Von Muziris Oy (“Von Muziris” or “we”) values and respects the right to privacy and data protection provided by applicable laws whenever we process personal data pertaining to our stakeholders. Von Muziris strives to process personal data in a transparent way, with due care and always in compliance with our obligations arising out of applicable privacy and data protection legislation.

This Privacy Policy is applicable to the processing activities of Von Muziris as data controller concerning personal data collected through our web-based Ethically+ platform available at, including any subdomains thereof (the “Platform”) as well as any of our services and web or mobile based applications provided on or through the Platform from time to time. The Platform and services thereof are hereinafter collectively referred to as the “Services”.

This Privacy Policy describes why and how we process personal data concerning the visitors to and authorized users of our Services (“User” or “you”) as data controller in accordance with the informing obligations set forth in articles 13 and 14 of the EU general data protection regulation 2016/679.

This Privacy Policy may be subject to changes from time to time if required due to changes in data processing practices or otherwise. The current version can be found on the Platform. No material changes shall be made without providing a general notice thereof on the Platform.

Kindly note that this Privacy Policy only applies to processing of personal data by Von Muziris as data controller. To the fullest extent permitted under applicable laws, we shall hereby disclaim all responsibility for the processing carried out by third parties including where the Services include hyperlinks or other links to websites or services of third parties.

This Privacy Policy forms a part of and is incorporated into the terms of the relevant agreement between you and Von Muziris governing the provision of the Services. If you object to your personal data being transferred or used as described in this Privacy Policy, please do not register, subscribe for, or use the Services.

You may contact us by email at and for information about processing your personal data.

what kind of personal data we process and from where do we obtain such data

Personal data of Users

Our Services may collect three (3) types of information concerning the Users: (i) User Data; (ii) Transaction Data; and (iii) Technical Data.

User Data is primarily received directly from you either in connection with your use of the Services (for example when you subscribe to the Services by filling out any registration forms available on the Platform or subscribe to our newsletter) or in connection with your interaction with us.

The categories of User Data we may collect and process, depending on the Services, include: (i) phone number; (ii) full name; (iii) e-mail address; (iv) encrypted account credentials or (v) data from your feedback or other interaction with us.

To trade through our Platform, Users may have to provide us with certain Transaction Data concerning e.g. trade references, inventories and commission payments as well as credit card, debit card or bank account information and date and time of purchase. Even though we have outsourced the processing of payment transaction concluded through the Platform to an external third-party payment service provider, Von Muziris may act as data controller for some processing activities pertaining to Transaction Data, in which case such processing shall be conducted in accordance with this Privacy Policy.

Without prejudice to the above, and to the extent our payment service provider should process the User’s Transaction Data as data controller under applicable laws, such processing shall be conducted in accordance with the applicable privacy policies of such payment service provider.

Technical Data is collected automatically by our Platform and may include the following: (i) IP address; (ii) language preferences; (iii) browser type; (iv) operating system; or (v) parts visited on our Services. Individuals cannot by default be identified from Technical Data. However, on some occasions individuals may be, either directly or in conjunction with other data, recognizable. In such case, Technical Data shall be considered personal data, and we shall process it in accordance with this Privacy Policy and applicable laws.


In addition to User, Transaction and Technical Data, we may from time to time use different technologies to collect and store Analytics Data pertaining to the use of the Services, including cookies. Analytics Data is primarily processed for us to analyze the use of and to develop our Services as well as engage in marketing activities. For detailed information about the use of cookies, analytics tools and social media plugins concerning the Services, please refer to our Cookie Policy

for what PURPOSES AND under which legal bases may we process PERSONAL DATA OF USERS

Purposes of processing

To provide the Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)

Our processing of your personal data is primarily based on the provision of the Services. We may process personal data to be able to provide essential functionalities for and access to the Services for Users and to personalize the user experience or enhance the quality of the Services. In some cases, personal data may be processed for the purpose of carrying out contractual obligations towards the User. Further, if you contact our customer service, we may use the provided information for answering questions and solving possible issues.

To fulfill our legal obligations (legal ground: compliance with a legal obligation)

We may need to process personal data to fulfill our legal obligations, such as our bookkeeping obligations or to provide information to competent authorities (e.g. tax authorities). We may further need to process personal data to ensure our compliance with any legal obligations pertaining to the trade of diamonds, gems or jewelry, including export control or sanctions laws and KYC/AML regulations.

For statistical and analytical purposes (legal ground: legitimate interest)

We may gather Analytics Data and other anonymous data in an aggregated form to generate reports and statistics and further use such reports and statistics for marketing purposes. By default, such reports or statistics do not include any personal data.

For communication and marketing (legal ground: legitimate interest)

We may process personal data for the purpose of contacting our Users regarding our Services and for informing Users of changes in our Service. We may also process personal data to market our Services, for example in the form of sending newsletters or analyzing the User’s activities within our Services to customize our marketing efforts.

Explaining the legal bases for processing

To the extent personal data is processed based on a contract between us and the User, the legal basis shall be performance of contractual obligations. We may also process personal data based on our legal obligations or other legitimate interests, for example in connection with quality improvement, analytics, marketing and legal processes. Whenever using your data based on our legitimate interest, we shall carefully weigh our interest against your right to privacy.

In certain cases, you may be requested to grant your consent for the processing of your personal data. In this event, the legal ground for such processing is your consent. You may withdraw your consent at any time.

We do not under any circumstances process Users’ personal data for the purposes of automated individual decision-making, including profiling.


We strive to keep all personal data subject to this Privacy Policy within the European Economic Area. However, we do have service providers engaged in the operation of the Platform in several geographic locations, such as [●]. As such, we and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or outside of your domicile.

In these situations, we shall ensure that your personal data is subject to adequate level of protection regardless of the jurisdiction. This happens by concluding a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards under chapter V of the EU General Data Protection Regulation (2016/679).


We shall not share your personal data within our organization, unless strictly necessary to perform our Services. We shall further not share personal data with any external third party, unless one of the following circumstances apply:

It is necessary for the purposes set out in this Privacy Policy

To the extent that third parties need access to personal data to ensure the performance of the Services, we have taken appropriate contractual and organizational measures to ensure that personal data is being processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.

For legal reasons

We may share personal data with third parties outside of our organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of Von Muziris, our Users or the public in accordance with the law. When possible, we will inform you about such transfer and processing.

To authorized service providers

We may share personal data to authorized service providers who perform services for us (including data storage, marketing and support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy.

For other legitimate reasons

To the extent Von Muziris is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to those concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.

With explicit consent

We may share personal data with third parties outside of our organization for other reasons than the ones mentioned above, when we have your explicit consent to do so. You have the right to withdraw your consent at any time.


Your personal data shall not be stored by us any longer than necessary for the purposes of providing the Services or parts thereof, or for another individual purpose for which your data is being processed hereunder. The exact storage period depends on the nature of the information and the purposes of processing. Hence, the maximum storage period may vary per use case.

Generally, personal data of Users is deleted within a reasonable time after the User no longer uses any part of the Services or when the User requests the deletion of such personal data, unless we are obligated to store the data for longer periods due to applicable law.

How do you use your rights hereunder

The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm your identity.

We reserve the right to reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.


We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience, and ability to restore the data. We regularly test our systems, and other assets for security vulnerabilities

Should despite of the security measures, a security breach occur that is likely to have negative effects on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as reasonably possible.


In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.

In Finland, the local supervisory authority is the Data Protection Ombudsman (