PRIVACY POLICY

Effective Date: May 19, 2026

Last Updated: May 19, 2026

Lusterline Inc. ("Company," "we," "us," or "our") operates the website, wholesale portals, and ordering platforms (collectively, the "Services"). This Privacy Policy governs our data collection, processing, and disclosure practices.

By accessing our Services, registering for a wholesale account, or purchasing inventory, you ("User," "Retailer," "you," or "your") explicitly agree to the terms of this Privacy Policy. If you do not agree, you must immediately cease using our Services.

1. Information We Collect

As a wholesale supplier, we primarily collect business information, though some data may constitute personal data under applicable laws.

• Business & Account Information: Legal business name, trade names (DBA), corporate structure, resale certificates, tax identification numbers, business addresses, billing details, and authorized buyer names.
• Transaction & Inventory Data: Purchase history, credit applications, payment terms, preferred diamond specifications (carat, cut, clarity, color, origin), and volume tiers.
• Technical & Usage Data: IP addresses, browser types, device identifiers, and interaction data collected via cookies, web beacons, and tracking pixels to optimize portal security and performance.

2. How We Use Your Information

We process your information strictly for commercial purposes, including:

• Vetting wholesale eligibility and verifying resale certificates.
• Processing, fulfilling, and shipping high-value inventory orders.
• Assessing creditworthiness and establishing commercial trade lines.
• Detecting, preventing, and mitigating fraud, unauthorized access, or intellectual property theft.
• Complying with legal, AML (Anti-Money Laundering), and Know Your Customer (KYC) regulations.

3. Maximized Liability Disclaimers & Absolute Protections

CRITICAL LEGAL NOTICE TO USER

To the maximum extent permitted by applicable law, Lusterline shall not be held liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, data, goodwill, or business opportunities arising out of data security incidents, server downtime, or third-party unauthorized access.

No Absolute Guarantee of Security: While we implement commercial-grade encryption and administrative safeguards appropriate for high-value asset trading, you acknowledge that no digital transmission or storage system is 100% secure. We disclaim all implied warranties regarding data security.

Third-Party Integration Immunity: Our Services rely on third-party payment processors, secure vault/logistics couriers (e.g., Malca-Amit, Brinks, FedEx), and credit reporting agencies. We hold zero liability for data breaches, leaks, or processing errors originating from these independent third-party infrastructures.

Inventory & Pricing Confidentiality: Wholesale pricing, memos, and tier structures are strictly proprietary. While we protect your transaction history, we reserve the right to utilize aggregated, anonymized transaction data for internal market analytics, pricing algorithms, and supply chain optimization without compensation or liability to you.

4. Strict Sharing & Disclosure Limits

We do not sell, rent, or trade your business or personal data to third-party brokers or marketing agencies. Disclosure is strictly confined to:

• Logistics & Security Partners: Secure transport services, insurers, and vaulting facilities to execute delivery.
• Financial & Legal Compliance: Merchant processors, underwriting banks, credit bureaus, and collections agencies in the event of default.
• Legal Mandates: Law enforcement, customs officials, or regulatory bodies where required to comply with subpoenas, anti-money laundering statutes, or trade regulations.

5. Mandatory Dispute Resolution & Class Action Waiver

To protect the Company from predatory litigation costs, any dispute or claim arising out of this Privacy Policy, data privacy practices, or digital platform security breaches shall be governed by the following strict escalation pathway:

• Mandatory Informal Negotiation: Parties must attempt to resolve any dispute informally for at least thirty (30) days prior to initiating formal action.
• Binding Arbitration: If unresolved, the dispute shall be settled exclusively through binding confidential arbitration administered by the American Arbitration Association (AAA) under its Commercial Arbitration Rules.

Class Action Waiver:

YOU AGREE THAT EACH PARTY MAY BRING CLAIMS AGAINST THE OTHER ONLY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.

6. Updates to This Policy

We reserve the right to modify, amend, or rewrite this Privacy Policy at any time at our sole discretion to reflect changes in legal mandates, security protocols, or operational frameworks.

Notice of significant updates will be communicated via the wholesale portal or by updating the "Last Updated" date above. Continued use of the Services post-update constitutes binding acceptance of the revised policy.

7. Contact & Data Rights Inquiries

For legal notices, data inquiries, or account compliance documentation, contact our compliance team:

Lusterline Inc Legal & Compliance Department
Email: sagar@lusterline.com