Above Rubies or Pearls

http://www.aboverubiesorpearls.com

Last updated: January 26, 2020

This Privacy Policy describes Our policies and procedures on the collection,
use and disclosure of Your information when You use the Service and tells You
about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the
Service, You agree to the collection and use of information in accordance with
this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined
under the following conditions.

The following definitions shall have the same meaning regardless of whether
they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• You means the individual accessing or using the Service, or the company,
  
  or other legal entity on behalf of which such individual is accessing or
  
  using the Service, as applicable.
  Under GDPR (General Data Protection Regulation), You can be referred to as
  
  the Data Subject or as the User as you are the individual using the
  
  Service.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this
  
  Agreement) refers to Above Rubies or Pearls.
  For the purpose of the GDPR, the Company is the Data Controller.
• Affiliate means an entity that controls, is controlled by or is under
  
  common control with a party, where “control” means ownership of 50% or
  
  more of the shares, equity interest or other securities entitled to vote
  
  for election of directors or other managing authority.
• Account means a unique account created for You to access our Service or
  
  parts of our Service.
• Website refers to Above Rubies or Pearls, accessible from
  
  http://www.aboverubiesorpearls.com
• Service refers to the Website.
• Country refers to: California, United States
• Service Provider means any natural or legal person who processes the data
  
  on behalf of the Company. It refers to third-party companies or
  
  individuals employed by the Company to facilitate the Service, to provide
  
  the Service on behalf of the Company, to perform services related to the
  
  Service or to assist the Company in analyzing how the Service is used.
  For the purpose of the GDPR, Service Providers are considered Data
  
  Processors.
• Third-party Social Media Service refers to any website or any social
  
  network website through which a User can log in or create an account to
  
  use the Service.
• Facebook Fan Page is a public profile named Above Rubies or Pearls
  
  specifically created by the Company on the Facebook social network,
  
  accessible from http://www.facebook.com/aboverubiesorpearls/
• Personal Data is any information that relates to an identified or
  
  identifiable individual.
  For the purposes for GDPR, Personal Data means any information relating to
  
  You such as a name, an identification number, location data, online
  
  identifier or to one or more factors specific to the physical,
  
  physiological, genetic, mental, economic, cultural or social identity.
  For the purposes of the CCPA, Personal Data means any information that
  
  identifies, relates to, describes or is capable of being associated with,
  
  or could reasonably be linked, directly or indirectly, with You.
• Cookies are small files that are placed on Your computer, mobile device or
  
  any other device by a website, containing the details of Your browsing
  
  history on that website among its many uses.
• Usage Data refers to data collected automatically, either generated by the
  
  use of the Service or from the Service infrastructure itself (for example,
  
  the duration of a page visit).
• Data Controller, for the purposes of the GDPR (General Data Protection
  
  Regulation), refers to the Company as the legal person which alone or
  
  jointly with others determines the purposes and means of the processing of
  
  Personal Data.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory
  
  authorities, in particular the U.S. Federal Trade Commission (FTC), for
  
  the Internet industry to develop and implement a mechanism for allowing
  
  internet users to control the tracking of their online activities across
  
  websites.
• Business, for the purpose of the CCPA (California Consumer Privacy Act),
  
  refers to the Company as the legal entity that collects Consumers’
  
  personal information and determines the purposes and means of the
  
  processing of Consumers’ personal information, or on behalf of which such
  
  information is collected and that alone, or jointly with others,
  
  determines the purposes and means of the processing of consumers’ personal
  
  information, that does business in the State of California.
• Consumer, for the purpose of the CCPA (California Consumer Privacy Act),
  
  means a natural person who is a California resident. A resident, as
  
  defined in the law, includes (1) every individual who is in the USA for
  
  other than a temporary or transitory purpose, and (2) every individual who
  
  is domiciled in the USA who is outside the USA for a temporary or
  
  transitory purpose.
• Sale, for the purpose of the CCPA (California Consumer Privacy Act), means
  
  selling, renting, releasing, disclosing, disseminating, making available,
  
  transferring, or otherwise communicating orally, in writing, or by
  
  electronic or other means, a Consumer’s Personal information to another
  
  business or a third party for monetary or other valuable consideration.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You.
Personally identifiable information may include, but is not limited to:

  * Email address
  * First name and last name
  * Usage Data

Usage Data  
~~~~~~~~~~

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol
address (e.g. IP address), browser type, browser version, the pages of our
Service that You visit, the time and date of Your visit, the time spent on
those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect
certain information automatically, including, but not limited to, the type of
mobile device You use, Your mobile device unique ID, the IP address of Your
mobile device, Your mobile operating system, the type of mobile Internet
browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our
Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies  

~~~~

We use Cookies and similar tracking technologies to track the activity on Our
Service and store certain information. Tracking technologies used are beacons,
tags, and scripts to collect and track information and to improve and analyze
Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a
Cookie is being sent. However, if You do not accept Cookies, You may not be
able to use some parts of our Service.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on
your personal computer or mobile device when You go offline, while Session
Cookies are deleted as soon as You close your web browser.

We use both session and persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies
  Type: Session Cookies
  Administered by: Us
  Purpose: These Cookies are essential to provide You with services
  
  available through the Website and to enable You to use some of its
  
  features. They help to authenticate users and prevent fraudulent use of
  
  user accounts. Without these Cookies, the services that You have asked for
  
  cannot be provided, and We only use these Cookies to provide You with
  
  those services.
• Cookies Policy / Notice Acceptance Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies identify if users have accepted the use of cookies
  
  on the Website.
• Functionality Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies allow us to remember choices You make when You use
  
  the Website, such as remembering your login details or language
  
  preference. The purpose of these Cookies is to provide You with a more
  
  personal experience and to avoid You having to re-enter your preferences
  
  every time You use the Website.
• Tracking and Performance Cookies
  Type: Persistent Cookies
  Administered by: Third-Parties
  Purpose: These Cookies are used to track information about traffic to the
  
  Website and how users use the Website. The information gathered via these
  
  Cookies may directly or indirectly identify you as an individual visitor.
  
  This is because the information collected is typically linked to a
  
  pseudonymous identifier associated with the device you use to access the
  
  Website. We may also use these Cookies to test new advertisements, pages,
  
  features or new functionality of the Website to see how our users react to
  
  them.
• Targeting and Advertising Cookies
  Type: Persistent Cookies
  Administered by: Third-Parties
  Purpose: These Cookies track your browsing habits to enable Us to show
  
  advertising which is more likely to be of interest to You. These Cookies
  
  use information about your browsing history to group You with other users
  
  who have similar interests. Based on that information, and with Our
  
  permission, third party advertisers can place Cookies to enable them to
  
  show adverts which We think will be relevant to your interests while You
  
  are on third party websites.

For more information about the cookies we use and your choices regarding
cookies, please visit our Cookies Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our
  
  Service.
• To manage Your Account: to manage Your registration as a user of the
  
  Service. The Personal Data You provide can give You access to different
  
  functionalities of the Service that are available to You as a registered
  
  user.
• For the performance of a contract: the development, compliance and
  
  undertaking of the purchase contract for the products, items or services
  
  You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other
  
  equivalent forms of electronic communication, such as a mobile
  
  application’s push notifications regarding updates or informative
  
  communications related to the functionalities, products or contracted
  
  services, including the security updates, when necessary or reasonable for
  
  their implementation.
• To provide You with news, special offers and general information about
  
  other goods, services and events which we offer that are similar to those
  
  that you have already purchased or enquired about unless You have opted
  
  not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

• With Service Providers: We may share Your personal information with
  
  Service Providers to monitor and analyze the use of our Service, to show
  
  advertisements to You to help support and maintain Our Service, to contact
  
  You, to advertise on third party websites to You after You visited our
  
  Service or for payment processing.
• For Business transfers: We may share or transfer Your personal information
  
  in connection with, or during negotiations of, any merger, sale of Company
  
  assets, financing, or acquisition of all or a portion of our business to
  
  another company.
• With Affiliates: We may share Your information with Our affiliates, in
  
  which case we will require those affiliates to honor this Privacy Policy.
  
  Affiliates include Our parent company and any other subsidiaries, joint
  
  venture partners or other companies that We control or that are under
  
  common control with Us.
• With Business partners: We may share Your information with Our business
  
  partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise
  
  interact in the public areas with other users, such information may be
  
  viewed by all users and may be publicly distributed outside. If You
  
  interact with other users or register through a Third-Party Social Media
  
  Service, Your contacts on the Third-Party Social Media Service may see You
  
  name, profile, pictures and description of Your activity. Similarly, other
  
  users will be able to view descriptions of Your activity, communicate with
  
  You and view Your profile.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary
for the purposes set out in this Privacy Policy. We will retain and use Your
Personal Data to the extent necessary to comply with our legal obligations
(for example, if we are required to retain your data to comply with applicable
laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage
Data is generally retained for a shorter period of time, except when this data
is used to strengthen the security or to improve the functionality of Our
Service, or We are legally obligated to retain this data for longer time
periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s
operating offices and in any other places where the parties involved in the
processing are located. It means that this information may be transferred to —
and maintained on — computers located outside of Your state, province, country
or other governmental jurisdiction where the data protection laws may differ
than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such
information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data
is treated securely and in accordance with this Privacy Policy and no transfer
of Your Personal Data will take place to an organization or a country unless
there are adequate controls in place including the security of Your data and
other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your
Personal Data may be transferred. We will provide notice before Your Personal
Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement  
~~~~~~~~~~~~~~~

Under certain circumstances, the Company may be required to disclose Your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).

Other legal requirements  

~~~

The Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no
method of transmission over the Internet, or method of electronic storage is
100% secure. While We strive to use commercially acceptable means to protect
Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their
tasks on Our behalf and are obligated not to disclose or use it for any other
purpose.

Analytics

We may use third-party Service providers to monitor and analyze the use of our
Service.

• Google Analytics
  Google Analytics is a web analytics service offered by Google that tracks
  
  and reports website traffic. Google uses the data collected to track and
  
  monitor the use of our Service. This data is shared with other Google
  
  services. Google may use the collected data to contextualise and
  
  personalise the ads of its own advertising network.
  You can opt-out of having made your activity on the Service available to
  
  Google Analytics by installing the Google Analytics opt-out browser add-
  
  on. The add-on prevents the Google Analytics JavaScript (ga.js,
  
  analytics.js and dc.js) from sharing information with Google Analytics
  
  about visits activity.
  For more information on the privacy practices of Google, please visit the
  
  Google Privacy & Terms web page:
  
  https://policies.google.com/privacy?hl=en

Advertising

We may use Service providers to show advertisements to You to help support and
maintain Our Service.

• Google AdSense & DoubleClick Cookie
  Google, as a third party vendor, uses cookies to serve ads on our Service.
  
  Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page:
  
  http://www.google.com/ads/preferences/

• http://g.ezoic.net/privacy/aboverubiesorpearls.com/annualRequestSummary

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or
promotional materials and other information that may be of interest to You.
You may opt-out of receiving any, or all, of these communications from Us by
following the unsubscribe link or instructions provided in any email We send
or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

• MailerLite MailerLite is an email marketing sending service provided by MailerLite, Inc. For more information on the privacy practices of MailerLite, please visit their privacy policy at: https://www.mailerlite.com/legal/privacy-policy
• Mailchimp
  Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.
  For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/
• Constant Contact
  Constant Contact is an email marketing sending service provided by Constant Contact, Inc.
  For more information on the privacy practices of Constant Contact, please visit their Privacy policy: https://www.constantcontact.com/legal/privacy-notice

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one
  
  or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the
  
  performance of an agreement with You and/or for any pre-contractual
  
  obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance
  
  with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect
  
  Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is
  
  carried out in the public interest or in the exercise of official
  
  authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the
  
  purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis
that applies to the processing, and in particular whether the provision of
Personal Data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data
and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the
EU, to:

• Request access to Your Personal Data. The right to access, update or
  
  delete the information We have on You. Whenever made possible, you can
  
  access, update or request deletion of Your Personal Data directly within
  
  Your account settings section. If you are unable to perform these actions
  
  yourself, please contact Us to assist You. This also enables You to
  
  receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have
  
  the right to to have any incomplete or inaccurate information We hold
  
  about You corrected.
• Object to processing of Your Personal Data. This right exists where We are
  
  relying on a legitimate interest as the legal basis for Our processing and
  
  there is something about Your particular situation, which makes You want
  
  to object to our processing of Your Personal Data on this ground. You also
  
  have the right to object where We are processing Your Personal Data for
  
  direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to
  
  delete or remove Personal Data when there is no good reason for Us to
  
  continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to
  
  a third-party You have chosen, Your Personal Data in a structured,
  
  commonly used, machine-readable format. Please note that this right only
  
  applies to automated information which You initially provided consent for
  
  Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on
  
  using your Personal Data. If You withdraw Your consent, We may not be able
  
  to provide You with access to certain specific functionalities of the
  
  Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and
opposition by contacting Us. Please note that we may ask You to verify Your
identity before responding to such requests. If You make a request, We will
try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our
collection and use of Your Personal Data. For more information, if You are in
the European Economic Area (EEA), please contact Your local data protection
authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using
the Service. As operator of the Facebook Fan Page
(http://www.facebook.com/aboverubiesorpearls/), the Company and the operator
of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms
for use of the Facebook Fan Page, among other things. These terms are mostly
based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for
more information about how Facebook manages Personal data or contact Facebook
online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road,
Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the
Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized
statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting
Our Facebook Fan Page. Each Cookie contains a unique identifier code and
remains active for a period of two years, except when it is deleted before the
end of this period.

Facebook receives, records and processes the information stored in the Cookie,
especially when the user visits the Facebook services, services that are
provided by other members of the Facebook Fan Page and services by other
companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit
Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy

CCPA Privacy

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California, You
have the following rights:

• The right to notice. You must be properly notified which categories of
  
  Personal Data are being collected and the purposes for which the Personal
  
  Data is being used.
• The right to access / the right to request. The CCPA permits You to
  
  request and obtain from the Company information regarding the disclosure
  
  of Your Personal Data that has been collected in the past 12 months by the
  
  Company or its subsidiaries to a third-party for the third party’s direct
  
  marketing purposes.
• The right to say no to the sale of Personal Data. You also have the right
  
  to ask the Company not to sell Your Personal Data to third parties. You
  
  can submit such a request by visiting our “Do Not Sell My Personal
  
  Information” section or web page.
• The right to know about Your Personal Data. You have the right to request
  
  and obtain from the Company information regarding the disclosure of the
  
  following:
  • The categories of Personal Data collected
  • The sources from which the Personal Data was collected
  • The business or commercial purpose for collecting or selling the
    
    Personal Data
  • Categories of third parties with whom We share Personal Data
  • The specific pieces of Personal Data we collected about You
• The right to delete Personal Data. You also have the right to request the
  
  deletion of Your Personal Data that have been collected in the past 12
  
  months.
• The right not to be discriminated against. You have the right not to be
  
  discriminated against for exercising any of Your Consumer’s rights,
  
  including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the
    
    use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or
    
    services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if you are a
California resident, You can email or call us or visit our “Do Not Sell My
Personal Information” section or web page.

The Company will disclose and deliver the required information free of charge
within 45 days of receiving Your verifiable request. The time period to
provide the required information may be extended once by an additional 45 days
when reasonable necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner
with (for example, our advertising partners) may use technology on the Service
that “sells” personal information as defined by the CCPA law.

If you wish to opt out of the use of your personal information for interest-
based advertising purposes and these potential sales as defined under CCPA
law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need
to opt out on every browser that you use.

Website

You can opt out of receiving ads that are personalized as served by our
Service Providers by following our instructions presented on the Service:

  * From Our "Cookie Consent" notice banner
  * Or from Our "CCPA Opt-out" notice banner
  * Or from Our "Do Not Sell My Personal Information" notice banner
  * Or from Our "Do Not Sell My Personal Information" link

The opt out will place a cookie on Your computer that is unique to the browser
You use to opt out. If you change browsers or delete the cookies saved by your
browser, you will need to opt out again.

Mobile Devices  

~~~

Your mobile device may give you the ability to opt out of the use of
information about the apps you use in order to serve you ads that are targeted
to your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on
  
  Android devices
• “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile
device by changing the preferences on your mobile device.

“Do Not Track” Policy as Required by California Online Privacy Protection Act

(CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of You browsing activities.
If You are visiting such websites, You can set Your preferences in Your web
browser to inform websites that You do not want to be tracked. You can enable
or disable DNT by visiting the preferences or settings page of Your web
browser.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly
collect personally identifiable information from anyone under the age of 13.
If You are a parent or guardian and You are aware that Your child has provided
Us with Personal Data, please contact Us. If We become aware that We have
collected Personal Data from anyone under the age of 13 without verification
of parental consent, We take steps to remove that information from Our
servers.

We also may limit how We collect, use, and store some of the information of
Users between 13 and 18 years old. In some cases, this means We will be unable
to provide certain functionality of the Service to these users.

If We need to rely on consent as a legal basis for processing Your information
and Your country requires consent from a parent, We may require Your parent’s
consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us.
If You click on a third party link, You will be directed to that third party’s
site. We strongly advise You to review the Privacy Policy of every site You
visit.

We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any
changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior
to the change becoming effective and update the “Last updated” date at the top
of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this
page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: robyn@aboverubiesorpearls.com

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