1. Privacy Policy
  2. Statement of Responsible Sourcing
  3. Staff Protection Policy
  4. Health & Safety Policy
  5. Know Your Counterparty Policy

Privacy Policy

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, 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.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested prior to signing up to our email subscription list.

  1. 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;
    “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of OurSite. Details of the Cookies used by OurSite are set out in Part 14, below; and
    “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
  2. Information About Us

    Our Site is owned and operated by Ocean Diamonds Limited, a 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: admin@oceandiamonds.com

    Telephone number: 01326 218510

  3. What Does This Policy Cover?

    This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

  4. 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.

  5. What Are My Rights?

    Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

    1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
    2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
    3. 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 in Part 15 to find out more.
    4. The right to be forgotten, i.e. the right to ask usto delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
    5. The right to restrict (i.e. prevent) the processing of your personal data.
    6. The right to object to us using your personal data for a particular purpose or purposes.
    7. 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.
    8. 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.
    9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

    For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

    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 in Part 15.

  6. What Data Do You Collect and How?

    Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about ouruse of Cookies and similar technologies and our Cookie Policy. We do not collect any ‘special category’ or ‘sensitive’ personal data.

    Data Collected How We Collect the Data
    Identity Information including name and title. Input when signing up for emails
    Contact information including email address Input when signing up for emails.
    Business information including business identity and job title. Input when signing up for emails
    Technical information including IP address, browser type and version and operating system. Collected by cookies.
  7. 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 table describes how wemay use your personal data, and our lawful bases for doing so:

    What We Do What Data We Use Our Lawful Basis
    Registering you on Our Site. Name and contact details. To respond to your requests and to verify legitimate trading credentials.
    Providing and managing your Account. Name and contact details of company and individuals. To verify legitimate trading credentials.
    Providing and managing your access to OurSite. Your identity information and technical information. To ensure proper functioning of the site and to analyse site usage.
    Personalising and tailoring your experience on OurSite. Technical information. To optimise your experience of using Our Site.
    Supplying our products to you. Name and contact details. To deliver physical goods.
    Communicating with you. Name and contact details. Provision of information that you have requested or consented to receiving.
    Supplying you with information by email and/orpost that you have opted into (you may opt-out at any time by notifying us by email or amending preferences on our website.) Name and contact details. Provision of potentially interesting information relating to our products or business.

    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 emailand/ortelephone and/ortext message and/orpost with information, news, and offers on ourproductsand/orservices. 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.Wewill 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.

    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 in Part 15.

    If we need to use your personal data for a purpose that is unrelated to, or incompatible 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.

  8. 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 reason(s) 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):

    Type of Data How Long We Keep It
    Identity Information including name and title, contact information and business information. Up to 24 months following your last usage of Our Site.
    Technical information including IP address, browser type and version and operating system. No more than 24 months from the date of data collection.
  9. How and Where Do You Store or Transfer My Personal Data?

    We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

  10. Do You Share My Personal Data?

    We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

    If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

    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.

  11. How Can I Control My Personal Data?
    1. In addition to your rights under the Data Protection Legislation, set out in Part 5, whenyou 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 links provided in our emailsorat the point of providing your details and by managing your Account.
    2. 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.
  12. Can I Withhold Information?

    You may access certain areas ofOur 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.

    You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy.

  13. 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 or postal addresses shown in Part 15.

    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 normally respond to your subject access request within three weeks 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 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.

  14. How Do You Use Cookies?

    Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

    All Cookies used by and on Our Site are used in accordance with current Cookie Law.

    Before any cookies that are not strictly necessary Cookies are placed on your computer or device, you will be shown a dialogue requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

    Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies have functions such as ensuring the security of an HTTP request. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

    Our Site uses analytics services provided by Google Analytics. 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.

    The analytics service used by Our Site uses Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

    In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

    You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

    It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

  15. 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 Robert Goodden:

    Email address: admin@oceandiamonds.com.

    Telephone number:  01326 218510.

    Postal Address: April Cottage, King Charles Quay, Falmouth, Cornwall, TR11 3HQ.

  16. Changes to this Privacy Policy

    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

    Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 18th January 2023.


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.

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.

Human Rights

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.

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.


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 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.



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.

Policy Implementation

There are four steps to the implementation of the policy:

Step 1:

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.

Step 2:

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.

Step 3:

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.

Step 4

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.


It is intended that there should be no exceptions to this policy although the policy may be implemented with a “light touch” in respect of transactions where no credit is extended. Any exceptions must be authorized in writing by the Compliance Officer who shall maintain a record of each exception.


This policy shall be reviewed at least once every two years.

The next review date is 9 th January 2025.

All of our policies have been complied with over the previous 12 months. 23rd January 2023.