FOX LAB GROWN DIAMONDS CORPORATION
Privacy Policy and Legal Notice
§ § Website under continuous development
1. Identity of the Controller
The controller responsible for the processing of personal data described in this policy is:
Trading name
FOX Lab Grown Diamonds Corporation
Controller / Proprietor
Fox
Tax identification number (RFC)
FORE830218EH2
Address
Diálogo 138, Solidaridad, C.P. 23090, La Paz, Baja California Sur, Mexico
For enquiries concerning privacy, data protection or the exercise of legal rights, please use the contact details above.
2. Scope and Purpose of this Policy
This policy explains how we process personal data when an individual visits our website, contacts us, requests information, begins commercial discussions or maintains a contractual relationship with FOX Lab Grown Diamonds Corporation. It applies to the website and to linked communication channels under our control.
3. Applicable Legal Framework
Where the Mexican Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP) and/or the European Union General Data Protection Regulation (GDPR) apply, processing shall be carried out in accordance with their principles and lawful bases. For services directed at the German or wider European market, the Digitale-Dienste-Gesetz (DDG), the Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz (TDDDG) and other applicable European legislation may also be relevant.
4. Categories of Data We May Process
• Identification and contact data: name, organisation, role, email address, telephone number and country.
• Communications data: enquiries, messages, documents submitted and responses.
• Contractual and transactional data: information required to prepare quotations, manage orders, perform contracts and retain supporting records.
• Technical data: IP address, date and time of access, page requested, referring URL, browser type, operating system and security events.
• Preference data: records of communication preferences and requests to object or withdraw consent.
5. Purposes and Lawful Bases of Processing
Purpose
Typical data
Lawful basis under the GDPR / justification
Purpose
Responding to enquiries and communications
Typical data
Identification, contact details and message content
Lawful basis under the GDPR / justification
Article 6(1)(b) GDPR for pre-contractual steps; Article 6(1)(f) GDPR for the efficient management of enquiries; Article 6(1)(a) GDPR where consent is requested
Purpose
Managing commercial relationships
Typical data
Contact, contractual, ordering, invoicing and follow-up information
Lawful basis under the GDPR / justification
Article 6(1)(b) GDPR for performance of a contract and Article 6(1)(c) GDPR for compliance with legal or tax obligations
Purpose
Operating and protecting the website
Typical data
Technical data, server logs and security events
Lawful basis under the GDPR / justification
Article 6(1)(f) GDPR: legitimate interests in stability, integrity and the prevention of attacks
Purpose
Compliance with legal obligations
Typical data
Data relevant to the applicable requirement
Lawful basis under the GDPR / justification
Article 6(1)(c) GDPR and applicable tax or regulatory requirements
Purpose
Commercial communications
Typical data
Professional contact details and preferences
Lawful basis under the GDPR / justification
Express consent under Article 6(1)(a) GDPR, or a legitimate commercial interest where permitted and subject to the applicable rules, including section 7 UWG in Germany
6. Contact by Email, Telephone or Form
When an individual contacts us, we process the information supplied in order to understand and manage the enquiry, provide a response and, where appropriate, take pre-contractual or contractual steps. We shall not use an enquiry for purposes incompatible with the reason for contact without an appropriate lawful basis.
7. Commercial Communications and the Right to Object
Commercial communications shall be sent only where a valid lawful basis exists. In Germany, advertising by email must also be assessed strictly in accordance with section 7 of the Gesetz gegen den unlauteren Wettbewerb (UWG). The mere publication of an email address does not in itself constitute authorisation to send advertising.
Right to object: the recipient may object at any time and free of charge to the processing of personal data for direct marketing by writing to us.
8. Cookies, Similar Technologies and Storage on Devices
The use of cookies and local storage technologies is subject, where applicable, to section 25 TDDDG in Germany.
• Technical or strictly necessary cookies: these may be enabled by default where required for navigation, technical delivery of the website and security functions.
• Analytics or third-party cookies: where non-essential tools such as Google Analytics, maps or video players are integrated, prior informed consent shall be obtained through the relevant preference mechanism.
9. Log Files, Security and Prevention of Abuse
The hosting server may generate technical logs required for delivery of the website, stability, detection of cyberattacks and fault resolution. We implement reasonable technical and organisational measures to protect the confidentiality and integrity of information.
10. Hosting, Providers and Processors
For the provision of our services and operation of the website, we use external technology infrastructure providers:
• Website hosting provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and/or Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States, through Google Sites.
• Email management and storage: Google Workspace.
Data Processing Terms
For the purposes of Article 28 GDPR and other applicable data-protection laws, FOX Lab Grown Diamonds Corporation relies, where applicable, on Google Cloud / Workspace Data Processing Terms governing processing and confidentiality.
11. International Data Transfers
Because FOX Lab Grown Diamonds Corporation operates legally from Mexico and uses global cloud-service providers, including Microsoft and Google, personal data may be transferred to and processed outside the European Economic Area (EEA).
Where the GDPR applies, international transfers shall be supported, as applicable, by the European Commission’s Standard Contractual Clauses incorporated into the provider’s terms, and/or an adequacy mechanism such as the EU-US Data Privacy Framework where it validly applies to the relevant receiving entity.
12. Recipients and Disclosure of Data
We do not sell or rent personal data. Data shall be disclosed only to authorised processors and to public authorities or official bodies where a valid legal obligation, administrative requirement or court order applies.
13. Retention Periods
We shall retain personal data only for as long as necessary for the purposes for which it was collected, or as required by legal, accounting, tax, contractual, security or claims-related obligations. Thereafter, the data shall be securely deleted, anonymised or restricted, as appropriate.
14. Rights of Individuals (ARCO / GDPR)
Subject to the applicable law and its conditions, individuals may exercise rights of access, rectification, cancellation or erasure, objection, restriction of processing, data portability and withdrawal of consent.
To exercise a right, please submit a signed request or complete a reasonable identity-verification process by contacting us. Individuals may also lodge a complaint with the competent supervisory authority in Mexico or the relevant data-protection authority in the European Union.
15. Children
Our services and website are intended solely for adults and corporate entities. We do not knowingly collect children’s personal data.
16. External Links
The website may contain links to third-party websites. FOX Lab Grown Diamonds Corporation is not responsible for the privacy practices or content of those external websites.
17. Intellectual Property
All website content, including trade marks, logos, text, images, photographs and code, is owned by FOX Lab Grown Diamonds Corporation or used under licence. Reproduction or distribution without express authorisation is prohibited, except where permitted by applicable law.
18. Legal Notice (Impressum)
Mandatory provider information:
• Trading name: FOX Lab Grown Diamonds Corporation
• Controller / Proprietor: Fox
• Tax identification number (RFC): FORE830218EH2
• Email: [email protected]
• Address: Andador Diálogo 138, Solidaridad, C.P. 23090, La Paz, Baja California Sur, Mexico
• Telephone: +52 612 125 1440
European Presence
FOX Lab Grown Diamonds Corporation is currently assessing potential locations for a future European office. Until such an office has been formally established and registered, the company’s official address remains the address stated above in Mexico
Hosting Information
• Service: Google Sites / Google Workspace.
• Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
• Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States.
19. Changes to this Policy
We reserve the right to amend or update this Privacy Policy to reflect legal, regulatory or technical developments. The current version shall be made available on the website.
20. Document Control
Document
Privacy Policy and Legal Notice
Owner
FOX Lab Grown Diamonds Corporation
Version
Consolidated British English translation 1.4
Status
Translation of the approved Spanish content; technical and jurisdiction-specific verification required before publication
Annex A. Checklist Before Final Publication
• Confirm the exact legal identity of the controller and its contact details.
• Confirm the actual hosting provider and remove contradictory provider references.
• Confirm the legal mechanism for international transfers used by each provider.
• Complete a technical inventory of cookies, tags, pixels, scripts and third-party integrations.
• Configure a consent mechanism where non-essential cookies or similar technologies are used.
• Obtain jurisdiction-specific legal review of the Legal Notice for each target market.
Annex B. Enhanced Protection of Digital Assets, Identity and Trade Secrets
Legal effect: This Annex records reservations of rights, conditions of use and protective measures. It does not create automatic private penalties and does not replace confidentiality agreements, trade mark registrations, technical controls or mandatory laws that may apply.
B.1 Ownership and Chain of Title
Original content created by FORE830218EH2 and/or FOX Lab Grown Diamonds Corporation for their activities, including text, photographs, videos, designs, databases, compilations, commercial documents, procedures, proposals, contact lists, training materials and software, belongs to the lawful owner to the extent recognised by applicable law.
Where an asset has been created by a third party, acquired, licensed or jointly developed, ownership shall be governed by the relevant contract, licence, commission, employment relationship or assignment instrument. Publication on the website does not transfer intellectual-property rights or grant an implied licence, apart from the technical permissions strictly necessary to display the content.
B.2 Reservation of Rights and Prohibited Uses
Unless the relevant rights holder has given prior, express and verifiable authorisation, no protected asset may be copied, extracted, reproduced, modified, adapted, translated, distributed, resold, sublicensed, published, communicated to the public, used to create derivative works or commercially exploited.
Unauthorised access, mass extraction, scraping contrary to applicable terms, circumvention of access controls, credential theft, impersonation, and the copying or downloading of non-public corporate files are likewise prohibited.
B.3 Prohibition of Cloning, Synthetic Profiles and Gaming or Speculative Exploitation
No authorisation is granted to use names, voices, images, signatures, biographies, personal data, corporate identities, documents, trade marks or family or business relationships to create cloned profiles, digital twins, avatars, simulations, individualised predictive models or false representations reasonably attributable to the protected individuals or entities.
Such assets must not be used for betting, auctions, prediction markets, speculative voting, competitions, games, entertainment based on personal events, manipulation campaigns, harassment, disinformation, social engineering or any system that commercialises or gamifies an individual’s life, reputation, decisions or safety without a valid lawful basis and the required authorisation.
B.4 Artificial Intelligence, Automated Training and Text and Data Mining
No authorisation is granted to use non-public content, personal data, trade secrets or protected materials to train, fine-tune, evaluate or supply artificial-intelligence or machine-learning systems.
In relation to public content, FOX Lab Grown Diamonds Corporation and the relevant rights holders reserve all available rights and, to the extent permitted by applicable law, object to unauthorised extraction and reutilisation, including commercial text and data mining where a legally recognised reservation mechanism is available.
B.5 Trade Secrets and Confidential Information
Confidential information includes non-public information that has commercial value because it is secret and is subject to reasonable protective measures, including plans, processes, prices, strategies, contacts, credentials, technical documentation, security records and contractual materials.
Acquisition through unauthorised access, theft or copying of documents or electronic files, and use or disclosure contrary to duties of confidence or contractual restrictions, may give rise to the remedies available under applicable law.
B.6 Cybersecurity Incidents and Preservation of Rights
No cyberattack, intrusion, data leak, configuration error, accidental receipt or technical access makes the affected information public or grants any right to use it. Any person who receives or accesses apparently confidential information must refrain from copying, disclosing, commercialising or exploiting it and should notify us where it is safe and lawful to do so.
FOX Lab Grown Diamonds Corporation reserves the right to preserve evidence, revoke access, implement containment measures, request removal or blocking, notify providers and competent authorities, and pursue any available civil, administrative or criminal remedies. Any compensation, injunction, penalty or liability shall be determined by applicable law and the competent authority; this notice does not set an automatic private penalty.
B.7 Authorisations and Signatures
Licences, assignments, special consents or authorisations for sensitive commercial uses must be recorded in a written instrument identifying the asset, permitted use, territory, duration, parties and the duly authorised signatory.
Where a signature is required, it may be handwritten or an electronic signature recognised by applicable law. The absence of a handwritten signature does not automatically invalidate an electronic signature or an agreement recognised by law.
B.8 Applicable Law and Territorial Limits
FOX Lab Grown Diamonds Corporation intends to align its activities directed at Europe with the GDPR and with the applicable law of the European Union and its Member States. However, this notice cannot exclude the mandatory laws of the country of establishment, the place of processing, the market addressed, the place where an infringement occurs or the competent jurisdiction.
The governing law for contractual relationships must be specified in each contract. Where legally permissible, the parties may select the law of an EU Member State; such a choice does not disapply mandatory rules, third-party rights, or applicable criminal, tax, corporate, employment, consumer, intellectual-property, data-protection or cybersecurity law.
B.9 Related Individuals, Companies and Projects
This document protects only those identified as owners, controllers or licensees, and only in respect of assets that lawfully belong to them. It does not grant FORE830218EH2 or FOX Lab Grown Diamonds Corporation rights over assets belonging to legally independent companies.
Fox Industrial S.A. de C.V., mobiliaro S.A. de C.V. and Copyright © mobiliarioseating S.A. de C.V. maintain family and independent consultancy links with FORE830218EH2 and/or associated projects, as applicable. Those links must not, however, be interpreted or presented as legal representation, corporate affiliation, shared ownership, joint liability, joint ownership of assets, authority to act on behalf of another entity or beneficiary status, unless supported by a written agreement and valid corporate authorisation from each entity. At present, such representation, shared ownership or joint liability is not publicly documented online.
Independent family consultancy services must be documented separately through agreements covering services, confidentiality, intellectual property, data protection and authorisation to use names and trade marks. The existence and content of those contracts, agreements, mandates, authorisations, strategies and coordination documents are confidential and are not intended for public disclosure. The parties reserve the right to keep them confidential and not to publish them online or provide them voluntarily to unrelated third parties, except with the joint written authorisation of the duly entitled entities or where disclosure is necessary to prepare, commence, pursue, defend or resolve joint legal proceedings against a person or entity outside the family companies.
In such circumstances, documents may be disclosed, strictly to the extent necessary, to lawyers, advisers bound by duties of confidence, insurers, experts, competent authorities, courts, tribunals, arbitrators or other persons whose involvement is legitimately required. Where possible, suitable protective measures shall be requested, including restricted access, redacted versions, procedural confidentiality, filing under seal or an equivalent mechanism permitted by the competent jurisdiction.
This reservation of confidentiality does not prevent compliance with a court order, legal obligation, valid administrative requirement, duty to preserve evidence, disclosure or discovery procedure, or any other mandatory requirement. The supply or production of a document for such purposes does not constitute a general waiver of confidentiality, ownership, trade-secret status, legal professional privilege or any other applicable right, to the extent recognised by law.
peachinvestment, FOX Lab Grown Diamonds Corporation and any sign still undergoing registration must be described accurately as a trading name, project or pending application, as applicable. The ® symbol must be reserved for trade marks that are registered in the relevant territory.
B.10 Reporting Infringements
Reports concerning unauthorised access, misuse, impersonation, cloned content, intellectual-property infringement or disclosure of confidential information may be sent to us. A report should identify the affected material, its location, the date, the disputed use, available evidence and the reporter’s contact details.
Annex C. Complementary Protective Measures
• Record ownership and assignments in writing for every work, photograph, video, design, database and document created by staff or suppliers.
• Put confidentiality and consultancy agreements in place with each family company before sharing non-public information.
• Maintain an asset register recording owners, licences, creation dates, versions and the location of evidence.
• Apply confidentiality labels, least-privilege access, multifactor authentication, audit logs and evidence-preservation controls.
• Register trade marks in relevant jurisdictions and do not present a pending application as a granted registration.
• Use technical notices and, where appropriate, text-and-data-mining reservations in metadata, website terms and access controls.
• Maintain an incident-response procedure covering detection, containment, evidence preservation, legal assessment, notification and recovery.