws, Eden gems reserves the right to do so without the prior consent of existing customers and business partners. However, the respective CUSTOMERS and BUSINESS PARTNERS may at any time refuse to receive further newsletters or other commercial communications through their account on the respective WEBSITE or through a dedicated link in each message. However, unsubscribing from one newsletter may not unsubscribe from other newsletters.

Eden gems reserves the right to provide advertising customization during your visit to the WEBSITE. Such advertising banners displayed to the CUSTOMER contain products offered on the WEBSITE that were previously viewed by the CUSTOMER. Advertising is generated by Eden gems using cookies (see Part I above).

VIDEO MONITORING SYSTEM

Some premises and offices of Eden gems are monitored by a camera system. By the administrator of personal data collected as part of the camera system recordings in relation to the collection of personal data in accordance with the European General Data Protection Regulation ("GDPR") and the provisions of other applicable laws governing the protection of personal data (collectively, "laws governing the protection of personal data") is the company Eden gems listed in the subject premises and offices. The processing of personal data is necessary for the purposes of the legitimate interests of Eden gems, i.e. to ensure security in the premises and protection of the property of Eden gems. Eden gems will not use personal data for automated decision-making purposes, including profiling. Eden gems usually keeps personal data for no longer than is necessary for the purposes for which the personal data is processed. Records are overwritten after a short period of time, unless they contain events that could be the subject of legal claims. In such a case, personal data is processed for the period of limitation of all claims. In accordance with personal data protection laws, Eden gems may transfer personal data to the following categories of third parties who process personal data in accordance with the purpose of data processing on behalf of Eden gems or for their own purposes: service providers including processors; to local, national and foreign authorities; to other parties in potential or actual legal proceedings. If data is provided to countries that do not guarantee adequate protection, Eden gems will ensure adequate protection of the transferred data by adopting adequate contractual guarantees (e.g. based on EU standard clauses), binding business rules or transfer based on consent, conclusion or performance of a contract, in in connection with the determination, application or enforcement of legal claims, prevailing public interests or for the purpose of protecting the integrity of these persons.

Any data subject may request information from Eden gems as to whether data concerning him or her is being processed. In addition, he has the right to request the correction, destruction or restriction of personal data concerning him, the right to object to the processing of personal data and the right to data portability. Any affected person can also file a complaint with the competent authority for the protection of personal data.

If you wish to exercise any of your rights or have any questions or objections regarding our privacy policy or the processing of your personal data, you can address them to the group's data protection team at edengems.cz@gmail.com.

III. SPECIAL PRIVACY NOTICE FOR CUSTOMER PROGRAMS

The provisions of this Part II define the general provisions in Part I that relate to Eden gems' customer programs.

1. ADDA.CZ SOCIETY (ACS)

The following provisions apply to data processing by Eden gems in connection with the customer loyalty program ADDA.CZ Society (ACS).

a. Responsibility for personal data (administrator)

PERSONAL DATA in connection with membership in the ACS program is processed by the administrator of Eden gems, which provides membership on the basis of a membership application and receives membership contributions.

b. Processing of personal data and source

Eden gems collects and stores the mandatory personal data provided in the ACS membership application (including, but not limited to, title, name, contact information, date of birth, previous ACS membership number, preferred language, order data, and if applicable including name, contact information and membership number in the ACS program of the donor of the membership) submitted by the ACS member on their own behalf or submitted by the person purchasing the ACS membership as a gift, and provides to Eden gems the PERSONAL DATA of the ACS member ("Application Data"). In addition, Eden gems also collects any personal information voluntarily provided by the customer in the member section of the website or when communicating with us: styles/interests (e.g. jewelry and accessories), social media accounts (and related information obtained when logging into social networks), gender, IP address and online identifiers.

Eden gems obtains this PERSONAL DATA from the points of sale where the membership was ordered and paid for. Each new member of the ACS program is assigned a unique membership number, records the membership start and renewal dates, the services and messaging methods selected by the ACS member, the services provided (including gifts sent) and, if applicable, other information about the ACS member's use of Internet offerings and messages sent by the Eden gems group (eg number of newsletter opens, click-through rates, websites visited online, social media interactions), and about interaction variables (eg click-through rates, interaction time or social media interactions). Eden gems may also process payment information, directly or through a third party, if necessary for the payment of ACS membership fees. In addition, Eden gems records the purchase history of each ACS member in the form of purchased goods (product specification, price) and place and time of purchase. Purchase history is recorded only in cases where the ACS membership number is provided at checkout when making a purchase in stores offering the ACS program. In the online store, a registered customer must activate his account online by creating an online account. A registered customer's purchase history is recorded if an account number is entered when making a purchase or if a registered customer makes a purchase while logged into their online account. Eden gems also collects and stores all coupons sent to the ACS member, possibly also other data about how the ACS member uses the Internet offers and communications sent by Eden gems (e.g. number of newsletter opens, click-through rate, websites visited online, interactions on social networks). If Eden gems determines that two different ACS membership numbers belong to the same person, or if it receives a valid application for an existing number, it may merge them.

c. Purpose of processing

The company Eden gems obtains and processes the personal data of members of the customer loyalty program in particular for the following purposes:

• ACS Program Membership Management
• Operating the ACS Program, specifically providing benefits and granting special conditions, participating in surveys, soliciting feedback and active use of social media
• Personalization and uniformity of customer experience in all channels (Adda stores, addagems.cz, e-mail communication, social networks)
• Delivering relevant information and personalized marketing content
• Other than marketing communications, including but not limited to changes related to our privacy policy, terms and conditions and/or terms of use; general changes to product and service offerings; account verification; password recovery; or information about incidents that could affect our services
• Providing personalized offers, help and advice on products and services
• Delivery of invitations to special events and promotional events reserved for registered customers
• Participation in surveys requesting customer feedback in all channels (Adda stores, addagems.cz, e-mail communication, social networks)

Membership in the ACS program allows its members to take advantage of extended advisory customer service in participating stores, where a store employee, after communicating the account number, has the opportunity to look at the registered customer's data and, based on his previous purchases, selected styles/interests or wish list, can better help him when purchasing help.

If a customer provides their ACS membership number, e-mail address, or registered customer's name and date of birth (or other unique identity verification information), the relevant store or customer service employee has access to that registered customer's relevant stored purchase data and wish list.

The Eden gems company uses the personal data obtained to ensure the administration and management of the membership (including for accounting and payment purposes), the provision of benefits and other services to which the members are entitled as a result of the membership (the legal basis is the membership), and the provision of commercial communications (e.g. newsletters, information about products, services and exclusive offers of the Eden gems group) to members of the ACS program by e-mail, post, in the form of messages to a mobile phone or by telephone based on the contact information provided by the member (to which Eden gems is authorized with the consent of the member of the program ACS). In all these cases, Eden gems may personalize the information sent to each member individually, so that the member receives in every possible case information that may be of interest to him in the opinion of the company. For this purpose, Eden gems analyzes the data from the request (in particular with regard to age, gender, interests and preferences) and other information that can be derived from purchase history or from data related to interactions in networks, or information voluntarily provided to Eden gems by an ACS member at any time thereafter. In addition, Eden gems may use personal data for the purposes of complying with its legal obligations and for statistical and research purposes if it has a legitimate interest, including to better understand ACS members, customers, for consumer market analysis, to improve the ACS program and to develop new products and services.

Non-marketing communications may be sent even if you have opted out of certain marketing communications, as they may be necessary in cases where we need to enter into a contract with you, we need to comply with legal obligations or security requirements. If you tell us your date of birth, we'll send you a personalized greeting card on that day.

d. Provision of personal data

During the processing of personal data in connection with the ACS program, Eden gems may transfer such data to the following categories of recipients:

• PARTNERS, including business partners and marketing and advertising partners (which includes social network partners), as well as all retail stores participating in this program or other authorized specialist sellers, regardless of whether the relevant entity is operated by Eden gems, or other business or collaboration partner; whereas these stores may be located in any country in the world and may use data obtained from Eden gems only for the purpose of operating the ACS program, including personalized offers to members and communications with members on behalf of Eden gems;

Data recipients may be located in a country where data protection is not at an adequate level. If this is the case, Eden gems will ensure an adequate level of data protection.

e. Rights of data subjects

ACS members and ACS membership donors are entitled to request from Eden gems at any time information regarding their stored personal data and other information required by applicable data protection laws. They are also entitled to request modification, restriction or deletion of their personal data or a copy thereof.

Registered customers of Eden gems may also withdraw any consent they have given to Eden gems in the future (e.g. consent to the use of data for promotional, advertising purposes, to the sending of newsletters and other commercial communications).

If you want to exercise your rights regarding subscription to the newsletter, access to data or the right to erasure of data, please do not hesitate to contact our customer care department at edengems.cz@gmail.com, where they will be happy to advise you and answer any questions. Please note that before we allow you access to your personal information, we may require verification of your identity.

f. Data Retention

Personal data will be retained and used for the duration of the membership; subsequently, they will be kept as long as necessary for the above-mentioned purposes, but not longer than five years, unless otherwise required for legal reasons. Purchase history is normally recorded for five years. As an exception to this rule, purchase history of ACS exclusive products will be retained for the duration of membership in order to assess the member's lifetime value to ACS. If an ACS member does not wish to have their purchase history of ACS exclusive products retained for more than 5 years, they may request deletion by contacting Customer Service and notifying them of their express wish to have this history deleted.