We respect your right to privacy. This Privacy Policy sets out details of the information that we may collect from you and how we may use that information. This Privacy Policy should be read alongside, and in addition to, the Terms and the Cookies Policy. Please read this Privacy Policy carefully.

Unless otherwise defined in this Privacy Policy, terms used have the same meaning as in the


1.1 In this Privacy Policy, references to “we” or “us” are to ASR Gems Limited, a company incorporated in England and Wales (registered number 09225913) whose registered office is at 95, Mortimer Street, London, London, W1W 7GB, who will be the controller of any personal data processed as described in this Privacy Policy.

1.2 If you have any questions about your personal information, please contact us


This Privacy Policy applies only to your use of the Website and Content or other linking sites found on the Website may also gather information and you should consult those other parties’ privacy policies as appropriate and applicable.


3.1 When you access the Website via any means, Content, or participate in any survey or questionnaire sent to you by us, provide comments via the contact us tab, or make a purchase through the Website, we may collect, store and use certain of your personal information in line with this policy. We may also ask you for information when you report a problem with the Website or the Content.

3.2 To register or make a purchase on the Website, we ask for your name and email address. As part of your profile you may also provide other information that will help to tailor the service to suit you. We may also ask you about your gender and other demographic details in order to understand more about you (responding to these questions will always be optional, however). When you make a purchase, our payment service provider, will also collect and process your credit card or other payment details. If you contact us, we may also keep a record of that correspondence.

3.3 We may also collect data relating to your visits to the Website that cannot identify you but records your use of our Website and Online Courses and Content including, for example, details of how long you have used the Website and the Online Courses and Content for.

3.4 We may also collect your computer’s IP address in order to help us tailor the service to your location.

3.5 If you elect to verify your identity through our Website, our identity verification partner will receive directly from you, process and store your personal information and identity documentation for this purpose.  Our identity verification partner may store your information for a maximum of 5 days for the sole purpose of resolving user support issues. Upon successful verification of your identity, we will store only the name given on your identification documentation; if you participate in a credit bearing course or Program, we may share the confirmation that we have received from our provider with the relevant course provider or accrediting organisation to allow you to receive credit.

3.6 Finally, we may receive information about you from third parties (such as credit reference agencies) who are legally entitled to disclose that information.


4.1 By accessing the Website via any means and Content, registering providing comments via the contact us, or making a purchase via the Website, you agree that your personal information may be collected, stored, used and shared by us and our partners, course and content providers, or third parties we work with, for any of the following purposes:

(a) to provide, maintain, protect and improve the quality of the Website and Content we offer, including by conducting anonymised market research, and to protect us and our users;
(b) to provide you with a personalised browsing experience when using the Website;
(c) to fulfil any contractual agreements between you and us;
(d) if you have paid, to send you details of our other products and services which we think may interest you, unless you opt out as described at paragraph 9.1.3 below. You can control your email preferences by emailing us at
(e) to tailor our advertising on social media to your use of the Website;
(f) to manage your Buyer account that you hold with us;
(g) to allow you to use the full range of features on or via our Website;
(h) to comply with legal and regulatory requirements;
(i) to contact you occasionally in order to invite you to share your opinions and experiences of ASR Gems;

4.2 We may use your email address to send you promotional updates about our Products. You can control your email preferences by emailing us at


5.1 All information is stored on our secure servers. When you register, we will ask you to choose a password which enables you to access the Online Account and Content. You are responsible for keeping this password confidential. We ask you not to share this password with anyone.

5.2 In addition, we (or third parties acting on our behalf) may also store or process information that we collect about you in countries outside the European Economic Area, which may have lower standards of data protection. Specifically, servers used by our Website are located in Ireland  and our third party service providers operate around the world. We have put in place technical and organisational security measures to prevent the loss or unauthorised access of your personal information. However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the Internet.


6.1 Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

6.2 However, we will normally collect personal information from you only (i) where we have your consent to do so, (ii) where we need the personal information to perform a contract with you, or (iii) where the processing is in our legitimate interests and not overridden by your rights. In some cases, we may also have a legal obligation to collect personal information from you.

6.3 If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your information).

6.4 Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.


We may disclose your personal information to third parties when permitted by law including:

(a) with your consent;
(b) to our suppliers in order for them to help us provide our services to you, this includes:
1. other partner institutions that provide Bespoke Jewellery products;
2. our provider of customer relationship management services (which
allows us, for example, to send personalised email communications to you);
3. our provider of file storage and management services if you email us directly;
4. our payment services provider (as discussed at paragraph 3.2 above) when you make a purchase to process your payment;
5. our identity verification partner (as discussed at paragraph 3.5 above)
to verify your identity where you choose to select this option;
6. where you have agreed, to our refer-a- friend scheme provider, solely to enable your participation in the refer-a- friend scheme;
7. our customer service software if you contact our support team; and
8. providers of assessments and marking services when you sign-up for an assessment or submit a piece of work for marking.

These suppliers’ use of your personal data may be subject to their own privacy policies, which are available on their websites, and which we suggest you familiarise yourself with in the relevant circumstances set out above.

(c) if we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets, provided that they continue to use your information substantially in accordance with the terms of this Privacy Policy;

(d) if all, or substantially all of our assets, are acquired by a third party provided that they continue to use your information substantially in accordance with the terms of this Privacy Policy, in which case information held by us will be one of the transferred assets;

(e) if we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect our rights, property, or safety, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.