Privacy Policy
Last Updated:
July 24, 2026
This Privacy Policy covers your use of our website and our online ordering services.
By using the Service, you agree to the collection and use of information in accordance with this policy, unless otherwise defined in this Privacy Policy or in our Terms and Conditions.
Terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, also accessible here:
https://imperialtopaz.net/terms_of_service/
- This page details our policies regarding the collection, use, and disclosure of personal data when you use our Service, and the associated choices you have.
- Special care is being taken in order to safeguard your privacy, to ensure complete compliance with the European Union's General Data Protection Regulation (GDPR), and to secure any of your personal details to a very high standard of information security.
- We use your data to provide the Service (including, among other objectives, in order to extend our customer service to you, be able to communicate with you, make it possible for you to purchase our Products, and to allow us to ship our Products to you), as well as to improve the Service.
1. INTRODUCTION
We are Suzerain Universal LTD, doing business under our fully-owned divisions and brands, including The Imperial Topaz Company ("Company", "we", "us" or "our"). We operate the website https://imperialtopaz.net/ (the “Service”).
This page informs you of Our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service, as well as to comply with legal obligations and our other policies, including our Terms of Service/Terms and Conditions and our Return Policy. By using the Service, you agree to the collection and use of information in accordance with this policy.
Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://imperialtopaz.net/terms_of_service/
2. DEFINITIONS
- Service: Service is the https://imperialtopaz.net/ website operated by Us.
- Personal Data: Personal Data means data about a living individual, who can be identified from this data (or from this and other information either in Our possession or likely to come into Our possession).
- Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Cookies: Cookies are small pieces of data stored on your device (computer or mobile device).
- Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which, and the manner in which, any personal information are, or are to be, processed. For the purpose of this Privacy Policy, We are a Data Controller of your Personal Data.
- Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
- Data Subject (or User): Data Subject is any living individual who is using our Service and is the subject of Personal Data.
3. INFORMATION COLLECTION AND USE
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected:
Personal Data:
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
Usage Data:
We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Location Data:
We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Service, to improve and customize our Service, to ensure our Terms of Service/Terms and Conditions, and to comply with laws and regulations of the Republic of Cyprus, the European Union and the United States of America (including, but not limited to, those mentioned in Section 7 of our Terms of Service/Terms and Conditions, aka "PROHIBITED ACTIVITIES", and/or section 5.5 of our Return Policy, aka "Political and Legal Obligations"). You can enable or disable location services when you use our Service at any time, through your device settings.
Tracking & Cookies Data:
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Reasons for Use:
We may use this data (including, but not limited to, Personal Data, Usage Data, Location Data, and Tracking & Cookies Data) to provide features of our Service, to improve and customize our Service, to ensure and/or apply and/or follow and/or comply and/or enforce our Terms of Service/Terms and Conditions and/or Our Return Policy, and to comply with laws and regulations of the Republic of Cyprus, the European Union and the United States of America (including, but not limited to, those mentioned in Section 7 of our Terms of Service/Terms and Conditions, aka "PROHIBITED ACTIVITIES", and/or in Section 5.5 of our Return Policy, aka "Political and Legal Obligations").
4. USE OF DATA
We use the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information.
- To be able to communicate with you in regard to your use of our services
- To make it possible for you to purchase our Products, and to allow us to ship our Products to you.
- To provide features of our Service
- To improve and customize our Service
- To ensure and/or apply and/or follow and/or comply and/or enforce our Terms of Service/Terms and Conditions and/or Our Return Policy
- To comply with laws and regulations of the Republic of Cyprus, the European Union and the United States of America
- To ensure and/or apply and/or follow and/or comply and/or enforce the terms in Section 7 of our Terms of Service/Terms and Conditions, aka "PROHIBITED ACTIVITIES", and/or the terms in Section 5.5 of our Return Policy, aka "Political and Legal Obligations").
5. LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATIONS (GDPR)
If you are a citizen of and/or residing in and/or accessing our Service from the European Economic Area (EEA), Our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
We may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- For payment processing purposes
- To comply with the law
6. YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you.
- Whenever made possible, you can access, update or request deletion of
- your Personal Data directly within your account settings section. If you
- are unable to perform these actions yourself, please contact us to
- assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability.
- You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent.
- You also have the right to withdraw your consent at any time where We relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
7. RETENTION OF DATA
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy and/or in Our Terms of Service/Terms and Conditions.
We will also retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security of the Service and/or to improve the functionality of our Service, and/or to ensure and/or apply and/or follow and/or comply and/or enforce the terms in Section 7 of our Terms of Service/Terms and Conditions, aka "PROHIBITED ACTIVITIES", and/or the terms in Section 5.5 of our Return Policy, aka "Political and Legal Obligations"), and/or if we are legally obligated to retain this data for longer time periods.
8. TRANSFER OF DATA
Your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside of the Republic of Cyprus, the European Union, Switzerland, Iceland, Israel and/or the United States of America, and choose to provide information to us, please note that we transfer the data, including Personal Data, to the Republic of Cyprus, the European Union, Switzerland, Iceland, Israel and/or the United States of America - and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
9. DISCLOSURE OF DATA
Disclosure for Law Enforcement:
Under certain circumstances, we may be required to disclose your Personal Data, if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements:
We may disclose your Personal Data in the good faith belief that such action is necessary for the following reasons:
- To comply with a legal obligation
- To ensure and/or apply and/or follow and/or comply and/or enforce the terms of our other policies (including our Terms of Service/Terms and Conditions and/or our Returns Policy
- To protect and defend the Service, and/or Our rights, and/or Our property
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
10. SECURITY OF DATA
We adhere to the following standard in regard to securing data in particular, and maintaining information security in general:
- GDPR / GDPR Article 32 (Security of processing)
We also base our policies for securing data in particular, and information in general on the following standards:
- NIS2 (Directive (EU) 2022/2555)
- PSD2 / SCA
- PCI DSS
- ISO 27001-style management
- OWASP
- CIS benchmarks
Among our security measures, we utilize the following practices:
- We encrypt sensitive data in transit (TLS) and at rest where appropriate
- We utilize strong access control for admin/backend systems (MFA, least privilege)
- We utilize secure session/authentication handling (protect accounts, prevent takeover)
- We apply a strict patch management policy for our platforms, plugins, web servers, and dependencies, as well as for any device that is being used by our employees and management before being able to gain access to any resource.
- We utilize a strict backups and tested restore procedures
- We conduct an excessive and comprehensive logging and monitoring of our online and offline resources and infrastructure, and maintain a high incident response readiness by a designated Information Security team, lead by a Chief Information Security Officer
- We maintain vendor management controls for sub-processors
In order to ensure a high degree of information security, we also use the services of third-party information security experts and information security firms, outside of our in-house information security and cyber-security teams.
It is crucial to acknowledge that while we maintain a high degree of information security under the above standards, any electronic system - both online or offline - is prone to failures that might lead to exploits and leakage of information. Such failures might not be a result of any negligence on our side. Any failure that results from the standards that we apply, or from the hardware or software that we use, including (but not limited) security failures due to to Zero-Day exploits, might be beyond our ability to mitigate in real time. We will not be liable for any damages that might be caused to you due to such failures. If you are not comfortable with any of the limitations reflected in any of the statements within this section (10. SECURITY OF DATA) - you may not use our Service in any way.
11. "DO NOT TRACK" SIGNALS
"Do Not Track" ("DNT") is a preference you may be able to set in your web browser to inform websites that you do not want to be tracked. Neither Us nor Our Service support "Do Not Track" signals, and such signals will be ignored by Us and by our Service, will not have any meaning while using our Service, will not be regarded, and will not be addressed.
12. SERVICE PROVIDERS
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Domain and Domain Name Server (DNS) Services:
We may use third-party Service Providers to provide us with Internet domain and DNS services. These services are necessary to allow your computer to access our servers through the Internet. Suppliers of such services include:
- NameCheap, Inc. (Based in the United States) - https://www.namecheap.com/legal/general/privacy-policy/
Analytics:
We may use third-party Service Providers to monitor and analyze the use of our Service.
- Google LLC / Alphabet Inc. (Based in the United States) - https://www.google.com/intl/en/policies/privacy/google_privacy_policy_en.pdf
- Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:
http://www.google.com/intl/en/policies/privacy/
Payments:
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
- PayPal / PayPal Holdings, Inc. (based in the United States) - https://www.paypal.com/webapps/mpp/ua/privacy-full
CONTACT US
In order to resolve a complaint regarding the Services or to receive further information regarding use of the Services, please contact us at:
Our postal address:
Suzerain Universal LTD
Panayides Building,
Chrysanthou Mylona 1,
Limassol,
Cyprus 3030.
And/or
Our email address:
contact@imperialtopaz.net
