LEGACY VAULT™ PRIVACY NOTICE

Last updated: October 2026

Your Legacy Vault™ holds the story of your diamond. It is private, it is yours, and it is never used for marketing. This notice explains what a Vault holds, who can see it and what your rights are. It sits alongside our main Privacy Notice and takes priority over it for anything in a Vault.

1. Who is responsible

De Vere Diamonds Limited (trading as De Vere Diamonds) is the controller of the personal information in your Vault. We are registered with the Information Commissioner’s Office under number ZC211926.

Registered office: 3rd Floor, 45 Albemarle Street, Mayfair, London, W1S 4JL. Email: legacyvault@deverediamonds.com.

2. What a Vault holds

The record we compile. The diamond’s grading report, its origin and its traceability record. For a setting, the sketches, CAD, making and hallmarking records, and a record of any later work we carry out.

What you and your guests add. Photographs, films, voice notes, letters, milestones, and notes on ownership and inheritance.

Account information. Your name and contact details, your sign-in details, the people you have invited, and a log of access.

Sensitive information. We do not ask for it. Something you add may reveal it, for example a pregnancy scan. We store it only because you chose to put it there, and you can remove it at any time.

3. Why we hold it, and our lawful basis

To provide your Vault: our contract with you, the Legacy Vault™ Terms.
To store sensitive information you choose to add: your explicit consent, which you withdraw by removing it.
To keep the Vault secure, restore access and prevent misuse: our legitimate interests, and yours.
To meet a legal duty, where one applies.

4. Where it is stored

Your Vault is stored on secure cloud servers, in its own private space, separate from every other Vault. Access is protected by authentication and encryption, and the Vault is backed up regularly.

If any of it is stored outside the United Kingdom, it is protected by the safeguards described in our main Privacy Notice.

The diamond’s provenance record is also anchored on Arweave, a permanent public storage network. That record cannot be altered or deleted, by us or by anyone. It contains no personal information.

5. Who can see it

You, at all times.
The people you invite. You decide who they are and what they see, and you can remove their access at any time.
Our team, only when needed to add a record, to help you at your request, or to keep the service secure. We keep a log of every access by our team.
Our hosting providers, who store the Vault for us under contract and may not use it for any purpose of their own.

Nobody else can see your Vault. It is not public and cannot be found through a search engine.

6. What we will never do

We will never use what is in your Vault for marketing or advertising.
We will never sell or share it with anyone for their own use.
We will never use your photographs, films, voice notes or words in a case study or promotion without your written permission.
We will never analyse it to draw conclusions about you.
We will never use it to train artificial intelligence.

7. Other people in your Vault

A Vault often holds other people’s faces, voices and words. Please add them only where they would be happy for you to.

Anyone you invite to contribute can ask us to remove what they added. Anyone who appears in a Vault can ask us about their information, and we will work with the Vault’s owner to respond fairly.

8. Children and First Dawn™

A First Dawn™ Vault is opened by an adult for a child, sometimes before the child is born. It is private by default and is controlled by the adult who opened it.

At the Stewardship Transfer, at 18 or 21, the Vault passes to the child, who then holds every right in this notice.

9. Passing it on

When a diamond is given, sold or inherited, its Vault passes with it. Privacy settings are fixed at that point, and entries marked private are not shown to the new owner.

Data protection law does not cover people who have died. Our commitments in section 6 continue all the same.

10. How long we keep it

Your Vault stays open for as long as you wish to keep it. That is its purpose.
If you ask us to close it and delete what you have added, we will do so within 30 days and confirm in writing.
The diamond’s provenance record stays with the diamond.
If De Vere Diamonds is ever sold or closes, we will give you at least 90 days’ notice and the chance to download everything first.

11. Your rights

Your right	What it means
To see what we hold	Ask at any time. We reply within one month, free of charge.
To correct it	Tell us what is wrong in the record we compiled, and we will put it right.
To download it	Take a complete copy of your Vault whenever you wish.
To delete it	Ask us to close your Vault. We do so within 30 days.
To object	Tell us if you think we are using your Vault in a way this notice does not allow.
To withdraw consent	Remove anything sensitive you have added, at any time.
To complain	Tell us first, at legacyvault@deverediamonds.com. We acknowledge within 2 working days, and always within the 30 days the law allows. You may then complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint.

12. Changes and questions

If we change this notice, we will tell you directly what has changed and why. We will not change it quietly.

Questions: legacyvault@deverediamonds.com.

Your Vault is yours. We are simply its custodians.