MBA Ventures, LLC: Privacy Policy

Your privacy is important to us at MBA Ventures LLC ("MBA", "we", "our", or "us"). This Privacy Policy applies to any website owned or operated by or on behalf of us, including, without limitation, this website currently located at mbadiamond.com (the "Website"), when you register for a customer account on the Website, when you complete or submit an order on the Website, when you authorize and consent to an MBA employee creating an account and/or submitting an order on your behalf, as well as any marketing or promotions subscribed to via the Website, and any other service or product of MBA, including digital properties, as expressly indicated by MBA such as through a link or other display of this Privacy Policy (collectively with the Website, the "Services"). This Privacy Policy describes what information, including Personal Information, we collect from or about you on our Services, how we use or share such information, and how to exercise any rights you may have with respect to your Personal Information.

Please carefully read this Privacy Policy, which is part of and subject to our Terms and Conditions, before using our Website or Services, including, without limitation, mbadiamond.com, and any related MBA web pages that display this Privacy Policy. If you do not agree with our Terms and Conditions and/or the Privacy Policy, please refrain from using our Website or Services. By accessing or using our Website or Services, you agree to our use of your Personal Information and other information consistent with the Terms and Conditions and this Privacy Policy.

Information We Collect

We collect various types of information about our users in connection with the Services, including:

• Information you provide to us during account creation, including identity data such as your full name;
• Contact Information and Account Information you provide to us during order submission, such as mailing address, billing address, email address, phone number, username and password, preferences, feedback, and survey responses;
• Information we collect from third-party shipping carriers and payment processors;
• Geolocation Information, which may include your IP address location;
• Transaction, Technical, and Communication Information, as well as Marketing Preferences our IT systems collect about your use of our Services to improve and customize your experience.

When information identifies or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, we refer to it as "Personal Information."

Personal Information You Provide to Us

We collect Personal Information you give us when you use certain Services. For example, we may ask for your name, email address, and account name when you sign up for an account with us, and we may ask for a street address or phone number when you submit an order. We also may collect information about the cards you've added to orders, how frequently you submit orders, and your use of promo codes.

Personal Information Shared with Us from Third-Parties

You consent to sharing some of your personal information with certain types of third parties for the purpose of using our Services when agreeing to our Terms and Conditions. We may collect Personal Information about you from these third parties, such as payment processors and shipping carriers handling your transactions. For example, a payment provider may return an email address or phone number that you provided to your bank, and a shipping carrier may return a zip code with your postal code. This information is logged as part of your transaction but not added to your customer profile. We are not responsible for the policies and practices of third parties. Any information you give to those organizations is dealt with under their privacy policy, Terms and Conditions, and other policies.

Your credit card information, debit card information, bank, and PayPal credentials are never seen nor retained by us. MBA does not access or store your financial information when you use our Services. MBA uses third-party providers to process payments. These providers' use and processing of your Personal Information, including your financial information, is subject to their privacy policies and not this Privacy Policy.

Personal Information Collected Automatically

In addition, we may use various tools and technologies like cookies and web server logs to automatically collect information about your use of the Services. This type of information would be used for system and Service troubleshooting. This information is not linked directly with your account and the personal information you have provided us. For example, we may collect:

• Device information - such as your hardware model, IP address, other unique device identifiers, operating system details, web browser type and version, internet service provider details, referring URLs, time and length of visits, and pages viewed, and settings of the device you use to access the Services.
• Usage information - the time and duration of your use of the Services and other information about your interaction with content offered through a Service, and any information stored in cookies and similar technologies that we have set on your device.
• Location information - such as your device's IP address, your mobile device's rough GPS signal when you use the Services.

Legal Basis for Processing Data

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

• Your consent When you have given clear consent for us to process your personal data for a specific purpose.
• Performance of a contract When the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
• Compliance with legal obligations When the processing is necessary for us to comply with the law (not including contractual obligations).
• Protection of vital interests When the processing is necessary to protect someone's life.
• Legitimate interests When the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

Data Breach Notification

In the event of a data breach, we will notify affected users and relevant authorities within 72 hours, as required by law. We will also take immediate steps to mitigate the breach and prevent future occurrences.

Children's Privacy

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any Personal Information to or on the Website. We do not knowingly collect Personal Information from children under 13. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.

Use by Minors Under 18

If you are under the age of 18 and use our Website or Services, you must have your parent's permission, and we will assume you have obtained such permission. We do not knowingly collect Personal Information from anyone under the age of 18. By using the Website or Services, you represent and warrant that you are at least 18 years old. If we become aware that a customer is under the age of 18 and has registered or otherwise provided Personal Information without parental consent, we will make reasonable efforts to delete such information from our records in accordance with applicable law.

How We Use Information

We use the information we collect to, among other things:

• Register and create your account.
• Send transactional emails to the email address specified on your account.
• Process and fulfill orders you submit.
• Deliver products and services you requested or contracted for.
• Charge payments and issue refunds for Services you request.
• Provide and manage the Services you request.
• Communicate with you about our products, services, and promotions that you have opted into receiving.
• Provide customer support and respond at your request.
• Manage your API credentials and access to data.
• Perform troubleshooting and debugging on IT systems.
• Comply with a legal obligation.
• Where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests.
• Help improve, upgrade, or enhance our services and products and develop new services and products.
• Monitor to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, and hold those responsible for that activity.
• Enforce our Terms and Conditions, including this Privacy Policy.
• We may otherwise use your information with your consent or at your direction.

Sharing of Your Personal Information

We will not sell, trade, or disclose your Personal Information to any third-party except as set forth in this Privacy Policy and as follows:

• For payment processors of our choosing to facilitate a payment or refund, including, but not limited to, PayPal and Authorize.Net, to complete credit card, debit card, PayPal, or any other MBA pre-approved method of payment.
• Shipping carriers and shipping carrier software providers, including but not limited to, USPS and FedEx. If you visit one of these linked websites, you should read the website's privacy policy, Terms and Conditions, and their other policies.
• Authentication platforms to verify your credentials.
• To fulfill the purpose for which you provide it.
• To MBA affiliated entities.
• Marketing and automation platforms for the purposes of sending notifications of events, products, and promotions that you have opted-in to.
• To designated service providers we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
• For any other purpose disclosed by us when you provide the information.
• To comply with any court order, law or legal process, including to respond to any law enforcement, government, or regulatory request.
• Other parties when required or permitted by law, as necessary to protect our users, or in connection with a corporate transaction.

We may disclose aggregated, non-personally identifiable information about the Website users without restriction.

Aggregated Data

We also work with, and may also provide to third parties, various types of data that are de-identified or aggregated, and not reasonably capable of being associated with, or reasonably be linked, directly or indirectly, with you or your household. This includes information about the items that have been serviced, their grades, certification codes, and images. This data is not Personal Information.

When Required or Permitted by Law, or As Necessary to Protect Our Users and Services

We reserve the right to disclose any personal information as needed if the information is requested by law enforcement agencies or if we are required to do so by law, regulation, subpoena, court order, or by a government entity. We also may disclose Personal Information to third parties if we have reason to believe that disclosing the information is necessary to conduct investigations of possible breaches of law, to cooperate in any legal investigations, or to identify, contact, or bring legal action against someone who may be violating the Terms and Conditions of our Website and Services.