Privacy Policy
1. Introduction
This Privacy Policy explains how Metfolio Limited trading as Gemfolio ("Gemfolio", "we", "us", "our") collects, uses, shares, and protects your personal information when you use our website, mobile application, and services (collectively, the "Platform").
By using our Platform, you consent to the data practices described in this Privacy Policy. If you do not agree with our practices, please do not use our Platform.
Data Controller Information:
Company: Metfolio Limited trading as Gemfolio
Registration Number: 14139437
Address: 290-292 Green Street, London, England
Contact: meeren@metfolio.com
2. Information We Collect
2.1 Information You Provide Directly
Account Information:
Full name
Email address
Date of birth
Residential address
Phone number
Payment card details
Bank account information
Identity verification documents (passport, driving licence)
Transaction Information:
Purchase history
Jewellery gram balances
Subscription details
Delivery information
Returns and refunds
Communications:
Customer service inquiries
Feedback and reviews
Survey responses
Marketing preferences
2.2 Information Collected Automatically
Device and Usage Information:
IP address
Device type and identifiers
Operating system and version
Browser type and version
App version
Screen resolution
Time zone settings
Language preferences
Behavioural Data:
Pages/screens viewed
Products browsed
Search queries
Click patterns
Time spent on pages
Navigation paths
Purchase funnel behaviour
App usage patterns
Location Data:
Approximate location from IP address
Postal code for delivery
Technical Data:
Log files
Error reports
Performance data
Crash analytics
2.3 Cookies and Tracking Technologies
We use various tracking technologies including:
Essential Cookies:
Session management
Security tokens
User preferences
Shopping basket functionality
Analytics Cookies:
Google Analytics
Mixpanel tracking
PostHog analytics
Performance monitoring
Marketing Cookies:
Facebook Pixel
TikTok Pixel
Google Ads tracking
Retargeting cookies
Conversion tracking
Third-Party Cookies:
Payment processor cookies
Customer support tools
Social media plugins
3. How We Use Your Information
3.1 Service Provision
Process your purchases and subscriptions
Manage your jewellery gram account
Facilitate deliveries
Process returns and refunds
Provide customer support
Send transactional communications
3.2 Platform Improvement
Analyse user behaviour and preferences
Improve user experience
Develop new features
Fix bugs and technical issues
Conduct A/B testing
Personalise your experience
3.3 Marketing and Communications
Send promotional emails (with consent)
Display personalised advertisements
Retarget across platforms
Send push notifications (with consent)
Conduct market research
Measure campaign effectiveness
3.4 Legal and Security
Verify your identity
Prevent fraud and financial crimes
Comply with legal obligations
Enforce our terms and conditions
Protect our legal rights
Maintain platform security
3.5 Analytics and Insights
Track conversion rates
Analyse user journeys
Monitor platform performance
Generate business intelligence
Understand customer segments
Measure feature adoption
4. Legal Basis for Processing
We process your personal data based on:
Contract Performance:
Processing purchases
Managing subscriptions
Delivering products
Customer service
Legitimate Interests:
Fraud prevention
Platform security
Business analytics
Direct marketing (existing customers)
Platform improvements
Legal Obligations:
Anti-money laundering checks
Tax reporting
Regulatory compliance
Court orders
Consent:
Marketing communications (new customers)
Non-essential cookies
Push notifications
Location tracking
5. Data Sharing and Disclosure
5.1 Service Providers
We share data with providers who assist us:
Payment processors (Stripe, PayPal)
Delivery partners (Royal Mail, DPD)
Cloud hosting (AWS, Google Cloud)
Customer support tools
Email service providers
SMS providers
5.2 Analytics and Advertising Partners
Mixpanel: User behaviour analytics
PostHog: Product analytics and feature tracking
Google Analytics: Website and app analytics
Facebook/Meta: Advertising and pixel tracking
TikTok: Advertising and conversion tracking
Google Ads: Search and display advertising
5.3 Other Disclosures
We may share information:
With your consent
To comply with legal obligations
To protect our rights and safety
In connection with business transfers
With professional advisors
To enforce our terms
5.4 International Transfers
Your data may be transferred outside the UK/EEA to:
United States (analytics providers)
Other countries where our service providers operate
We ensure appropriate safeguards through:
Standard contractual clauses
Adequacy decisions
Privacy Shield compliance (where applicable)
6. Data Retention
We retain your data for:
Account information: Duration of account plus 6 years
Transaction records: 6 years (legal requirement)
Marketing data: Until consent withdrawn or 3 years of inactivity
Analytics data: 26 months
Customer service: 3 years
Cookies: See Cookie Policy for specific durations
7. Your Rights
Under UK GDPR, you have the right to:
7.1 Access
Request a copy of your personal data
7.2 Rectification
Correct inaccurate or incomplete data
7.3 Erasure
Request deletion of your data (subject to legal obligations)
7.4 Restriction
Limit how we process your data
7.5 Portability
Receive your data in a portable format
7.6 Objection
Object to certain processing activities
7.7 Automated Decisions
Not be subject to purely automated decision-making
7.8 Withdraw Consent
Withdraw consent where processing is based on consent
To exercise these rights, contact: meeren@metfolio.com
8. Cookie Management
8.1 Cookie Controls
You can manage cookies through:
Browser settings
Our cookie preference centre
Device settings (mobile apps)
8.2 Opting Out of Tracking
Google Analytics: Install Google Analytics Opt-out Browser Add-on
Facebook: Visit Facebook Ad Preferences
TikTok: Adjust TikTok Ad Preferences
General: Visit www.youronlinechoices.com
8.3 Do Not Track
We do not currently respond to Do Not Track signals.
9. Children's Privacy
Our Platform is not intended for children under 18. We do not knowingly collect data from children. If we learn we have collected data from a child, we will delete it promptly.
10. Data Security
We implement appropriate measures including:
Encryption in transit and at rest
Access controls and authentication
Regular security assessments
Incident response procedures
Employee training
Secure development practices
PCI DSS compliance for payments
However, no system is 100% secure. You are responsible for maintaining the security of your account credentials.
11. Third-Party Links
Our Platform may contain links to third-party websites. We are not responsible for their privacy practices. Please review their privacy policies before providing personal information.
12. Marketing Communications
12.1 Email Marketing
Opt-in required for promotional emails
Unsubscribe link in every email
Preference centre for granular control
12.2 Push Notifications
Explicit consent required
Can be disabled in app settings
12.3 SMS Marketing
Explicit opt-in required
Text STOP to unsubscribe
13. California Privacy Rights
California residents have additional rights under CCPA:
Right to know categories and specific pieces of personal information
Right to delete personal information
Right to opt-out of the sale of personal information
Right to non-discrimination
We do not sell personal information.
14. Changes to This Policy
We may update this Privacy Policy periodically. We will notify you of material changes by:
Email notification
Platform notification
Prominent notice on our website
The "Last Updated" date will reflect the latest version.
15. Contact Information
For privacy inquiries or to exercise your rights:
Data Protection Officer:
Email: meeren@metfolio.com
Post: Data Protection Officer, Metfolio Limited trading as Gemfolio, 290-292 Green Street, London, England
Response Time: We aim to respond within 30 days
16. Supervisory Authority
You have the right to lodge a complaint with the Information Commissioner's Office (ICO):
Information Commissioner's Office
Website: https://ico.org.uk
Phone: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
17. Specific Platform Disclosures
17.1 Mixpanel
We use Mixpanel to:
Track user interactions
Analyse feature usage
Monitor conversion funnels
Create user cohorts
Measure retention
Data shared: User ID, events, properties, device info Privacy Policy: https://mixpanel.com/legal/privacy-policy/
17.2 PostHog
We use PostHog for:
Session recording (anonymised)
Feature flags
A/B testing
User analytics
Heatmaps
Data shared: User actions, page views, feature interactions Privacy Policy: https://posthog.com/privacy
17.3 Facebook/Meta Pixel
We use Facebook Pixel for:
Conversion tracking
Retargeting campaigns
Lookalike audiences
Campaign optimisation
Data shared: Email (hashed), purchase events, page views Privacy Policy: https://www.facebook.com/privacy/policy
17.4 TikTok Pixel
We use TikTok Pixel for:
Ad performance tracking
Audience building
Conversion optimisation
Retargeting
Data shared: Email (hashed), events, purchase value Privacy Policy: https://www.tiktok.com/legal/privacy-policy
By using the Gemfolio Platform, you acknowledge that you have read and understood this Privacy Policy.
