Privacy Policy
Last Updated: October 12, 2026
1. Introduction
Welcome to Daray (“Daray,” “we,” “our,” or “us”).
This Privacy Policy explains how Gold Top Jewellery Limited collects, uses, discloses, stores, and protects personal information when you visit https://www.daray.shop/ (the “Website”), browse our jewelry collections, place an order, contact customer service, or otherwise interact with our services.
Our product categories include Engagement & Wedding, Marriage Celebrations, and Promise Stage. Our products include rings, necklaces, and other jewelry items.
We respect your privacy and are committed to handling personal information responsibly and transparently. This Privacy Policy describes our information practices and explains the privacy rights that may be available to you under applicable laws, including relevant United States state privacy laws.
By using our Website, you acknowledge that you have had the opportunity to review this Privacy Policy. Where applicable law requires consent for a particular processing activity, we will obtain that consent separately.
2. Company Information
The company responsible for the Website is:
Company Name: Gold Top Jewellery Limited
Website: https://www.daray.shop/
Business Address:
Room 11, 3/F, Block C, Kaiser Estate Phase 1,
37–45 Ma Tau Wai Road, Hung Hom, Hong Kong
Privacy and Customer Service Email: [email protected]
For privacy-related questions or requests, please use the email address above and include “Privacy Request” in the subject line.
3. Personal Information We Collect
The categories of information we collect depend on how you interact with our Website and which services you use.
3.1 Information You Provide Directly
We may collect the following information when you place an order, submit a form, or contact us:
Identity information: Your name and, where applicable, the recipient’s name.
Contact information: Email address, telephone number if provided, and billing or shipping address.
Order information: Products purchased, quantities, order number, order history, delivery preferences, and transaction status.
Customer service information: Messages, inquiries, complaints, return requests, refund requests, and information you choose to provide when contacting us.
Account information: Login details and account preferences, if Website account functionality is available.
Gift or personalization information: Gift messages, engraving instructions, or other details you provide when ordering personalized products, if such services are offered.
Review and feedback information: Product reviews, feedback, or other content you voluntarily submit, where these features are available.
Please do not send unnecessary sensitive personal information through our customer service email.
3.2 Payment Information
When you purchase products, payment information may be collected and processed by the payment service provider available at checkout.
Depending on the payment method, the information processed may include payment card details, billing information, transaction identifiers, payment authorization results, and fraud-prevention information.
Where payment details are handled directly by a payment provider, we generally receive only the information needed to confirm and manage the transaction.
We do not request that you send complete payment card details, security codes, or account passwords through ordinary email.
3.3 Technical and Device Information
When you visit our Website, certain technical information may be collected automatically, depending on your browser, device, hosting platform, and website settings.
This information may include:
Internet Protocol (IP) address.
Browser type and version.
Device type and operating system.
Language and regional settings.
Referring website or page.
Pages visited and interactions with the Website.
Date, time, and duration of visits.
Cookie identifiers and similar technical identifiers.
Website performance, diagnostic, and security information.
We use this information for purposes such as maintaining Website functionality, diagnosing technical problems, understanding general usage patterns, preventing fraud, and protecting our services.
3.4 Information from Third Parties
We may receive information from third parties that support our business, where permitted by law.
These sources may include:
E-commerce hosting and website service providers.
Payment processors and payment services.
Shipping carriers and order fulfillment providers.
Fraud-prevention and security services.
Analytics providers, where enabled.
Advertising or marketing partners, where enabled.
Customer service or communication platforms.
The information received depends on the service involved and the permissions, settings, and contractual arrangements governing that service.
4. How We Use Personal Information
We may use personal information for the following purposes:
4.1 Order Processing and Fulfillment
To accept, verify, process, and fulfill orders; arrange payment; prepare products for shipment; provide tracking information; and manage cancellations, returns, exchanges, and refunds.
4.2 Customer Service
To respond to questions, resolve order issues, investigate complaints, provide product information, and communicate with customers about their purchases.
4.3 Website Operation and Improvement
To operate, maintain, troubleshoot, and improve the Website, its functionality, its product pages, and the overall shopping experience.
4.4 Payment Security and Fraud Prevention
To verify transactions, detect suspicious activity, protect against fraud, investigate unauthorized transactions, and safeguard our business and customers.
4.5 Communications and Marketing
To send transactional communications, such as order confirmations and shipping updates.
Where permitted by applicable law and, where required, with your consent, we may also send promotional emails about products, collections, or offers.
You may unsubscribe from promotional emails by following the instructions in the message. Unsubscribing from marketing communications will not prevent us from sending essential messages about your orders or transactions.
4.6 Analytics and Advertising
Where applicable tools are enabled, we may use information about Website interactions to measure Website performance, understand customer interests, evaluate advertising effectiveness, or deliver relevant advertisements.
Certain advertising technologies may involve sharing online identifiers or browsing activity with advertising partners. Depending on the technology and applicable law, these activities may constitute a sale or sharing of personal information under California law or targeted advertising under other state privacy laws.
Where required, we will provide appropriate notices and choices.
4.7 Legal Compliance
To comply with applicable laws, tax and accounting obligations, lawful requests, legal proceedings, and other legitimate legal requirements.
4.8 Protection of Rights and Interests
To enforce our policies, investigate suspected fraud or misuse, protect our Website and business, and establish, exercise, or defend legal claims.
We will not use personal information for materially different purposes that are incompatible with the purposes disclosed at collection without providing any notice or obtaining any consent required by law.
5. Cookies and Similar Technologies
Our Website may use cookies, pixels, tags, local storage, and similar technologies.
These technologies may be used for the following purposes:
Strictly necessary technologies: To support essential Website functions, shopping cart operations, checkout, security, and transaction processing.
Preference technologies: To remember selected settings or preferences, where available.
Analytics technologies: To understand Website traffic, usage patterns, performance, and technical issues, where enabled.
Advertising technologies: To measure advertising performance, recognize browsers or devices, or support personalized advertising, where enabled and permitted.
The specific cookies and technologies used depend on our Website configuration and third-party integrations.
Managing Cookies
You may be able to manage cookies through your browser settings and through any cookie preference tool provided on our Website.
Blocking certain cookies may affect the availability or functionality of some Website features.
Where required by applicable law, we will obtain consent before using non-essential cookies or similar technologies and will provide appropriate mechanisms to withdraw consent.
Global Privacy Control
Where required by applicable law, we will process valid opt-out preference signals, including Global Privacy Control (GPC) signals, for applicable sale, sharing, or targeted advertising activities.
Browser settings alone may not disable every third-party tracking technology. Please also use any privacy choices made available through our Website.
6. How We Disclose Personal Information
We may disclose personal information to the following categories of recipients when reasonably necessary for the purposes described in this Privacy Policy.
6.1 Service Providers and Processors
We may disclose information to companies that provide services on our behalf, such as:
E-commerce hosting and Website infrastructure providers.
Payment processing providers.
Order fulfillment and shipping providers.
Customer support and email service providers.
Website security and fraud-prevention providers.
Analytics and technical support providers.
These parties may process information to perform services for us, subject to applicable contractual requirements and legal obligations.
6.2 Advertising and Analytics Partners
If advertising or analytics technologies are enabled, certain information may be disclosed to relevant partners to measure advertising performance, analyze Website activity, or deliver advertisements.
Where applicable law classifies these activities as a sale, sharing, or targeted advertising, you may have the right to opt out.
We encourage you to review the privacy information and settings associated with any third-party services you use.
6.3 Shipping and Business Partners
We may share the information necessary to fulfill your order with shipping carriers, fulfillment providers, and other parties involved in delivering products or providing requested services.
6.4 Legal and Regulatory Authorities
We may disclose information when we reasonably believe disclosure is required or permitted by applicable law, legal process, court order, or a lawful governmental request, or when necessary to protect our rights, property, security, or the safety of others.
6.5 Business Transfers
If our business undergoes a merger, acquisition, restructuring, financing, or sale of assets, personal information may be disclosed or transferred as part of the transaction, subject to applicable legal requirements.
6.6 With Your Direction or Consent
We may disclose information to other parties when you direct us to do so or provide consent where consent is required.
We do not authorize third parties receiving personal information from us to use it in ways that are inconsistent with applicable law or the purposes for which it was disclosed.
7. Sale, Sharing, and Targeted Advertising
We do not sell personal information in exchange for monetary payment as a standard part of our stated business model.
However, certain disclosures to advertising or analytics partners may qualify as a “sale,” “sharing,” or targeted advertising under applicable state privacy laws, even when no money is exchanged directly for the information.
Whether such activities occur depends on the tracking technologies and third-party services actually enabled on our Website.
Where applicable law provides a right to opt out of the sale or sharing of personal information or targeted advertising, you may exercise that right by contacting [email protected] with the subject line “Privacy Opt-Out.”
If our Website uses advertising technologies subject to applicable opt-out requirements, we will provide any additional links, preference controls, or mechanisms required by law.
We will not knowingly sell or share personal information for cross-context behavioral advertising in a manner prohibited by applicable law.
8. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
Retention periods depend on the type of information and the reason it was collected.
For example:
Order and transaction records: May be retained for order management, accounting, tax compliance, dispute resolution, and legal obligations.
Customer service communications: May be retained for an appropriate period to resolve inquiries, maintain records, and address recurring issues.
Account information: May be retained while an account remains active and for a reasonable period afterward, subject to applicable requirements.
Technical and analytics information: May be retained according to the settings and retention periods of the relevant Website or analytics services.
Marketing preferences and suppression records: May be retained as needed to honor unsubscribe requests and comply with applicable marketing laws.
When personal information is no longer reasonably necessary, we will take appropriate steps to delete it, anonymize it, or otherwise dispose of it securely, subject to applicable legal and operational requirements.
9. Data Security
We use reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, loss, and misuse.
Depending on the information and the risks involved, these measures may include access restrictions, service-provider safeguards, secure communications, and other appropriate security practices.
However, no website, electronic transmission, or storage system can be guaranteed to be completely secure.
You should use appropriate precautions when accessing the Website and avoid sending sensitive payment credentials or account passwords through email.
If a security incident occurs, we will take appropriate steps in accordance with applicable legal requirements, including any required notifications.
10. International Data Transfers
Gold Top Jewellery Limited is located in Hong Kong, and personal information may be processed in Hong Kong or other countries where our service providers, payment processors, hosting providers, or business partners operate.
The data protection laws of these countries may differ from those in your state or country of residence.
Where required by applicable law, we will implement appropriate safeguards for international transfers and provide any required notices or obtain any required consent.
By using our Website and providing personal information, you understand that your information may be processed in jurisdictions outside your place of residence, subject to applicable legal requirements and the protections described in this Privacy Policy.
11. Your Privacy Rights
Depending on your state of residence, the nature of our activities, and whether applicable legal thresholds are met, you may have certain rights regarding your personal information.
These rights may include:
Right to know or access: Request information about the categories and specific pieces of personal information we collect, use, disclose, sell, or share, subject to applicable law.
Right to deletion: Request deletion of personal information we have collected, subject to legal exceptions.
Right to correction: Request correction of inaccurate personal information.
Right to opt out: Opt out of the sale or sharing of personal information or targeted advertising, where applicable.
Right to limit certain uses: Where applicable, limit certain uses or disclosures of sensitive personal information.
Right to data portability: Request a copy of certain personal information in a portable format, where required by law.
Right to appeal: Appeal a decision we make concerning a privacy request, where applicable law provides this right.
Right to nondiscrimination: Exercise applicable privacy rights without unlawful discrimination.
Not every right is available to every consumer or applies to every business. Certain exceptions may permit us to retain or process information when necessary to fulfill orders, maintain required records, prevent fraud, comply with law, or establish or defend legal claims.
How to Submit a Privacy Request
To submit a privacy request, email:
Please use one of the following subject lines as appropriate:
“Privacy Access Request”
“Privacy Deletion Request”
“Privacy Correction Request”
“Privacy Opt-Out”
“Privacy Appeal”
Please describe your request and provide enough information for us to identify the relevant records.
We may need to verify your identity or authority before fulfilling certain requests. We will request only information reasonably necessary for verification and will handle it in accordance with applicable law.
You do not need to create an account solely to submit a privacy request where applicable law prohibits such a requirement.
We will respond within the timeframes required by applicable law. Where permitted, we may extend a response period when reasonably necessary and will provide any required notice.
If we deny a request, we will provide an explanation and information about any applicable appeal rights, as required by law.
12. Additional Privacy Rights for California Residents
This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), applies to our business and the relevant processing activity.
12.1 Categories of Personal Information
Depending on how you interact with our Website, we may collect the following categories of personal information as defined under California law:
Identifiers, such as names, email addresses, IP addresses, and shipping addresses.
Customer records, such as contact information, billing information, and purchase records.
Commercial information, such as products purchased, transaction history, and shopping preferences.
Internet or other electronic network activity information, such as browsing activity and Website interactions.
Approximate geolocation information inferred from an IP address, where available.
Inferences drawn from Website interactions or shopping activity, where applicable.
We do not intend to collect sensitive personal information beyond what is reasonably necessary for the purposes disclosed in this policy, unless otherwise disclosed and permitted by law.
12.2 Sources of Personal Information
We may collect personal information from:
You directly.
Your browser or device when you use our Website.
Service providers and business partners.
Payment and shipping providers.
Analytics or advertising partners, where enabled.
12.3 Business and Commercial Purposes
We may use the categories of personal information listed above to fulfill orders, provide customer support, maintain and improve the Website, process payments, prevent fraud, measure Website performance, conduct permitted marketing activities, and comply with legal obligations.
12.4 Categories of Recipients
We may disclose relevant categories of personal information to service providers, payment processors, shipping and fulfillment providers, security providers, analytics providers, advertising partners, professional advisers, and governmental authorities, as appropriate for the purposes described in this policy.
12.5 Sale or Sharing of Personal Information
We do not sell personal information for monetary consideration as a standard business practice.
However, if our use of advertising or tracking technologies constitutes a sale or sharing under the CCPA, California residents may have the right to opt out of those activities.
You may submit an opt-out request using the contact information in Section 11. Where required, we will also provide a conspicuous opt-out link and honor applicable opt-out preference signals.
12.6 Retention
We retain personal information for the periods reasonably necessary to fulfill the purposes for which it was collected, as described in Section 8, subject to applicable legal requirements.
12.7 Exercising California Privacy Rights
Subject to applicable legal requirements and exceptions, California residents may request access to, deletion of, or correction of their personal information and may opt out of applicable sales or sharing.
We will not unlawfully discriminate against you for exercising your privacy rights.
Where the CCPA applies, we will follow its applicable verification, response, disclosure, and appeal requirements.
13. Marketing Communications
If you subscribe to promotional communications or otherwise provide consent where required, we may send emails about our jewelry collections, products, promotions, or store updates.
You may unsubscribe by using the unsubscribe link in a marketing email or by contacting [email protected].
We will process opt-out requests in accordance with applicable law.
Even after you unsubscribe from marketing emails, we may continue to send necessary transactional messages relating to an order, payment, delivery, return, refund, or other requested service.
14. Children’s Privacy
Our Website is intended for a general audience and is not directed to children under the age of 13.
We do not knowingly collect personal information online from children under 13 without legally required parental consent.
If we learn that we have collected personal information from a child under 13 in circumstances requiring parental consent and that consent has not been obtained, we will take appropriate steps to delete the information or otherwise address the situation in accordance with applicable law.
A parent or legal guardian who believes that a child has provided personal information to us may contact [email protected].
15. Third-Party Websites and Services
Our Website may contain links to third-party websites, payment services, social media platforms, or other external services.
Those third parties may have their own privacy policies, security practices, and data collection methods.
We do not control the privacy practices of independent third-party websites. We encourage you to review their privacy policies before providing personal information or using their services.
Any third-party service integrated into our Website should be evaluated according to its actual role and applicable privacy requirements.
16. Do Not Track and Browser Privacy Settings
Some browsers offer privacy settings or signals intended to limit online tracking.
The meaning and legal effect of these signals may vary by technology and jurisdiction.
Where applicable law requires us to recognize a particular privacy signal, including a valid Global Privacy Control signal for applicable opt-out purposes, we will process it as required.
You may also manage certain tracking technologies through available Website privacy controls and your browser settings.
17. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our business practices, Website functionality, service providers, legal obligations, or privacy requirements.
When we make changes, we will publish the updated policy on:
We will revise the “Last Updated” date at the beginning of the policy. If a material change requires additional notice or consent under applicable law, we will provide that notice or obtain consent as required.
We encourage you to review this page periodically to remain informed about how we handle personal information.
18. Contact Us
If you have questions about this Privacy Policy, wish to exercise an applicable privacy right, or have concerns about how your personal information is handled, please contact us.
Company Name: Gold Top Jewellery Limited
Website: https://www.daray.shop/
Privacy Contact Email: [email protected]
Business Address:
Room 11, 3/F, Block C, Kaiser Estate Phase 1,
37–45 Ma Tau Wai Road, Hung Hom, Hong Kong
Please include “Privacy Request” in the subject line of your email and describe your question or request.
We will make reasonable efforts to review and respond to privacy inquiries in accordance with applicable law.
Thank you for visiting Daray and trusting us with your information.