- Statement of Responsible Sourcing
- Staff Protection Policy
- Health & Safety Policy
- Know Your Counterparty Policy
- Complaints and Grievances
Ocean Diamonds Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, http://www.oceandiamonds.com(“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings: “Account” means an account required to access and/or use certain areas and features of Our Site.
- Information About Us
Our Site is owned and operated by Ocean Diamonds Limited, a Private Limited Company registered in England under company number 05236265.
Registered address: April Cottage, King Charles Quay, Falmouth, Cornwall, TR11 3HQ
Data Protection Officer: Robert Goodden
Email address: firstname.lastname@example.org
Telephone number: 01326 218510
- What Does This Policy Cover?
- What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. This is outlined below.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details at the end of this document to find out more. Page 1 of 6
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details below to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details at the end of this document. It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details at the end of this document.
- What Data Do We Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal and nonpersonal data set out below, using the methods also set out below. We do not collect any ‘special category’ or ‘sensitive’ personal data and personal data relating to children and data relating to criminal convictions and/or offences.
Data Collected: Email address.
How We Collect the Data: By the Email Sign Up form on Our Site. Ocean Diamonds Limited may also collect information about your usage of our website to make a tailored website available to you. This may include technical information including the IP (Internet Protocol) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and if you access our site by your mobile device, we may collect your unique phone identifier.
We may also collect information about your visit, including, but not limited to the full Uniform Resource Locators (URL) and query string, clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain Page 2 of 6 pages, page interaction information (such as but not limited to, scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.
- How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following describes how we will use your personal data, and our lawful basis for doing so:
Ocean Diamonds Limited may use your Personal Data as outlined in any fair processing notice in a transparent manner at the time of collection or registration where appropriate, in accordance with any preferences you express. This may include the following purposes: providing and managing your access to Our Site; registering you on Our Site; to provide goods and services to you; to provide and manage any registered account(s) that you hold with us; with your agreement, to contact you electronically about promotional offers and products and services which we think may interest you; for market research purposes to better understand your needs; personalise and tailor your experience on Our Site and our services for you; to verify your identity; communicating with you; to enable Ocean Diamonds Limited to manage customer service interactions with you; supplying you with information by email and post that you have opted-in-to (you may opt-out at any time by clicking ‘Unsubscribe’ at the bottom of our email communication or contacting Ocean Diamonds Limited via the email address email@example.com.)
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone and text message and post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Personal data provided to us may also be profiled to help us with advertising targeting. For example, we may use your personal data to find online users with a similar profile to yourself who may be interested in our products or services.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details at the end of this document. If we need to use your personal data for a purpose that is unrelated to, or incompatible Page 3 of 6 with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
We will hold and process your data (including email address) whilst you are interacting with us and for a 24 month period after the last interaction or until you change your communication preferences.
- Sharing your Data with Third Parties
We will never share your data with third parties outside of Ocean Diamonds Limited for inclusion within their marketing campaigns.
Ocean Diamonds Limited may disclose your Personal Data to third parties who Ocean Diamonds Limited instruct to process that Personal Data on its behalf, particularly with regard to mail shots, marketing, market research and support services. Such third parties are required by Ocean Diamonds Limited to confirm that they apply appropriate data protection and security controls in compliance with EU General Data Protection Regulation. They agree to only use your Personal Data for the purposes Ocean Diamonds Limited instructs and to take appropriate measures to prevent unauthorised or unlawful access to it. These include marketing service providers. Our current partner for Marketing is Klaviyo. This may change over time and this policy will be updated accordingly.
- How and Where Do You Store or Transfer My Personal Data?
Ocean Diamonds Limited data is stored in servers based in the USA through Klaviyo. Some organisations which provide services to us may transfer data outside of the European Union (EU) but we’ll only allow this if your data is adequately protected. Some of our systems are provided by US companies and whilst it is our policy that we prefer data hosting and processing to remain on EU- based solutions, it may be that using their products results in data transfer to the USA. However we only allow this when we are certain it will be adequately protected. (e.g. US Privacy Shield or Standard EU contractual clauses).
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
- Do You Share My Personal Data?
- We will not share without your permission any of your personal data with any third parties for any purposes, without first obtaining your consent, subject to the following exceptions. Page 4 of 6
- In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
- If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.
- How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the link provided in our emails and at the point of providing your details.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
- How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email address shown below. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal Page 5 of 6 data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Ocean Diamonds Limited):
Email address: firstname.lastname@example.org.
Telephone number: 01326 218510.
STATEMENT OF RESPONSIBLE SOURCING
Code of Ethics
Recognizing the vital importance of conducting its business subject to high ethical standards and in full compliance with all applicable laws and, even where not required by law, with integrity and honesty, Ocean Diamonds limited has adopted a Code of Ethics applicable to all of our employees and suppliers together with a code of conduct.
Code of Conduct
This Code of Conduct is designed to promote honest, ethical and lawful conduct by all employees, officers and directors of Ocean Diamonds Limited and all subsidiaries and entities controlled by it. The Code is intended to help employees, officers and directors understand the Company’s standards of ethical business practices and to stimulate awareness of ethical and legal issues that may be encountered in carrying out their responsibilities.
Supplier Code of Conduct
Ocean Diamonds Limited has the objective to operate as a profitable and responsible diamond dealing business, whilst seeking to uphold our Social, Ethical and Environmental Principles and considering the interests of our customers, employees, those with whom we do business, and society as a whole.
In seeking to achieve our objective we recognize that there are indirect impacts generated by our activities, in particular through our supply chain. We will seek to use our influence with those with whom we do business directly, in particular our agents and suppliers, to promote the achievement of our Social, Ethical and Environmental Principles. As a customer we believe we have an opportunity to seek to influence the social, ethical and environmental performance of our suppliers in a positive manner. In order to do so it is necessary that our suppliers, and in turn their suppliers, should understand Ocean Diamonds standards as set out in this Code. Therefore, we encourage suppliers to ensure that this Code is communicated throughout our supply chain.
Responsible Sourcing Policy
As a new category of loose diamonds, we know we must lead by example. Our dedication to product integrity is at the core of how we do business. When a customer purchases diamonds from Ocean Diamonds, they assume that our stones have been sourced responsibly. When a customer asks a question about our sourcing practices, our Team Members have the information available to answer them. We are dedicated to our own supply chain, ensuring that this is transparent.
Ocean Diamonds Limited and our South African suppliers are fully committed to the responsible sourcing of our products and the respect of human rights. We continually strive to assure our customers, employees, investors, and other stakeholders that our supply chain avoids action that may directly or indirectly finance armed conflict and serious human rights violations around the world including the Democratic Republic of Congo and its adjoining countries.
We only sell or purchase diamonds that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:
- a. control mine sites, transportation routes, points where diamonds are traded and upstream actors in the supply chain; or
- b. tax or extort money or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or from intermediaries, export companies or international traders.
We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described above.
Ensuring the integrity of the supply chain is an issue that affects the entire diamond industry. Ocean Diamonds therefore believes it is often best to address the challenges through dedicated industry organizations. Ocean Diamonds Limited is working towards becoming a Certified member of the Responsible Jewellery Council (RJC), an organization that is committed to promoting responsible ethical, human rights, social and environmental practices throughout the jewellery supply chain. As a New Member, we fully support the RJC’s membership Code of Practices and Chain of Custody standards.
Throughout our supply chain, when we are sourcing directly from our divers and South African/Namibian connections we have a rigorous due diligence process. We only purchase Diamonds from legitimate sources not involved in funding conflict and in compliance with United Nations resolutions. Ocean Diamonds hereby guarantees that our diamonds are conflict free, based on personal knowledge and/or written guarantees provided by our suppliers.
Representatives of Ocean Diamonds shall, from time to time, monitor the recovery of diamonds by its suppliers, in person (subject to any restrictions on travel advised by government). All visits to suppliers shall be recorded and any adverse practices noted are to be notified to the Director for further investigation.
We recognize that the diamond trade has the potential for human rights infringements. Such human rights infringements would be incompatible with the ethos of Ocean Diamonds and the responsible business ethics that we seek to embody. We therefore strive to deal with other businesses that share our ethical standards. We will not deal with any business that we have reasonable cause to believe either engages in activities or practices that a reasonable person would not regard as compatible with human rights, or which engages in business activity with third parties that may reasonably be suspected of human rights abuse.
All Ocean Diamonds personnel are required to be vigilant for any evidence of human rights abuse anywhere in our supply chain. Any relevant concerns raised by a third party shall also be recorded and actioned. Any cause for concern from any source, without exception, is to be immediately reported to the Director for investigation. Ocean Diamonds is committed to mitigating the consequences of any breach of human rights with which it may have been associated, to the extent that is reasonably possible.
Ocean Diamonds will not tolerate any form of discrimination. This means that discrimination within the organisation is totally unacceptable, and that Ocean Diamonds expects its suppliers to avoid discrimination.
A statement on human rights is to be available on the Ocean Diamonds website and reviewed at least once per year. The statement will also include a summary of any significant related actions during the preceding year.
Ocean Diamonds actively opposes the exploitation of child labour and will not engage in business with entities that Ocean Diamonds reasonably believes to be engaged in such exploitation. As a minimum Ocean Diamonds will seek assurances to this effect from suppliers and any other high risk business counterparties.
Bribery and Gifts
It is absolutely forbidden for any personnel of Ocean Diamonds to offer or receive money or an object of value as an inducement to enter into any form of transaction or to provide any form of benefit, licence or favourable treatment. Traditional hospitality and token gifts are acceptable provided they are given or received transparently with the knowledge of the Director at Ocean Diamonds. The Director is to maintain a register of any gifts of significant value, made or received. No party acting on behalf of Ocean Diamonds shall be permitted to engage in any activity that may reasonably be perceived as corrupt, and any suspicion of corrupt practice shall be reported to the Director of Ocean Diamonds for investigation. A breach of policy in relation to bribery or corruption shall be regarded as gross misconduct and can be expected to result in a termination of the relationship between the party concerned and Ocean Diamonds.
Ocean Diamonds is not in the business of politics and shall not make political donations. Ocean Diamonds may make charitable donations to appropriately registered charities and may sponsor activities that are demonstrably for the benefit of a community or legitimate stakeholder group linked to Ocean Diamonds and where the benefit is transparently of a charitable nature.
Ocean Diamonds is based upon a concept of environmental sustainability with the sourcing of stones from the ocean having a far smaller environmental impact than that of terrestrial mining. Ocean Diamonds is committed to extending the concept of environmental sustainability to all aspects of its business such as the use of environmentally friendly packaging materials.
TREATMENT OF STAFF POLICY
All personnel of Ocean Diamonds Limited are entitled to undertake their work free from violence, harassment or abuse of any kind from any source. Any incidents of unacceptable behaviour encountered by any personnel in connection with their work for Ocean Diamonds Limited is to be reported to the company owner for action.
The risk of violence or harassment within an open office environment is considered to be low. Consideration will be given to the circumstances when female personnel are required to undertake travel and engagements at remote locations in order to minimise risk.
The owner of the company is committed to the fair treatment of all parties working in or for the company and will listen carefully to any grievances on matters within the control of the company. The owner is committed to take appropriate action in respect of any justified grievances brought to their attention.Ocean Diamonds is committed to treating all staff and contractors fairly and in compliance with applicable laws and conventions. In particular Ocean Diamonds is committed to ensuring that remuneration is, as a minimum, in line with industry and regional levels, that working hours are not excessive and are not incompatible with a reasonable work life balance. Discrimination of any kind will not be tolerated. Ocean Diamonds will strive to achieve a healthy and enjoyable working environment for everyone involved in the business.
HEALTH AND SAFETY POLICY
Ocean Diamonds is committed to full compliance with all applicable legislation. The most applicable legislation has been identified as being the Health and Safety at Work Act.
The work of those engaged in activities internal to the business are generally office based and of inherently low risk. The workplace will always be light and spacious without undue levels of stress. No harmful chemicals are used but in the event that any such substances are brought into the work environment, it is recognised that the provisions of COSHH must be applied.
It is recognised that the activity of greatest risk to those engaged in the internal activities of Ocean Diamonds is likely to be travel in the course of business. Consideration of risk will be undertaken prior to any such travel, with particular attention being paid to travel overseas or travel when in possession of high value goods.
Any person engaged in Ocean Diamonds business is actively encouraged to raise any concerns about health and safety with the business owner.
KNOW YOUR COUNTERPARTY POLICY
The objective of the policy is to ensure compliance with both the legal obligations and the ethical standards to which Ocean Diamonds wishes to adhere. It shall apply to all commercial dealings of Ocean Diamonds.
A Counterparty is any third party with which Ocean Diamonds has a trading relationship.
Ocean Diamonds shall maintain a record of all Counterparties and relevant information pertaining to them.
Ocean Diamonds shall use its knowledge of Counterparties to identify any legal, ethical, economic, reputational or other risks arising from the relationship.
There are four steps to the implementation of the policy:
Collect, record and maintain all relevant information pertaining to all current and intended Counterparties. Relevant information shall usually include a complete name and registered address (including legal form and company registration number if applicable), trading status, financial status and the identities of individuals authorized to enact transactions on behalf of the Counterparty.
Documents recorded by Ocean Diamonds shall include, as applicable, Articles of Association, proof of registered address and documentation to support the signing authority of any individuals or entities authorized to act on behalf of the Counterparty. Ocean Diamonds may also keep a record of financial statements from the Counterparty.
Ocean Diamonds shall take reasonable measures to verify information submitted by Counterparties. The level of verification measures shall be proportionate to the perceived level of risk arising from the relationship.
Ocean Diamonds shall risk assess its Counterparties on a regular basis, at least once per year and more frequently for counterparties identified as high risk. The outcome of the risk assessment shall include an internal credit limit and any special measures required to control or limit identified risks. This may include specific guidelines or procedures for dealing with specific Counterparties.
Monitoring and maintenance of Information about Counterparties.
Ocean Diamonds recognizes that non-compliance with this Policy places the company at financial, reputational and legal risk. All reasonable efforts will be made to implement this Policy in full and to ensure that all Counterparties are open and honest in the provision of information.
From time-to-time Ocean Diamonds shall audit (or have audited) compliance with this Policy.
Ocean Diamonds shall refuse to enter into or continue transactions with any Counterparty that insists on anonymity or provides false, inconsistent or conflicting information where the inconsistency or conflict cannot be resolved after reasonable inquiry. Ocean Diamonds shall also suspend transactions with any Counterparty that Ocean Diamonds reasonably suspects to be engaged in activities that may not be legal or that do not meet the standards of ethics and practice required by Ocean Diamonds.
The Compliance Officer at Ocean Diamonds is Michelle Wood who can be contacted at Michelle@oceandiamonds.com
The person responsible for internal audit of this policy is Robert Goodden.
There will be no exceptions to this policy.
This policy shall be reviewed at least once every two years.
The next review date is 9 th January 2025.
COMPLAINTS AND GRIEVANCES
Ocean Diamonds has established this grievance procedure to hear concerns about any operations of Ocean Diamonds Ltd.
Robert Goodden is responsible for implementing and reviewing this procedure.
Concerns can be raised by interested parties via email or telephone to:
On receiving a complaint, we will aim to:
- Get an accurate report of the complaint.
- Explain our complaint procedure.
- Find out how the complainant would like it addressed/resolved.
- Assess the eligibility of the complaint and, where applicable, decide who should handle it internally. In cases where we are unable to address the complaint internally (e.g. where our company is too far removed from the origin of the issue raised in the complaint) , we may redirect it to a more appropriate entity or institution, such as the relevant supplier or industry body.
- Where the issue can be handled internally, seek further information where possible and appropriate.
- Identify any actions we should take including hearing from all parties concerned, and monitoring the situation.
- Advise the complainant of our decisions or outcomes.
- Keep records on complaints received and the internal process followed, for at least five years.
All of our policies have been complied with over the previous 12 months. 16th March 2023.