Privacy policy

This Privacy Policy describes how Ulka Jewells ("Ulka Jewells", "we", "us", or "our") collects, uses, and discloses your personal information when you visit ulkajewells.com (the "Site"), place an order for jewellery with us, or otherwise communicate with us regarding the Site (collectively, the "Services"). For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully.

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the "Last updated" date and take any other steps required by applicable law.

To provide the Services, we collect and have collected over the past 12 months personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us.

In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide or improve the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

What Personal Information We Collect

The types of personal information we obtain about you depend on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

Information We Collect Directly from You

Information that you directly submit to us through our Services may include:

• Contact details including your name, address, phone number, and email.
• Order and jewellery purchase information including your billing and shipping address, the pieces you purchase, ring sizing or personalisation details (such as engraving or a gift message), payment confirmation, email address and phone number.
• Account information including your username, password, security questions and other information used for account security purposes.
• Delivery verification details for insured, high-value shipments, our courier partner may request a signature, OTP, or photo ID at the time of delivery, which we retain only as required to confirm safe delivery of your order.
• Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services, our contact form, email or WhatsApp.

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

Information We Collect about Your Usage

We may also automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

Information We Obtain from Third Parties

Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

• Companies who support our Site, hosting and Services, such as our website platform, IT and analytics providers.
• Our payment processors, who collect payment information (e.g., bank account, credit or debit card, UPI or wallet information, billing address) to process your payment in order to fulfil your orders and provide you with the jewellery you have purchased. We do not store your full card or payment credentials ourselves — these are handled directly by our payment processor.
• Our courier and logistics partners, who share delivery status, tracking and delivery confirmation information with us to help fulfil and support your order.
• When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Also see the section below, Third Party Websites and Links.

How We Use Your Personal Information

• Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, craft and fulfil your orders, send notifications related to your account, purchases, returns, exchanges or other transactions, create, maintain and otherwise manage your account, arrange for insured shipping, facilitate any returns, exchanges or our Upcycling Program, and other features and functionalities related to your account.
• Marketing and Advertising. With your consent or where otherwise permitted, we may use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, WhatsApp, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in selling our products, according to Art. 6 (1) (f) GDPR.
• Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity, and to verify the identity of recipients for high-value, insured jewellery deliveries. If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in keeping our website secure for you and other customers, according to Art. 6 (1) (f) GDPR.
• Communicating with You and Service Improvement. We use your personal information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you according to Art. 6 (1) (f) GDPR.

Like most websites, we use Cookies on our Site to keep your cart and preferences remembered as you browse, to help our Site function correctly, and to run analytics so we can better understand how customers use our Services (in our legitimate interests to administer, improve and optimise the Services). We may also permit trusted third parties and service providers to use Cookies on our Site to better tailor the services, products and advertising you see on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your experience and may cause some features of the Services to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

Our website also recognises the Global Privacy Control (GPC) signal, which enables you to opt out of certain uses or disclosures of your information. If you notify us of your preference through GPC, we will treat such signal as a valid request to opt out of sharing or targeted advertising for the associated browser or device. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/. Other than the Global Privacy Control, we do not currently recognise other "Do Not Track" signals that may be sent from your web browser or device.

In certain circumstances, we may disclose your personal information to third parties for contract fulfilment purposes, legitimate purposes and other reasons subject to this Privacy Policy. Such circumstances may include:

• With vendors or other third parties who perform services on our behalf (e.g., website hosting and IT management, payment processing, courier and logistics fulfilment, data analytics, customer support, cloud storage).
• With business and marketing partners to provide services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices.
• When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you your jewellery or through your use of social media widgets or login integrations, with your consent.
• With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
• In connection with a business transaction such as a merger or sale of the business, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

We have in the past 12 months disclosed the following categories of personal information for the purposes set out above in "How We Collect and Use Your Personal Information" and "How We Disclose Personal Information":

We do not use or disclose sensitive personal information without your consent or for the purpose of inferring characteristics about you.

We have "sold" or "shared" (as those terms are defined in applicable law) personal information over the preceding 12 months for the purpose of engaging in advertising and marketing activities, as follows.

Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you share on public or semi-public venues, including third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

As of the effective date of this Privacy Policy, we do not have actual knowledge that we "share" or "sell" (as those terms are defined in applicable law) personal information of individuals under 16 years of age.

We take reasonable technical and organisational measures to protect your personal information, particularly given the value of the jewellery orders and payment details we handle. That said, please be aware that no security measures are perfect or impenetrable, and we cannot guarantee "perfect security". Any information you send to us may not be secure while in transit, so we recommend that you avoid using insecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, provide the Services (including warranty, resizing or upcycling requests on past orders), comply with legal obligations, resolve disputes, or enforce other applicable contracts and policies.

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information — for example, under the EU/UK General Data Protection Regulation (GDPR), applicable US state privacy laws, or India's Digital Personal Data Protection Act, 2023. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

• Right to Access / Know: You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.
• Right to Delete: You may have a right to request that we delete personal information we maintain about you.
• Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you.
• Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.
• Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.
• Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.
• Managing Communication Preferences: We may send you promotional emails or WhatsApp messages, and you may opt out of receiving these at any time by using the unsubscribe option in our emails, or by telling us directly. If you opt out, we may still send you non-promotional messages, such as those about your account or orders.

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or order information, before providing a substantive response to your request. In accordance with applicable laws, you may designate an authorised agent to make requests on your behalf. Before accepting such a request from an agent, we will require that the agent provide proof you have authorised them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request within the time required under applicable law.

If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response, depending on where you live, you may have the right to appeal our decision by contacting us again, or to lodge your complaint with your local data protection authority. For the EEA, you can find a list of the responsible data protection supervisory authorities here.

As we ship our jewellery worldwide, we may transfer, store and process your personal information outside the country you live in, including in India where our studio is based. Your personal information may also be processed by our staff and third-party service providers and partners in these countries.

If we transfer your personal information out of Europe, we will rely on recognised transfer mechanisms such as the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, unless the transfer is to a country determined to provide an adequate level of protection.