Privacy Policy

1. Overview

  • 1.1 The Diarough group of companies offers information and trading services ("the Services") through, amongst others, its website. In order to operate the Services and to be in compliance with United States laws and regulations, including the USA PATRIOT ACT and OFAC requirements, Diarough may ask you to provide us with company, personal, credit card and/or bank account details. This Privacy Policy applies to all Diarough websites and Services and describes the information we collect and how we use that information. By virtue of the Belgian Act of 8 December 1992, on the protection of privacy with respect to the processing of personal data - M.D., 18 March 1993, the Client is informed of the fact that any personal data regarding himself, will be processed and saved by Diarough. These data are necessary for the execution of the Contract to which the Client is a party or for the execution of pre-contractual measures that may be taken on his request. The data will be used for the purpose of client administration, client services and commercial offers. The collected data will also be used for direct marketing. The Client has a right of access and rectification with respect to the personal data regarding himself, and to this effect may address Diarough at any time.
  • 1.2 Diarough takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Paragraph 4.3 below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on, whether the services are offered by Diarough, by its Subsidiaries, Business Partners or by its Affiliates in the Diarough Group.
  • 1.3 By using this website and the Services, you agree to accept the provisions of this Privacy Policy. By applying for any of the Services offered through this website, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy.

2. Notification of Changes

  • 2.1 This policy may be revised over time as new features are added to the Services or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only 30 days after we post an amended Privacy Policy.
  • 2.2 We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check this Web site at any time for the most current version of our Privacy Policy.
  • 2.3 This Web site may include links to third party Web sites. These sites are governed by their own privacy statements, and Diarough group is not responsible for their operations, including but not limited to their information practices. Licensees submitting information to or through these third party Web sites should review the privacy statement of these sites before providing them with personally identifiable information.

3. Information We Collect

  • 3.1 Required Information
    To subscribe or use the Services, you must provide personal and company details, address, phone number, and e-mail address. In order to trade through our website, you may be required to provide trade references, ID proofs, credit card, debit card or bank account information. This information is necessary for us to approve your membership and to process transactions or to contact you should the need arise in administering your membership.
  • 3.2 Transaction Information
    When you list a diamond for sale, purchase or sell a diamond, or use the Services in any way, we record information related to each transaction, including the amount of the transaction. We retain this information for each of your transactions through our website. We also collect the Internet address (IP address) of the computer or device you use to access your ediarough account.
  • 3.3 Information About You From Third Parties
    In order to protect us and our customers against potential fraud, we may verify with third parties the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. This may include background and credit check from a credit bureau or a business information service such as Dun & Bradstreet. Diarough group, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account, and reserves the right to close an account based on information obtained during this credit review process or for any reason whatsoever.
  • 3.4 Additional Verification
    If we cannot verify the information that you provide we may ask you to send us additional information (such as your drivers' license, credit card statement, and/or a recent utility bill or other information linking you to the applicable address), or to answer additional questions.
  • 3.5 Web Site Traffic Information
    Because of the way that World Wide Web communication standards work, when you arrive at or leave this Web site, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with ediarough.
  • 3.6 Diarough Message Center
    Messages sent to you and from you through the ediarough / Diarough communication tools are kept and maintained by Diarough.
  • 3.7 Our Use of "Cookies"
    This Web site uses cookies to enhance your browsing experience. Cookies are small pieces of information saved by your browser onto your computer. Cookies are used to remember various aspects of your visit. This information is used by us to guarantee a consistent and uninterrupted experience. Cookies will allow you to revisit without losing many of your settings. We do not use cookies to save personal information for outside uses.
  • 3.8 Customer Service Correspondence
    If you send us correspondence, including e-mails and faxes, we may retain such information in the records of your account. We may also record phone calls to or from our various offices. We may also retain customer service correspondence and other correspondence from Diarough to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our Agreement. We may, over time, delete these records if permitted by law.
  • 3.9 Questionnaires, Surveys and Profile Data
    From time to time, we may offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

4. Our Use and Disclosure of Information

  • 4.1 Internal Uses
    We use the information we collect about you in order 1) to provide our services and process your transactions, 2) to provide customer service, 3) to determine your eligibility to receive special trading privileges or products and 4) to improve our products and services. We will not use any personal identification information without your permission.
  • 4.2 Disclosure to Other Diarough Customers
    If you are a registered Diarough customer, your name, Company name, telephone numbers and e-mail address and other personal information in addition to the diamonds you are listing for sale may be displayed to other Diarough customers in diamond listings or in a member directory. Should you be expelled or excluded as a member/customer, your name and member details may be posted online. However, your credit card number, bank account and other financial information will NEVER be revealed to anyone except with your express written permission or if we are required to do so pursuant to a subpoena or other legal process.
  • 4.3 Disclosure to Third Parties Other Than Diarough Customers
    Diarough will not sell, rent or share any of your personally identifiable information to third parties, except in the limited circumstances described below, or with your express permission (or with other Diarough customers as described above). We may disclose information we collect in response to a law enforcement request, subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action. We may disclose information we collect in circumstances in which Diarough believes the Services are being used in the commission of a crime; when we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person; or when necessary either to protect the rights or property of Diarough, the Services or our subsidiaries, or affiliates in the Diarough Group, or for us to render the Services provided. We may disclose information we collect to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you). We may share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users have addresses in New York. However, this aggregated information is not tied to personally identifiable information. We may share your information with our parent, subsidiaries, affiliates and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.
  • 4.4 Our Contacts with Diarough Customers
    We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone or letter. We may use your e-mail to send information, transaction confirmations and to send notifications. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional. We also use your e-mail address to send you other types of communications which you may opt out of.
  • 4.5 Internet Address Information
    We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.
  • 4.6 Your Use of Information and Our Services - I
    In order to facilitate the transactions between Diarough & its clients, our Service may allow you limited access to other users' contact or shipping information. As a member, you may have access to the member information, email address or other contact or shipping information of other members. By consenting to the applicable Terms of Service, you agree that you will not share ediarough access logins and you will only use this information for: (a) ediarough-related communications that are not unsolicited commercial messages, (b) using services offered through (e.g. diamond trading), and (c) any other purpose that such user expressly agrees to after adequate disclosure of the purpose(s). In all cases, you must provide users with the opportunity to remove themselves from your database and review any information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personally identifiable information about another ediarough user to any third party without our consent and the consent of such other user after adequate disclosure. Note that law enforcement personnel and other rights holders are given different rights with respect to information they access. ediarough does not tolerate spam. Therefore, without limiting the foregoing, you may not add a ediarough user to your mail list (email or physical mail) without their express consent after adequate disclosure, even if said user has previously done business with you.
  • 4.6 Your Use of Information and Our Services - II
    Except if otherwise mentioned, Diarough grants the user a non-exclusive right, which cannot be assigned and which is limited in access, for the use, the visualization of this Website and the documents contained therein for a personal, non-commercial use that is to be in accordance with the stipulations of these Conditions of Use. Downloading the Contents onto your computer does not imply any right of property on this Content. It is strictly forbidden for you to modify the Contents or to use it to other effects, more in particular, in printed form, or to use it on any other Website or on any other information network, without having obtained prior authorization in writing from Diarough. By using this website, you accept not to use any web-robot, browser or any other automatic device or manual procedure intended to monitor or copy web-pages from our website or any Contents thereof, without having obtained prior authorization in writing from Diarough. You undertake not to use any device, software nor sub-program, intended to disturb or try to disturb the proper functioning of the website. In addition, you undertake not to perform any manipulation imposing an unreasonable or disproportionate load on the infrastructure of the website.

5. Information Security

  • 5.1 Diarough is committed to handling your customer information with high standards of information security. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
  • 5.2 The security of your subscription to any of the Services also relies on your protection of your password. You may not share your password with anyone. Diarough will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the website.
  • 5.3 Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, should be treated as unauthorized and suspicious and should be reported to Diarough immediately. If you do share your Diarough password with a third party for any reason, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please contact us immediately on [email protected]