TRU JEWELRY LTD. – Effective Date: 15 May 2026
1. Introduction
Tru Jewelry Ltd. (“Tru Jewelry”, “we”, “us” or “our”) is a Bermuda-incorporated company that designs and sells sterling silver 18K gold plated jewelry celebrating Bermudian heritage. We respect your privacy and are committed to protecting the personal information that you entrust to us when you visit our website at https://www.trujewelry.bm, purchase from us, subscribe to our newsletter, or otherwise interact with our brand (together, our “Services”).
This Privacy Policy explains what personal information we collect about you, why we collect it, who we share it with, how long we keep it, how we protect it, and the rights you have in respect of it. It is our privacy notice for the purposes of Section 9 of the Personal Information Protection Act 2016 of Bermuda (PIPA).
Please read this policy carefully. By using our Services, you acknowledge that you have read and understood this Privacy Policy. Where we rely on your consent to use your personal information, we will ask for it separately.
2. Who We Are and How to Contact Us
Tru Jewelry Ltd. is the organisation responsible for your personal information (the “controller” in non-PIPA terminology). Our details are:
• Legal name: Tru Jewelry Ltd.
• Registered office: 13A Lighthouse Rd, Southampton, SN 02 Bermuda
• Email: info@trujewels.com
• Website: https://www.trujewels.com
You can contact us at any time about this Privacy Policy or about how we handle your personal information using the details above, or the dedicated Privacy Officer contact details in the next section.
3. Our Privacy Officer
In accordance with Section 5 of PIPA, we have appointed a Privacy Officer with primary responsibility for our compliance with PIPA and for communicating with the Office of the Privacy Commissioner for Bermuda (PrivCom). You can contact our Privacy Officer with any question, request or complaint about how we handle your personal information:
• Privacy Officer: Ryan Taylor
• Email: privacy@trujewels.com
• Postal address: Privacy Officer, Tru Jewelry Ltd.P.O. Box SN 17, Southampton, SN BX, Bermuda
4. The Personal Information We Use
We collect and use personal information about you when you interact with our Services. “Personal information” means any information about an identified or identifiable individual.
4.1 Information you give us directly
• Identity and contact information: your first and last name, billing and shipping address, email address, and telephone number.
• Account information: if you create a customer account, your login credentials and any preferences you save (such as a wish list).
• Order and transaction information: details of the items you purchase, gift messages, order history, returns and refunds. Card payment details are entered directly into our payment processor’s secure environment and are not stored by Tru Jewelry.
• Marketing preferences: whether you have subscribed to our newsletter, and the categories of content you wish to receive.
• Communications: the content of messages you send us by email, contact form, social media or messaging app, including any information you provide when you ask a question, leave a review, request a custom piece or contact our customer-service team.
• Event and giveaway information: if you register for an event, trunk show, giveaway or pop-up, the information you submit on the entry form.
4.2 Information collected automatically when you use our website
• Device and technical information: IP address, device type, operating system, browser type and version, language settings, time-zone setting, and screen resolution.
• Usage information: pages visited, products viewed, items added to cart, the date and duration of your visit, referring URLs, and clickstream data.
• Cookies and similar technologies: see Section 10 below.
4.3 Information we receive from third parties
• Payment processors: order confirmation, payment status, and limited card information (such as the last four digits and card type) needed to identify a transaction.
• Shipping carriers: delivery status updates.
• Retail partners: where you purchase a Tru Jewelry piece from one of our authorised retailers (such as The Shops at Hamilton Princess, Cassine Boutique, TABS Bermuda or other partners) and they share information with us in connection with a charm registration, warranty, customer query or marketing opt-in that you have given them.
• Social media platforms: if you engage with our content or messages on Instagram, Facebook or other platforms, we may receive your public profile information and the content of your interaction with us.
4.4 Sensitive personal information
We do not knowingly collect “sensitive personal information” as defined in Section 7 of PIPA (which includes information about race, ethnic origin, sex, sexual orientation, marital status, health, religious beliefs, political opinions, trade-union membership, biometric data or genetic data). Please do not provide us with sensitive personal information unless we specifically ask for it.
5. Why We Use Your Personal Information
We use your personal information for the purposes described in the table below. For each purpose, we have identified the lawful condition for use under Section 6(1) of PIPA on which we rely.
• Purpose: To process and fulfil your order — including taking payment, arranging shipping, providing order updates, and handling returns, refunds and warranty claims.
Lawful condition: Performance of a contract with you (s.6(1)(c)).
• Purpose: To create and manage your customer account.
Lawful condition: Performance of a contract with you (s.6(1)(c)).
• Purpose: To respond to your enquiries, customer-service requests, custom-piece consultations, complaints and feedback.
Lawful condition: Steps taken at your request with a view to entering into a contract, or the legitimate use of information you would reasonably expect us to make (s.6(1)(b)–(c)).
• Purpose: To send you our newsletter and marketing communications about new collections, restocks, events, charm stories and brand updates.
Lawful condition: Your consent (s.6(1)(a)), which you can withdraw at any time (see Section 7).
• Purpose: To run our retailer and wholesale relationships, including coordinating fulfilment with Hamilton Princess Boutique, Cassine Boutique and other partners.
Lawful condition: Performance of contracts, and the lawful and reasonable conduct of our business (s.6(1)(b)–(c)).
• Purpose: To improve our Services — including analysing how visitors use our website, troubleshooting, testing and developing new features.
Lawful condition: Reasonable use that does not prejudice your rights (s.6(1)(b)), and your consent where required (e.g. for non-essential cookies).
• Purpose: To personalise your experience — including showing you content and product recommendations relevant to you on our site and on social platforms.
Lawful condition: Your consent (s.6(1)(a)) for non-essential tracking, and reasonable use for first-party personalisation (s.6(1)(b)).
• Purpose: To prevent and detect fraud, protect our website and customers, and enforce our terms.
Lawful condition: Reasonable use that does not prejudice your rights (s.6(1)(b)) and compliance with law (s.6(1)(d)).
• Purpose: To comply with our legal, tax, accounting and regulatory obligations in Bermuda and elsewhere.
Lawful condition: Compliance with a provision of law (s.6(1)(d)).
• Purpose: To establish, exercise or defend legal claims and to protect our rights.
Lawful condition: Use that is reasonable to protect or defend the organisation in any legal proceeding (s.6(3)(f)).
We will only use your personal information for the purpose(s) for which it was collected, or for related purposes that you would reasonably expect, in accordance with the purpose-limitation principle in Section 10 of PIPA. If we ever wish to use it for an unrelated new purpose, we will provide you with a fresh notice and, where required, obtain your consent.
6. Sensitive Personal Information
As noted above, we do not routinely collect sensitive personal information. If circumstances require us to use any sensitive personal information you provide (for example, to accommodate a specific accessibility need at an in-person event), we will only do so with your express consent or where another lawful authority under Section 7(3) of PIPA applies.
7. Marketing Communications and Your Right to Opt Out
We will only send you marketing communications by email if you have given us your consent — for example by signing up to our newsletter or ticking the marketing opt-in box at checkout. We use Flodesk to deliver our newsletters and email campaigns; Flodesk processes your email address and engagement data on our behalf.
Under Section 6 of PIPA, you have the right at any time to ask us to cease, or not to begin, using your personal information for the purposes of advertising, marketing or public relations. You can opt out by:
• clicking the “unsubscribe” link at the bottom of any marketing email we send you;
• updating your preferences in your customer account; or
• emailing our Privacy Officer at privacy@trujewels.com
Even after you opt out of marketing, we may still send you service messages relating to your orders, account, or warranty (for example, an order confirmation, shipping update or response to a customer-service query).
8. Who We Share Your Personal Information With
We do not sell your personal information. We share it only with the categories of recipients listed below, and only to the extent reasonably necessary for the purpose described.
• E-commerce platform: WooCommerce hosts our website, processes orders, and stores customer and order data on our behalf.
• Payment processors: Authourize.net process card payments. They receive the payment details you enter at checkout and share back the information we need to complete and reconcile your order.
• Shipping and fulfilment providers: Bermuda Post and international carriers (such as FedEx, DHL) receive your name, shipping address and contact details to deliver your order.
• Email and marketing platform: Flodesk sends our newsletters and email campaigns and processes engagement data.
• Customer-service and communications tools: [e.g. Gmail / Google Workspace, our help-desk software] used to manage correspondence with you.
• Analytics providers: Google Analytics helps us understand how visitors use our website. We have configured analytics to limit the personal information sent to providers wherever possible (for example, by enabling IP anonymisation).
• Advertising and social media partners: Meta (Facebook/Instagram), Pinterest where you have consented to advertising and personalisation cookies (see Section 10).
• Retail and wholesale partners: our authorised stockists, including Hamilton Princess Boutique, TABS Bermuda and Cassine Boutique, where you have bought from them or asked us to coordinate a transaction with them.
• Professional advisers: lawyers, accountants, auditors and insurers, in confidence and only where reasonably necessary.
• Government, regulators and law enforcement: where we are required or permitted by law to disclose personal information, including in response to a lawful order or to the Office of the Privacy Commissioner for Bermuda.
• Purchasers of our business: if Tru Jewelry Ltd. is sold, restructured or merges with another business, your personal information may be disclosed to the purchaser and its advisers, subject to confidentiality and to the disclosure rules in Section 45 of PIPA.
9. International Transfers of Personal Information
Bermuda is a small jurisdiction. Many of the providers listed above are located outside Bermuda, principally in the United States, Canada and the European Union, which means that your personal information will be transferred to and processed in countries other than Bermuda.
Section 15 of PIPA requires us, before transferring personal information to an overseas third party, to assess whether that third party will provide a level of protection comparable to PIPA. Where we transfer your personal information overseas, we do so on the basis of one or more of the following safeguards:
• we enter into written contracts with the overseas third party that require it to use the personal information only for our purposes and to apply security and privacy standards comparable to those required by PIPA;
• we satisfy ourselves that the third party is subject to a comparable privacy regime (for example, EU/UK GDPR) or to enforceable certifications or codes of practice;
• where neither of the above applies, we rely on your consent, after providing you with information about the transfer; or
• we transfer the personal information on another basis permitted by Section 15 of PIPA.
You can ask our Privacy Officer for more information about a specific overseas transfer by writing to privacy@trujewels.com .
10. Cookies and Similar Technologies
A cookie is a small text file placed on your device when you visit a website. We and our service providers use cookies, pixels, tags and similar technologies to operate our website, remember your preferences, understand how the site is used, and (where you consent) deliver personalised content and advertising.
We use the following categories of cookies:
• Strictly necessary cookies: required for the website to function (for example, to remember the items in your cart or to keep you logged in). These cannot be switched off.
• Functional cookies: remember your preferences (such as language or currency).
• Analytics cookies: help us measure and improve the performance of the website.
• Marketing and advertising cookies: used by us and our advertising partners (such as Meta) to show you relevant ads and measure their effectiveness.
When you first visit our website you will be presented with a cookie banner that lets you accept or reject non-essential cookies and adjust your preferences. You can change your choices at any time by clicking the “Cookie preferences” link in the footer, or by adjusting your browser settings to reject or delete cookies. Rejecting cookies may affect the functionality of parts of our website.
11. How We Protect Your Personal Information
In accordance with Section 13 of PIPA, we maintain appropriate technical and organisational safeguards to protect personal information from loss, unauthorised access, destruction, use, modification, disclosure or other misuse. Those safeguards are proportionate to the sensitivity of the personal information and the context in which it is held, and include:
• encryption of personal information in transit (via HTTPS/TLS) and, where appropriate, at rest;
• access controls so that personal information is only accessible to staff and service providers who need it;
• the use of reputable third-party platforms (such as our e-commerce platform and payment processors) that maintain industry-standard security certifications;
• a written contract with each service provider that uses personal information on our behalf, requiring it to apply appropriate safeguards; and
• staff awareness, training and review of our privacy practices.
No transmission over the internet or method of electronic storage is fully secure. While we take all reasonable steps to protect your personal information, we cannot guarantee absolute security.
12. Personal Information Breach Notification
In the unlikely event of a breach of security that is likely to adversely affect you, we will, without undue delay, notify the Privacy Commissioner for Bermuda and the affected individuals, as required by Section 14 of PIPA. Our notice will describe the nature of the breach, the personal information involved, the consequences and the measures we are taking to address it, and will include the contact details of our Privacy Officer.
13. How Long We Keep Your Personal Information
We keep your personal information only for as long as we need it for the purposes set out in this Privacy Policy, including to satisfy any legal, tax, accounting, regulatory or reporting requirements. As a guide:
• Customer account information: for as long as your account is active, and for up to [two years] after your last interaction with us, after which we will delete or anonymise it.
• Order and transaction records: for the period required by Bermuda tax, accounting and consumer-protection laws (typically up to five (5) years from the date of the transaction).
• Marketing data: until you unsubscribe or otherwise withdraw your consent, and for a short period thereafter to record your opt-out.
• Cookie and analytics data: for the period stated in our Cookie Preferences settings, typically no more than thirteen (13) months.
• Correspondence: for as long as needed to handle your query and for a reasonable period thereafter for record-keeping and dispute resolution.
Where information is no longer required, we will securely delete or anonymise it.
14. Children
Our Services are intended for adults. We do not knowingly collect personal information from children under the age of 14 without the consent of a parent or legal guardian. Where we provide an information-society service to a child, in accordance with Section 16 of PIPA, we will use clear language that is easily understandable to a child of that age. If you believe that we hold personal information about a child without appropriate consent, please contact our Privacy Officer and we will delete it.
15. Your Rights
PIPA gives you the following rights in respect of the personal information we hold about you:
• Right to be informed: to be given a clear privacy notice (this one) about how we use your personal information.
• Right of access (Section 17): to ask us whether we hold personal information about you and, if we do, to be given a copy of it together with information about how it is used and to whom it has been disclosed.
• Right of rectification (Section 19): to ask us to correct personal information about you that is inaccurate, irrelevant, incomplete, out of date or excessive.
• Right of erasure, blocking and destruction (Section 19): to ask us to erase, block or destroy personal information about you that we have no continuing lawful reason to use.
• Right to withdraw consent: where we are using your personal information on the basis of your consent, to withdraw that consent at any time (without affecting the lawfulness of use before withdrawal).
• Right to object to direct marketing (Section 6): to ask us to cease, or not to begin, using your personal information for advertising, marketing or public relations.
• Right to compensation (Section 21): to seek compensation for financial loss or distress caused by a contravention of PIPA.
• Right to complain to PrivCom: to ask the Privacy Commissioner for Bermuda to review our handling of your personal information or to make a complaint (see Section 16 below).
Some of these rights are not absolute and may be subject to exemptions and conditions set out in PIPA. If we are not able to act on your request in full, we will explain why.
16. How to Exercise Your Rights or Make a Complaint
You can exercise any of the rights above by contacting our Privacy Officer using the details in Section 3. To help us respond quickly, please:
• tell us which right you wish to exercise and what personal information your request relates to;
• include enough information to allow us to verify your identity (so that we do not disclose personal information to the wrong person); and
• let us know how you would like to receive our response.
We will acknowledge your request and respond within the timescales set out in PIPA (generally no later than 45 days after we have received the information needed to respond). We will not charge a fee unless we are permitted to do so by PIPA, and we will tell you in advance if we propose to do so.
If you are not satisfied with our response, you have the right to ask the Office of the Privacy Commissioner for Bermuda to review our decision, or to make a complaint:
• Office of the Privacy Commissioner for Bermuda (PrivCom)
• Website: https://www.privacy.bm
• Email: info@privacy.bm
• Telephone: +1 (441) 543-7748
17. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, our Services, or the law. The “Effective Date” at the top of this policy shows when it was last updated. Where the changes are material, we will draw them to your attention (for example, by a notice on the website or by email) before they take effect.
18. Governing Law
This Privacy Policy and any matter relating to our use of your personal information are governed by the laws of Bermuda, including the Personal Information Protection Act 2016.
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