Jewellink Privacy Policy

Effective date: 5/01/2026

This Privacy Policy explains how Jewelry Sales Academy LLC d/b/a Jewellink ("Jewellink," "we," "us," or "our") collects, uses, discloses, and protects information in connection with our websites, applications, CRM, sales analytics, messaging, training, AI, mobile, and related services.

1. Scope

This Policy applies to:

• visitors to Jewellink websites;

• retailers and their personnel who use Jewellink;

• individuals who communicate with Jewellink; and

• personal information we process for our own business purposes.

When Jewellink processes a retailer's customer data on behalf of that retailer, the retailer is generally responsible for its own privacy notices and legal obligations. Jewellink processes that data as described in our agreements with the retailer.

2. Information We Collect

We may collect:

• account information, such as name, email, phone number, role, company, location, login credentials, and permissions;

• retailer business information, such as store details, billing contacts, subscription details, A2P registration information, and integration settings;

• customer and CRM data submitted or synced by retailers, such as names, contact information, preferences, notes, birthdays, anniversaries, sales history, wishlist data, appointment data, form submissions, and relationship history;

• POS, sales, transaction, inventory, product, associate, and location data;

• communications data, such as SMS/MMS, email, webchat, Messenger, Instagram, call, and message content and metadata;

• training and learning data, such as course enrollment, progress, scores, roleplay sessions, transcripts, audio, and coaching activity;

• AI feature data, such as prompts, outputs, transcripts, generated replies, summaries, and feedback;

• media and files, such as images, videos, product photos, training assets, uploads, and generated media;

• mobile data, such as device tokens, app version, permissions, local authentication settings, and push notification metadata;

• usage and device data, such as IP address, browser, operating system, pages viewed, feature usage, logs, errors, and security events; and

• billing and payment metadata, while payment card details are generally processed by our payment processor.

Retailers are prohibited from submitting social security numbers, full payment card numbers, CVV codes, bank account or routing numbers, consumer credit reports, credit scores, financing applications, loan applications, income information, protected health information, medical information, government identification numbers, driver's license numbers, passport numbers, biometric identifiers or biometric templates, account passwords, authentication credentials, children's data, or other highly sensitive or specially regulated information unless Jewellink has expressly authorized that processing in writing.

3. Sources of Information

We may collect information from:

• retailers and their Authorized Users;

• retailer systems, POS systems, imports, and connected accounts;

• customers and prospects who interact with retailer-facing forms, messaging, or webchat features;

• service providers and integration partners;

• public sources and business contact sources;

• mobile apps and websites; and

• automated logs and security tools.

4. How We Use Information

We may use information to:

• provide, operate, support, secure, and improve the Services;

• manage accounts, authentication, permissions, billing, and subscriptions;

• provide CRM, analytics, messaging, training, AI, mobile, and reporting features;

• sync data from POS systems and third-party integrations;

• send transactional, administrative, support, and security communications;

• process SMS, MMS, email, social, webchat, push, and other communications;

• provide AI-assisted features such as summaries, suggestions, roleplay, transcription, and generated content;

• prevent fraud, abuse, misuse, spam, security incidents, and unauthorized access;

• debug, monitor, analyze, and improve performance;

• create aggregated or de-identified data;

• comply with law, legal process, carrier rules, platform requirements, and contractual obligations; and

• enforce our terms and policies.

5. AI and Product Improvement

We may use Usage Data, Aggregated Data, De-Identified Data, feedback, evaluation data, and non-identifying telemetry to improve and develop Jewellink services and AI features.

We do not use retailer customer data containing personal information to train shared or generally available Jewellink AI models unless the retailer has expressly authorized that use in writing.

Third-party AI providers may process data as service providers to deliver AI features. We seek to use business/API configurations that do not permit those providers to train their generally available models on retailer data unless disclosed or authorized.

6. How We Disclose Information

We may disclose information to:

• cloud hosting, database, infrastructure, and security providers;

• messaging, email, push notification, and communications providers;

• payment and billing providers;

• AI, transcription, voice, media, and analytics providers;

• POS, CRM, learning management, social, email, calendar, and other integration providers;

• professional advisors, auditors, insurers, and legal counsel;

• authorities, courts, regulators, carriers, and platforms where required or appropriate;

• parties involved in a merger, acquisition, financing, restructuring, or sale of assets; and

• other parties with consent or at the direction of the retailer or user.

We do not sell retailer customer lists.

7. Cookies and Website Technologies

Our websites and applications may use cookies, pixels, SDKs, local storage, and similar technologies for authentication, security, preferences, analytics, performance, and website functionality.

If we use advertising or cross-context behavioral advertising technologies, we will provide additional notices or choices where required by law.

8. SMS and Communications

If you opt in to receive SMS/MMS or other communications from Jewellink or a retailer using Jewellink, message frequency may vary. Message and data rates may apply. You may opt out of SMS messages by replying STOP where supported. You may request help by replying HELP or contacting the sender.

Retailers are responsible for their own customer messaging practices and consent obligations.

9. Data Retention

We retain information for as long as reasonably necessary to provide the Services, comply with legal obligations, resolve disputes, maintain security, enforce agreements, support business operations, and meet legitimate business needs.

Retention periods vary depending on the type of data, feature, retailer instructions, legal requirements, backup cycles, and operational needs.

10. Security

We use commercially reasonable safeguards designed to protect information in our possession. No method of transmission, storage, vendor processing, AI processing, or electronic system is completely secure.

Retailers are responsible for securing their own accounts, devices, personnel, POS systems, email accounts, social accounts, networks, and connected services.

11. Privacy Rights

Depending on where you live, you may have rights to request access, correction, deletion, portability, restriction, objection, opt-out of certain processing, or non-discrimination.

If your information is processed by Jewellink on behalf of a retailer, we may refer your request to that retailer.

To submit a privacy request to Jewellink, contact us at privacy@jewellink.com or support@jewellink.com.

12. California Privacy Notice

California residents may have rights under the California Consumer Privacy Act, as amended, including rights to know, delete, correct, opt out of sale or sharing, limit use of sensitive personal information, and non-discrimination.

We do not knowingly sell retailer customer data. We do not knowingly share retailer customer data for cross-context behavioral advertising.

We may disclose personal information to service providers and contractors for business purposes described in this Policy.

13. Children

The Services are intended for business use by retail jewelry businesses and are not directed to children under 13. Retailers must not use the Services to collect information from children unless they have all required rights and consents.

14. Changes

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated effective date.

15. Contact

Jewelry Sales Academy LLC d/b/a Jewellink
[Business Address]