Introduction

The websites located at the following URL www.benchmarkrings.com are operated by Tosyali Int. Inc (hereafter referred to as "Benchmark" or "we" or "us"). Unless otherwise stated, this Benchmark DATA USE & SECURITY POLICY ("Privacy Policy") covers information collected and or submitted by the user through the Website. By using or accessing the Website, users of the Website ("you" or "user" or "Benchmark Consumer") accept the following terms set forth in this Privacy Policy.

Privacy Policy

To help us achieve our goal of providing the highest quality products and services, we use information from our interactions with you and other customers, as well as from other parties. Because we respect your privacy, we have implemented procedures to ensure that your personal information is handled in a safe, secure, and responsible manner.

We have posted this Privacy Policy in order to explain our information collection practices and the choices you have about the way information is collected and used.

As we continue to develop our Website and take advantage of advances in technology to improve the services we offer, this Privacy Policy likely will change. We therefore encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current privacy policy.

Information We May Receive from Users

Generally, you may browse the Website without providing any personally identifiable information. However, we may ask you to provide personally identifiable information at various times and places on the Website. This may include the following:

• Information you choose to share, such as location, name, email address, phone number, etc. We may also receive your name, email and zip code and phone number for SMS notification if you choose to use the Free Preview option. If you choose to register your Benchmark ring through our authenticity registration, located at http://www.benchmarkrings.com/register-your-ring, in addition to the above information we may receive your phone number, wedding date, purchase date, retailer name where the item was purchased.
• We may also receive other types of information from your use of the Website, such as the date and time you visit, the city and state you are located in, and log data and IP addresses.
• Third parties may provide information to Benchmark, such as our advertising partners and affiliates that assist us in understanding online preferences and help develop the functionality, appeal and usefulness of the Website.

In some cases, depending on the functionality of the Website page you are interested in, you may not have the ability to fully access the contents of the Website or participate in all of its features.

How We Use the Information We Receive

How we use the information we receive will vary depending on the information and/or how the information is received.

Non-Public Information

We use the information we receive through the functionality of the Website from use by you and other users. For example, we may use the information we receive about you:

• To protect the safety and security of the Website.
• To protect Benchmark and other users’ rights or property.
• To tailor our products to the user’s desire.
• To measure and understand the effectiveness of our ads, including delivering relevant ads to our users.
• To send you our Free Preview appointment email and notification email and other offerings that may arise from time to time.
• To identify your product preferences, so we can notify you of new or additional products, services, and promotions that might be of interest to you.
• To improve our merchandise selections, customer service, and overall shopping experience.

Cookies

We may use tracking pixels/web beacons, cookies and or other technologies to receive and store certain types of information. This information includes Internet Protocol (IP) addresses, browser information, Internet Service Provider (ISP), operating system, date/time stamp and clickstream data. This information helps us customize your website experience and make our marketing messages more relevant. This includes our content presented on other websites. In order to provide the best customer experience possible, we also use this information for reporting and analysis purposes, such as how you are shopping our website, performance of our marketing efforts, and your response to those marketing efforts.

Third-Parties

Benchmark does not share information we receive from our users unless we have permission from the user, given you notice, such as this Privacy Policy, or after personally identifiable information is removed.

A few examples of how Benchmark may share information about you the user to third parties, includes:

• Providing the information to service providers that help us bring you the products and services we offer. For example, we may work with outside companies to manage a database of customer information, assist us in distributing e-mails, assist us with direct marketing, provide fraud prevention, and other services designed to assist us in maximizing our business potential. We require that these outside companies agree to keep confidential all information we share with them and to use the information only to perform their obligations in the agreements.
• We may transfer or share a copy of personal information about you in the event that Benchmark goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets. You will be notified via email or prominent notice on the Website prior to a change in control of your personal information, if your personal information will be used contrary to this policy.
• We may provide access to information when legally required to do so, to cooperate with police investigations or other legal proceedings, to protect against misuse or unauthorized use of our Website, to limit our legal liability and protect our rights or to protect the rights, property or safety of visitors of the Website or the public.

Third-Party Cookies

We may allow third-party companies to collect anonymous information when you visit the Website and to use that information to serve ads for our products or services when you visit the Website. These companies may use anonymous information (e.g., navigational, non-personally identifiable information, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, etc.) during your visits to the Website in order to provide advertisements about our goods and services likely to be of interest to you. These parties may use a cookie or a third-party web beacon, or other technologies, to collect this information.

No Sharing with Third Party Vendors

We do not share your information with any third parties who may send you email solicitations.

Security

We are committed to handling your personal information with high standards of information security. We take appropriate physical, electronic and administrative steps to maintain the security and accuracy of personally identifiable information we collect, including limiting the number of people who have physical access to our database servers, as well as employing electronic security systems and password protections that guard against unauthorized access. Please note that e-mail is not encrypted and is not considered to be a secure means of transmitting confidential information.

Minor's Privacy

Protecting minors' privacy is important to us. Our Website is a general audience site. We do not collect or maintain information from those we actually know are under 18, and no part of our Website is targeted to attract anyone under 18. We also do not send email correspondence to anyone who tells us that they are under the age of 18 without their parent's consent.

People under the age of 18 should always ask their parents or guardians for permission before providing any personal information to anyone online. We urge parents and guardians to participate in their children's online activities and use parental control or other web filtering technology to supervise children's access to the web.

Email(s)

We only send our Benchmark Free Preview emails to those who have specifically requested to receive them. If you have decided that you no longer wish to receive email from Benchmark, you can click on the unsubscribe link and hit send at the bottom of any email communication sent by us. Please allow us 3 business days from when the request was received to complete the removal, as some of our promotions may already have been in process before you submitted your request.

Any Questions?

We'll be happy to provide additional information or answer any questions. Please contact us at customerservice@benchmarkrings.com if you have any additional questions or concerns regarding this Privacy Policy or any of the products and/or services offered by Benchmark.

Legal Terms

When you use this Website, you are automatically agreeing that both your access to the site and your use of it are:

• Subject to the terms and conditions in this Privacy Policy and may change from time to time without notice.
• Subject to all applicable laws.
• And undertaken at your own risk.

Please refer to this page frequently to review our current terms and conditions of use.

Copyright

The following elements of this Website are the property of Benchmark or our suppliers and are protected by United States and international copyright laws:

• All text, graphics, logos, button icons, images, audio clips, digital downloads, and data compilations -- both individually and as they are compiled on the site.
• All Benchmark Jewelry.
• All software.

Trademarks

The trademarks or trade dress of Benchmark may not be used without our written permission. Trademarks or trade dress include the Benchmark name and logo, and other graphics, logos, page headers, button icons, scripts, and names of Benchmark products, services, and programs.

Use

You have permission to electronically copy and print hard copies of pages from this Web site solely for personal, non-commercial purposes related to placing an order or shopping with the Website. Unless we give you written permission in advance, any other use of this Website, its content and its information, including linking or framing to this Website, is strictly prohibited.

Errors and Inaccuracies

Our goal is to provide complete, accurate, up-to-date information on our Website. However, it is not possible to ensure that any Website is completely free of human or technological errors. This site may contain typographical mistakes, inaccuracies, or omissions, and some information may not be complete or current. We reserve the right to correct any errors, inaccuracies or omissions and to change or update information at any time without prior notice. We sincerely apologize for any inconvenience this may cause.

Disclaimer of Liability

WE MAKE NO REPRESENTATIONS OR WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO THE WEBSITE, ITS CONTENT, OR THE INFORMATION AVAILABLE ON OR THROUGH IT; THEY ARE PROVIDED "AS IS," WITH ALL FAULTS. ALL INFORMATION, INCLUDING BUT NOT LIMITED TO INFORMATION REGARDING DIAMOND AND OTHER STONE WEIGHTS, AND ANY RING OR JEWELRY SPECIFICATION ARE APPROXIMATE AND ARE SUBJECT TO CHANGE WITHOUT ANY NOTICE. YOU AGREE THAT BENCHMARK SHALL NOT BOUND TO ANY SPECIFICATIONS OR OTHER INFORMATION CONCERNING BENCHMARK JEWELRY AND THAT ANY CLAIMS OR STATEMENTS ON THE WEB SITE CAN NOT AND WILL NOT BE USED AGAINST BENCHMARK.

EXCEPT AS OTHERWISE PROVIDED UNDER APPLICABLE LAWS, WE AND THE DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, CONTRACTORS, SUCCESSORS AND ASSIGNS OF BENCHMARK, WILL NOT BE LIABLE FOR ANY DAMAGES WHATSOEVER ARISING OUT OF OR RELATED TO THE USE OF THE WEBSITE OR ANY OTHER WEBSITE LINKED TO IT. THIS LIMITATION OF LIABILITY APPLIES TO DIRECT, INDIRECT, CONSEQUENTIAL, SPECIAL, PUNITIVE OR OTHER DAMAGES YOU OR OTHERS MAY SUFFER, AS WELL AS DAMAGES FOR LOST PROFITS, BUSINESS INTERRUPTION OR THE LOSS OF DATA OR INFORMATION, EVEN IF WE ARE NOTIFIED IN ADVANCE OF THE POTENTIAL FOR ANY SUCH DAMAGES.

Non-Confidentiality

Except for information necessary to request the Benchmark email newsletter, we do not want to receive confidential or proprietary information or trade secrets through this Website. Any information, materials, suggestions, ideas or comments sent to us will be deemed non-confidential, and by submitting it, you are granting us an irrevocable and unrestricted license to use, modify, reproduce, transmit, display and distribute it for any purpose whatsoever, with no payment or other compensation to you.

Applicable Law

By visiting this Website, you agree that the laws of the state of Alabama, without regard to principles of conflict of laws, will govern this Privacy Policy and any dispute of any sort that might arise between you and us or any of our affiliates.

Disputes

Any dispute relating in any way to your visit to our Website or to products purchased here shall be submitted to confidential arbitration in Tuscaloosa, Alabama. However, if you have in any manner violated or threatened to violate our intellectual property rights, we may seek injunctive or other appropriate relief in any state or federal court in the state of Alabama. You consent to exclusive jurisdiction and venue in such courts. Any arbitration under this agreement shall be conducted under the prevailing rules of the American Arbitration Association. The arbitrator's award shall be binding and may be entered as a judgment in any court of competent jurisdiction. To the fullest extent permitted by applicable law, no arbitration with respect to this Website or to products purchased here shall be joined to an arbitration involving any other party, whether through class arbitration proceedings or otherwise.

Benchmark is a member of the Responsible Jewellery Council (RJC).

The RJC is a standards-setting organization established to advance responsible ethical, human rights, social and environmental practices throughout the gold, silver, platinum group metals, diamond, and colored gemstone jewelry supply chain.

The RJC has developed a benchmark standard for the jewelry supply chain and credible mechanisms for verifying responsible business practices through third-party auditing.

As an RJC member, we commit to operating our business in accordance with the RJC Code of Practices. We commit to integrating ethical, human rights, social, and environmental considerations into our day-to-day operations, business planning activities, and decision-making processes. This includes, but is not limited to, a commitment to never engage in or knowingly support child labor (including the worst forms of child labor) as defined by International Labour Organisation (ILO) conventions 138 and 182, and to never engage in or knowingly support forced labor as defined by International Labour Organisation (ILO) convention 29, including bonded labor, deceptive recruitment, human trafficking, and indentured or involuntary prison labor. We commit that we do not engage in or tolerate bribery, corruption, money laundering, or financing of terrorism.

Learn more here.

This policy confirms Benchmark's commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions, and laws. Benchmark is a member of the Responsible Jewellery Council (RJC), and as such, we commit that we:

1. respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;
2. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
3. support transparency of government payments and rights-compatible security forces in the extractives industry;
4. do not provide direct or indirect support to illegal armed groups;
5. enable stakeholders to voice concerns about the jewelry supply chain; and
6. are implementing the OECD five-step framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

We also commit to using our influence to prevent abuses by others. We will conduct an annual risk assessment in accordance to OECD guidance of all suppliers of precious metals, diamonds, and gemstones. Executive members will meet to identify and assess risks and assign a risk level. For any risk assessed to be at an unacceptable status, the executive members will establish an action plan to work with the supplier to mitigate the risk. In the event that mitigation is unsuccessful, alternative actions, up to termination of business relationship will be taken.

Regarding serious abuses associated with the extraction, transport or trade of minerals

We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

1. torture, cruel, inhuman and degrading treatment;
2. forced or compulsory labor;
3. the worst forms of child labor;
4. human rights violations and abuses; or
5. war crimes, violations of international humanitarian law, crimes against humanity or genocide.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing any of the serious abuses described above, or are sourcing from, or linked to, any party committing these abuses.

Regarding direct or indirect support to non-state armed groups

We only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

1. control mine sites, transportation routes, points where diamonds are traded and upstream actors in the supply chain; or
2. tax or extort money or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or

from intermediaries, export companies or international traders.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described above.

Regarding public or private security forces

We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment, and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described above or that act illegally as described above.

Regarding bribery and fraudulent misrepresentation of the origin of minerals

We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of minerals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of minerals.

Regarding money laundering

We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of minerals.

Grievance Mechanism

External stakeholders may raise Human Rights and Supply Chain risk concerns by notifying Benchmark. We will ensure anonymity of the person raising the grievance and protect that person from retaliation. We provide the following methods of communication:

Email your concerns to ap2@benchmarkrings.com.

Call our Human Resources Director at 205-345-0555 ext. 281.

You may also notify us in writing through US Postal service, by mailing correspondence to Human Resources Director, P.O. Drawer 2929, Tuscaloosa, AL 35403.

Benchmark Wedding Rings was founded by Tom Tosyali with the goal of producing the finest wedding rings in the world- the Benchmark of wedding rings. Mr. Tosyali started his first factory in the back room of a small retail store with nothing but a lathe and a polishing station. It was here that he developed and manufactured what would become the very first Benchmark rings- with Mr. Tosyali himself traveling the country to sell them. Through his hard work and dedication, Benchmark has continued to grow and gain its reputation as an elite ring manufacturer.

Benchmark is proud to be part of a dying breed of U.S.-based manufacturers. Manufacturing excellence is at the core of our company, and it is our goal to produce rings that are well-engineered, aesthetically pleasing, and socially and environmentally conscious. As a commitment to social and environmental responsibility, Benchmark joined the Responsible Jewellery Council (RJC) in 2019. The RJC is a standards-setting organization established to advance responsible ethical, human rights, social and environmental practices throughout the gold, silver, platinum group metals, and diamond and colored gemstone jewelry supply chain. The RJC has developed a benchmark standard for the jewelry supply chain and credible mechanisms for verifying responsible business practices through third-party auditing.

As an RJC member, we commit to operating our business in accordance with the RJC Code of Practices. We commit to integrating ethical, human rights, social and environmental considerations into our day-to-day operations, business planning activities, and decision-making processes. Benchmark regularly reviews not only our company policies but also our daily operations to ensure that our core values are fully embedded into our practices. Despite the unique challenges presented by the global COVID-19 pandemic in 2020, we were able to implement new and strengthen existing policies and procedures to further align ourselves with the RJC Code of Practices on our path to becoming a certified member of the RJC. This momentum carried through the following years and has helped us recognize opportunities for continued improvement.

In 2022, while continuing to enhance our business practices as a whole, Benchmark chose to focus on getting to better know our suppliers to ensure their practices align with our goals. Through an enhanced supply chain policy, supplier questionnaires, risk assessments, and open communication, Benchmark has confidence that our suppliers are equally dedicated to socially and environmentally responsible business practices. By implementing annual supplier questionnaires, we were able to determine that over half of our suppliers of precious metals and diamonds are current members of the RJC. Those that are not members of the RJC have documented practices in place to ensure that their supply chain is conflict-free. Our expanded Supply Chain Policy was sent out to all of our precious metals and diamond suppliers in an effort to clearly communicate our expectations for ethically and responsibly sourced materials. Risk assessments were carried out on suppliers following our due diligence processes that have been enhanced over the last year, and it was determined there were no notable risks to upholding the standards set out in our Supply Chain Policy. As our business continues to grow and evolve, we remain committed to strengthening our relationships with responsible business partners and encouraging others to examine their own business structures for opportunities to develop a solid stance on responsible sourcing.

To further our commitment to responsible business practices, our goal for the future is to evaluate our environmental practices in depth. On our path to becoming a certified member of the RJC, we have found opportunities to enhance our environmental practices. Through employee training, research, and goal development we hope to set science-based targets to help limit our impact on climate change. Benchmark already has existing policies in place to minimize our environmental impact such as using recycled gold, recycling all of our precious metals scrap, internal re-use procedures for paper waste, and hazardous waste disposal protocols. We hope to integrate new procedures and strengthen existing policies over the next year to minimize not only our impact to the climate internally but also through our business partners. We will examine our business relationships for opportunities to positively influence our partners to implement and reinforce their own environmental standards.