This policy explains how Gray Commercial (Yancheng) Co., Ltd., trading as TELULA Fine Jewelry, collects and protects personal and commercial data, and how our non-disclosure commitments work. It applies to our website, quotations, sample development and production services.

1. Client Design Confidentiality

• Access to client designs is restricted to the CAD studio and production staff assigned to that order, on a need-to-know basis.
• Client-specific designs are never displayed in our catalogue, showroom, trade-fair display, social media or marketing collateral.
• Production is siloed: components for different clients are never mixed on a shared bench, and photography inside the atelier is prohibited for staff and visitors.
• Bench jewellers and setters work under individual confidentiality undertakings in addition to the corporate NDA.
• Finished pieces are photographed only for your approval and internal QC records, filed against your PO number.

2. 3D CAD Data Security

• CAD and render files are stored on access-controlled, encrypted servers with per-user permissions and full audit logging.
• Approval files are delivered watermarked; production-ready native files (.3DM / .STEP) are released only after PO confirmation and a signed NDA.
• Files are never shared with third-party bureaus, casting subcontractors or marketplaces without your written consent.
• Two-factor authentication is enforced on all accounts that can access client design data, and workstation USB mass-storage is disabled.
• On written request we delete or return all CAD data within 30 days, issuing a certificate of destruction; the only retention exception is statutory accounting records.

3. Information We Collect

4. How We Use Your Information

• To prepare quotations, develop CAD, manufacture and ship your orders
• To communicate about production status, approvals, shipping and warranty claims
• To meet export, customs, tax and anti-money-laundering obligations
• To improve our website and service quality through aggregated analytics
• To send trade updates where you have opted in — you may unsubscribe at any time

We do not sell, rent or trade personal data, and we do not use client design data for any purpose beyond fulfilling your order.

5. Sharing & Sub-Processors

Data is shared only where necessary to deliver your order, and only with parties bound by confidentiality obligations:

• Logistics: DHL, FedEx, Malca-Amit, Brink’s — name, address, phone and declared value
• Payments: Stripe and banking partners — transaction data
• Certification: IGI, GIA, GRS, assay offices — stone specifications and images
• Infrastructure: hosting, email and CRM providers under data-processing agreements

We disclose data to authorities only where legally compelled, and we notify you unless prohibited from doing so.

6. International Transfers & Retention

Our atelier is located in China, so business data is processed there under PRC law. Transfers to the EU, UK and US are covered by standard contractual clauses with our processors. Order and accounting records are retained for the period required by PRC tax and customs law (generally 10 years). Design and CAD data is retained only while an active production relationship exists, or until you request deletion.

7. Cookies & Analytics

Our website uses strictly necessary cookies for cart and session function, plus optional analytics cookies to understand traffic patterns. Analytics data is aggregated and never linked to design files. You can block or delete cookies in your browser settings; strictly necessary cookies are required for the shop to function.

8. Your Rights

Subject to applicable law (including GDPR, UK GDPR, CCPA and PRC PIPL), you may request access to, correction of, or deletion of your personal data; object to processing; withdraw consent; and request portability. Email admin@telulagray.com with the subject line “Data Request”; we respond within 30 days and may ask you to verify your identity. You also have the right to lodge a complaint with your local data-protection authority.

9. Non-Disclosure Agreement (NDA) Terms

A bilateral NDA is executed before any design file is exchanged. Its standard terms:

• Scope: sketches, CAD, renders, technical specifications, stone maps, pricing, supplier and client identities.
• Term: obligations survive for five years after the end of the commercial relationship; trade secrets remain protected indefinitely.
• Permitted use: solely to quote and manufacture the Client’s order.
• Exclusions: information already public, independently developed without reference to the disclosed material, or lawfully received from a third party.
• Return or destruction: on request, all materials and copies are returned or destroyed with written certification within 30 days.
• Remedies: injunctive relief is available in addition to damages, reflecting the irreparable nature of a design leak.

We will sign your NDA template where it is materially equivalent; where terms conflict, the stricter confidentiality standard applies.

10. Contact

Gray Commercial (Yancheng) Co., Ltd. / TELULA Fine Jewelry
Yancheng, Jiangsu, China
Email: admin@telulagray.com
Data and NDA requests are handled by the compliance desk within one business day.

We may update this policy to reflect changes in law or practice; the effective date below always reflects the current version.