California Privacy Policy
CALIFORNIA PRIVACY POLICY
Last Updated: December 29, 2022
California residents have specific rights under the California Consumer Privacy Act (“CCPA”) and other laws regarding their personal information. Our California Privacy Choices page provides California consumers with a one-stop shop to learn about our privacy practices, your legal rights and privacy choices, and other important information with respect to California residents. To make things as easy as possible, we have provided important links to help you navigate this page.
California Consumer Privacy Act Disclosures
- Notice at Collection. Learn more about the categories of personal information we collect as a CCPA-covered business and the purposes for which it is used.
- California Privacy Policy. View our comprehensive disclosures regarding the collection, use, disclosure, and sale of your personal information and understand your rights under the CCPA.
- Submit a CCPA Request. Exercise your rights under the CCPA, including your right to know, correct, or delete the personal information we have collected about you.
- Do Not Sell or Share My Personal Information. Opt-out of the sale or sharing of your personal information to third parties.
California Privacy Policy
This California Privacy Policy supplements the information contained in the Privacy Policy and applies solely to visitors, users, and others who are residents of the State of California. This section describes your rights under the California Consumer Privacy Act of 2018 (“CCPA”) and other California laws. Any terms defined in the CCPA have the same meaning as when used herein.
While we have set out the categories below as required by the CCPA, you can review our Privacy Policy for examples and other information that describes our data collection and use, which will not change under this notice.
Notice at Collection: The Personal Information We Collect
This Section provides notice of our personal information collection and use practices with respect to California residents. For ease of reference, we have presented the relevant information in a chart explaining our collection, use, and disclosure practices related to California residents. You can learn more about our specific practices by reading our more detailed disclosures in our Privacy Policy, including what terms used in this chart mean.
| Categories of Personal Information | Categories of Sources from which the Information was Collected | Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | Types of Third Parties with Whom this Category of Personal Information Is Shared/Sold |
| Identifiers (e.g., name, signature, address, telephone email, IP address) | · You (or your device) · Other Individuals · Business Services Providers · Affiliates · Governmental Entities | · Business Services Providers · Affiliates · Governmental Entities | Marketing and Advertising Providers |
| Customer Records (as defined in Cal. Civ. Code § 1798.80(e)) | · You (or your device) · Other Individuals · Business Services Providers · Affiliates · Governmental Entities | · Business Services Providers · Affiliates · Governmental Entities | We do not sell or share |
| Protected Classifications(e.g., Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status). | · You · Other Individuals · Affiliates · Governmental Entities | · Business Services Providers · Affiliates · Governmental Entities | We do not sell or share |
| Biometric Information | We do not collect | ||
| Commercial Information(e.g., your purchasing or consuming histories or tendencies). | · You (or your device) | · Business Services Providers · Affiliates · Governmental Entities | Marketing and Advertising Providers |
| Internet/Network Activity (your browsing history, search history). | · You (or your device) | · Business Services Providers · Affiliates · Governmental Entities | Marketing and Advertising Providers |
| Geolocation Data | We may gather your geolocation based on your address, IP address, or other data associated with a particular location. If you are using company-equipment that collects geolocation, we may associate that geolocation with you. | · Business Services Providers · Affiliates | Marketing and Advertising Providers |
| Sensory Data (e.g., Audio, electronic, visual, thermal, olfactory, or similar information). | We may collect your image, voice, electronic activity, or other sensory data through recording devices such as cameras (including video cameras and security cameras), audio recording devices (including call recording devices), or thermal image scanner. | · Business Services Providers · Affiliates | We do not sell or share |
| Professional or employment-related information (e.g., Current or past job history or performance evaluations). | We do not collect from consumers generally. See our Candidate Privacy Policy for additional disclosures for workforce candidates. | ||
| Education Information | We do not collect from consumers generally. See our Candidate Privacy Policy for additional disclosures for workforce candidates. | ||
| Inferences drawn from other personal information | We may make inferences about your preferences, likes, and interests based on personal information you provide to us. | · Business Services Providers · Marketing and Advertising Providers | Marketing and Advertising Providers |
| Sensitive Personal Information | · You · Other Individuals · Governmental Entities | · Business Services Providers · Affiliates · Governmental Entities | We do not sell or share |
Our Purposes for Collecting and Using Your Personal Information
Our purposes for collecting and using your personal information include the following:
- Delivering Our Services to you and to provide the related customer support, communication, and security.
- Processing Transactions to process or fulfill orders and transactions, verify customer information, process payments, confirm eligibility promotional benefits, and perform similar activities.
- Customer Service and Development to provide customer service, maintain and service products and accounts, provide training for quality assurance purposes, develop customer audiences, and perform similar activities.
- Advertising & Marketing to send advertisements and marketing material via physical and electronic mail relating to product specials and other promotional events or offers, perform marketing research and data analytics, and perform similar activities.
- Online Advertising to serve ads to you on other websites.
- Counting Ad Impressions & Website Interactions to audit interactions with our websites, applications, or advertisements, count ad impressions to unique visitors, verify position and quality of ad impressions, and perform similar activities.
- Fraud Prevention to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity.
- Public Health and Safety to conduct screening or temperature checks for COVID-19 symptoms or similar screening activities related to public health and safety.
- Defending Against Claims & Litigation to defend against or respond to potential or actual claims and litigation.
- Policy Enforcement, including enforcing our terms of service, legal compliance policies, and other similar policies.
Retention
We will retain your personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your California Privacy Rights
California Residents have certain rights under the CCPA. For information on how to exercise these rights, please see below.
- The Right to Know. The right to know what personal information Lugano has collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about you.
- The Right to Deletion. The right to delete personal information that the business has collected about you, subject to certain exceptions.
- The Right to Correction. The right to correct inaccurate personal information that a business maintains about a consumer.
- The Right to Opt-Out of the Sale/Sharing. If we sell or share personal information, the right to opt-out of the sale or sharing of your personal information by Lugano.
- The Right to Limit the Use of Sensitive Personal Information. If Lugano uses or discloses sensitive personal information for reasons other than those permitted by the CCPA, the right to limit the use or disclosure of sensitive personal information by Lugano.
- Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred by the CCPA.
Lugano will honor the privacy rights afforded to individuals in accordance with applicable law.
Exercising Your CCPA Rights
California residents may submit CCPA requests themselves or by using an authorized agent. CCPA requests are subject to our verification measures, which vary depending on the type of request made and the sensitivity of the information you request. We may ask you to provide a few pieces of information to confirm your identity in our records. If you authorize an agent to submit a request on your behalf, we may require the agent to provide proof that you gave the agent signed permission to submit the request and may verify the agent’s identity and authority to act on your behalf.
- Submitting Access, Deletion, and Correction Requests
To make an access, deletion, correction, or limitation request, please use our Client Services Request Page, email us at compliance@luganodiamonds.com or call us at (949) 514-6431.
- Limiting the Use of Your Sensitive Personal Information
Californians have the right to limit a business’s use or disclosure of sensitive personal information. However, Lugano does not use or disclose sensitive personal information for any purpose other than for permissible purposes under the CCPA.
- Opting Out of the Sale/Share of Your Personal Information
Please review the Lugano Privacy Policy for more information about opt-out rights for website visitors.
Other California Disclosures
How We Respond To Do-Not-Track Signals & Global Privacy Controls: A “do-not-track” signal is a privacy preference feature in some web browsers that tells a website that a user does not want their online activity to be tracked. We currently support Global Privacy Control (GPC), a specification designed to allow internet users to notify businesses of their privacy preferences, such as whether or not they want to be tracked or have their personal information sold or shared with third parties for targeted advertising. It consists of a setting or extension in the user’s browser or mobile device and acts as a mechanism that our websites can use to honor your privacy settings. GPC is available for an increasing number of browsers and browser extensions, click here to view the options. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC can be found by clicking here. If your browser or device has GPC enabled, it will override your preferences selected in the cookie banner or privacy settings on this Site.
California Shine the Light Disclosures: California Civil Code Section 1798.83 permits visitors to our Sites and users of our Services who are California residents to request, once a year, certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make a request, please send us an email at info@luganodiamonds.com and include “Shine the Light Request Privacy Request” in the subject line.
Notice of Financial Incentive
We may offer our customers loyalty and other incentive programs that provides certain benefits, such as rewards and exclusive offers. We may also provide other promotional campaigns, such as sweepstakes, contests, or limited-time promotions (collectively, the “Programs”). When you sign up for one of these Programs, we typically ask you to provide your name and contact information (such as email address and/or telephone number). Because our Programs involve the collection of personal information, they might be interpreted as a “financial incentive” program under the CCPA. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program, less the expense related to offering those products, services, and benefits to Program participants. Participation in a Program is governed by the applicable terms and conditions (including the Official Rules for any sweepstakes or contest or the promotional terms for any short-term promotion), which will also describe the financial incentives association with the promotion and how to participate. You are not obligated to participate in any contest, sweepstakes, or short-term promotion and may terminate your participation at any time (as described in the survey terms and conditions). You may withdraw from participating in a Program at any time by contacting us using the designated method set forth in the applicable Program terms and conditions.
Updates to Our California Privacy Policy
We may update this California Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the page and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).
Contact Us Regarding Your Privacy Rights
If you would like additional information related to your privacy, please contact us.
Email: compliance@luganodiamonds.com
Address: 620 Newport Center Drive, #100, Newport Beach CA 92660
Phone: (949) 514-6431