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, including material preserved through an authorized Memorial Provider before any jewelry purchase is made.

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.

Biometric and memorial material: fingerprint and handprint files, physical impressions, handwriting, signatures, photographs, and related names, dates, inscriptions, or other information associated with the material. This material may be submitted directly by you for product personalization or, where an authorized Memorial Provider collects it on our behalf, preserved in an authorized Persona record even if no jewelry purchase is made at that time.

Authorization and preservation records: information reasonably necessary to document that an authorized Memorial Provider obtained the required family authorization, confirmed that authorization before fingerprint capture, and created or maintained an authorized memorial preservation record. We may retain the authorization itself or minimal auditable evidence associated with it, depending on the approved workflow.

Persona PIN information: a reference code linked to an eligible fingerprint record created through an authorized Memorial Provider. The PIN associates that record with the Memorial Provider location through which it was created and, if an order is later placed using the record, enables the order to be attributed to that location. A Persona PIN 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, preservation or record questions, order questions, support requests, warranty claims, privacy requests, 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, submit a privacy or support request, or otherwise contact us

•       Automatically from your device and through cookies and similar technologies

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

•       From an authorized Memorial Provider where it collects or submits memorial material on our behalf through approved Persona tools and workflows after the required family authorization has been completed and the Memorial Provider has confirmed that authorization before capture

•       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 and maintain an authorized memorial preservation record

•       Associate an eligible fingerprint record with a Persona PIN and the Memorial Provider location through which the record was created

•       If a product is ordered, create, process, personalize, fulfill, deliver, repair, remake, or support that order

•       Process payments and prevent fraud

•       Create and maintain customer accounts

•       Send transactional communications about authorized preservation records, orders, production, shipping, requests, and support

•       Respond to questions and administer customer service, warranty, refund, privacy, and legal requests

•       Improve our products, Site, customer experience, and business operations using information that we are permitted to use for those purposes

•       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, consent, record-keeping, and dispute-related obligations

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

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, consent workflows, and business operations

•       Production personnel and manufacturing partners to create, inspect, repair, remake, or otherwise complete an authorized 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 another 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

Memorial Providers. Only a funeral home or other memorial provider authorized under a written arrangement with us may handle Biometric and Memorial Data on our behalf. Where authorized, approved staff may act only for their assigned location, only inside tools and workflows we approve, and only for the authorized preservation record and any later Persona order that properly relies on that record.

Beyond that authorized handling, a Memorial Provider may receive information necessary for record administration and, where a later purchase creates partner attribution, order attribution and commission information. It does not receive Biometric and Memorial Data for its own independent purposes unless you expressly direct otherwise and the disclosure is permitted.

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 is a reference code associated with an eligible fingerprint record created through an authorized Memorial Provider. It links that record to the Memorial Provider location through which the record was created.

A Persona PIN may exist before any jewelry purchase is made. If a later order uses the eligible record, the PIN helps connect the order to the correct fingerprint record and attribute the order to the issuing Memorial Provider 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 Memorial Provider 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.

Direct customer submissions. When you upload memorial material through our product-personalization process, 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.

Memorial Provider collection. Where a Memorial Provider authorized under a written arrangement with us collects a fingerprint or other memorial material on our behalf, we require a signed Persona Family Fingerprint Authorization, or equivalent auditable evidence of authorization, before fingerprint capture occurs.

The person providing that authorization must represent that they have lawful authority to authorize the collection and preservation of the material. The Memorial Provider is responsible for confirming, under its own professional procedures and applicable obligations, that the required authorization has been completed before it proceeds with capture.

Persona uses the Memorial Provider's confirmation as an operational requirement for access to the fingerprint-capture workflow. Persona does not, as part of that workflow, independently determine family hierarchy or adjudicate competing claims about who should act for the person whose material is being preserved. This does not eliminate any consent or authorization requirement imposed by applicable law.

No immediate purchase is required. An authorized fingerprint record may be created and preserved without a jewelry purchase at the time of collection. If the family later chooses to place an eligible Persona Jewelry order, the preserved record may be used for that authorized product purpose.

Purpose limitation. We use Biometric and Memorial Data only to create and maintain an authorized preservation record, associate an eligible record with its Persona PIN and issuing Memorial Provider location, create or fulfill an authorized Persona Jewelry product if one is ordered, inspect, repair, remake, or complete an authorized reorder, respond to related requests, and maintain required consent, transaction, warranty, fraud-prevention, security, or legal records.

We never use Biometric and Memorial Data for marketing, advertising, profiling, unrelated identification, or to train any artificial-intelligence or machine-learning model. We do not sell, rent, license, lease, barter, or otherwise disclose it for value.

The full rules governing Memorial Provider 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, security, consent, and record-keeping 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 concerning the material, and sooner once the purpose has ended or once we have carried out a valid deletion or withdrawal request

•       Physical impressions and molds: until the authorized purpose for holding them is complete, plus 90 days; or, if you ask us to retain them for possible later product creation or an authorized reorder, 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 authorization, that we hold: five years, measured from the later of the date of the authorization or the last order that relied on it. If no order relies on the authorization, the five-year period is measured from the date of authorization

•       The copy an authorized Memorial Provider 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 and family communications: for as long as reasonably necessary to manage the preservation record, request, order, warranty, dispute, or business record

When you ask us to delete material, or withdraw your consent where withdrawal is available, we aim to have the request carried out within 90 days. That is how long the work may take across our systems. It is not a separate period for which we are entitled to 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 that every law requires the same period, and a shorter period required by applicable law 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 an order number, Persona PIN, or other relevant record reference if one is available.

We may need to verify your identity and, where the request concerns material belonging to someone who has died, your authority to act in relation to the record. 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, consent, 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, fingerprint preservation, or access to an authorized memorial record.

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 authorized preservation record, order, account, request, delivery, security issue, or other transaction or service you requested.

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 have responsibilities for handling applicable privacy requests concerning its 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 applicable, a supported Global Privacy Control signal may be used to communicate an opt-out choice for the browser or device sending the signal. Shopify's privacy tools may apply that choice to supported processing as described in Shopify's privacy documentation.

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 version and 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.

16. Contact Information

Email: info@personajewels.com

Phone: +1 (786) 550-0303

Brand Name: Persona Jewelry

Legal Entity: Tempus Luxury, LLC

Mail: 133 NE 2nd Avenue, Unit 2013, Miami, Florida 33132, United States

Website: https://www.personajewels.com

Biometric and memorial-data requests: use the subject line “Biometric Data Request” and include an order number, Persona PIN, or other relevant record reference if one is available.

General privacy-rights requests: use the subject line “Privacy Rights Request.”