Last updated: October 2026

De Vere Diamonds respects your privacy and is committed to safeguarding your personal information. This notice explains what we collect, why, who sees it and what your rights are. It covers our website, our consultations (in person and by video, telephone, WhatsApp and email), your commission, and the Legacy Vault™.

1. Who we are

De Vere Diamonds Limited, trading as De Vere Diamonds (“we”, “us”, “our”), is the controller of your personal information.

• Company name: De Vere Diamonds Limited (trading as De Vere Diamonds)

• Company number: 16212521, registered in England and Wales

• Registered office: 3rd Floor, 45 Albemarle Street, Mayfair, London, W1S 4JL

• ICO registration number: ZC211926

• Privacy enquiries: hello@deverediamonds.com

• Legacy Vault™ enquiries: legacyvault@deverediamonds.com

2. The information we collect

• Identity: name, title, date of birth, gender.

• Contact: address, email address, telephone and WhatsApp number.

• Your commission: what you tell us about the occasion and the person it is for, your budget, ring size, design preferences, important dates, and our correspondence and notes.

• Transactions: details of commissions, payments, refunds and deliveries.

• Financial: payment card details, which are processed securely by our payment providers. We do not see or store your full card number.

• Identity checks: identification documents and verification information, where anti-money-laundering or sanctions rules require them.

• Technical: IP address, login details, browser type, time zone and device identifiers.

• Usage: how you use our website, services and communications.

• Marketing and communications: your preferences for hearing from us and for event invitations.

• Legacy Vault™: your account details, the diamond’s records, and whatever you or the people you invite choose to add, such as photographs, videos, voice notes, letters and milestones.

Information about other people. A commission is often for someone else, and a Vault often holds other people’s faces and words. Please share other people’s information with us only where they would expect it, or where it is yours to share, as with a surprise we will keep.

Sensitive information. We do not ask for information about health, beliefs or other specially protected matters. Something you place in a Vault 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. How we collect it

• Directly from you, when you send an enquiry, speak with us, place a commission, use a Legacy Vault™, sign up for news or contact us.

• Automatically, through cookies, server logs and analytics when you use our website.

• From others, such as payment providers, identity verification and fraud prevention services, credit reference agencies, carriers confirming delivery, and a Vault owner who invites you to contribute.

4. How we use it, and our lawful basis

Where we rely on legitimate interests, we have weighed them against your rights. Where we rely on consent, you can withdraw it at any time.

5. The Legacy Vault™

Your Vault is private. Only you, and the people you choose, can see what it holds. Nothing in it is ever used for marketing.

We do not look at what you keep in your Vault unless you ask us for help, we need to keep the service secure, or the law requires it.

When a diamond is inherited or passed on, its Vault passes with it. Privacy settings are fixed at the point of transfer, so entries marked private stay private.

The Legacy Vault™ Privacy Notice gives more detail. Where it differs from this notice, it applies to the Vault.

6. Who we share it with

• Payment service providers, banks and insurers.

• Specialist carriers, couriers and customs agents.

• Our workshop and aftercare partners in the United Kingdom and India, who receive only what they need to make or care for your piece.

• Professional advisers, such as lawyers, auditors and accountants.

• Identity verification, compliance and fraud prevention services.

• IT providers, including hosting, cloud storage, email, enquiry forms, analytics, video calling and the systems behind the Legacy Vault™.

• WhatsApp, if you choose to message us there.

• Regulators and authorities, such as HMRC, law enforcement and supervisory bodies, where the law requires it.

• A successor to our business, so that your records and your Vault can continue.

We do not sell your personal information.

7. International transfers

We are based in the United Kingdom, and some of our providers and partners are elsewhere, including in India, the United States and the European Economic Area. Where your information leaves the United Kingdom we protect it with one of the following:

• UK adequacy regulations, which cover the EEA and certain other countries;

• the ICO’s International Data Transfer Agreement, or its Addendum to the EU standard contractual clauses;

• additional safeguards where necessary.

If you are outside the United Kingdom, your information is transferred to us here. You can ask us for details of the safeguard used for any transfer.

8. How long we keep it

• Commissions and transactions: at least 7 years, for tax and accounting.

• Identity checks: 5 years after the end of our relationship with you.

• Enquiries that do not become a commission: 2 years after our last contact. They are then securely erased or shredded.

• Marketing: until you unsubscribe or withdraw consent. We then keep only enough to make sure we do not contact you again.

• Technical and usage information: only for as long as we need it to improve our services.

• Legacy Vault™ content: for as long as the Vault is kept, or until its owner removes it. The diamond’s own provenance record stays with the diamond.

9. How we protect it

We use appropriate technical and organisational measures, including:

• encrypted payment processing;

• secure servers and firewalls;

• access controls and staff training;

• regular review and testing of our security.

If a breach is likely to put you at risk, we will tell you and the ICO as the law requires.

10. Cookies

We use cookies and similar technologies. Our Cookie Policy explains which, why, and how to manage them.

11. Automated decisions, profiling and AI

Our payment providers may use automated tools to detect fraudulent or suspicious transactions. We do not make decisions that have a legal or similarly significant effect on you by automated means alone. A person is always involved, and you can ask us to review any decision.

De Vere Diamonds may use AI-assisted tools to support content creation, website optimisation and client experience. These are used under strict human supervision.

We do not use AI to make fully automated decisions about pricing, transactions, certification or your rights.

Personal information is not processed by AI systems unless appropriate contractual, technical and legal safeguards are in place, in line with data protection law.

12. Marketing

You will hear from us only if:

• you have opted in; or

• you are a client of ours and have not opted out.

You can unsubscribe at any time through the link in any email, or by contacting us.

13. Children and First Dawn™

Our services are for adults, and we do not knowingly collect information directly from children under 16. If we learn that we have, we will delete it.

A First Dawn™ diamond is commissioned by an adult for a child. The adult may give us the child’s name and date of birth and may add photographs and messages to the child’s Vault. That Vault is private by default and is controlled by the adult who opened it.

At the Stewardship Transfer, at 18 or 21, the diamond and its Vault pass to the child, who then holds every right in this notice over it.

14. Your rights

Under UK data protection law you have the right to:

• access your personal information;

• have inaccurate information corrected;

• have your information erased;

• object to our use of it, including an absolute right to object to direct marketing;

• ask us to restrict its use;

• receive it in a portable form;

• withdraw consent at any time, without affecting what was done before.

To use any of these rights, email hello@deverediamonds.com. We reply within one month, there is normally no charge, and we may need to confirm your identity first.

15. Complaints

If you think we have mishandled your information, please tell us first. Email hello@deverediamonds.com with “Data protection complaint” in the subject line.

We acknowledge every complaint within 2 working days, and always within the 30 days the law allows. We then look into it without undue delay and tell you the outcome.

If you are not satisfied, you may complain to the Information Commissioner’s Office: ico.org.uk/make-a-complaint, telephone 0303 123 1113, or Wycliffe House, Water Lane, Wilmslow, SK9 5AF.

16. Changes to this notice

We may update this notice from time to time. The latest version is always on our website, and we will tell you directly about any change that significantly affects you.

17. Contact

Questions about this notice: hello@deverediamonds.com, or write to us at our registered office.