Last updated: August 29, 2011

1. Overview

1.1 Rapaport USA Inc. and the Rapaport Group ("Rapaport" or "we") offers free as well as subscriber/membership based services ("the Services") through its Rapnet.com Diamonds.Net, and Rapaport.com websites. In order to operate the Services and to be in compliance with the USA PATRIOT ACT, Rapaport may ask you to provide us with company, personal, credit card and/or bank account details. This Privacy Policy applies to all Rapaport websites and describes the information we collect and how we use that information.

1.2 Rapaport takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Paragraph 3 below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the Diamonds.Net, Rapaport.com and Rapnet.com websites, whether the services are offered by Rapaport, by its subsidiaries, or by its affiliates in the Rapaport Group.

1.3 By using this website, you agree to accept the Privacy Policy and RapNet Terms of Service (TOS) . By applying for any of the subscription or membership based services offered through this website, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into the terms of the RapNet TOS.

1.4 Please note that your personal information will be stored and processed on our computers in the United States, in accordance with United States laws. Rapaport will hold and transmit your personal information in a safe, confidential and secure environment. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register for the Services.

1.5 Notification of Changes

This policy may be revised over time as new features are added to the Services or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only 30 days after we post an amended Privacy Policy.

We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check this Web site at any time for the most current version of our Privacy Policy.

1.6 This Web site may include links to third party Web sites. These sites are governed by their own privacy statements, and Rapaport is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party Web sites should review the privacy statement of these sites before providing them with personally identifiable information.

2. Information We Collect

2.1 Required Information
To subscribe to the Services, you must provide company details, address, phone number, and e-mail address. In order to trade through our INDEX-Internet Diamond Exchange or RapNet trading systems, you must provide trade references, credit card, debit card and bank account information. This required information is necessary for us to approve your membership and to process transactions or to contact you should the need arise in administering your membership.
For USA PATRIOT ACT purposes we are required to collect your Employee Identification Number ("EIN") or other Taxpayer Identification Number ("TIN"). If you choose to register or apply for certain optional/additional features or products offered through Rapaport Web sites, you will be required to provide additional information to establish that you qualify for such features or products.

2.2 Transaction Information
When you list a diamond for sale, purchase or sell a diamond, or use the Services in any way, we record information related to each transaction, including the amount of the transaction. We retain this information for each of your transactions through Diamonds.Net, Rapaport.com and Rapnet.com websites. We also collect the Internet address (IP address) of the computer or device you use to access your Rapaport account, in order to help detect possible instances of unauthorized transactions.

2.3 Information About You From Third Parties
In order to protect us and our customers against potential fraud, we may verify with third parties the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. This may include background and credit checks by obtaining information about you and your business from a credit bureau or a business information service such as Dun & Bradstreet. If you incur a debt to Rapaport, we will generally conduct a credit check by obtaining additional information about you from a credit bureau, to the extent permitted by law. Rapaport, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account, and reserves the right to close an account based on information obtained during this credit review process.

2.4 Additional Verification
If we cannot verify the information that you provide we may ask you to send us additional information by fax (such as your drivers' license, credit card statement, and/or a recent utility bill or other information linking you to the applicable address), or to answer additional questions online to help verify your information.

2.5 Web Site Traffic Information
Because of the way that World Wide Web communication standards work, when you arrive at or leave this Web site, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with Rapaport. We do not track the Web sites that you visit before or after you leave the Rapaport site.

2.6 Rapaport Message Center
Messages sent to you and from you through the Rapaport Message Center or Rapaport communication tools are kept and maintained by Rapaport.

2.7 Our Use of "Cookies"
This Web site uses cookies to enhance your browsing experience. Cookies are small pieces of information saved by your browser onto your computer. Cookies are used to remember various aspects of your visit. This information is used by us to guarantee a consistent and uninterrupted experience. Cookies will allow you to revisit without losing many of your settings. We do not use cookies to save personal information for outside uses.

2.7 Our Use of "Cookies"
This Web site uses cookies to enhance your browsing experience. Cookies are small pieces of information saved by your browser onto your computer. Cookies are used to remember various aspects of your visit. This information is used by us to guarantee a consistent and uninterrupted experience. Cookies will allow you to revisit without losing many of your settings. We do not use cookies to save personal information for outside uses.

2.8 Customer Service Correspondence
If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Rapaport to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our Terms of Service Agreement. We may, over time, delete these records if permitted by law.

2.9 Questionnaires, Surveys and Profile Data
From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

3. Our Use and Disclosure of Information

3.1 Internal Uses
We collect, store and process your personal information on servers located in the United States . We use the information we collect about you in order 1) to provide our services and process your transactions, 2) to provide customer service, 3) to determine your eligibility to receive special trading privileges or products and 4) to improve our products and services.

3.2 Disclosure to Other Rapaport Customers
If you are a registered RapNet or INDEX-Internet Diamond Exchange member, your name, Company name, telephone numbers and e-mail address in addition to the diamonds you are listing for sale may be displayed to other RapNet or INDEX-Internet Diamond Exchange members. However, your credit card number, bank account and other financial information will NEVER be revealed to anyone except with your express written permission or if we are required to do so pursuant to a subpoena or other legal process.

3.3 Disclosure to Third Parties Other Than Rapaport Customers Rapaport will not sell or rent any of your personally identifiable information to third parties. Rapaport will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission (and with other Rapaport customers as described above). These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.
We disclose information we collect in response to a law enforcement request, subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
We disclose information we collect in circumstances in which Rapaport believes the Services are being used in the commission of a crime; when we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person; or when necessary either to protect the rights or property of Rapaport, the Services or our subsidiaries, or affiliates in the Rapaport Group, or for us to render the Services provided.
We disclose information we collect to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users have addresses in New York. However, this aggregated information is not tied to personally identifiable information.
We share your information with our parent, subsidiaries, affiliates and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.

3.4 Our Contacts with Rapaport Customers
We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone or letter. We use your e-mail to send information, transaction confirmations and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional. We also use your e-mail address to send you other types of communications that you can control, including the Rapaport Tradewire weekly email.

3.5 Internet Address Information
We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.

3.6 Your Use of Information and Our Services
In order to facilitate the transactions between Rapaport members, our Service allows you limited access to other users' contact or shipping information. As a member you may have access to the User ID, email address and other contact or shipping information of other members. By consenting to the applicable Terms of Service, you agree that, with respect to other users' personally identifiable information that you obtain through the site or through an Rapaport-related communication or Rapaport-facilitated transaction, you will only use this information for: (a) Rapaport-related communications that are not unsolicited commercial messages, (b) using services offered through Rapaport (e.g. diamond sales, shipping or insurance), and (c) any other purpose that such user expressly agrees to after adequate disclosure of the purpose(s). In all cases, you must provide users with the opportunity to remove themselves from your database and review any information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personally identifiable information about another Rapaport user to any third party without our consent and the consent of such other user after adequate disclosure. Note that law enforcement personnel and other rights holders are given different rights with respect to information they access. Rapaport does not tolerate spam. Therefore, without limiting the foregoing, you may not add a Rapaport user to your mail list (email or physical mail) without their express consent after adequate disclosure, even if said user has previously made a purchase from you. We strictly enforce our Anti-Spam Policy. To report Rapaport-related spam, please send an email to: info@diamonds.net.

4. Information Security

4.1 Rapaport is committed to handling your customer information with high standards of information security. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.

4.2 The security of your subscription to any of the Services also relies on your protection of your password. You may not share your password with anyone. Rapaport will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the website.

4.3 Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, should be treated as unauthorized and suspicious and should be reported to Rapaport immediately. If you do share your Rapaport password with a third party for any reason, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please contact us immediately.



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While the information presented is from sources we believe reliable, we do not guarantee the accuracy or validity of any information presented by Rapaport or the views expressed by users of our internet service.