Privacy Policy
This Privacy Policy (“Privacy Policy”) explains how information is collected and used by Sherlock Holmes Detect Ltd. (“Company” or “we”, “us”, “our”) when you use our Sherlock Holmes Application (“App”) on your mobile phone together with our Dr. Watson Detector Box, Sherlock Holmes 4.0 Detector box or BIG Sherlock Detector Box (each, a “Detector”), to test whether diamonds are natural or lab grown.
We respect your privacy and are committed to protecting it. Please read this Privacy Policy carefully.
KEY PROVISIONS OF THIS PRIVACY POLICY
The following key points are provided for your reading convenience, but do not substitute the full Privacy Policy that is provided thereafter.
- To use the App, you must create an account and provide details of one payment method.
- We will collect and process your data only for the purposes listed in this Privacy Policy. We will not process your information for other purposes without obtaining your prior consent.
- We will not share your information with third parties except as detailed in this Privacy Policy.
- We may transfer your personal data for processing at locations outside of your jurisdiction. By using the App, you consent to such transfers.
- We retain your personal information for as long as we deem necessary or as otherwise required by law.
- We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information, but do not guarantee that the App will be immune to all information security risks.
- We do not knowingly or intentionally collect information from minors under the age of 13.
- If you reside in the UK or in one of the EU member states, you may have additional rights as detailed in the Privacy Policy.
- If you are a resident of the State of California, you may have additional rights as detailed in the Privacy Policy.
- We may, from time to time, change this Privacy Policy. Your continued use of the Services indicates your consent to the new policy.
PERSONAL DATA PROCESSED
We collect and process your information when you create an account on the App
When you register to create an account on the App, we collect your full name, email address and phone number. During registration, you may also provide information about your business, such as business name and address, and a profile picture.
We refer to this type of data as “Profile Information”.
Please note that your Profile Information will be available to all registered App users who are listed as employees of your business.
Registration and use of the App are subject to payment of a monthly subscription. Therefore, we will collect your credit card details. However, we do not save your credit card or payment method information in our database. Sensitive credit card details and payment method information is saved and used by our third party payment processor, Stripe, who processes this data in accordance with its privacy policy: https://stripe.com/gb/privacy.
We refer to this type of data as “Payment Information”.
We collect and process information about your mobile device
In order to connect your mobile phone to the Detector, we will collect your Bluetooth address.
We refer to this as “Device Information”.
We collect and process information about your authentication tests
We collect information about the diamond tests you run through the App and their results, and any other related files you upload to the App.
We refer to this as “Tests Information”.
Please note that Tests Information is stored on a cloud operated by our service provider. We will not access this information, neither by ourselves nor with the assistance of our service provider, unless you provide us with your express permission.
We collect and process information of others you invite to join the App
If you choose to invite other employees of your business to join the App, we will collect from you their full name, email address and business role.
We refer to this type of data as “Invite Information”.
We collect and process your information when you contact us
When you contact us via the App chat, email, or phone, we collect the contents of the chat conversation you have had with our online representative.
We refer to this data as “Inquiry Information”.
You do not have a legal obligation to provide us with your Profile Information, Payment Information, Device Information, Tests Information, Invite Information or Inquiry Information. However, if you choose to not share this information with us, we may not be able to provide our services to you, invite your colleagues to join the App, or respond to your inquiries.
We also collect analytics information and logs about your use of the App
When you use the App, we record and collect certain information about your interaction with the App, including the IP address from which you access the App, time and date of access, language used, links clicked, and actions taken while using the App.
We refer to this data as “Analytics“.
DATA CONTROLLER
Sherlock Holmes Detect Ltd is the data controller
Sherlock Holmes Detect Ltd is the data controller of the information described in this Privacy Policy. We determine the purposes and means of processing that data as part of our App.
HOW WE PROCESS PERSONAL DATA
To provide our services to you
We process your Profile Information to create your account on the App. We process your Device Information and Tests Information to connect your device to the Detector and provide you our diamond detection features.
To process your subscription payment
We process your Payment Information to complete the payment for your chosen subscription plan. Sensitive credit card details and payment method information is saved and used by our third party payment processor, Stripe, who processes this data in accordance with its privacy policy: https://stripe.com/gb/privacy.
To respond to your inquiries
We process your Inquiry Information to handle and respond to your inquiries.
To send App invites to your colleagues, per your request
We process your Invite Information to contact your colleagues from your business, and invite them to join the App.
To operate and maintain the App
We process Analytics to provide, maintain and improve your user experience accessing and using our App, and to troubleshoot problems. We also will use the Analytics for quality assurance and for development and enhancement of the App.
To enforce the terms and comply with applicable law and judicial orders
We will process your information to prevent fraud, handle and resolve disputes, assist with any investigations, enforce this Privacy Policy and our Terms of Use, and take other actions otherwise permitted by law.
WHO PROCESSES YOUR DATA
We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.
We will process information with our service providers helping us in the operation of our App.
We will process your information with the help of our service providers who assist us with the internal operations of our App, such as our cloud service provider and payment processing providers. These companies are authorized to use your personal information in this context only as necessary to provide these services to us, and not for their own promotional purposes.
We will share information with competent authorities, if you abuse your right to use the App or violate any applicable law.
If you abused your rights to use the App, or violated any applicable law, we will share information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach.
We will share your information if we are legally required.
We will share information if we are required to do so by a judicial, governmental, or regulatory authority.
We will share your Information with third parties in any event of change in our structure.
If the operation of our company is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share information only as required to enable the structural change in the operation of our company.
SECURITY AND DATA RETENTION
We retain your information for as long as we need it for business purposes, or as otherwise required by law.
We generally retain your personal information for as long as we deem necessary for the purposes listed above or until you delete your account. Nonetheless, we reserve the right to delete your information (including your Tests Information) if you do not meet your payment obligations to us, or for any other reason we, in our reasonable discretion, deem to justify the deletion of your information – all, subject to a prior notice from us, as specified in our Terms of Use [LINK].
We may further retain your information where necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce this Privacy Policy or the Terms of Use [LINK].
We implement measures to secure your Information
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure personal information, it is not guaranteed, and you cannot expect that the App will be immune from information security risks.
INTERNATIONAL DATA TRANSFERS
We will internationally transfer information in accordance with applicable data protection laws.
If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations.
INFORMATION OF MINORS
We do not knowingly or intentionally collect information of minors
Our Services are not intended for minors under the age of 13. We do not knowingly or intentionally collect information from minors under the age of 13.
ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EU OR UK
Company contact information
The following is the contact information of the Company, who is the data controller of the information detailed in this Privacy Policy:
Sherlock Holmes Detect Ltd
16 Hacharoshet Street
Or Yehuda 6037584, Israel
Email: SH@yehuda.com
Legal basis for processing your personal data.
The legal basis for processing your Profile Information, Device Information, Tests Information and Payment Information is the performance of our Terms of Use contract [LINK] with you for the provision of the diamond detection features to you.
The legal basis for processing your Inquiry Information for the purpose of handing responding to your inquiry is our legitimate interests in providing you with customer service and maintaining our relations with customers.
The legal basis for processing your Invite Information is our legitimate interest in inviting your colleagues from your business to join us as users of our App.
The legal basis for processing Analytics is our legitimate interest in maintaining, developing, and enhancing the App.
The legal basis for processing your information for the purpose of handling instances of abusive use of the App is our legitimate interests in defending and enforcing against violations and breaches that are harmful to our business.
The legal basis for processing your information where we are legally required to share it, is our legitimate interests in complying with mandatory legal requirements imposed on us.
The legal basis for processing your information in the event of a change in our corporate structure is our legitimate interests in our business continuity.
You have certain rights to access, update or delete information, obtain a copy of your information, and object or restrict certain data processing activities.
If you are in the EU or UK, you have the following rights under the GDPR regarding the information we process as a controller:
Right to Access your personal data and receive a copy of it.
Right to Rectify inaccurate personal data about you and to have incomplete personal data completed.
Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used, and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.
Right to Object, based on your particular situation, to use your personal data on the basis of our legitimate interest, including processing your information for marketing purposes. However, in cases other than processing your information for marketing purposes, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims. You may also object at any time to the use of your personal data for direct marketing purposes.
Right to Restrict the processing of your personal data (except for storing it) if: (i) you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; (ii) you believe that the processing is unlawful and you oppose the erasure of the personal data and request instead to restrict its use; or (iii) we no longer need the personal data for the purposes outlined in this Privacy Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.
Right to be Forgotten. Under certain circumstances, such as when you object to us processing your data and we have no compelling legitimate grounds to override your objection, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation, where we are subject to under laws in EU Member States or the UK, or for the establishment, exercise, or defense of legal claims.
If you wish to exercise any of these rights, please contact us at: sh@yehuda.com
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you the information that you have asked for, we will explain the reason for this.
You have a right to submit a complaint to the relevant supervisory data protection authority.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, particularly in the Member State of your residence, place of work or place of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
If you are in the UK, you can lodge a complaint to Information Commissioner’s Office (ICO) pursuant to the instructions provided here.
CCPA INFORMATION FOR CONSUMERS RESIDING IN CALIFORNIA
This is the personal information we have collected over the past 12 months when we operate as a “business” under the California Consumer Privacy Act (CCPA):
| Categories of Personal Information | Specific Types of Personal Information Collected | Source of Information |
|---|---|---|
| Identifiers | Name, email address | The consumer themselves |
| Customer records information | Phone number, physical address, credit card details or other financial information | The consumer themselves |
| Information that identifies, relates to, describes, or is capable of being associated with, a particular individual | Content of inquires made through the chat | The consumer themselves |
| Professional or employment-related information | Business role, business name and address | The consumer themselves or other consumers who are employees of the same business |
| Commercial information, including products or services purchased, obtained, or considered | Tests history and results, and files regarding tests uploaded to the App Content of inquires made through the chat |
The consumer themselves and the App usage data |
| Internet or other electronic network activity information | Bluetooth address, IP address from which you access the App, time and date of access, language used, links clicked, and actions taken while using the App | The consumer’s device |
The following are the CCPA business or commercial purposes for which we use each category of personal information. Details about the information we collect for each category are provided in the table above. More details about the business or commercial purposes are provided in the privacy policy’s section titled ‘HOW WE PROCESS PERSONAL DATA’.
Please note that we do not sell your data and we have not done so in the preceding 12 months.
Categories of Personal Information
Identifiers
Customer records information
Professional or employment-related information
Commercial information, including products or services purchased, obtained, or considered
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual
Internet or other electronic network activity information
Business or commercial purposes pursuant to the CCPA
Providing customer service, processing or fulfilling orders and transactions, processing payments, verifying customer information
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity
Undertaking internal research for technology development and demonstration
Undertaking activities to verify or maintain the quality of the App and to improve, upgrade or enhance the App
Debugging to identify and repair errors
The following rights apply to California residents who are using our App:
Disclosure of Personal Information We Collect About You. You have the right to know:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting personal information;
- The categories of third parties with whom we share personal information, if any;
- The specific pieces of personal information we have collected about you.
Right to Deletion. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your personal information from our records; and
- Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with an existing legal obligation; or
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination. You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide a different level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Designate an authorized agent to submit CCPA requests on your behalf. You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.
If you would like to exercise any of your CCPA rights as described above, you should email us to: sh@yehuda.com.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of information you require.
CHANGES TO THIS PRIVACY POLICY
If we change this Privacy Policy, we will make efforts to proactively notify you of such changes.
From time to time, we may change this Privacy Policy. If we do so, we will make efforts to proactively notify you of such changes. In any event, the latest version will always be accessible on the App.