Introduction and Overview
Information We Collect
Information You Provide
We collect information you provide directly via the Service, including but not limited to when you register an account, update your profile, access our content, make a purchase, participate in a sweepstakes, contest, survey, or other promotion (“Promotion”), contact customer support, or apply for a job. We may use Service Providers (defined below) to collect this information.
The information we collect includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. The following is a list of the categories of information we collect and have collected in the last 12 months:
- Contact Data. We collect your first and last name, e-mail address, postal address, phone number, and other similar contact data.
- Credentials. We collect passwords and other information for authentication and account access.
- Demographic Data. We collect demographic information including your age, gender, and country.
- Payment Data. We collect data necessary to process your payment if you make a purchase, including your credit card number, and the security code and expiration date associated with your payment instrument. We do not store payment information after purchase.
- Profile Data. We collect your interests, favorites, wish lists, ring size preferences, and other profile data.
- Content. We collect the content of messages you send to us, such as feedback and product reviews you write, questions and information you provide to customer support or comments and content that you may post on social media channels. For example, if you contact a customer service representative or jewelry consultant and provide information to the consultant or submit a request through our Service, we will use your information to respond to your request and to provide you with additional information that we believe may be helpful to you. We may also collect content such as photos, videos or other content that you submit to us.
- Employment Data. We collect data as necessary to consider you for a job opening if you submit an application to us, including your employment history, resume, transcript, responses to questions listed on our job applications or other forms related to your application for employment, writing samples and references.
- Government Identification Data. You may provide to us other personal identifying information such as an image of your driver’s license or other government issued identification for fraud prevention purposes. You may also provide government issued identification numbers such as your social security number for tax reporting purposes in the event that you win a sweepstakes prize.
You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
Information Collected Automatically
VRAI automatically collects information about your device and how your device interacts with our Service. We may use Service Providers to collect this information. The categories of information we automatically collect and have collected in the last 12 months includes:
- Service Use Data. We collect data about the features you use, the pages you visit, the e-mails and advertisements you view, the products you purchase, the time of day you browse, your referring and exiting pages, and other similar information.
- Device Connectivity and Configuration Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information.
- IP Address and Device Identifiers. VRAI collects your IP address and other device identifiers, including mobile advertising identifiers. We collect this data for various purposes, including to assess, diagnose problems, and improve functioning of our Service, servers, and hosting providers as well as to analyze trends and traffic patterns, gather demographic information, track the date, time, and duration of each session within our website, prevent fraud, and customize our services and advertisements.
- Location Data. We collect data about your device’s location.
- Log Files. Our server logs automatically collect information, such as your IP address, your browser type and language, and the date and time of your visit, which helps us track users' movements around our site and understand trends.
- Operational: Cookies are essential in order for you to use our Service, such as our shopping bag, as well as to access password protected areas, such as your personal account.
- Analytics and Performance: Cookies collect information about how you use our Service and remember the choices you make (such as your language or location) to provide an enhanced performance and a more personalized experience.
- Customization: Cookies allow us to gather information on how our Service is being used so that we can provide content that is relevant to you.
- Social Networking: Cookies allow users to share our pages and content to third-party social networking sites.
- Web Beacons. VRAI also uses electronic images known as web beacons (also known as pixels) on the Service. When you access a website, video, e-mail, or advertisement that contains a pixel, the pixel may permit us or another party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from other parties that allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
- Location-Identifying Technologies. Location-aware technologies may be used to collect precise location data when you enable location-based services through your device. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.
Some information about your use of the Service and certain unaffiliated websites or services (described below) may be collected using Tracking Technologies across time and services and used by us and other parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and unaffiliated websites and services.
For further information on Tracking Technologies and your rights and choices regarding them, see the sections entitled “Other Parties” and “Your Rights and Choices” below.
Information from Other Sources
- Data brokers from which we purchase demographic data to supplement the data we collect.
- Social networks when you reference our Service or grant permission to VRAI to access your data on one or more of these services.
- Financing providers with which we offer financing for purchases, and financial services providers used for processing payments.
- Partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
- Advertising and marketing partners.
- Publicly-available sources such as open government databases or other data in the public domain.
Use of Information
- Manage our Service, including your registration, account, and transactions.
- Perform services requested by you, such as to process and fulfill your order, to respond to your comments, questions, and requests, and provide customer service.
- Send appointment reminders and otherwise assist in confirming or scheduling interactions with us.
- Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
- Prevent or take action regarding illegal activities, including suspected fraud.
- Monitor and analyze trends, usage, and activities.
- Conduct surveys and/or research on our users' demographics, interests, behavior.
- Improve our marketing and promotional efforts, Service content and product and service offerings.
- Develop and send you direct marketing, including advertisements and communications about our and other party products, offers, promotions, rewards, events, and services.
- Verify your eligibility and deliver prizes in connection with Promotions you have entered.
- Provide and serve advertising on our Service and unaffiliated websites and services.
- Comply with any applicable law, regulation, legal process or governmental request.
- Fulfill any other business or commercial purposes disclosed to you at your direction or with your consent.
We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.
Sharing of Information
- Service Providers. We share your information with agents, contractors, and other service providers in connection with their work on our behalf (collectively “Service Providers”). Our Service Providers only receive your information if such information is needed to perform their function(s), and they are not authorized to use such information for any other purpose(s) other than the purpose(s) set forth by VRAI. We only provide Service Providers with the information necessary to complete the requested service, product or transaction and contractually prohibit them from retaining, using, or disclosing information about you for any purpose other than performing the services for us. Notwithstanding the above, we may permit our Service Providers to use aggregate information which does not identify you or de-identified data for other purposes.
- Affiliates: We may share your information with our related entities including our parent and sister companies. For example, we may share your information with our affiliates for business purposes such as customer support, marketing, and technical operations.
- Business Partners: We may share your information with our business partners in connection with offering you co-branded services, selling or distributing our products, or engaging in joint marketing activities. For example, we may share information about you with a business partner for purposes of providing you with co-branded products or services that we may offer.
- Special Events: If you choose to participate in a special event (for example, a Promotion), VRAI may share your information with those organizations participating in the applicable event. Typically, these other parties do not use your information for any other purpose other than to manage the event. In some cases, these promotional partners may send you promotional materials regarding their products and services. By entering a Promotion, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness or other submitted content in advertising or marketing materials.
- Feedback, Testimonials and User Provided Content. If you provide feedback or testimonials on the Service or on VRAI products or services, or provide other user provided content (such as photos or videos), we may post and share this feedback, testimonial or other user provided content, including your information, on the Service, with partners, or in marketing and promotional materials. We may, in our sole discretion, edit feedback, testimonials or user provided content for length and content. California residents and data subjects in Europe have additional rights as set forth in “Additional Disclosures for California Residents” and “Additional Disclosures for Data Subjects in Europe” below.
- Facilitating Requests. We may share your information with other parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Service).
- Vendors and Other Parties. We share information with vendors and other parties for business and commercial purposes. For example, if we need to ship something to you, we must share your name and address with a shipping company. Vendors also include: web hosting companies, shipping and fulfillment companies (e.g., companies that ship or fulfill product orders), diamond or gemstone suppliers, jewelers, assemblers, insurance companies, data analysis firms, analytics and advertising technology companies, affiliates, customer service providers, consulting or marketing firms/providers, accounting, bookkeeping or legal firms, financial services firms, technology companies including, but not limited to, enterprise application firms, firms which provide technologies to enable electronic communications and data storage providers. Additionally, if you use a credit card or other financing alternative to place an order with VRAI, we will use a payment processor to process your information in association with the transaction. We may also share information with other companies and organizations for credit fraud protection and risk reduction. Vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. Information may be disclosed to vendors and other parties in connection with tailoring advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.
- Business Transfer. Your information may be disclosed as part of, or in connection with, any investment in the company, any merger, sale of company assets, or acquisition, as well as in the event of an insolvency, bankruptcy or receivership, in which information would be transferred as one of the business assets of VRAI.
- Security, Compliance with Law, and Fraud Protection. We may disclose your information as we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request. We also may share your information in order to investigate, prevent or take action regarding illegal activities, including suspected fraud, or as otherwise required by law. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any person or party.
- Consent. We may share your information for any other business or commercial purposes disclosed to you and with your consent.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with other parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.
VRAI does not knowingly collect personal information from children under the age of thirteen (13). In the event that VRAI ever does so, we will strictly comply with the Children's Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and believe VRAI has collected such information in a manner not permitted by COPPA, please contact us as set forth in the section entitled “Contact Us” below, and we will remove such data to the extent required by COPPA. In addition, we do not sell the personal information of minors under 16 years old who are California residents.
Other Party Websites And Services
- Liking and Sharing. We may embed a pixel or SDK on our Service that allows you to “like” or “share” content on your VRAI account through another website or service, including social networks such as Facebook and Twitter. If you choose to interact with social networks through our Service, we may collect any information you have authorized the social network to share with us (such as your user ID, billing information, public profile information, e-mail address, birthday, friends list, and other account and profile data). Likewise, if you choose to interact with other websites or services through our Service or visit our Service while logged into another party’s service, that other party may receive information about your activities on our Service and be able to associate that information with information the other party already has about you.
Analytics and Interest-Based Advertising
Our Service contains Tracking Technologies owned and operated by vendors and other parties. For example, we use Tracking Technologies from analytics provides, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide us with other services relating to Service activity and internet usage. We also work with ad serving services, advertisers, and other parties to serve advertisements on the Service and/or on other websites and services. These other parties may use Tracking Technologies on our Service (including in e-mails and advertisements) and on other websites and services to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on our Service and other parties’ services or devices after you have left the Service (“Interest-based Advertising”).
We may serve ads on other websites and services, which are targeted to reach people (or similar people) who have visited our Service or that are also identified in one of more of our databases (“Matched Ads”). This is done by us uploading a customer list to another party or incorporating a pixel from another party into our own Service, and the other party matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences.
For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.
Your Rights and Choices
Review and Update of Account Information
You may access, update, or remove certain account information that you have voluntarily submitted to us through the Service. If you would like to update or revise information in your account, you may do so through your account or by contacting us as set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents and data subjects in Europe have additional rights as set forth in the sections entitled “Additional Disclosures for California Residents” and “Additional Disclosures for Data Subjects in Europe” below.
Tracking Technology Choices
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit allaboutdnt.com.
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.
Analytics and Interest-Based Advertising
You can opt-out of your data being used by Google Analytics through cookies by visiting tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.
Some of the other parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit for website opt-out, aboutads.info/choices. In addition, some of these other parties may be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, please visit networkadvertising.org/choices/. If you are in the EU, please also visit the EU online choices page at http://www.youronlinechoices.com/. lease note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks).
We are not responsible for effectiveness of, or compliance with, any other parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
To opt-out of receiving e-mail promotions from VRAI, please follow the unsubscribe instructions in our promotional e-mail correspondence or contact us as set forth in the section entitled “Contact Us” below. Please note that opting out of promotional communication received from VRAI does not affect our non-promotional communications with you, including those related to your account, orders placed with VRAI, or our ongoing business relations.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Despite the measures we take, transmission via the Internet is not completely secure and we cannot guarantee the security of your information.
By email: firstname.lastname@example.org
By mail: VRAI LLC, attn: Legal / Privacy, 731 S Spring St, Ste 500, Los Angeles, CA 90014, USA
Additional Disclosures For California Residents
These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
California Notice Of Collection
In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:
- Identifiers, such as name, email address, phone number account name, IP address, and an ID or number assigned to your account.
- Customer records, such as billing and shipping address.
- Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
- Commercial information, such as products or services history and purchases.
- Internet activity, such as your interactions with our Service.
- Audio or visual data, such as photos or videos you share with us or post on the Service.
- Geolocation data,
- Employment and education data, such as data you provide when you apply for a job with us.
- Inferences, such as information about your interests, ring size preferences and favorites.
For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Use of Information” section, including to provide and manage our Service.
We use and partner with different types of entities to assist with our daily operations and manage our Service. Please review the “Sharing of Information” section for more detail about the parties we have shared information with.
VRAI does not sell your personal information.
Right To Know And Delete
If you are a California resident, you have the rights to delete the personal information we have collected from you and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the personal information; and
- The specific pieces of personal information we have collected about you.
To exercise any of these rights, please email a customer service representative at email@example.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
Right To Non-Discrimination
You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.
Shine The Light
If you are a customer in California, in addition to the rights set forth above, you have the right to request information from VRAI regarding the manner in which VRAI shares certain categories of personal information as defined by California’s “Shine the Light” with third parties and/or affiliates for their own direct marketing purposes. To receive this information, send us a request at the address set forth in the section entitled “Contact Us” above. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that VRAI may provide this information in a standardized format that is not specific to you and is not required to respond to requests made by means other than through the provided e-mail address or mail address.
Any California residents under the age of eighteen (18) who have registered to use the Service and posted content or information on the Service, can request that such information be removed from the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.
Additional Disclosures For Nevada Residents
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at firstname.lastname@example.org.
VRAI does not sell your personal information.
Additional Disclosures For Data Subjects In Europe
EU data protection law makes a distinction between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). VRAI, located at the address in the section entitled “Contact Us” above, is the controller with respect to information you provide through the Service.
EU data protection law requires a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or another party, and your interests and fundamental rights and freedoms do not override those interests.
Data Subject Rights
If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” above and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.