LUXYSOURCE TM PRIVACY POLICY

The LUXYSOURCE TM Platform and Website is a proprietary B2B system and technology for sourcing vendors, retailers and manufacturers (“Vendors”) of jewelry, diamonds, watches, glasses and other luxury goods (“Vendor Products”) and enabling such Vendors to sell Vendor Products through third party on-line and mobile digital retail platforms (“Digital Retail Platforms”). All such Vendors are direct sellers of their Vendor Products to end user consumers and/or the Digital Retail Platforms and enter into agreements with the Digital Retail Platforms for display and sale of their Vendor Products... To perform its inherent B2B functions, information regarding Vendors and Vendor Products must be provided by LUXYSOURCE to the applicable Digital Retail Platforms.

LUXYSOURCE provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of information we receive from users of www.Luxysource.com (the LUXYSOURCE Platform and Website) and our corresponding applications for mobile devices.

USE OF INFORMATION FOR LUXYSOURCE TO PROVIDE SERVICES

Every Vendor who utilizes the LUXYSOURCE Platform and Website must enter into a LUXYSOURCE VENDOR AGREEMENT (“LVA”). The LVA specifically authorizes LUXYSOURCE to obtain from Vendor and to upload, transmit or otherwise provide Vendor and Vendor Product information and photographs to Digital Retail Platforms selected by LUXYSOURCE.

Vendors who utilize the LUXYSOURCE Platform and Website to facilitate display and sale of Vendor Products on Digital Retail Platforms upload to LuxySource specific information describing Vendor, their Vendor Products as well as photographs of such products. LUXYSOURCE makes available such information and photographs of such Vendor Products and information regarding Vendor to Digital Retail Platforms selected by LUXYSOURCE for on-line and mobile display 1and sale of such Vendor’s Products. The selection, use, format, and display of such Vendor and Vendor Product Information and photographs by the Digital Retail Platforms and the availability of such information to users of such Digital Retail Platforms is controlled by the Digital Retail Platforms and not LUXYSOURCE, and may be governed by the contractual arrangements between the Vendor and the Digital Retail Platform and the terms of use and privacy policies of such Digital Retail Platforms. Digital Retail Platforms may require additional specific information to be disclosed and displayed regarding a Vendor and Vendor Products.

Such information regarding Vendor may include its business name, address, contact information, type of Vendor Products generally offered, sales, shipping, return, repair and warranty policies. Such information regarding Vendor products, in addition to photographs, may include size, color, grade, quality, condition, manufacturer, brand, SKU number, age of product, whether there is any third party certification, warranty, price, discounts, shipping charges, descriptions of design, features, and functions, and descriptions of any defects or damage. Vendor is responsible for the accuracy and completeness of all information supplied by Vendor as to Vendor and Vendor Products. The provision of such information regarding Vendor and Vendor Products does NOT imply any endorsement or certification by LUXYSOURCE which are hereby disclaimed.

The Digital Retail Platforms selected by LUXYSOURCE which facilitate on-line and mobile display of Vendor and Vendor Products may provide LUXYSOURCE with information regarding utilization and sale of Vendor Products by Vendor on such Digital Retail Platforms, including Vendor Products displayed, sold, price and payments collected.

Specific information personally identifiable to a Vendor and specific Vendor Products (whether obtained from Vendor or Digital Retail Platforms) is not provided to third parties (other than Digital Retail Platforms selected by LUXYSOURCE as described above) and information regarding Vendor’s transactions on a particular Digital Retail Platform is not provided to other Digital Retail Platforms.

AGGREGATION

LUXYSOURCE does aggregate information and develop statistics, analytics and data regarding utilization of the LUXYSOURCE Platform and Website and associated mobile applications by types and number of Vendors, types of 2numbers of Vendor Products, utilization of particular Digital Retail Platforms, price ranges, brand names, and other criteria and filters. However, such aggregations, analytics and data, which may be provided to third parties, will NOT include information personally identifiable to Vendor and specific Vendor Products.

ARTIFICIAL INTELLIGENCE

LUXYSOURCE may develop and employ advanced artificial intelligence methodologies to track and attempt to predict and target end user customer preferences. Such information may be developed from the aggregate analytics referenced above and may be provided to multiple Vendors and/or Digital Retail Platforms and/or third parties. Any such information which contains any information personally identifiable to Vendor and specific Vendor Products will only be provided to the identifiable Vendor and not to other Vendors or third parties.

CERTAIN PROTECTED INFORMATION.

In order for LUXYSOURCE to provide services to Vendors and Digital Retail Platforms, LUXYSOURCE may collect and store certain personally identifiable protected information such as bank accounts, wire transfer instructions and credit card numbers (“Protected Information”). LUXYSOURCE will not disclose Protected Information to third parties except in connection with Compliance with Law and Law Enforcement (discussed below).

USE OF COOKIES

We may place cookies on computers used by Vendors, Digital Retail Platforms and others accessing the LuxySource Platform and Website and associated mobile applications. A cookie is a small data file that is transferred to your computer or mobile device’s hard disk for record-keeping purposes. Cookies may assist LuxySource in processing information regarding Vendors, Digital Retail Platforms and other users of our system, in developing statistics, analytics and data, for security and maintenance purposes, and for preserving preferences, settings and customizations of our users. Digital Retail Platforms and third party advertisers may also place or read cookies on computers used by Vendors. By visiting the LUXYSOURCE Website with your browser settings adjusted to accept cookies informs us that you desire to utilize our Website and that you consent to our use of cookies to provide such services to you.

IF YOU DO NOT WISH TO ACCEPT COOKIES. You can instruct your browser, by changing its options or settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all functionalities of the LUXYSOURCE Platform and Website.

THIRD PARTY SERVICE PROVIDERS

LUXYSOURCE may engage third party contractors, whether businesses or individuals, to perform services for LUXYSOURCE, including programming, coding, maintenance, research and analytics, to add functionalities, backup and data storage, and for physical and cyber security and for other business purposes. These third parties, in the normal course of providing their services, have access to specific identifiable information regarding Vendors and Vendor Products only to perform their services to LUXYSOURCE and are obligated not to disclose or use it for any other purpose.

SOCIAL MEDIA

We may share information specific to Vendor and Vendor Products with the social media, as authorized by the LVA that each Vendor has entered into. Social Media sites may have access to Vendor information separate and apart from LuxySource because Vendors may link or provide Vendor information directly to social media, and/or Digital Retail Platforms displaying Vendor Products may link or provide such information directly to social media in accordance with the Digital Retail Platform’s terms and use and contract arrangements with Vendors. LuxySource does not control and has no responsibility for Vendor and Vendor Product information linked or provided to social media by Vendors, Digital Retail Platforms or other providers separate and apart from LuxySource.

FACEBOOK CONNECT

LUXYSOURCE enables Vendors to automatically post recent activity onto to Facebook, and give them the option to disable Facebook Connect at any time by logging into their profile and selecting the option to disable Facebook Connect. Further, Vendors may be able to edit your privacy settings for the content which appears on Facebook by making selections in Vendor’s LuxySource account settings.

COMPLIANCE WITH LAWS AND LAW ENFORCEMENT; SECURITY BREACHES

LUXYSOURCE may cooperate with government and law enforcement officials and private parties to enforce and comply with the law. LUXYSOURCE may disclose any information about you to government or law enforcement officials or private parties as we believe necessary or appropriate to respond to claims and legal process (including, but not limited to, subpoenas), to protect the property and rights of LUXYSOURCE or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

LUXYSOURCE may make any legally required disclosures and notifications of any breach of the security, confidentiality, or integrity of information of Vendors, Digital Retail Platforms and other users of the LUXYSOURCE PLatform and Website to you via email or conspicuous posting on the Website or associated mobile application as promptly as practicable as consistent with the legitimate needs of law enforcement or and the need to determine the scope of the breach and restore the operation and integrity of the Website.

LOG DATA

When Vendors, Digital Retail Platforms or others access and log in to Confidential the LUXYSOURCE Website, we record such logins, which enables LUXYSOURCE to verify permitted access to the site, recognize the user, access the user’s profile and data and provide the appropriate services to the user. Log in data also enables LUXYSOURCE to monitor the use of the site, record and develop analytics, better address user’s preferences. Login data for a particular user may include the user’s Internet Protocol; what type of device was used to access the site; how long the user spent on the LUXYSOURCE site and what pages were visited and functionalities utilized. LUXYSOURCE will not share with third parties specific log in data as identifiable to a particular user, but LUXYSOURCE will aggregate such data for analytics and may share such aggregated information with third parties. We may also provide login data to third parties in connection with Compliance with Law and Law Enforcement and for cyber security and fraud protection.

CORRECTION /UPDATE OF INFORMATION

Vendors may review, update, correct or delete information specific to the Vendor by contacting LUXYSOURCE at Support@luxysource.com or as to some items, by editing such information via the 5Website itself. If a Vendor deletes certain items that are necessary for LUXYSOURCE to provide services, then some or all functionalities may be suspended until replacement information is provided. In the event an LVA is terminated, LUXYSOURCE will continues to be authorized to provide information on Vendor and Vendor Products to Digital Retail Vendors and as necessary to process Vendor Products already uploaded to Digital Retail Vendors and any payments ad charges relating to such Vendor Products.. We may retain an archived copy of information relating to Vendors, Digital Retail Platforms and other users of the LUXYSOURCE Platform, Website and associated mobile applications as required by law or for legitimate business purposes.

SECURITY--USER RESPONSIBILITIES

 Vendors, Digital Retail Platforms and other users of the LUXYSOURCE Platform and Website and associated mobile applications should limit access to those of their employees to need to have access to carry out their legitimate functions for such parties. Usernames, passwords and access keys to the LUXYSOURCE Platform and Website and associated mobile applications should be restricted to those employees who have a need to know them to carry out their responsibilities, should be changed frequently, should not be easily recognized or duplicated, should be hidden and never be displayed openly.

INFORMATION TRANSFER TO/FROM INTERNATIONAL AND OTHER JURISDICTIONS

LUXYSOURCE operates on a global basis. In order to properly provide services to Vendors, Digital Retail Platforms and other users, information of such parties collected or stored on or processed by or uploaded to or from the LUXYSOURCE Platform and Website and associated mobile applications may be transferred to and stored on computers located outside of such parties’ state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in such parties’ home jurisdiction. Vendors, Digital Retail Platforms and other users located outside the United States and choose to provide information to LUXYSOURCE acknowledge that LUXYSOURCE transfer such information to the United States and processes it there consent to such policy and transfer of information by entering into LVAs or other contracts with LUXYSOURCE and submission of such information.

LINKS TO OTHER SITES

The LUXYSOURCE Website may contain links to other websites. If a Vendor, Digital Retail Platform or other user elects to visit an advertiser by "clicking on" a banner ad or other type of advertisement, or click on another third party link, such party is transferred to that third party’s website. The fact that LUXYSOURCE may link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. LUXYSOURCE does not exercise control over third party websites. These other websites may place their own cookies or other files on a user’s computer or mobile device, collect data or solicit personal information. Other sites follow different rules regarding the use or disclosure of the personal information submitted to them.

POLICY TOWARD CHILDREN

The LUXYSOURCE Platform and Website and associated mobile applications are a B2B system and service and are not intended to be utilized by anyone under the age of 18 years old. We do not knowingly collect personally identifiable information from anyone under 18 years of age. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at Support@Luxysource.com If we become aware that a child under 18 has provided us with personal information, we will delete such information from our files.

CONTACT US REGARDING THIS PRIVACY POLICY. If you have any questions about this Policy or any of the practices described herein, please contact us at 529 Fifth Avenue, Suite 1700 New York, New York 10017 or send us an email at Support@luxysource.com

TERMS OF SERVICE, NOTICES, AND UPDATES TO PRIVACY POLICY

Any use of or visit to the LUXYSOURCE Website or services provided thereby, and any potential or actual dispute concerning privacy is subject to this Privacy Policy, our Terms of Service, and an LVA or other contract between LUXYSOURCE and such user, including but not limited to, limitations on damages and resolution of disputes. If any user has any questions or issues regarding privacy in connection with the LUXYSOURCE Platform and Website, our associated mobile applications or services, please contact us with a full and complete description of the issues, and we will do our best to resolve any issues as soon as commercially practicable. 7As the LUXYSOURCE Platform and Website and related services may change from time to time, and there may be changes in applicable law, LUXYSOURCE may have to make changes to this Privacy Policy or our Terms of Service. LUXYSOURCE therefore reserves the right to amend this Privacy Policy or our Terms of Service from time to time. We may email periodic reminders of our changes to our Privacy Policy or Terms of Service, but users should periodically check the Website to obtain the current Privacy Policy or Terms of Service. Any changes we make to our Privacy Policy or Terms of Service will become effective upon posting of the revised version(s) to our Website or associated mobile applications, as the case may be.