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999Jewels — Privacy Policy

Oct 12, 2026

Effective Date: Oct 12, 2026 · Last Updated: Oct 12, 2026

1. Who We Are

This Privacy Policy explains how 999Jewels LLC ("999Jewels," "we," "us," or "our"), a Wyoming limited liability company with its registered address at 1309 Coffeen Ave, Sheridan, WY 82801, USA, collects, uses, discloses, retains, and protects personal information.

999Jewels LLC is the controller (or "business," as that term is used under U.S. state privacy laws) of the personal information described in this Privacy Policy, except where Section 15 states that we act on behalf of a client.

Privacy questions and requests: help@999jewels.com

2. Scope

This Privacy Policy applies to personal information we process through any of the following (together, the "Platform"):

  • The main website at 999jewels.com, including its service pages, vendor directory, and all forms;
  • The members' club at club.999jewels.com, a private, invitation- and application-based marketplace where approved members list jewelry, diamonds, gemstones, and related items, make offers, buy, sell, trade, and message one another;
  • Any other domains, subdomains, landing pages, and forms we operate now or in the future;
  • Community channels we create or administer, including WhatsApp groups, Telegram groups, Facebook groups, and LinkedIn groups (the "Community Channels");
  • Business services we provide to members and other businesses, including Local Ads, Business Help, 24/7 Phone & Message Assistant, Local Media & Trust, Social Media Management, Video Content Creation, Website Creation & Review, Training & Learning, and introductions to independent legal professionals (the "Services");
  • Online and offline events we organize, host, or co-host (the "Events"), and information about events organized by third parties that we list, mention, or promote ("Third-Party Events");
  • Our communications with you by email, phone, messaging apps, and social media.

This Privacy Policy does not apply to the practices of third parties we do not control, including other members, vendors, independent legal professionals, event organizers, payment processors, and the operators of messaging and social media platforms. Personal information collected through separate lead-generation pages or advertising campaigns that display their own privacy notice is governed by that notice, together with this Privacy Policy where it is referenced.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy. Where applicable law requires your consent for a specific processing activity, we will request it separately.

3. Eligibility

The Platform is intended solely for individuals who are at least 18 years old and who act on behalf of a business. Membership in the club is limited to businesses operating in the jewelry trade and related industries, such as jewelers, jewelry retailers and wholesalers, manufacturers, diamond and gemstone dealers, precious-metal dealers, pawnbrokers, and second-hand dealers, and their authorized representatives.

The Platform is a business-to-business service. It is not directed at consumers acting for personal, family, or household purposes, and it is not directed at children. See Section 20.

4. Information We Collect

The categories of personal information we collect depend on how you interact with us. We may collect the following.

4.1 Information you provide to us

  • Membership applications and account registration: full name, phone number, email address, position in the business, physical business address, company website, legal business name, years of operation, account login credentials, and any other information you include in your application.
  • Business verification documents: where we request them, copies of business registration documents, certificates of formation, business licenses, resale or seller's permits, precious-metal or dealer licenses, or equivalent documents, together with any personal information contained in them (such as names, addresses, registration numbers, and dates, and, if you choose to include it, government identification).
  • Member profile and listings: profile details, business information, photographs, item descriptions, metal type and purity, stone details, grading reports and certificates, brand and designer details, condition, prices, and any other content you choose to post in the club.
  • Offers, trades, and messages: offers, counteroffers, trade proposals, and the content of messages you send to other members or to us through the club.
  • Service requests: information you submit when requesting a Service, including business details, project requirements, access to your accounts or assets where needed to perform a Service, and billing contacts.
  • Event registrations: name, company name, contact details, and attendance preferences for online or offline Events.
  • Vendor applications and listings: business name, website, email address, phone number, logo or image, and description of services.
  • Payment information: billing name, billing address, and transaction details. Card and payment-account numbers are collected and processed directly by our payment processor, Stripe; we do not receive or store full card numbers.
  • Communications: information you provide when you contact us by email, phone, messaging app, social media, or at an Event, including recordings or transcripts where permitted by law and disclosed to you.
  • Feedback and testimonials: reviews, comments, survey responses, and testimonials you provide.

4.2 Information we collect automatically

  • Device and connection data: IP address, browser type and version, operating system, device identifiers, language settings, and approximate location derived from your IP address.
  • Usage data: pages viewed, links clicked, referring and exit pages, time spent, search queries, form interactions, and dates and times of access.
  • Advertising and analytics data: cookie identifiers, pixel and tag events, advertising identifiers, campaign and click identifiers (such as gclid, fbclid, and ttclid), and conversion events.
  • Session data: where enabled, interaction data such as mouse movements, scrolling, and clicks, which may be used to produce session replays and heatmaps.

See Section 10 for more detail on cookies and similar technologies.

4.3 Information we receive from other sources

  • Public and official sources: public business registries, licensing databases, court and government records, regulatory bodies, and, where we consider it necessary to verify a business, the issuing authority or a law-enforcement agency.
  • Online sources: search engines, public social media profiles, business websites, and review sites.
  • Advertising platforms: information submitted through lead forms on Meta (Facebook and Instagram), Google, TikTok, LinkedIn, and other platforms, and reports about the performance of our advertisements.
  • Members, vendors, and partners: referrals, recommendations, and reports about conduct on the Platform.
  • Service providers: payment status from Stripe and information from our CRM, communication, and analytics providers.

4.4 Community Channels

When you join a Community Channel we administer, we and other participants can see your name, username, profile photo, phone number (on WhatsApp and, depending on your settings, Telegram), and any messages, photos, and files you share. We may record your participation and contact details in our records for membership administration, moderation, safety, and communications purposes.

4.5 Event recordings

We may photograph, film, or record Events, including online sessions. If you attend an Event, your name, image, voice, and statements may be captured. Notice of recording will be given at or before the Event. Third-Party Events may be photographed or recorded by their organizers under their own terms.

5. How We Use Personal Information

We use personal information for the following purposes. The right-hand column states the legal basis we rely on where the EU or UK General Data Protection Regulation ("GDPR") or a similar law applies.

We may also use personal information for any other purpose disclosed to you at the time of collection or with your consent. We may create aggregated or de-identified information that no longer identifies you, use and share it for any lawful purpose, and will not attempt to re-identify it, except as permitted by law.

6. Member Verification and Screening

To keep the club limited to eligible businesses, we review membership applications. Our review may include any of the following:

  • reviewing the information in your application;
  • requesting and reviewing business registration documents, business licenses, permits, or equivalent documents (we do not request documents in every case);
  • checking public business registries and licensing databases where they are available;
  • reviewing your company website, search-engine results, social media presence, and online reviews;
  • contacting a registering or licensing authority, a local law-enforcement agency, or another issuing body to confirm that a business or document is valid;
  • contacting you or your business by phone, email, or messaging app.

The extent of our review varies. In some cases we approve an application based only on the information provided, without requesting documents or performing independent verification. Approval of an application is not a representation, warranty, or guarantee that a member is registered, licensed, solvent, honest, or trustworthy. Members remain responsible for their own due diligence when dealing with each other.

Membership decisions are made by our staff. We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing. If we have requested documents from you and they expire or change, we may ask you to provide updated copies, and we may restrict or suspend your membership until you do.

7. Monitoring of Messages and Activity

We may access, review, and retain messages, listings, offers, trades, and other activity on the club and in our Community Channels where we have reason to do so, including:

  • to investigate a dispute between members or a complaint;
  • to investigate suspected fraud, scams, stolen or counterfeit goods, or other unlawful activity;
  • to enforce our Terms of Service and channel rules;
  • to respond to a request from a law-enforcement agency or other legal process;
  • to protect the safety and rights of members, us, or the public.

Messages on the club are not end-to-end encrypted. Do not use the club or Community Channels to share information you would not want us to review in these circumstances.

7.1 Use of artificial-intelligence tools

We sometimes use third-party artificial-intelligence tools to assist our staff, for example to draft responses, summarize inquiries, sort and qualify leads, transcribe communications, answer calls and messages as part of the 24/7 Phone & Message Assistant Service, and produce marketing content. When we do so, personal information contained in the relevant content may be processed by the provider of the tool. We select providers that commit to protecting the information they process for us. AI outputs are subject to human review before we rely on them for any decision about your membership.

8. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients.

  • Other members. Your profile, business details, listings, offers, trade proposals, and messages are visible to the members you interact with and, for profiles and listings, to other members of the club. Members may contact you directly.
  • Participants in Community Channels. Anything you post in a Community Channel, and your name, profile photo, and (on some platforms) phone number, is visible to other participants.
  • Service providers. Companies that process personal information on our behalf, including providers of website hosting and content delivery (for example AWS, Google Cloud, Vercel, Cloudflare, Netlify, WordPress, Webflow, Wix, or Squarespace); CRM and sales tools (for example HubSpot, GoHighLevel, Pipedrive, Salesforce, Airtable, Notion, or Google Sheets); email and messaging (for example Google Workspace, Microsoft 365, Mailchimp, Brevo, Klaviyo, SendGrid, WhatsApp Business, and Telegram); phone, call-answering, and scheduling services (for example Twilio, Calendly, or Zoom); payment processing (Stripe); invoicing and accounting (for example Stripe Invoicing, QuickBooks, Xero, or PayPal); file storage, design, and video production tools; AI tools; customer support; and security and fraud prevention.
  • Advertising and analytics partners. Including Google, Meta, TikTok, LinkedIn, Microsoft, X, Pinterest, Snap, and Reddit, through the technologies described in Section 10 and through the upload of hashed contact information for custom-audience, lookalike, and conversion-measurement purposes.
  • Members who receive leads or introductions. When we generate or receive an inquiry from a person who wants to buy, sell, appraise, or pawn jewelry or another item, we may provide that inquiry, together with the person's name, phone number, email address, ZIP code, item description, and photos, to one or more members, for a fee or otherwise. The inquirer's privacy rights are described in the notice shown where the inquiry is collected.
  • Independent legal professionals and other referral partners. If you ask to be connected with a lawyer, law firm, or other partner, we will share the contact details and description of your matter needed for the introduction. We may receive compensation for these introductions. Legal professionals are independent of us; we do not provide legal advice and are not responsible for their services.
  • Event organizers, co-hosts, and sponsors. Only if you ask us to, or agree to it, for example by opting in at registration or asking us to register you for a Third-Party Event.
  • Vendors listed on the Platform. Only at your request or with your agreement, for example when you ask to be introduced to a vendor.
  • Professional advisers. Lawyers, accountants, auditors, and insurers, under duties of confidentiality.
  • Corporate transactions. A buyer, successor, or other party in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, receivership, or sale of all or part of our business or assets.
  • Affiliates. Companies under common ownership or control with 999Jewels LLC, which will treat the information in accordance with this Privacy Policy.
  • Legal, safety, and law enforcement. Courts, regulators, law-enforcement agencies, registering and licensing authorities, and other parties, where we believe in good faith that disclosure is required by law or legal process, or is necessary to verify a business, investigate fraud or suspected stolen or counterfeit goods, enforce our Terms of Service, or protect the rights, property, or safety of members, us, or others.
  • With your consent or at your direction.

9. "Sales" and "Sharing" under U.S. State Privacy Laws

Several U.S. state laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA"), define "sale" and "sharing" broadly. Under those definitions:

  • We "share" and may "sell" identifiers (such as IP address, cookie and device identifiers, and hashed email address or phone number) and internet activity information with advertising and analytics partners for cross-context behavioral advertising and analytics.
  • We may "sell" identifiers, commercial information, and professional information to members and referral partners in connection with leads and introductions described in Section 8.

We do not knowingly sell or share the personal information of individuals under 16 years of age.

Your choices. You may opt out of the sale and sharing of your personal information at any time by using the "Do Not Sell or Share My Personal Information" link in the footer of our website; adjusting your preferences in our cookie banner; enabling a recognized opt-out preference signal such as Global Privacy Control (GPC), which we honor for the browser or device that sends it; or emailing  with the subject line "Do Not Sell or Share."

We do not use or disclose sensitive personal information for purposes that would require us to offer a right to limit its use under the CCPA.

10. Cookies and Similar Technologies

We and our partners use cookies, pixels, tags, software development kits, local storage, server-side event APIs, and similar technologies ("Cookies") on the Platform.

The specific technologies in use may change over time. Where required by law, including in the European Economic Area, the United Kingdom, and Switzerland, we will place non-essential Cookies only with your consent, collected through our cookie banner. You can change your choices at any time through the cookie settings link on the website.

You can also block or delete Cookies through your browser settings; opt out of interest-based advertising at optout.aboutads.info, youronlinechoices.eu, and optout.networkadvertising.org; manage ad preferences in your Google, Meta, TikTok, and LinkedIn account settings; and opt out of Google Analytics using the Google Analytics opt-out add-on. Blocking some Cookies may affect how the Platform works. Except for Global Privacy Control as described in Section 9, we do not currently respond to browser "Do Not Track" signals, because no common industry standard for them exists.

11. Marketing Communications

We may send you marketing emails and messages through WhatsApp, Telegram, LinkedIn, and other messaging apps about the club, Services, Events, and offers, where permitted by law and, where required, with your consent. You can opt out at any time by clicking the "unsubscribe" link in an email, replying "STOP" or asking us to stop in a message, or contacting . We will continue to send non-marketing messages, such as account, membership, billing, and security notices.

We do not currently send marketing text (SMS) messages. If we begin to do so, we will obtain any consent required by law, including under the U.S. Telephone Consumer Protection Act, before sending them. We and our members may contact applicants, members, and people who submit inquiries by phone or messaging app to respond to their request. We do not record telephone calls with applicants or members unless we notify you at the start of the call and, where required, obtain your consent.

12. Your Content, Testimonials, and Event Recordings

Listings, photos, reviews, testimonials, and posts you make in the club or a Community Channel may be visible to others. In accordance with our Terms of Service, we may use content you submit, including Event photographs and recordings in which you appear, to operate and promote the Platform, including on our websites, social media, and advertising. Where the law requires your consent to use your name, image, or likeness, we will ask for it. You may ask us to stop future promotional use of your image or testimonial by contacting ; this will not affect materials already published or distributed. Please do not post personal information of other people, such as customers, unless you have the right to do so.

13. Interactions Between Members, Vendors, and Third Parties

The club and Community Channels allow members to communicate and transact directly with each other and with vendors. We are not a party to those transactions. We do not act as a broker, agent, escrow, guarantor, appraiser, gemologist, shipper, or payment processor between members, and we do not handle payments, shipping, or delivery between members.

When you share personal information with another member, a vendor, a legal professional, or another participant, that person's use of the information is governed by their own practices and not by this Privacy Policy. We are not responsible for how members, vendors, legal professionals, or other third parties collect, use, disclose, or secure personal information they obtain through the Platform or the Community Channels, including any misuse, fraud, or unauthorized contact. Vendors listed on our website are independent businesses; listing a vendor is not an endorsement or guarantee of its services. If you believe another member or a vendor has misused your personal information, please report it to .

14. Third-Party Platforms, Events, and Links

Our Community Channels operate on WhatsApp, Telegram, Facebook, and LinkedIn, and the Platform may contain links to third-party websites and services. Those platforms collect and process personal information under their own privacy policies, which we do not control. We are not responsible for the privacy or security practices of third-party platforms.

Third-Party Events. Some events we list, mention, or promote are organized by other people or companies, not by us. We do not organize, control, endorse, or guarantee Third-Party Events, and we are not responsible for their content, safety, changes, or cancellation, or for how their organizers collect, use, and protect personal information. If you register for a Third-Party Event, including through a link we provide, your information is collected by the organizer under its own privacy policy. If you ask us to register you or to pass your details to the organizer, we will share only the information needed for that purpose.

15. Data We Process on Behalf of Clients

When we provide Services such as Social Media Management, the 24/7 Phone & Message Assistant, Local Ads, or Website Creation & Review, we may process personal information about our clients' own customers and contacts, for example messages received on a client's social media accounts, calls and messages answered on a client's behalf (which may be recorded and transcribed), and contact form submissions on a client's website. For that information, we act as a service provider or processor on behalf of the client, and the client is the controller. We process it only to provide the Services and in accordance with our agreement with the client. The client is responsible for providing any notices and obtaining any consents required by law, including consents to call recording. Individuals whose information we process on behalf of a client should direct privacy requests to that client.

16. Data Retention

We may keep information longer where required or permitted by law, including where it is needed to resolve disputes, investigate fraud or suspected unlawful activity, comply with legal process or a legal hold, or establish, exercise, or defend legal claims. When information is no longer needed, we delete it, de-identify it, or securely store it until deletion is possible. Information may persist in backups for a limited period.

17. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including access controls and encryption in transit. However, no website, application, transmission, or storage system is completely secure, and we cannot guarantee the security of personal information. You are responsible for keeping your login credentials confidential and for the security of your own devices. If you believe your account has been compromised, contact us immediately at . If a security incident affects your personal information, we will notify you and the relevant authorities where required by law.

18. International Data Transfers

999Jewels LLC is based in the United States, and personal information is processed in the United States. Our staff, contractors, and service providers may also access and process personal information in other countries, including the United Arab Emirates, Ukraine, Israel, the United Kingdom, and member states of the European Union. Where we transfer personal information from the European Economic Area, the United Kingdom, or Switzerland to a country that has not been recognized as providing an adequate level of protection, we use appropriate safeguards, such as the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum, or rely on another lawful transfer mechanism. You may request a copy of the relevant safeguards by contacting .

19. Your Privacy Rights

Depending on where you live, you may have some or all of the rights below. These rights are subject to exceptions under applicable law; for example, we may keep information needed to prevent fraud, comply with legal obligations, or defend legal claims.

19.1 European Economic Area, United Kingdom, and Switzerland

You have the right to access your personal information and receive a copy; rectify inaccurate or incomplete information; erase your information in certain circumstances; restrict our processing in certain circumstances; data portability; object to processing based on our legitimate interests, and to object at any time to direct marketing; withdraw consent at any time, without affecting the lawfulness of processing before withdrawal; and lodge a complaint with the data-protection authority in your country of residence or work, or where an alleged infringement occurred, or, in the United Kingdom, with the Information Commissioner's Office.

19.2 California

This section supplements this Privacy Policy for California residents and describes our practices during the 12 months before the Last Updated date.

We collect these categories from the sources described in Section 4, for the purposes described in Sections 5 through 7, and retain them as described in Section 16.

California residents have the right to know the categories and specific pieces of personal information we collected, the categories of sources, the purposes, and the categories of third parties to whom we disclosed, sold, or shared it; to delete personal information we collected from them; to correct inaccurate personal information; to opt out of the sale and sharing of personal information (see Section 9); and to not receive discriminatory treatment for exercising these rights. We do not offer financial incentives in exchange for personal information. California residents may also request, once per year, information about disclosures of personal information to third parties for their own direct marketing purposes (Cal. Civ. Code § 1798.83).

19.3 Other U.S. states

Residents of states with comprehensive privacy laws, including Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, may have the right to confirm whether we process their personal information, to access, correct, delete, and obtain a portable copy of it, and to opt out of targeted advertising, the sale of personal information, and profiling in furtherance of decisions that produce legal or similarly significant effects. Where provided by law, you may appeal our decision on your request by replying to our response with the subject line "Appeal." If your appeal is denied, you may contact your state attorney general. Nevada residents may submit a request to opt out of the sale of covered information to . Some of these laws exempt information collected in a business-to-business context or apply only above certain thresholds; we nonetheless honor the requests described in this section to the extent required by law.

19.4 Canada, Brazil, the United Arab Emirates, and other countries

If you are located in Canada, Brazil (under the LGPD), the United Arab Emirates, Australia, Switzerland, Japan, Singapore, South Africa, or any other country with data-protection law, you may have rights to access, correct, delete, or object to the processing of your personal information, to withdraw consent, and to complain to your local authority, such as the Office of the Privacy Commissioner of Canada or Brazil's Autoridade Nacional de Proteção de Dados (ANPD). We will honor those rights as required by the law that applies to you.

19.5 How to exercise your rights

Send your request to help@999jewels.com with the subject line "Privacy Request," stating your name, the email address or phone number associated with your account, your state or country of residence, and the right you wish to exercise. For opt-outs of sale and sharing, you may also use the methods in Section 9.

We will verify your identity before fulfilling requests to know, access, correct, or delete, by matching information you provide with information we hold and, where necessary, by asking for additional information. You may use an authorized agent; we may require proof of the agent's authority and ask you to verify your identity directly. We will respond within the time required by applicable law, generally within 30 days (GDPR) or 45 days (CCPA), which may be extended where permitted. We may decline requests that are manifestly unfounded, excessive, or not permitted by law, and we will explain why where required.

20. Children

The Platform is not directed at, and we do not knowingly collect personal information from, anyone under 18 years of age. If we learn that we have collected personal information from a person under 18, we will delete it and close any related account. If you believe a minor has provided us with personal information, contact .

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will change the "Last Updated" date above. If we make material changes, we will provide notice through the Platform, by email to members, or by other means required by law, and, where the law requires, we will obtain your consent. Your continued use of the Platform after the updated Privacy Policy takes effect means you acknowledge the changes.

22. Relationship to Our Terms of Service

This Privacy Policy forms part of, and should be read together with, our Terms of Service, which contain additional terms, including disclaimers of warranties, limitations of liability, and dispute-resolution provisions that apply to your use of the Platform. If there is a conflict between this Privacy Policy and the Terms of Service regarding personal information, this Privacy Policy controls to the extent required by applicable privacy law.

23. Contact Us

999Jewels LLC, 1309 Coffeen Ave, Sheridan, WY 82801, USA

Email: help@999jewels.com

For privacy requests, please use the subject line "Privacy Request." For opt-outs of sale and sharing, use the subject line "Do Not Sell or Share" or the link in our website footer.

999JEWELS

A private B2B club and growth agency for verified jewelry dealers, boutique owners, and industry professionals. Your network is your net worth.

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