HRD PRIVACY POLICY
Last Update: 30 January 2026
1. INTRODUCTION
HRD Antwerp BV and our related entities (“HRD”, “we”, “our”, “us”) are committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you interact with us — whether you request grading, valuation, appraisal, or related gemological services from us, and whether you purchase equipment, register for our education courses, use our online platform, or visit our premises (collectively referred to as our “Services”).
This includes data that we collect about you through our website www.hrdantwerp.com, and other HRD websites on which this Notice is posted (collectively, the “Sites”) and offline (such as trade shows or at HRD locations). We collect data directly from you, automatically as you use our Services, from vendors, and from other individuals, as set forth below.
This Privacy Notice does not apply to any information, data, or materials collected by thirdparty websites, applications, or social media platforms (“Platforms”). These Platforms maintain their own privacy and security practices, for which HRD assumes no responsibility. Your use of such Platforms is undertaken at your own risk. If you choose to communicate with us through these Platforms, any personal data we receive from you will be processed in accordance with this Privacy Notice.
HRD operates in accordance with the General Data Protection Regulation (GDPR) (implementation as per 25 May 2018) with regards to processing personal data.
HRD provides its Services across the world. The data controller for any data submitted through our services is listed in the details set forth below:
HRD Antwerp
Hoveniersstraat 22
2018 Antwerp
BELGIUM
2. CONSENT
You are not legally required to provide us with your personal data. However, certain services — such as grading, valuation, report issuance, or secure item handling — may not be available if you choose not to provide the information necessary to perform them.
By accessing or using our website or services, you acknowledge that you have read this Privacy Policy. The legal bases on which we process personal data are described in Section 5. “Purposes and Legal Bases for Processing” section of this policy. Where we rely on consent, you may withdraw it at any time.
If you do not agree with this Privacy Policy, please discontinue use of the website and our online services.
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The “Last Updated” date at the top of this page indicates when the most recent changes were made.
3. DATA WE COLLECT
We do not collect Data from you for you to have access to general information available on our Website, but we do receive/collect data from you should you require services from us. The information that we may collect is listed below, please note the list may not be exhaustive.
a. Data You Provide
Depending on your interaction with us, we may collect:
- Name/Company Name and contact details
- Billing, invoicing and shipping information
- Identification documents, Ultimate Beneficiaries and Directors details (for antifraud checks, or KYC requirements)
- Payment information and purchase history
- Location information (through the collection of your IP address) in order to locate a store near you
- Certificates, grading reports, or provenance documents you provide
- Details about the item submitted (weight, characteristics, serial numbers, inscriptions, certificates)
- Any other required data and communications with our team
b. Data Collected Automatically
When you access or use our Website, certain information is collected automatically to support its functionality, maintain security, and improve performance. This information may include your IP address, device type, operating system, browser details, and the date and time of your visit.
We also gather data about how you interact with the Website, such as the pages you view, the links you click, and general usage patterns. This information helps us understand how visitors use our services and enables us to enhance the user experience.
In addition, we may use cookies, web beacons, and similar technologies to collect technical and usage data. Further details about these technologies and how you can manage your preferences are provided in Section 7. “Cookies and Tracking Technologies” section of this Privacy Policy.
c. Data from Third Parties
We may receive personal data about you from third parties who assist us in delivering our services. This may include information provided by jewelers, brokers, or other intermediaries acting on your behalf when submitting items for grading or valuation.
We may also obtain data from service providers that support our operations, such as identityverification and fraudprevention partners, payment processors, logistics companies, and insurance providers involved in the secure handling or transport of highvalue items.
In certain cases, we may receive information from publicly available sources or industryrecognized certification bodies when such data is necessary to verify provenance, authenticity, or prior documentation associated with an item.
4. HOW WE USE YOUR DATA
Providing and Improving Our Services: We use your personal data to process and fulfill your orders, manage your account, and support the delivery of our grading and valuation services and any other services that we provide. We also use your data to respond to your inquiries, to develop new features, products or services and to perform technical operations as well as customer support services.
Marketing and Similar Communications: Your personal data may also be used to operate, maintain, and enhance our Website, as well as to provide you with information, marketing communications, or promotional materials that we believe may be relevant to your interests. We may contact you regarding updates, services, or offerings related to the Website or our products and services.
Storing or Processing Data: We may transfer your personal data to our subsidiaries or affiliated entities, whether located domestically or abroad, for the purposes of storing or processing such information on our behalf. These transfers may involve the movement of data to other countries. All such entities are required to process personal data in accordance with this Privacy Policy and applicable dataprotection standards.
Personalize your experience: We may use your personal data to tailor and enhance your experience with our Website and services. This may include presenting content, recommendations, or features that are more relevant to your interests, preferences, and prior interactions with us. Such processing enables us to provide a more efficient, userfriendly, and personalised service environment. We may also share your personal data with thirdparty service providers and business partners who assist us in operating our business and delivering our Website and related services. These third parties may be located in other jurisdictions. We make commercially reasonable efforts to engage only with service providers and partners that maintain privacy practices consistent with the protection of personal data.
Comply with Legal Obligations: We may disclose your personal data, or any information submitted through the Website, when we consider such disclosure reasonably necessary to safeguard our rights, interests, and operations. This may include actions taken to protect the security of our systems, prevent or investigate fraudulent or unlawful activity, address technical vulnerabilities, or respond to potential threats. We may also disclose information to comply with legal obligations, support the enforcement of our Terms, cooperate with regulatory authorities, or present evidence in legal proceedings. Such disclosures may be made to protect the safety, property, or legitimate interests of our organization, our service providers, our users, or the public.
5. LEGAL BASES FOR PROCESSING
Purposes and Legal Bases for Processing
|
Purpose |
Examples |
Legal Basis |
|
Fulfilling orders and providing services |
Grading diamonds/jewelry, arranging shipping, issuing invoices and reports, provide education courses, provide equipment |
Performance of a contract |
|
Verifying identity and preventing fraud |
KYC checks, antimoneylaundering compliance, highvalue transaction verification |
Legal obligation / Legitimate interests |
|
Managing provenance and certification |
Handling grading reports, authenticity documentation |
Performance of a contract / Legitimate interests |
|
Communicating with you |
Customer support, appointment scheduling, wholesale inquiries |
Legitimate interests / Performance of a contract |
|
Marketing and promotions |
Newsletters, product updates, event invitations |
Consent |
|
Improving our services |
Website analytics, customer experience optimization |
Legitimate interests |
|
Legal and regulatory compliance |
Tax, accounting, AML regulations |
Legal obligation |
6. HOW WE SHARE DATA
We will not disclose your Data to non-HRD Entities for their own marketing purposes. We may, however, share your data with the following entities:
- HRD entities so that they may contact you about our services or respond to your enquiries/requests.
- Gemological laboratories or specialists assisting in advanced analysis
- Insurance providers when you request valuation reports for insurance purposes
- Secure logistics and courier partners handling transportation services
- Payment processors and financial institutions
- Identityverification and fraudprevention services
- Service providers, vendors, contractors, professional advisors, agents, or others who perform functions on our behalf
- Authorities when required by law
- Business successors in case of merger or acquisition
We may share aggregated or deidentified information regarding the use of our Services with service providers for purposes such as marketing, advertising, research, analytics, and other operational needs. We may also produce and publish summary reports that reflect overall usage patterns and trends across our Services.
We do not sell your personal data.
7. COOKIES AND TRACKING TECHNOLOGIES
We use cookies to enable core site functionality, analyze usage, improve user experience, support marketing efforts and support security and fraud detection. A cookie is a small text file placed on your device when you visit a website. Cookies enable websites to function efficiently and provide certain features by storing information about your browsing activity, preferences, and device. They help improve performance, enhance user experience, and support security and analytics functions.
Our website uses several categories of cookies to support its functionality and improve your experience. Functionality cookies enable us to recognize returning users and remember their preferences, such as language selection and geographic location. These cookies may be set by us or by authorized thirdparty providers.
We also use advertising cookies to collect information about your interactions with our website, including the pages you visit, the content you view, the links you follow, and technical details about your browser, device, and IP address. We may share limited portions of this data with third parties for advertising and analytics purposes. In addition, information gathered through these cookies may be combined with data from our advertising partners to deliver relevant advertisements on other websites based on your browsing behavior on our site.
Most web browsers allow you to manage your cookie preferences, including whether to accept cookies and how to delete them. You may configure your browser to notify you when a cookie is being placed or to block cookies entirely.
If you do not agree with the use of cookies, you can refuse them by changing your browser settings. Please bear in mind however that not installing these cookies may lead to website malfunctions and failures.
The Website may use Google Analytics, a web analytics service, to gather information about how users interact with the Website. Google Analytics collects data such as the frequency of visits, the pages viewed, and the websites visited prior to accessing our Website. We use this information to operate, maintain, and improve the Website and our services. We do not combine data collected through Google Analytics with personally identifiable information.
Google’s use and disclosure of information collected through Google Analytics is governed by the Google Analytics Terms of Service and the Google Privacy Policy. Additional information about how Google collects and processes data in connection with Google Analytics can be found in Google’s “How Google uses data” documentation. Users may prevent their data from being used by Google Analytics by installing the Google Analytics Optout Browser Addon.
8. DATA RETENTION
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including the provision of our services, compliance with legal and regulatory obligations, resolution of disputes, and enforcement of our agreements. Retention periods may vary depending on the nature of the information and the requirements of applicable law. When personal data is no longer required for these purposes, we take reasonable steps to delete, anonymize, or otherwise render it inaccessible.
9. DATA SECURITY
We employ a combination of administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. These measures are regularly reviewed and updated to address evolving security risks and industry’s best practices. Despite our efforts, no method of transmitting information over the internet or storing data is entirely secure, and we cannot guarantee absolute protection. You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password or keeping your login and password private.
10. YOUR GDPR RIGHTS
If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have certain rights regarding your personal data under applicable dataprotection laws. These rights are subject to specific conditions and legal limitations, and we will respond to any request in accordance with those requirements.
Right of Access: You have the right to request confirmation as to whether we process your personal data and, where applicable, to obtain a copy of such data along with information about how it is used. We reserve the right to charge a reasonable fee for attending this.
Right to Rectification: You may request that we correct or update any personal data that is inaccurate, incomplete, or outdated.
Right to Erasure: In certain circumstances, you may request the deletion of your personal data, for example where you withdraw your consent.
Right to Restrict Processing: You may ask us to limit the processing of your personal data in specific situations, such as when you contest the accuracy of the data or object to its processing, under certain conditions.
Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machinereadable format and to request that we transmit that data to another controller where technically feasible. We reserve the right to charge a reasonable fee for attending this.
Right to Object: You may object to the processing of your personal data where we rely on legitimate interests as our legal basis, including profiling. You also have the right to object at any time to the processing of your data for direct marketing purposes.
Right to Withdraw Consent: Where we rely on your consent to process personal data, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
Right to Lodge a Complaint: You have the right to submit a complaint to your local dataprotection authority if you believe that our processing of your personal data violates applicable law.
To exercise these rights, contact us at: privacy@hrdantwerp.com.
11. INTERNATIONAL DATA TRANSFERS
Depending on how you interact with us, your personal data may be transferred, accessed, stored, or otherwise processed by our organization, our affiliated entities, or external service providers in jurisdictions outside your country of residence. These locations may include, among others, the UAE and India, where dataprotection laws may differ from those in your home jurisdiction and may not offer the same level of protection. Such transfers may also occur in response to lawful requests from courts, regulatory bodies, or lawenforcement authorities in those jurisdictions.
We implement measures designed to safeguard personal data during crossborder transfers, including, where required, the use of written dataprocessing agreements and legally recognized transfer mechanisms. These may include the execution of the European Commission’s Standard Contractual Clauses or other appropriate safeguards permitted under applicable law.
12. Marketing Choices
Where permitted by applicable law, we may periodically send you electronic communications regarding our products, services, newsletters, or promotional offerings. These communications may be delivered by email. You may opt out of receiving marketing messages at any time by using the “unsubscribe” link included in our emails or by submitting a request to privacy@hrdantwerp.com. Please note that opting out of marketing communications will not affect our ability to send you nonmarketing messages relating to your account, transactions, or services you have requested or received, such as updates about an order or other essential service notifications.
13. Links
For your convenience, our Website may contain links to thirdparty websites or references to products and services that are not affiliated with us. If you choose to access these external sites or engage with such thirdparty offerings, please be aware that their own privacy policies—not this Notice—govern your interactions and any personal data you provide. We do not control and are not responsible for the privacy practices, content, or security of these nonaffiliated websites or applications.
14. CHILDRENS’ PRIVACY
Our Services are not intended for children under 18, and we do not knowingly collect their data. If we learn that we have collected personal information of those under 18, we will take steps to delete the information as soon as possible.
15. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. The “Last Updated” date will reflect the most recent changes.
16. CONTACT US
If you have questions or requests regarding this Privacy Policy, contact us at:
Legal Department
HRD Antwerp
Hoveniersstraat 22
2018 Antwerp
BELGIUM