Privacy Policy

Effective Date: November 17, 2025
Last Updated: November 17, 2025

1. Introduction

JewlArray ("we," "our," or "us") operates the website https://jewlarray.ch(the "Site"). This Privacy Policy informs you of our policies regarding the collection, use, disclosure, and protection of personal information we receive from users of the Site.

By accessing or using our Site, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

2. Information Controller

For the purposes of the General Data Protection Regulation (GDPR) and the Swiss Federal Data Protection Act (FADP), the data controller is:

JewlArray
Email: shop@jewlarray.ch
Website: jewlarray.ch

3. Information We Collect

3.1 Personal Data You Provide

We collect personal data that you voluntarily provide to us when you:

• Create an account: Name, email address, phone number, password
• Place an order: Billing address, shipping address, payment information (processed through Shopify Payments)
• Contact us: Name, email address, message content, any other information you choose to provide
• Subscribe to marketing: Email address, communication preferences
• Participate in surveys or promotions: Name, contact information, responses, preferences

3.2 Payment Information

Payment transactions are processed through Shopify Payments and other secure third-party payment processors. We do not directly collect or store complete credit card numbers. Payment information is encrypted and transmitted directly to our payment processors in compliance with Payment Card Industry Data Security Standard (PCI-DSS) requirements.

3.3 Automatically Collected Information

When you visit our Site, we automatically collect certain information about your device and usage:

• Device Information: IP address, browser type and version, operating system, device identifiers
• Usage Data: Pages visited, time and date of visits, time spent on pages, click-stream data, referring/exit pages
• Location Information: Approximate geographic location based on IP address
• Cookies and Tracking Technologies: Cookie identifiers, web beacons, pixel tags (see Section 8)

3.4 Information from Third Parties

We may receive information about you from third-party sources, including:

• Social media platforms (if you interact with our social media presence)
• Analytics providers (Google Analytics, Shopify Analytics)
• Advertising networks and partners
• Fraud prevention services

4. How We Use Your Information

We process your personal data for the following purposes, based on the legal bases outlined in Section 5:

4.1 Order Processing and Fulfillment

• Process and fulfill your orders
• Arrange for shipping and delivery
• Process payments and prevent fraudulent transactions
• Send order confirmations, shipping notifications, and delivery updates
• Handle returns, exchanges, and refunds

4.2 Customer Service and Communication

• Respond to your inquiries, requests, and customer service needs
• Provide technical support
• Send important notices about changes to our terms, policies, or Site
• Manage your account and preferences

4.3 Marketing and Personalization

• Send promotional emails, newsletters, and special offers (with your consent)
• Personalize your shopping experience and product recommendations
• Display targeted advertisements based on your interests
• Conduct surveys and collect feedback

4.4 Business Operations and Improvement

• Analyze site usage and trends to improve our products and services
• Monitor and analyze the effectiveness of our marketing campaigns
• Develop new products, services, and features
• Conduct research and data analysis

4.5 Security and Legal Compliance

• Detect, prevent, and address fraud, security breaches, and illegal activities
• Protect the rights, property, and safety of JewlArray, our users, and the public
• Comply with applicable laws, regulations, legal processes, and governmental requests
• Enforce our Terms of Service and other legal agreements
• Resolve disputes and troubleshoot problems

5. Legal Basis for Processing (GDPR & Swiss FADP)

We process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to fulfill our contract with you (e.g., order processing, delivery)
• Consent: You have given explicit consent for specific processing activities (e.g., marketing emails)
• Legitimate Interests: Processing necessary for our legitimate business interests (e.g., fraud prevention, business analytics), provided these interests don't override your fundamental rights
• Legal Obligation: Processing required to comply with applicable laws and regulations

6. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information in the following circumstances:

6.1 Service Providers and Business Partners

We share information with trusted third-party service providers who perform services on our behalf:

• E-commerce Platform: Shopify Inc. (order processing, hosting)
• Payment Processors: Shopify Payments, credit card processors (PCI-DSS compliant)
• Shipping and Logistics: Swiss Post, DHL, and other carriers (delivery services)
• Email Services: Marketing and transactional email providers
• Analytics Providers: Google Analytics, Shopify Analytics (website analytics)
• Customer Support: Help desk and customer relationship management tools
• Fraud Prevention: Fraud detection and prevention services

These service providers are contractually obligated to use your personal data only for the specified purposes and to implement appropriate security measures.

6.2 Legal Requirements and Protection of Rights

We may disclose your information when required by law or when we believe disclosure is necessary to:

• Comply with applicable laws, regulations, legal processes, or governmental requests
• Enforce our Terms of Service, Privacy Policy, or other agreements
• Detect, prevent, or address fraud, security, or technical issues
• Protect the rights, property, or safety of JewlArray, our users, or the public
• Respond to claims that content violates the rights of third parties

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your personal information may be transferred to the successor entity. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

6.4 With Your Consent

We may share your information for purposes not described in this Privacy Policy with your explicit consent.

7. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption for data transmission
• Secure data storage with access controls
• Regular security assessments and audits
• Employee training on data protection and security
• PCI-DSS compliance for payment processing
• Firewalls and intrusion detection systems

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

8. Cookies and Tracking Technologies

8.1 Types of Cookies We Use

We use the following types of cookies and similar technologies:

• Essential Cookies: Required for the Site to function properly (e.g., shopping cart, authentication)
• Analytics Cookies: Help us understand how visitors use our Site (e.g., Google Analytics)
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Track your browsing activity to deliver personalized advertisements

8.2 Third-Party Cookies

We use third-party services that may place cookies on your device:

• Google Analytics (analytics and website optimization)
• Shopify (e-commerce platform functionality)
• Social media platforms (for social sharing features)

8.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies or delete specific cookies. Please note that blocking essential cookies may affect your ability to use certain features of our Site. For more information about managing cookies, visit:

• Chrome: chrome://settings/cookies
• Firefox: about:preferences#privacy
• Safari: Preferences > Privacy

9. Your Privacy Rights

9.1 General Rights

Depending on your location, you may have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal information we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete information
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data under certain circumstances
• Right to Restriction of Processing: Request that we limit how we use your information
• Right to Data Portability: Receive your data in a structured, commonly used format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw your consent at any time (where processing is based on consent)
• Right to Lodge a Complaint: File a complaint with a supervisory authority

9.2 Exercising Your Rights

To exercise any of these rights, please contact us at shop@jewlarray.ch. We will respond to your request within 30 days. To protect your privacy, we may ask you to verify your identity before processing your request.

9.3 Marketing Communications

You can opt out of receiving marketing emails at any time by:

• Clicking the "Unsubscribe" link in any marketing email
• Updating your account preferences
• Contacting us at shop@jewlarray.ch

Please note that even if you opt out of marketing communications, we will still send you transactional emails related to your orders and account.

10. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy. Specific retention periods include:

• Account Information: Retained until you request deletion or your account is inactive for 3 years
• Order Information: Retained for 10 years to comply with tax and accounting obligations
• Marketing Data: Retained until you withdraw consent or for 2 years of inactivity
• Analytics Data: Typically retained for 26 months (Google Analytics default)
• Customer Service Records: Retained for 3 years after the last interaction

After the retention period expires, we will securely delete or anonymize your personal information. We may retain certain information for longer periods if required by law or to establish, exercise, or defend legal claims.

11. International Data Transfers

Your personal information may be transferred to and processed in countries other than Switzerland, including the European Union, United States, and Canada. These countries may have different data protection laws than your country of residence.

When we transfer your data internationally, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions recognizing equivalent data protection standards
• Binding Corporate Rules for transfers within corporate groups
• Your explicit consent for specific transfers

For more information about the safeguards we use for international data transfers, please contact us at shop@jewlarray.ch.

12. Children's Privacy

Our Site is not directed to individuals under the age of 16, and we do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16 without parental consent, we will take steps to delete that information as quickly as possible.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at shop@jewlarray.ch.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

• Update the "Last Updated" date at the top of this policy
• Post the revised policy on this page
• Notify you via email or prominent notice on our Site for material changes
• Obtain your consent if required by applicable law

We encourage you to review this Privacy Policy periodically. Your continued use of the Site after changes are posted constitutes your acceptance of the revised policy.

14. Third-Party Links and Services

Our Site may contain links to third-party websites, plugins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices.

When you leave our Site, we encourage you to read the privacy policy of every website you visit.

15. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

16. Specific Jurisdictional Provisions

16.1 GDPR (European Union & EEA Residents)

If you are located in the European Union or European Economic Area, you have additional rights under the General Data Protection Regulation (GDPR):

• Legal Basis: We process your data based on consent, contract performance, legal obligations, or legitimate interests (as described in Section 5)
• Automated Decision-Making: We do not make decisions based solely on automated processing that produces legal effects concerning you
• Data Protection Officer: For data protection inquiries, contact shop@jewlarray.ch
• Supervisory Authority: You have the right to lodge a complaint with your local data protection authority
• Cross-Border Transfers: Data transfers outside the EEA are protected by Standard Contractual Clauses or adequacy decisions

EU Representative: For inquiries regarding our GDPR compliance, please contact shop@jewlarray.ch.

16.2 Swiss Federal Data Protection Act (FADP)

Swiss residents have rights similar to those under the GDPR. The Federal Data Protection and Information Commissioner (FDPIC) is the supervisory authority in Switzerland.

• Right to Information: You have the right to request information about the processing of your data
• Data Security: We implement measures consistent with Swiss data protection standards
• Complaints: You may file a complaint with the FDPIC at www.edoeb.admin.ch

16.3 California Consumer Privacy Act (CCPA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA):

• Right to Know: Request disclosure of the categories and specific pieces of personal information we collect
• Right to Delete: Request deletion of your personal information (subject to certain exceptions)
• Right to Opt-Out: We do not sell personal information, so there is no opt-out required
• Right to Non-Discrimination: You will not receive discriminatory treatment for exercising your CCPA rights

Categories of Personal Information Collected: Identifiers, commercial information, internet activity, geolocation data, and inferences drawn from this information.

Business Purposes: We use personal information for purposes described in Section 4 of this policy.

Do Not Sell My Personal Information: We do not sell personal information to third parties.

To exercise your CCPA rights, contact us at shop@jewlarray.ch or call +41 [phone number if available].

17. Consent and Acknowledgment

By using our Site, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Site or provide us with your personal information.

This Privacy Policy is effective as of November 17, 2025 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.