Privacy Policy

DEFINITIONS

"Company" means Neve Jewels FZCO, a free zone company trading as Austen & Blake, registered at Gold Tower-4C, Jumeirah Lake Tower, Premise No. 393-15174-3, Dubai, UAE, with Trade License Number DMCC-968128, which is a wholly-owned subsidiary of Neve Jewels Limited (UK, Company Number 06453160).

"Group Companies" means Neve Jewels FZCO, its parent company Neve Jewels Limited (UK, Company Number 06453160), its fellow subsidiaries and related entities of Neve Jewels Limited as defined under Federal Law No. 32 of 2021 on Commercial Companies.

"Website" means www.austenblake.ae and its associated pages and content.

"Website Content" means any information, text, images, photos, design, files, software, music, sound, and video available on the Website.

1. WHO WE ARE (DATA CONTROLLER)

Neve Jewels FZCO, a free zone company trading as Austen & Blake, registered at Gold Tower-4C, Jumeirah Lake Tower, Premise No. 393-15174-3, Dubai, UAE, with Trade License Number. We are the controller of your data.

We have appointed a Data Protection Officer (DPO) to oversee compliance with this policy, Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL). In case of queries, you can contact our DPO at [email protected]. The policy is available in English and Arabic upon request.

2. WHAT WE COLLECT (COLLECTION OF PERSONAL DATA)

Personal information is required only at the point of purchasing an item, when ordering a ring sizer or when you sign up for the newsletter. Personal Information includes, but is not limited to:

First Name, Last Name, Home, Billing or Physical address; E-mail Address; Phone Number & other Contact Information.

We may also collect the following information:

• Demographic information such as postcode, preferences and interests
• IP Addresses
• Other information relevant to customer preferences, surveys and/or offers
• We do not collect or process sensitive personal data (e.g., health, religion) unless directly relevant and with your explicit consent or other legal basis under PDPL Article 12.
• We minimize collection to what's necessary as defined under Federal Decree-Law No. 45 of 2021 (PDPL). We state that we do to collect children's data (under 16) without parental consent PDPL Article 4 and applicable UAE child protection regulations.

3. WHAT WE DO WITH THE INFORMATION WE GATHER

We are 100% committed to protecting your privacy and security and we totally appreciate and respect how important privacy is. We will strive to ensure that your data is not used for any other than aforementioned by us or by the third parties engaged by us.

This personal data will only be used for the specific purpose it was collected for.

We require this information to understand your needs and provide you with a better service, and for the following reasons:

• To process the order and deliver products in a timely manner
• To send confirmation and updates on your order
• Internal record keeping (e.g., order history; retained for up to 5 years per commercial laws, or until no longer needed)
• We may use the information to improve our website, products and services
• We may periodically send promotional emails about new products, special offers or other information, which we think you may find interesting using the email address, which you have provided (only with your explicit consent under TDRA Mobile Spam Policy and Cabinet Decision No. 56/2024; you can withdraw consent at any time)
• Note: At any point in time, if you do not wish to receive further communications from Us, you may select to opt-out of receiving such information or contact us.
• Opt-outs are processed within 10 business days, with unsubscribe in every message, sender ID, and no messages 9pm-7am. We maintain consent records for 2 years.
• When you visit our Website, Austen & Blake collects your IP address to, among other things, help diagnose problems with its server, administer and tune the operation of its Website, analyse trends, track traffic patterns, gather demographic information for aggregate use, and track the date and duration of each session within our Website. Your IP address may also be used in combination with your personal information for credit fraud protection and risk reduction (retained only as long as necessary for these purposes, typically up to 2 years; no profiling without transparency under Article 13).
• Before using or disclosing information, we ensure its accuracy and conduct Data Protection Impact Assessments (DPIA) for high-risk activities (Article 19). We limit retention to what's needed and delete when no longer required. You can withdraw consent for non-essential uses without affecting essential services.
• We comply with Federal Law No. 15/2020 on Consumer Protection for fair marketing.

4. SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

In the event of a breach compromising security or posing high risk, we will notify the Telecommunications and Digital Government Regulatory Authority (TDRA) immediately and affected individuals if high risk, as per Article 9. We maintain an incident response plan overseen by our DPO.

5. COMPLIANCE WITH LAW AND FRAUD PROTECTION

We may collect and disclose any information, including personal information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request. We may collect and possibly share personally identifiable information and any other information available to us in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any personal or as otherwise required by law. We may also exchange information, including personally identifiable information, with other companies and organizations for credit fraud protection and risk reduction.

All disclosures are limited to what is necessary, with appropriate safeguards.

6. INFORMATION SHARED WITH THIRD PARTIES

Third parties may use your personal information with third parties only when necessary and with safeguards under PDPL Article 16 (processor contracts). For instance, when we ship the product out to you, we need to share your Full Name, Shipping Address with our delivery agent. Examples of other third parties that we may share your personal information will include: web hosting companies, fulfilment companies (e.g., companies that fulfil product orders), our group companies, its fellow subsidiaries (within and outside the UAE, with appropriate safeguards) jewellers, assemblers, data analysis firms, affiliates, third party consulting or marketing firms and e-mail service providers.

Additionally, if you use a credit card or other financing alternative to place an order with Austen & Blake, to confirm and process your order, we will share your personal information with such financing company.

These third parties only receive personal information if such information is needed to perform their function(s), and they are not authorized to use any personal information for any other purpose(s) other than the purpose(s) set forth by Austen & Blake.

We only provide third parties with the minimum amount of personal information necessary to complete the requested service, product and or transactions and are bound by contracts requiring PDPL compliance, including security obligations.

We conduct vendor due diligence and audits. Non-essential sharing requires your explicit consent.

7. YOUR RIGHTS

Under Federal Decree-Law No. 45 of 2021 (PDPL), you can:

• Right of Access (Article 14) - You can request confirmation on how your data is being processed, get access to the data, and also request details like purposes, recipients, retention periods, and sources. We will provide a copy (e.g., in electronic format when requested).
• Right of Rectification (Article 15) - You can request correction of inaccurate or incomplete data without undue delay. We will notify recipients (e.g., third parties) of changes.
• Right to Erasure ("Right to be Forgotten") (Article 16) - You can request deletion of data if it's no longer needed, or you withdraw your consent, or if we are unlawfully processing your personal data, or If you have any other objection. We will notify recipients (e.g., third parties) of changes.
• Right to Restriction of Processing (Article 17) - You can request temporary "freezing" of processing of your data (e.g., marking data as restricted) while accuracy is verified or your complaint is resolved. Your data can only be stored or used for legal claims.
• Notification Obligation Regarding Rectification or Erasure (Article 18)- We will communicate rectifications, erasures, or restrictions to recipients (e.g., third parties) unless impossible or disproportionate.
• to Data Portability (Article 19)- You can receive their data in a structured, machine-readable format (e.g., CSV/JSON) and transfer it to another controller. Such transfers apply only to automated processing based on consent or contract.
• Right to Object (Article 17)- You can object to processing based on legitimate interests, public tasks, or direct marketing at any time. We will stop these marketing or promotional campaigns, unless compelling reasons override (e.g., legal claims).
• Right Not to be Subject to Automated Individual Decision-Making (Article 20)- You can object to decisions based solely on automated processing (e.g., AI scoring) with legal effects (e.g., credit denial). We must allow human intervention if objected.

You can send a request via email at [email protected]. We will verify the identity.

You can also send an appeal to the UAE Data Office in case of no response from us for a month.

8. EMAIL THIS PRODUCT TO A FRIEND

When you e-mail a product to a friend, you and your friend's names and e-mail addresses are requested. This ensures that your friend will know that you have requested that Austen & Blake send them an email. You and your friend's e-mail addresses will only be used for this purpose unless permission is otherwise granted.

9. PRIVACY POLICY MOBILE MESSAGING SERVICE

• We value your privacy and the information you consent to share in relation to our SMS marketing service. We use this information to send you text notifications (for your order, including abandoned checkout reminders), text marketing offers, and transactional texts, including requests for reviews from us. Opt-in data and consent for text messaging will not be shared with any third parties except with messaging partners hired by us or the parent company, for the purpose of enabling and operating our text messaging program.
• Opt-in data and consent for text messaging will not be shared with any third-parties except with messaging partners, for the purpose of enabling and operating our text messaging program.
• Our website uses cookies to keep track of items you put into your shopping cart, including when you have abandoned your checkout. This information is used to determine when to send cart reminder messages via SMS.
• Explicit consent is required under PDPL Article 6 and UAE Consumer Protection Law (Federal Law No. 15 of 2020), with unsubscribe in every message (valid 1 month).Opt-out by replying "STOP" (valid 10 business days). We maintain consent records for 2 years.

10. BUSINESS TRANSFER

Your personally identifiable information may be disclosed as part of any merger, sale of company assets or acquisition, as well as in the event of an insolvency, bankruptcy or receivership, in which personally identifiable information would be transferred as one of the business assets of the Company. In Such cases, we ensure the successor adheres to PDPL standards and notifies you for consent to changes, per Article 4.

11. INTERNATIONAL TRANSFERS

Information collected on this Website may be stored and processed in the United Kingdom or any other country in which Austen & Blake or its affiliates, its fellow subsidiaries or agents maintain facilities and by using this Website, you consent to any such transfer of information outside of your country.

We ensure transfers comply with PDPL Article 23 (to adequate jurisdictions or with safeguards like standard contractual clauses). Your consent is obtained (e.g., via checkbox), with details of destinations, safeguards, and risks disclosed.

• We use safeguards such as: Standard Contractual Clauses (SCCs) .
• Data Protection Agreements with our service providers.

You can request details of these safeguards by contacting our DPO.

12. COOKIES & TRACKING

We use cookies for functionality (essential), analytics (Google Analytics—consent via banner), and marketing (retargeting). Manage via browser or our tools. See Cookie Policy.

14. LINKS TO OTHER WEBSITES

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information, which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question. Links comply with Consumer Protection Law No. 15/2020 (non-deceptive).

15. CONTROLLING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of your personal information in the following ways:

• Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes.
• If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or contacting us.

16. COMPLAINTS

We are always at your service, for any issue or complaint your may have with our website and our privacy policy. You may contact our DPO for issues. In case your issue is not resolved, you may escalate the matter to the UAE Data Office, the federal authority responsible for personal data protection.

Access, rectification, erasure, restriction, objection, portability (generally free unless unfounded; response within 1 month).

To exercise rights, contact our DPO at [email protected]. Provide verification details. If unsatisfied, complain to TDRA under Article 33.

You can restrict via forms (e.g., marketing opt-out checkboxes) or by emailing us.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties, which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information, which we hold about you under the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), as well as any applicable regulations issued by the UAE Data Protection Authority or relevant free zone authorities. A small fee will be payable.

If you would like a copy of the information held on you please contact Austen & Blake or send a letter to us at:

Austen & Blake's Business Address:

Austen & Blake

Gold Tower-4C,
Jumeirah Lake Tower,
Premise No. 393-15174-3
Dubai, UAE

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.

WE APPRECIATE YOUR VALUABLE FEEDBACK

If you have questions about this privacy policy, please contact the Austen & Blake customer service department. You may also send us your comments about the Austen & Blake website or the shopping experience in general, as we always appreciate feedback.