Introduction
This Privacy Policy explains how SARATTI (“we,” “us,” or “our”) collects, uses, shares, and protects your personal information when you interact with our services. These services include visiting our website (www.saratti.com), shopping in our physical stores, contacting our customer support team, engaging with us on social media, or participating in promotions. “Personal information” refers to any details that can identify you directly or indirectly, such as your name, email address, or purchase history.
By using our services, you agree to the practices described in this policy. If you do not agree, please stop using our services immediately. If you have questions, reach out to us using the contact details at the end of this document.
Information You Provide
We collect Personal Information you provide directly when interacting with our services. This occurs when you register for an account, update your profile, access content, make purchases, participate in promotions (e.g., sweepstakes, contests, or surveys), contact customer support, enroll in our text messaging program, or apply for a job. The Personal Information we collect includes:
- Contact Data: Your first and last name, email address, postal address, phone number (including mobile carrier details if you join our text messaging program), and similar contact details.
- Credentials: Passwords and authentication information required for account access.
- Demographic Data: Age, birth month/day, gender, and country of residence.
- Payment Data: Credit card numbers and payment details processed securely by our payment partners to complete transactions.
- Profile Data: Interests, wish lists, ring size preferences, and other personalized information.
- Contacts: Names and email addresses of friends or contacts when you use features like “email a product” or referrals. By using these features, you confirm you have consent to share their information.
- Content: Messages, feedback, product reviews, chat interactions, social media comments, photos, videos, or materials you submit. For example, our Virtual Try On feature uses uploaded photos to superimpose jewelry images, which you can share, save, or discuss with a consultant.
- Employment Data: Resumes, employment history, transcripts, job application responses, writing samples, and references submitted during job applications.
- Government Identification Data: Images of government-issued IDs (e.g., driver’s license) for fraud prevention or tax reporting purposes (e.g., prize winnings).
You may voluntarily provide additional information not explicitly requested, but you are solely responsible for such submissions.
Information Collected Automatically
We automatically gather technical and usage details when you interact with our services, including:
- Service Use Data: Features used, pages visited, emails or ads viewed, purchases made, browsing times, referral/exiting pages, and session durations.
- Device Connectivity and Configuration Data: Device type (e.g., smartphone, tablet), browser type, operating system, internet service provider, and regional/language settings.
- IP Address and Device Identifiers: IP addresses (with approximate location data) and mobile advertising IDs to analyze trends, prevent fraud, and improve service functionality.
- Session Replay Data: Real-time tracking of browsing behavior (e.g., clicks, cursor movements, keystrokes, screen recordings) to evaluate user interactions.
We use Online Technologies like cookies, web beacons, and device fingerprinting to collect this data:
- Log Files: Server logs tracking website usage patterns and trends.
-
Cookies: Small text files stored on your device to enhance functionality, such as remembering shopping cart items, analyzing site performance, and personalizing ads. Types include:
- Necessary Cookies: Essential for core functions like account access and shopping carts.
- Performance Cookies: Collect usage data to improve site performance.
- Functional Cookies: Remember preferences (e.g., language, location) for tailored experiences.
- Targeting/Advertising Cookies: Deliver personalized ads and measure campaign effectiveness.
Web Beacons: Invisible pixels embedded in pages, emails, or ads to track activity (e.g., page visits, ad clicks) and link devices.
Device Fingerprinting: Combines browser and device data (e.g., fonts, settings) to uniquely identify your device.
Location Technologies: Collects precise location data (if enabled) to deliver location-specific content or ads.
Data from Online Technologies may be aggregated across devices and services to associate your activity and target ads.
Information from Other Sources
We supplement collected data with information from third parties, including:
- Friends who refer you to our services.
- Marketing Companies providing demographic data for analysis.
- Social Networks when you engage with our content or grant access to your profile.
- Financing Providers facilitating payment plans or financial services.
- Partners involved in co-branded services, product distribution, or joint marketing.
- Advertising Partners delivering or measuring ad campaigns.
- Public Databases such as government records or publicly available data.
This combined data enhances our understanding of your preferences and improves service delivery.
Use of Information
We use the Personal Information we collect for a variety of purposes to operate our business, deliver services to you, and enhance your experience. Below is a detailed explanation of how your information is utilized:
Service Management and Fulfillment
We use your Personal Information to manage your account, process transactions, and provide the services you request. For example, when you place an order, we use your payment and shipping details to complete the purchase and deliver your items. If you use our Virtual Try On feature, we superimpose jewelry images onto photos you upload to help you visualize how a piece might look. Importantly, we do not scan, analyze, or store the physical characteristics of individuals in these photos, nor do we use them to identify you. We also respond to your inquiries, address customer service requests, and provide support through live chat, email, or phone.
Communication and Updates
We communicate with you to share important updates, such as appointment reminders, order confirmations, shipping notifications, or changes to our policies. These messages are essential to keep you informed about your interactions with us and ensure transparency about how we handle your data.
Improving Our Services
We analyze trends and user behavior (e.g., popular products, browsing patterns) to enhance our website’s functionality, personalize your experience, and improve our product offerings. This includes refining marketing strategies, tailoring promotions, and developing new services based on customer feedback and preferences.
Promotions and Research
When you participate in surveys, contests, or sweepstakes, we use your responses to understand demographics, interests, and behaviors. This helps us create more relevant campaigns and improve customer satisfaction. For instance, survey results might influence future jewelry designs or promotional events.
Marketing and Advertising
With your consent (where required by law), we send promotional materials about our products, exclusive offers, or events via email, SMS/text messages, or other channels. For example, if you opt into our text messaging program, you may receive cart reminders or personalized discounts. You can opt out of these communications at any time (see “Your Choices” section).
Fraud Prevention and Legal Compliance
We use your data to detect and prevent fraudulent activities, such as unauthorized transactions or identity theft. This protects both you and our business. Additionally, we comply with legal obligations, such as responding to court orders, enforcing our Terms and Conditions, or defending legal claims.
Employment Opportunities
If you apply for a job, we review your resume, employment history, and references to assess your qualifications. This process ensures we connect with candidates who align with our values and needs.
Other Legitimate Purposes
We may use your information for other purposes disclosed to you at the time of collection or with your explicit consent. For example, if you participate in a collaboration with a partner brand, we may share limited data to fulfill joint offers.
Non-Identifiable Data
Information that cannot personally identify you (e.g., aggregated purchase trends or anonymized browsing data) may be used freely for analytics, market research, or improving our services. This data helps us understand broader customer preferences without compromising individual privacy.
For details on how to control how your information is used, including opting out of marketing communications, please review the “Your Choices” and “Requests” sections of this policy.
Disclosure of Information
We may share your Personal Information in the following circumstances to operate our business, deliver services, and comply with legal obligations:
Affiliates
Your information may be shared with SARATTI’s related entities, including parent or sister companies, for purposes such as customer support, marketing, and operational efficiency. For example, our Hong Kong and U.S.-based affiliates may collaborate to process custom orders or manage global shipments.
Business Partners
We disclose information to partners involved in co-branded services, joint promotions, or product collaborations. This includes luxury designers, artisan workshops, or gemstone suppliers who help craft bespoke jewelry. For instance, if you purchase a limited-edition collection co-designed with a partner, your contact details may be shared for order fulfillment.
Special Events
When you participate in promotions (e.g., contests, trunk shows, or exclusive launches), we may share your data with event sponsors or collaborators. For example, winning a designer collaboration giveaway might require sharing your address with the partner for prize delivery.
Feedback and User-Generated Content
Testimonials, reviews, or photos/videos you submit (e.g., social media posts tagged with #SARATTI) may be displayed on our website, social media, or marketing materials. Edited for clarity, this content helps showcase SARATTI’s craftsmanship and customer experiences.
Facilitating Requests
If you choose to share SARATTI content on social media (e.g., Instagram or Pinterest), we may disclose your name or username to the platform to enable sharing.
Vendors and Service Providers
We partner with trusted third parties to deliver seamless services:
- Shipping: Global carriers like DHL or FedEx for order delivery.
- Payments: Secure processors like Stripe or PayPal.
- Certifications: Gemological labs (GIA, IGI) for diamond/gemstone authentication.
- IT & Marketing: Platforms like Shopify for e-commerce and Google Analytics for site optimization.
- Fraud Prevention: Agencies that screen transactions for security.
Business Transfers
In mergers, acquisitions, or asset sales, your data may transfer as part of SARATTI’s business assets. For example, if SARATTI merges with a luxury conglomerate, customer records would transition to ensure service continuity.
Legal Compliance and Safety
We disclose information when required by law, such as responding to court orders, preventing fraud, or protecting safety. For instance, SARATTI may share purchase records with authorities to investigate counterfeit claims.
With Your Consent
We share data for purposes explicitly agreed to by you, such as collaborating with a personal jeweler or financing partner.
Non-Identifiable Data
Aggregated or anonymized data (e.g., sales trends by region) may be shared freely for market analysis or partnerships, ensuring no individual identification.
Your Choices
To limit how your information is shared, adjust preferences in your account settings, opt out of marketing emails, or contact us at support@saratti.com. For details, see the “Your Rights” section.
Children
SARATTI’s Services are not intended for individuals under the age of 13, and we do not knowingly collect personal information (as defined by the U.S. Children’s Online Privacy Protection Act) from children under this age. If we discover that we have unintentionally collected personal information from a child under 13, we will take immediate steps to delete it. Parents or guardians of a child under 13 who believe their child has provided personal information to SARATTI may contact us via the details in the “Contact Us” section below to request removal.
For guidelines regarding individuals under 18, please review our Terms and Conditions, which outline requirements for parental consent and restrictions for minors using our Services.
Other Parties
Third-Party Websites and Services
Our Services may include links to websites, platforms, or services operated by third parties outside our control. These external sites, such as social media platforms or payment gateways, are not governed by this Privacy Policy. SARATTI does not oversee or endorse their content, privacy practices, or data handling methods. We strongly encourage you to review the privacy policies of any third-party services you access through our links to understand how they collect, use, and share your information.
Social Media Interactions
SARATTI’s Services may integrate social media features, such as “Like” buttons or sharing tools, that allow you to interact with platforms like Instagram, Facebook, or Pinterest. If you use these features, both SARATTI and the social media provider may collect information about your activity. For example:
- Liking/Sharing Content: Clicking a social media button (e.g., sharing a product on Instagram) may allow the platform to collect data such as your profile information, device details, or browsing history. SARATTI may receive limited data from these platforms (e.g., username or engagement metrics) to analyze trends or improve marketing.
- Brand Pages: SARATTI maintains official pages on platforms like Facebook and Instagram. Interactions with our content (e.g., commenting on a post) are subject to both this Privacy Policy and the platform’s terms. Publicly referencing SARATTI (e.g., using #SARATTI in a post) grants us permission to feature your content in marketing materials or on our website.
Analytics and Targeted Advertising
We partner with third-party analytics and advertising providers to enhance your experience and deliver relevant content:
- Analytics Tools: Services like Google Analytics help us analyze website traffic, user behavior, and engagement patterns. These tools collect anonymized data (e.g., pages visited, device type) to improve site performance and tailor offerings.
- Interest-Based Ads: SARATTI and our advertising partners may use cookies, pixels, or device identifiers to display ads tailored to your interests, both on our Services and elsewhere online. For example, if you browse engagement rings on our site, you might see SARATTI ads on other platforms. These technologies track activity across websites to associate your devices and serve relevant content.
- Matched Ads: We may share anonymized data (e.g., email hashes) with platforms like Facebook to show ads to users who have visited our site or match our customer profiles. This ensures our promotions reach audiences most likely to appreciate SARATTI’s craftsmanship.
For details on managing tracking technologies or opting out of targeted ads, review the “Your Choices” and “Information Collected Automatically” sections.
Your Choices
You have the right to control how your personal information is collected, used, and shared. Below, we outline the steps you can take to manage your data and preferences when interacting with SARATTI’s services.
Review and Update Your Account Information
You may access, correct, or delete certain personal information associated with your SARATTI account at any time. To update details such as your email address, shipping information, or communication preferences, log into your account through our website or mobile app. If you encounter issues or prefer assistance, contact our customer support team at support@saratti.com. For security purposes, we may request additional verification, such as a government-issued ID or recent transaction details, to confirm your identity before processing changes. Please note that SARATTI retains certain information even after account deletion to comply with legal obligations, resolve disputes, enforce agreements, or prevent fraudulent activity. For example, transaction records may be kept for tax reporting, and product reviews may remain published unless explicitly removed.
Manage Cookies and Tracking Technologies
SARATTI uses cookies, pixels, and similar technologies to enhance your browsing experience, analyze site traffic, and deliver personalized content. You can adjust your browser settings to block or delete cookies. Most browsers, including Chrome, Safari, and Firefox, allow you to manage cookies through their privacy or security settings. Keep in mind that disabling cookies may limit functionality on our website—for instance, items may not remain in your shopping cart between sessions, or personalized recommendations may not display. Additionally, SARATTI does not currently respond to “Do Not Track” (DNT) signals due to the lack of standardized industry guidelines. For more information on DNT, visit All About DNT.
Opt Out of Analytics and Targeted Advertising
SARATTI partners with third-party analytics and advertising providers to improve our services and deliver relevant ads. To limit how your data is used for these purposes:
- Google Analytics: Install the Google Analytics Opt-Out Browser Add-on to prevent Google from collecting and processing your activity on our site. Adjust ad personalization settings via Google Ads Settings.
- Microsoft Advertising: Visit Microsoft’s Ad Preferences to opt out of personalized ads.
- Industry Programs: Many advertising networks participate in self-regulatory programs like the Digital Advertising Alliance (DAA) or Network Advertising Initiative (NAI). Use these tools to opt out of interest-based ads from participating companies. Residents of the European Union can visit Your Online Choices for additional options.
Note that opting out applies only to the specific browser or device you use and does not block all advertisements. You may still see generic ads unrelated to your browsing history. SARATTI is not responsible for the effectiveness of third-party opt-out mechanisms or their compliance with your preferences.
Control Marketing Communications
You may unsubscribe from SARATTI’s promotional messages at any time:
- Emails: Click the “Unsubscribe” link at the bottom of any marketing email.
- Text Messages: Reply with “STOP,” “END,” or “UNSUBSCRIBE” to the shortcode provided in SARATTI’s SMS messages.
- Postal Mail: Contact us at support@saratti.com to request removal from physical mailing lists.
Opting out of promotional communications does not affect transactional messages related to your account, orders, or ongoing business interactions. For example, you will still receive order confirmations, shipping notifications, and warranty updates even if you unsubscribe from marketing emails.
Data Security and Retention
SARATTI employs robust administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, loss, theft, or misuse. These measures include encryption of sensitive data during transmission, restricted access controls to our systems, and regular security audits to identify and address vulnerabilities. While we strive to maintain industry-standard protections, no method of data transmission over the internet or electronic storage is entirely secure. As such, we cannot guarantee absolute security, though we continuously update our practices to mitigate risks and safeguard your information.
We retain your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy, including providing services to you, complying with legal obligations (e.g., tax or warranty requirements), resolving disputes, enforcing agreements, or preventing fraud. To determine retention periods, we consider factors such as the sensitivity of the data, the purpose for which it was collected, and applicable legal or regulatory mandates. For example, transaction records may be retained for tax reporting, while customer service interactions may be archived to address future inquiries or claims.
International Data Transfers
SARATTI operates globally, with headquarters in Hong Kong and a registered presence in the United States (SARATTI LLC). Your information may be stored, processed, or transferred to these regions or other countries where our service providers, partners, or affiliates operate. By using our Services, you consent to the cross-border transfer of your data, which may be governed by laws differing from those in your home country. For instance, data protection regulations in the U.S. or Hong Kong may not align with the GDPR or other regional standards. In all cases, we ensure transfers comply with applicable legal frameworks, such as implementing Standard Contractual Clauses for EU/UK data transfers, and collaborate only with partners committed to safeguarding your privacy. Note that local authorities in certain jurisdictions may access data under specific legal circumstances, such as national security requests.
Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or operational needs. When revisions occur, the “Last Updated” date at the top of this document will be revised, and changes take effect immediately upon posting. For material updates—such as significant shifts in data usage or sharing practices—we will notify you via email or prominent notices on our website, where required by law. Your continued use of SARATTI’s Services after such updates constitutes acceptance of the revised policy. We encourage you to review this page regularly to stay informed about how we protect your information.
Contact Us
For questions, concerns, or requests regarding this Privacy Policy or SARATTI’s data practices, please reach out using the following details:
By Email: support@saratti.com
By Mail:
For general inquiries:
SARATTI LLC
Attn: Legal / Privacy Team
1001 S North Main Street Ste 700
Kalispell, Montana 59901, United States
By Mail: Hong Kong
Block A, Yip Fat Industrial Building
77 Hoi Yuen Road Kwun Tong, Kowloon
Hong Kong
By Phone: +1 575 277-9670 (U.S.)
+852 9424 2327 (Hong Kong)
If you require this Privacy Policy in an alternative format due to a disability, please contact us via email at support@saratti.com or call the numbers above.
Additional Disclosures for California Residents
This section applies solely to California residents and supplements the information provided in SARATTI’s Privacy Policy. It outlines your rights under the California Consumer Privacy Act (CCPA) and describes how we handle your personal information.
Categories of Personal Information Collected
SARATTI collects the following categories of personal information as defined by the CCPA:
- Identifiers: Your name, email address, phone number, account username, IP address, and unique identifiers linked to your account.
- Customer Records: Billing and shipping addresses, payment card details, and transaction histories.
- Demographics: Age, gender, and other details that may qualify as protected classifications under California or federal laws.
- Commercial Information: Purchase history, product preferences, and services used.
- Internet Activity: Interactions with our website, including pages visited, search queries, and engagement with ads.
- Audio/Visual Data: Photos or videos you upload (e.g., product reviews or design inspirations).
- Geolocation Data: Approximate location derived from your IP address or device settings.
- Employment Data: Resumes, work history, and references submitted during job applications.
- Inferences: Preferences such as ring sizes, favorite products, or interests inferred from browsing behavior.
We may also collect sensitive personal information, including precise geolocation (if enabled), account credentials (e.g., passwords), and government-issued IDs for fraud prevention or legal compliance.
Purposes for Collecting and Using Your Information
We use and disclose the above categories of personal information for the following business and commercial purposes:
- Service Delivery: Processing orders, managing accounts, providing customer support, and personalizing your experience (e.g., tailored product recommendations).
- Operational Needs: Maintaining website functionality, troubleshooting technical issues, and securing our systems against fraud.
- Analytics and Improvement: Analyzing user behavior to enhance our services, develop new features, and conduct market research.
- Advertising: Delivering targeted ads through third-party platforms based on your interactions with SARATTI.
- Legal Compliance: Responding to law enforcement requests, enforcing our Terms and Conditions, and defending legal claims.
- Business Partnerships: Collaborating with trusted partners (e.g., gemstone suppliers, shipping carriers) to fulfill orders and offer co-branded promotions.
Data is sourced directly from you, your interactions with our services, and third parties such as marketing agencies, social media platforms, or referral programs.
Disclosure of Personal Information
We share California residents’ personal information with third parties as described in the “Disclosure of Information” section, including:
- Service Providers: Payment processors (e.g., Stripe), shipping companies (e.g., DHL), and IT vendors.
- Advertising Networks: Platforms like Google Ads or Meta to display relevant ads.
- Legal and Government Authorities: When required by law or to protect SARATTI’s rights.
Categories commonly disclosed include identifiers, commercial information, and internet activity data.
Your Rights Under the CCPA
As a California resident, you have the right to:
-
Know: Request details about the personal information SARATTI has collected, including:
- Categories and sources of data collected.
- Business purposes for collection or sharing.
- Third parties with whom data is shared (e.g., advertisers, shipping partners).
- Delete: Ask us to erase personal information, subject to legal exceptions (e.g., retaining transaction records for tax compliance).
- Correct: Request updates to inaccurate personal information. SARATTI may deny requests if correction is impractical or violates legal obligations.
- Opt Out of Sales/Sharing: SARATTI does not sell personal information as defined by the CCPA.
- Non-Discrimination: Exercise your rights without facing discriminatory treatment.
How to Submit Requests
To exercise these rights, contact us via:
-
Email: privacy@saratti.com
-
Mail:
SARATTI LLC | Attn: CCPA Request
1001 S North Main Street Ste 700
Kalispell, Montana 59901
United States
We will verify your identity (e.g., matching submitted details to account records) and respond within 45 days, with a possible 45-day extension if notified.
Notice of Financial Incentive
SARATTI may, from time to time, offer rewards, incentives, or promotional opportunities in exchange for your participation in specific activities, such as sharing information about your preferences, referring friends or contacts, or entering sweepstakes or contests. These programs are entirely voluntary, and you may choose to participate by completing the requested actions, such as providing your email address, submitting feedback, or inviting others to join SARATTI.
Nature of Incentives
When you opt into these programs, the specific reward or incentive—such as discounts, exclusive access to sales, or entries into prize drawings—will be clearly disclosed at the time of your participation. For example, referring a friend to SARATTI may grant you a credit toward a future purchase, while participating in a contest might offer the chance to win a custom jewelry piece.
Valuation of Your Information
The value of these incentives is based on a reasonable assessment of the monetary worth of the information you provide. SARATTI calculates this value by considering factors such as:
- Revenue Insights: The potential revenue generated from analyzing customer preferences to improve marketing strategies or product offerings.
- Operational Costs: Expenses related to administering the incentive programs, including prize fulfillment, promotional materials, and platform maintenance.
- Business Benefits: Anticipated revenue growth from enhanced customer engagement or referrals resulting from these initiatives.
Your Rights and Choices
Your participation in these programs is optional, and you may withdraw at any time by refraining from the requested actions or contacting us directly. For instance, if you no longer wish to receive referral incentives, you can discontinue sharing referral links or notify us to remove your eligibility. Opting out of financial incentives will not affect your access to SARATTI’s services or non-incentive communications.
Contact Us
For questions about active incentives, contest terms, or to withdraw from a program, reach out to our team:
Email: support@saratti.com
Updates to This Notice
SARATTI reserves the right to modify or discontinue incentive programs at any time. Changes will be reflected in an updated "Last Updated" date at the top of this policy. Material revisions will be communicated via email or prominent website notices, where required by law.
Additional Disclosures for California, Nevada, and European Users
California Minor Content Removal
California residents under the age of 18 who have registered for SARATTI’s Services and posted content (e.g., reviews, social media posts, or photos) may request removal of such content by contacting us at support@saratti.com. To process your request, please:
- Specify the content: Clearly identify the posted material (e.g., product review dated [Date] on the "Diamond Earrings" page).
- Confirm ownership: State that you personally posted the content and provide verification details (e.g., account email or username).
SARATTI will make reasonable efforts to remove the content from public view promptly. However, removal may not be comprehensive if the content has been copied, reposted, or shared by others (e.g., another user screenshotting your review). This process does not guarantee complete erasure from all platforms or archives.
Nevada Resident Rights
Under Nevada Revised Statutes (NRS 603A.340), Nevada consumers may submit requests to opt out of the "sale" of certain personal information. SARATTI does not engage in the sale of personal information as defined under Nevada law. However, if you wish to submit a formal opt-out request or have questions about our compliance, contact us at
Include "Nevada Privacy Request" in the subject line and provide your full name, Nevada residency confirmation, and contact details for verification.
Additional Disclosures for California, Nevada, and European Users
California Minor Content Removal
California residents under the age of eighteen (18) who have registered for SARATTI’s digital platforms and subsequently contributed user-generated content, including but not limited to textual reviews, visual media, or interactive social features, retain the statutory right to petition for the removal of such content under Section 22581 of the California Business and Professions Code. To initiate this process, eligible individuals must submit a formal request via the designated communication channel outlined in the “Contact Us” section of this policy, explicitly detailing the nature and location of the content in question while affirming personal authorship. SARATTI undertakes commercially reasonable efforts to expeditiously obscure the identified material from public visibility within its controlled digital environments. It is imperative to acknowledge that the efficacy of such removal may be circumscribed by external factors, including but not limited to third-party replication, archival practices, or cross-platform dissemination, which fall beyond SARATTI’s operational purview.
Nevada Resident Rights
Pursuant to Nevada Revised Statutes Chapter 603A, consumers domiciled within the State of Nevada are endowed with the statutory prerogative to direct covered entities to abstain from engaging in the exchange of specific categories of covered information for monetary consideration. SARATTI hereby affirms that its operational protocols do not constitute the monetization of consumer data as construed under NRS 603A.340. Notwithstanding this affirmation, Nevada residents may exercise their statutory rights by transmitting a verifiable consumer request through the communication modalities enumerated within this policy, wherein SARATTI shall undertake appropriate measures to effectuate such directives in accordance with prevailing legal frameworks.
Additional Disclosures for European Data Subjects
In fulfillment of obligations under Regulation (EU) 2016/679 (General Data Protection Regulation) and cognate data protection regimes operative within the European Economic Area, United Kingdom, and Switzerland, SARATTI provides the following elucidations:
Data Controller Identification
SARATTI Limited, in its capacity as the primary entity determining the purposes and means of processing personal data collected through digital and physical consumer interactions, is formally designated the data controller under applicable European data protection legislation.
Comprehensive Articulation of Data Subject Rights
Natural persons situated within the territorial ambit of European data protection jurisdictions are vested with an array of enforceable entitlements, including but not restricted to: the right to obtain confirmation of processing activities pertaining to their personal data and access thereto in a structured, commonly used, and machine-readable format; the right to secure rectification of inaccurate or incomplete personal data; the right to demand erasure of personal data under conditions satisfying the prerequisites of Article 17 GDPR; the right to impose restrictions on processing during the pendency of accuracy verification, lawful basis challenges, or objection proceedings; the right to data portability facilitating transmission of personal data between data controllers; and the right to lodge objections to processing activities predicated on legitimate interests or public authority tasks.
Transborder Data Flow Mechanisms
In instances necessitating the extraterritorial transfer of personal data beyond the jurisdictional boundaries of the European Economic Area, United Kingdom, or Switzerland, SARATTI implements a multilayered compliance architecture incorporating Standard Contractual Clauses ratified by the European Commission, Binding Corporate Rules subject to regulatory approval, and supplementary technical safeguards designed to preserve data integrity and confidentiality commensurate with European adequacy standards.
Lawfulness of Processing Foundations
SARATTI’s processing activities are anchored in lawful bases enumerated within Article 6 GDPR, including contractual necessity for order fulfillment, unambiguous consent solicited for marketing communications, and legitimate interests pursued in fraud mitigation, service optimization, and direct marketing endeavors, subject to proportionality assessments balancing organizational objectives against data subject rights.
Unified Exercisation of Rights
To operationalize the entitlements delineated herein or to lodge inquiries pertaining to SARATTI’s data governance practices, data subjects may initiate contact through the singular conduit of support@saratti.com, wherein SARATTI’s dedicated compliance personnel shall orchestrate identity verification protocols and substantive response mechanisms in accordance with statutory response windows.
Policy Dynamism
SARATTI reserves the unilateral prerogative to periodically revise these disclosures to reflect evolving regulatory mandates, operational exigencies, or technological advancements. Material amendments shall be demarcated through temporal annotations within the policy header, with significant alterations potentially triggering supplementary notification modalities as prescribed under regional legislative instruments.
Lawful Basis for Processing Personal Data
In adherence to the stringent requirements imposed by European data protection legislation, including but not limited to Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”), SARATTI hereby delineates the lawful foundations underpinning its processing activities involving personal data. These legal bases are meticulously aligned with the principles of lawfulness, fairness, and transparency enshrined within the aforementioned regulatory frameworks. The lawful bases invoked by SARATTI for the processing of personal data encompass the following circumstances:
- Explicit Consent: Processing is predicated upon the unambiguous, freely given, and specific consent voluntarily tendered by the data subject, either directly to SARATTI or to its duly authorized service providers and partners, for one or more explicitly defined purposes. Such consent may be withdrawn at any time through mechanisms delineated within this policy, without prejudice to the lawfulness of processing activities conducted prior to withdrawal.
- Contractual Necessity: Processing is indispensable for the execution of pre-contractual measures undertaken at the data subject’s request or for the performance of a contract to which the data subject is party, including but not limited to order fulfillment, warranty administration, and customer support operations.
- Legal Obligation: Processing is mandated by statutory, regulatory, or judicial obligations incumbent upon SARATTI as a data controller, including tax reporting, anti-money laundering compliance, and responses to lawful subpoenas or court orders.
-
Legitimate Interests: Processing is requisite for the furtherance of legitimate interests pursued by SARATTI or third parties, provided such interests are not overridden by the data subject’s fundamental rights and freedoms. Illustrative legitimate interests include, inter alia:
- Facilitating responsive communications to data subject inquiries, submissions, or service requests.
- Executing advertising, marketing, and promotional initiatives integral to the commercial operations and growth of SARATTI’s business.
- Conducting research, development, and security optimization endeavors, including cybersecurity protocols and fraud prevention mechanisms.
- Managing recruitment processes, evaluating employment applications, and enhancing talent acquisition strategies.
A proportionality assessment is invariably conducted to equilibrate SARATTI’s legitimate interests against the data subject’s reasonable privacy expectations.
Transborder Data Transfer Mechanisms
In instances necessitating the transfer of personal data beyond the territorial confines of the European Economic Area, United Kingdom, or Switzerland to jurisdictions not formally recognized by the European Commission as affording an “adequate” level of data protection, SARATTI institutes a robust compliance architecture designed to uphold the sanctity of data subject rights. Such safeguards include, without limitation:
- Standard Contractual Clauses (SCCs): Execution of European Commission-approved contractual stipulations between SARATTI and the transferee, binding the latter to GDPR-equivalent data protection standards.
- Binding Corporate Rules (BCRs): Adoption of intra-organizational policies governing extraterritorial data flows within SARATTI’s corporate group, subject to regulatory validation.
- Supplementary Technical Safeguards: Implementation of encryption, pseudonymization, and access controls to mitigate unauthorized disclosure risks.
For granular elucidation of the specific safeguards applicable to your data, you are invited to direct inquiries to the contact modalities enumerated within the “Contact Us” section herein.
Exercisation of Data Subject Rights
Pursuant to the panoply of entitlements conferred by European data protection law, data subjects may, subject to jurisdictional applicability and verifiable identity confirmation, initiate requests to:
- Confirm and Access: Obtain verification regarding the existence of processing activities involving their personal data and procure a comprehensive, structured, and machine-readable copy thereof.
- Rectify: Secure the amendment or completion of inaccurate or fragmentary personal data.
- Erase: Effectuate the deletion of personal data upon satisfaction of statutory prerequisites, including but not limited to data obsolescence or withdrawal of consent.
- Restrict Processing: Impose temporal limitations on processing activities pending the resolution of accuracy disputes, lawful basis challenges, or objection proceedings.
- Data Portability: Acquire personal data in a universally interoperable format for transmission to an alternative data controller.
- Object: Contest processing activities predicated on legitimate interests or public interest grounds, inclusive of direct marketing profileration.
- Revoke Consent: Retract previously granted consent, where such consent constituted the exclusive lawful basis for processing.
Submission Protocol:
To actuate these rights, data subjects must transmit a verifiable request to support@saratti.com, specifying the nature and scope of the entitlement sought. SARATTI reserves the prerogative to solicit supplementary information, including government-issued identification or transactional corroboration, to authenticate the petitioner’s identity. Third-party agents purporting to act on a data subject’s behalf must furnish notarized authorization and cooperate in identity validation protocols.
Prohibited Disclosures:
Data subjects are expressly enjoined from disclosing sensitive personal data (e.g., national identification numbers, biometric identifiers, health records, or financial account particulars) within request submissions, irrespective of the communication medium employed.
Adjudication and Appeals:
SARATTI shall adjudicate all requests within the temporal parameters prescribed by applicable law, furnishing a written rationale for any wholly or partially denied petitions. Data subjects aggrieved by such denials may lodge a formal appeal by resubmitting their grievance to support@saratti.com, accompanied by a meticulous exegesis of the alleged error and corroborating evidentiary materials.
Supervisory Authority Recourse:
Data subjects domiciled within Europe retain the inviolable right to lodge complaints pertaining to SARATTI’s data protection practices with the competent supervisory authority in their jurisdiction of residence or habitual abode.
Last Updated: 22/03/2025