Privacy Policy of Judith Capital Group
Last Updated: 7/8/2025

Judith Capital LLC (“Judith Capital”) is the parent company of a U.S.-based group of specialized subsidiaries engaged in the sourcing and sale of loose diamonds, market analytics, exclusive gold bullion, secondhand acquisitions, professional material testing, and private club services. Our operations are supported by advanced AI systems and in-house laboratory capabilities. For ease of reference, Judith Capital and its subsidiaries may be collectively referred to as “Judith Capital,” “we,” “our,” or “us” throughout this document.

We are committed to protecting your privacy at every step. This Privacy Policy applies to all client-facing interactions with the Judith Capital Group, including the purchase and sale of jewelry, diamonds, bullion, secondhand acquisitions, testing services, market analytics, and private club operations.

Discretion, exclusivity, and trust are at the heart of everything we do. Every client experience with Judith Capital is handled with care and confidentiality. We do not sell personal information, and we use your data only as needed to deliver secure, personalized services and comply with applicable laws.

1. In-Person Transactions. All in-person transactions are handled with discretion, ensuring your personal data is treated with the same care as online transactions.

2. Information We Collect, Why We Collect It, and How It Is Used. We collect only the information necessary to provide the highest standard of service and security, ensuring all data is used solely for processing orders, improving our services, and complying with legal requirements.

When you browse our website, we collect data through cookies, pixels, log files, and other tracking technologies. This helps us improve website operations, analyze trends, track activity, and provide personalized content, targeted offers, and ads. You can opt out of non-essential cookies through your browser settings.

If you create an account or purchase a product, we collect personal details such as your name, email, shipping/billing address, phone number, and payment information. This data is necessary to process your order, fulfill transactions, and provide post-sale services. We retain this information as long as needed for legal and operational purposes.

If you request customized services or independent testing, we collect personal information related to the items being tested and your contact details. This information allows us to fulfill your request and ensure confidentiality.

When we purchase secondhand items from the general public, we collect identifying information, including your name, age, address, and business details, in compliance with legal requirements.

For customer reviews, we may collect your email, age, address, photo, and details of your experience with our products or services. This data helps us analyze customer feedback and engage with you on social media platforms.

If you contact us for support or inquiries, we collect your name, email, phone number, and any other relevant information you provide. This enables us to assist you and improve our services.

We also engage with customers through social media platforms, where we may collect and store personal information that you provide, such as your name and email address, to respond to inquiries and provide updates.

In some cases, we may use the collected data to detect and prevent fraud, ensure the security of our website and systems, comply with legal obligations, or resolve disputes.

3. Legal and Regulatory Compliance. We comply with all applicable federal, state, and local laws, including AML regulations under the U.S. Patriot Act and IRS requirements. This includes the collection, retention, and reporting of certain information to government authorities, such as:

• IRS Form 8300: For cash transactions over $10,000 USD.

• IRS Form 1099-B: For certain quantities of bullion sold by customers.

Additionally, we ensure all transactions, including those involving an attorney or proxy, meet legal requirements while maintaining confidentiality. All client-facing transactions are conducted through the appropriate subsidiary, depending on the nature of the service or product.

For more detailed information on how these requirements may impact your privacy, please refer to our separate Anti-Money Laundering Policy.

4. How We Share Your Personal Data. We do not sell personal information, and we never share your details for unrelated marketing or third-party solicitation. We may share your data as follows:

• For High-Value Transactions: With trusted partners, solely to process high-value transactions and ensure legal compliance.

• For Privacy-Conscious Transactions (Attorney Proxy): If you use an attorney or proxy, we use their information exclusively to complete your specific transaction. Proxy details are kept secure, retained only as legally required, and not shared except as needed to fulfill or document the transaction. By providing proxy details, you confirm the proxy’s consent.

• With Service Providers: To fulfill orders and provide IT, customer support, payment processing, and other essential functions.

• With Affiliates: For legitimate business, operational, and promotional purposes.

• For Legal Matters and Safety: To comply with laws, respond to law enforcement, or protect rights and interests.

• For Business Transfers: In the event of a merger, acquisition, or asset sale, as allowed by law.

• With Your Consent: When you expressly permit, such as for marketing.

• Aggregate or Anonymous Data: We may share data that cannot identify you, for analytics or marketing.

5. How We Protect and Store Your Information.

5.1 Security. We use technical and organizational safeguards to protect your data. While no method is 100% secure, we encourage you to protect your passwords and use secure devices.

5.2 Retention of Personal Data. We retain your personal data only as long as needed to fulfill the purposes described here, comply with legal requirements, or resolve disputes. If you request deletion, we will respond in accordance with applicable law.

6. Cookies, Tracking Options, and Do Not Track Disclosures.

6.1 Cookies and Tracking Technologies. Our website uses cookies to personalize your experience and improve site functionality. You can manage cookies through your browser settings, though disabling them may limit features.

6.2 Do Not Track Disclosures. We do not respond to “Do Not Track” signals. Third-party providers may collect information about your activity across other sites.

7. Your Privacy Rights and Choices.

7.1 Rights Under GDPR (if applicable). You have the right to access, correct, delete, restrict, or object to the processing of your data.

7.2 Rights Under CCPA (if applicable). You have the right to know what personal information is collected, request deletion, know if your data is sold, and exercise non-discrimination rights. You can exercise these rights by contacting us.

7.3 How to Exercise Your Rights. To exercise your rights, contact us. We may need additional information to verify your identity before processing requests.

8. Use by Children. Our services are not intended for use by children under 18. We do not knowingly collect data from minors. If you believe we have such data, contact us, and we will delete it.

9. Links to and Interaction with Third-Party Products. Our website may contain links to third-party websites. We are not responsible for their privacy practices, and you should review their privacy policies.

10. Nevada-Specific Privacy Rights. Under Nevada law, you have the right to request information regarding the collection, use, and disclosure of personal data. Contact us for inquiries.

11. Updates to This Privacy Policy. We may update this policy periodically. Significant changes will be posted on our website. Your continued use of our services constitutes acceptance of these changes.

12. Customer Engagement and Consent. Judith Capital is committed to engaging with our clients transparently. We ensure that your consent is obtained for any new data uses not covered in this policy. Should our practices change, we will notify you promptly through your preferred method of communication, ensuring you always have control over your personal data.

13. Data Minimization and Accuracy. We strive to collect only the personal information that is necessary to fulfill the purposes outlined in this Privacy Policy. We take steps to ensure that the information we collect is accurate, complete, and up to date. You have the right to request corrections to any inaccuracies in your personal data, ensuring that we maintain the highest standards of data accuracy and integrity.

14. How to Contact Us. If you have any questions, concerns, or complaints regarding our compliance with this notice and data protection laws, or if you wish to exercise your rights, please contact us at:

Email: info@judithcapital.com
Address: 2520 Saint Rose Parkway, Suite 203, Henderson, Nevada, 89074, United States

Thank you for choosing Judith Capital. We are committed to safeguarding your information with the same precision and care that defines all of our client relationships. Your trust is our highest priority, and every policy we maintain is designed to ensure discretion, clarity, and peace of mind.