Privacy policy

Version 1.3 · Effective July 27, 2026

This Privacy Policy explains what personal information Persona Jewelry collects, where it comes from, why we use it, who we disclose it to, and the choices available to you.

Persona Jewelry is a brand of Tempus Luxury, LLC. This Policy should be read together with our Biometric and Memorial Data Policy, which provides additional rules for fingerprints and other memorial material.

1. What We Collect

When you order: your name, email address, phone number, billing and shipping addresses, payment confirmation, and the details of what you ordered. Payment card details are processed by our payment providers; we do not store your full card number.

Memorial material: fingerprint and handprint files, physical impressions, handwriting, signatures, photographs, and the names, dates, or inscriptions you ask us to use. This may be uploaded by you or, where we have authorized a funeral home under a written arrangement with us, submitted on your behalf by that funeral home.

Persona PIN information: a PIN used to locate an eligible fingerprint record and attribute an order to the funeral home through which the record was created. A Persona PIN is a reference code and does not itself display a fingerprint image or the name of the person associated with the record.

When you contact us: the information in your messages, order questions, support requests, warranty claims, and our replies.

Automatically when you visit: device and browser information, IP address, pages viewed, interactions with the Site, and information collected through cookies and similar technologies.

Marketing preferences: your email address or phone number, consent timestamp, and opt-in or opt-out status when you choose to receive marketing.

2. Where Information Comes From

We collect personal information:

• Directly from you when you browse, create an account, place an order, upload personalization material, or contact us

• Automatically from your device and through cookies and similar technologies

• From Shopify and other service providers that support payments, fraud prevention, analytics, customer service, and order fulfillment

• Where a funeral home is authorized under a written arrangement with us, from that funeral home for material collected with the authorization described in Section 7

• From shipping carriers and logistics providers in connection with delivery and tracking

3. Why We Use Personal Information

We use personal information as reasonably necessary to:

• Create, process, personalize, fulfill, deliver, repair, remake, or support your order

• Process payments and prevent fraud

• Create and maintain customer accounts

• Send transactional communications about orders, production, shipping, and support

• Respond to questions and exercise customer-service, warranty, refund, and legal rights

• Improve our products, Site, customer experience, and business operations

• Send direct marketing communications when you have opted in

• Support advertising and personalization using standard personal information as described in Section 11

• Comply with tax, accounting, legal, security, and record-keeping obligations

We do not use Biometric and Memorial Data for marketing, advertising, profiling, unrelated identification, or unrelated artificial-intelligence or machine-learning training.

4. How We Disclose Personal Information

We may disclose personal information to:

• Shopify and service providers that host the Site or support payments, fraud prevention, analytics, communications, storage, customer service, fulfillment, and business operations

• Production personnel and manufacturing partners to create, inspect, repair, or remake the product

• Shipping and logistics providers to deliver an order or transport an authorized physical impression or mold

• Legal authorities where disclosure is required by law, court order, warrant, subpoena, or a valid government request

• A successor to the business in connection with a merger, acquisition, sale, reorganization, or similar transaction, subject to applicable protections

• Other parties at your direction or with your consent

Funeral homes. Only a funeral home authorized under a written arrangement with us may handle memorial material on our behalf. Where authorized, approved staff may act only for their assigned location, inside tools and workflows we approve, and only for the family’s order. Beyond that authorized handling, the funeral home receives order attribution and commission information—not memorial material—unless you expressly direct otherwise.

We do not sell personal information for money. Certain uses of standard personal information for advertising, personalization, or analytics may be considered “sharing,” “sale,” or “targeted advertising” under some U.S. state privacy laws. Available opt-out choices are described in Section 11.

We do not sell, lease, trade, or otherwise profit from Biometric and Memorial Data.

5. International Processing and Transfers

Persona Jewelry operates from the United States, and some production and service providers may process information in other countries, including Türkiye. Personal information may therefore be transferred to, stored in, or processed outside the country where you live.

Privacy laws differ between countries. We require personal information to be handled for the authorized purpose and apply this Policy to information under our control wherever it is processed.

Where applicable law requires a specific transfer mechanism or contractual protection, we will use the mechanism or protection required for that transfer.

6. The Persona PIN

A Persona PIN links an eligible fingerprint record to the funeral home location through which the record was created so that an order can be connected to the correct record and attributed to that location.

The PIN is not a coupon, discount code, or promotional code. A fingerprint uploaded directly by a customer does not receive a Persona PIN and does not create funeral-home attribution.

The PIN itself does not reveal a fingerprint image or the name of the person associated with the record.

7. Biometric and Memorial Data

Biometric and Memorial Data includes fingerprint and handprint material, physical impressions and molds, handwriting, signatures, memorial photographs, and associated authorization records.

Consent and authority. When you upload memorial material through our product-personalization form, you must affirmatively confirm that you are authorized to submit it and consent to its use for the purposes described in our Biometric and Memorial Data Policy.

Where we have authorized a funeral home under a written arrangement with us and it collects material for us, we require it to obtain a signed Persona Family Fingerprint Authorization — or equivalent auditable evidence of consent — from the legally authorized next-of-kin before collecting anything, and to keep that record.

Purpose limitation. We use Biometric and Memorial Data only to create, inspect, fulfill, repair, remake, or complete an authorized reorder, respond to related requests, and maintain required consent, transaction, warranty, fraud-prevention, or legal records. We never use it for marketing, profiling, or identification, and we never train any artificial-intelligence or machine-learning model on it. We do not sell, rent, license, lease, barter, or otherwise disclose it for value.

The full rules governing funeral-home restrictions, disclosure, security, retention, deletion, and requests are in our Biometric and Memorial Data Policy.

8. How Long We Keep Information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and for applicable legal, tax, accounting, fraud-prevention, dispute, warranty, and security requirements.

We keep information only as long as we actually need it. The periods below are outside limits — not periods we aim to reach.

• Order and transaction records: for the period required for fulfillment, accounting, tax, fraud-prevention, dispute, and legal purposes

• Account information: while the account is active and for a reasonable period afterward

• Fingerprint and handprint files, handwriting, signatures, and memorial photographs: no longer than three years after your last related interaction with us — and sooner once the purpose has ended, or once we have carried out a valid deletion or withdrawal request

• Physical impressions and molds: until your order's quality is confirmed, plus 90 days — or, if you ask us to keep them for possible reorders, up to the same maximum of three years after your last related interaction with us

• The signed Persona Family Fingerprint Authorization, or the minimal auditable evidence of consent, that we hold: five years, measured from the later of the date of the authorization or the last order that relied on it

• The copy an authorized funeral home holds: the same five years, kept as a controlled record, after which it must destroy it securely

• Marketing preferences: until you opt out, followed by a record sufficient to honor the opt-out

• Customer communications: for as long as reasonably necessary to manage the request, order, warranty, dispute, or business record

When you ask us to delete, or withdraw your consent, we aim to have it carried out within 90 days. That is how long the work takes across our systems. It is not a period for which we keep your material — the limits above still apply.

We keep something for longer only where a litigation hold, a legal obligation, or another documented lawful requirement applies. If that happens, we tell you what we kept and why, where legally permitted.

These periods are the standard we set for ourselves. They describe how we operate. They are not a statement about what any particular law requires, and a shorter period required by law always takes precedence.

9. Your Privacy Rights

Depending on where you live and subject to applicable exceptions, you may have the right to:

• Know or access the personal information we hold about you

• Obtain a copy of eligible information

• Correct inaccurate information

• Delete eligible information

• Withdraw consent where processing is based on consent

• Opt out of sale, sharing, or targeted advertising where applicable

• Appeal a decision regarding a privacy request where applicable

To submit a request, email info@personajewels.com with the subject line “Privacy Rights Request,” describe the request, and include your order number where relevant.

We may need to verify your identity and, where you act for someone who has died, your legal authority. We will respond within the period required by applicable law.

We will not discriminate against you for exercising an applicable privacy right. Some requests may be limited by information we must retain for legal, tax, accounting, fraud-prevention, security, or transaction-completion purposes.

10. Marketing and Communications

We send direct marketing emails or text messages only when you have opted in. Marketing consent is not a condition of purchase.

You may unsubscribe from marketing emails using the unsubscribe link in the message. You may opt out of marketing text messages by replying STOP.

Even after opting out of marketing, you may still receive non-promotional messages about an order, account, request, delivery, security issue, or other transaction.

11. Cookies, Shopify Network Intelligence, and Your Privacy Choices

We and our service providers, including Shopify, use cookies and similar technologies to operate the Site, secure checkout, remember preferences, measure performance, personalize experiences, prevent fraud, and support advertising.

Cookie controls. A cookie-consent banner may appear in regions where our configured markets and applicable requirements call for consent. In other regions, the banner may not appear. You may also control cookies through your browser and available Site tools, although disabling some cookies may affect functionality.

Shopify Network Intelligence. Shopify Network Intelligence is enabled for our store. Shopify may process information from your interactions with our store together with information from interactions with Shopify and other Shopify merchants to provide enhanced services, including personalization, analytics, advertising, fraud prevention, and store improvement. Other merchants cannot access our customer data through this feature.

For processing connected with Shopify’s enhanced services, Shopify may act independently and is responsible for handling applicable privacy requests concerning that processing. More information is available through the Shopify Consumer Privacy Policy and the Shopify Privacy Portal.

Your Privacy Choices. In jurisdictions where applicable law provides a right to opt out of sale, sharing, or targeted advertising, you may use the “Your Privacy Choices” link in the footer of our Site.

Global Privacy Control. Where required by applicable law, we treat a supported Global Privacy Control signal as an opt-out request for the browser or device sending the signal. If Shopify can associate that signal with a customer account, the choice may also be applied to the account.

Additional information about cookies and controls is available in our Cookie Policy.

12. Children

The Site and our products are not directed to children under 16, and we do not knowingly collect personal information from children under 16.

If you believe a child has provided personal information to us, contact us and we will review and delete eligible information as required.

13. Security

We use reasonable technical, administrative, and organizational safeguards designed to protect personal information and limit access to people who require it for an authorized purpose.

No electronic or physical system can be guaranteed to be completely secure. If a security incident affects personal information, we will investigate and provide notifications where required by applicable law.

14. Third-Party Sites and Services

The Site may link to websites, applications, or services operated by third parties. Their privacy practices are governed by their own policies. We are not responsible for the privacy, security, content, or practices of a third-party service merely because the Site links to it.

15. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, services, or legal requirements.

Material changes will be posted on this page with an updated date. Where a change materially expands how we collect or use Biometric and Memorial Data, we will obtain additional consent where required rather than relying only on publication of the updated Policy.