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Privacy: Our promise to you
At the Watches of Switzerland Group, we aim to build long-lasting relationships with our clients, based on trust and respect. When you visit or talk to us online or in person, we collect personal information which we use and share as necessary to manage our business efficiently and legally. We also use it to gradually get to know you and build our relationship. This in turn allows us to give you a truly personalised experience wherever, whenever, and however you interact with us – and rest assured that we never sell your personal information.
Our Privacy policy explains how we use your personal data. Most of the information in it will be exactly as you’d expect of a privacy policy, but we’ve highlighted a few sections with a symbol to indicate a few things you may not already know and which we’d suggest you read.
The policy was most recently updated in September 2024.
If you’re looking for information about our Group’s internal approach to data protection and cyber security, please refer to the Data Protection and Information Security statement on our corporate website.
Our Privacy policy explains how we use your personal data. Most of the information in it will be exactly as you’d expect of a privacy policy, but we’ve highlighted a few sections with a symbol to indicate a few things you may not already know and which we’d suggest you read.
The policy was most recently updated in September 2024.
If you’re looking for information about our Group’s internal approach to data protection and cyber security, please refer to the Data Protection and Information Security statement on our corporate website.
The Watches of Switzerland Group privacy policy
The Watches of Switzerland Group privacy policy
Who are ‘we’, and who controls your personal data?
In this policy, ‘we’, ‘our’, ‘our group’ or ‘Watches of Switzerland’ means The Watches of Switzerland Group including subsidiaries, affiliates, and joint ventures. Our registered address is Aurum House, 2 Elland Road, Braunstone, Leicester, LE3 1TT.
At the time of writing, our group comprises Goldsmiths, Mappin and Webb, Watches of Switzerland, our Monobrand Boutiques and Hallmark Claims Service. It includes Mayors, Betteridge and Analog: Shift in the USA, and these are covered by our US privacy policy, which you can find on each of the respective websites. You can always find up to date information about our Group on our corporate website.
Under UK data protection law, the legal entity that controls client personal data for our Group is The Watches of Switzerland Company Limited, which is registered as a ‘data controller’ with the information commissioner’s office (ICO). In Ireland, the data controller is WOSG (Ireland) Ltd.
In respect of Hallmark Claims service, we act as a ‘data processor’ for our insurance partners. If you are a Hallmark client, the data controller will be your insurer, to which you should direct any queries or requests about your personal data in the first instance.
Data protection law
When we refer to ‘data protection law’ in this policy, we mean the law that currently applies in the UK and Europe: The UK Data Protection Act 2018 and its local equivalents, the General Data Protection Regulation (‘GDPR’) and UK GDPR, The Privacy and Electronic Communications Regulations, and all applicable supporting law and regulation.
How to contact us
If you have any concerns about how Watches of Switzerland handles your personal information, you can contact our Data Protection Officer at DPO@thewosgroup.com. To exercise any of your data protection rights, please contact our Client Experience team.
The personal information we hold about you and where it comes from
We collect personal information about you whenever you interact with us in person or online. Some of this comes directly from you and is as you would expect, while some is collected indirectly over the course of your relationship with us, as set out below
Getting To Know You
We aim to get to know you well and build up a picture of who you are, what you like and what interests you, so that we can give you a truly personal experience every time you interact with us. To do this, we collect information from the conversations we have in our showrooms, at formal or informal social events, and when chatting with our showroom colleagues via messaging, social media, email, or over the phone.
This includes practical information like food or drink preferences or allergies and any additional needs you may have when you visit our showrooms, as well as your favourite brands, personal style, and items you’re interested in. If you’re already a watch enthusiast or collector, we’ll keep a note of anything you tell us about your collection and the pieces you have or aspire to. We also make a note of things you tell us about yourself, your lifestyle, family, hobbies and interests, work, and aspirations or achievements. Sometimes we might add to this with information from social media, for example if we hear of any special work or personal achievements. We will also note birthdays, anniversaries and other significant dates or events that you mention are coming up for you or family members.
We use all this to give you a personalised service, suggest items you might like and events we think you’ll enjoy, celebrate life’s milestones with you and give you the unique client experience on which we pride ourselves.
We don’t use it to ‘profile’ you for direct marketing purposes but, based on everything we know about you, our showroom colleagues may contact you informally to, for example, let you know if a watch you’ll like becomes available, suggest a gift for an anniversary, congratulate you on a special occasion or invite you to a social event.
What’s our legal basis for doing this?
High Value Purchases: Collecting Additional Information About You
When you buy high value items we will check and/or collect additional information to satisfy money laundering and fraud prevention requirements, including your date of birth and identification details such as a passport or driving licence. We may also verify information through commercially or publicly available sources like Companies House, the Land Registry, the Electoral Roll, insolvency registers, industry, or professional bodies of which you may be a member, and social media. Although this information is publicly available, we remain mindful of your privacy and use it only as needed for this purpose.
We are privileged to work with brands including Rolex and Patek Phillippe. To preserve the integrity and exclusivity of those brands, they may require us to provide biographical information about people purchasing or looking to purchase their high demand timepieces, which they then use in allocating items and arranging events for potential purchasers. This may include your date of birth or age group, occupation or employment, previous purchase history and any details we have about your watch collection or aspirations. We do not share data for them to use in their own direct marketing.
What’s our legal basis for doing this?
Checks We Carry Out To Identify Reselling
To protect our business and industry and the integrity of the brands we work with, we are committed to doing all we can to reduce the grey market in watches. We sell all timepieces to you as the ultimate consumer for you to use personally, gift to someone else or add to your personal collection.
We carry out checks to identify reselling, using the personal data we have about you and publicly available sources such as Companies House, social media, online marketplaces and auction sites, and watch forums. Resale of a timepiece, or any activity consistent with reselling, may lead to future purchases being refused. The information we find will remain on our records after you cease to be an active Watches of Switzerland Client.
What’s our legal basis for doing this?
Information We Get From Third Parties
We occasionally obtain personal data from third parties who have your consent to pass it to us, for example where you enter a competition or promotion that we’re running jointly with a brand or retailer.
Where we acquire another business in whole or part, this may include its client data. If that is how we obtained your personal information, we will have notified you and provided you with a link to this privacy policy. We will not send you marketing without your consent.
To keep our records accurate and up to date and learn more about our clients, we may supplement our own records with data from companies that collate and update address and household information from a range of sources and make it commercially available. If we do this, we will work only with reputable organisations that obtain their data legally.
Personal Data In Our Monobrand Boutiques
We operate Monobrand Boutiques for a number of watch and jewellery brands. At the time of writing these are Breitling, Cartier, TAG Heuer, ROLEX, OMEGA, Hublot, Longines, FOPE and TUDOR. The personal data we collect in those boutiques is controlled by us and used in accordance with this privacy policy, and we share it with the relevant brand only as necessary to provide you with your chosen products and services or where we have another valid legal basis for doing so.
While in the boutique, we may also offer you the opportunity to sign up directly with the brand itself to receive its own marketing material. This information will be registered directly on the brand’s system, controlled by the brand, and used in accordance with its privacy policy. A link to that policy will be available when you sign up and you can also refer to it on the relevant brand’s website at any time. To opt out of a brand’s own marketing, simply click on the ‘unsubscribe’ link in one of its marketing e-mails or refer to the details on its website.
Hallmark Claims Service: Using Your Personal Data
Hallmark handles claims on behalf of a number of insurers, acting as a ‘data processor’, which means we are legally and contractually obliged to use your personal data only as instructed by them to provide the agreed service. Your insurer remains ‘data controller’ of your data, and you should address any queries or concerns about the handling of that data, and any requests to exercise your data protection rights to the insurer in the first instance, although if you ask us to forward a request on, we will of course be pleased to do so. Your insurer will share your personal data with us, and we with them, as necessary in handling your claim and any queries that may arise. You will find your insurer’s privacy policy on its website.
Where applicable in providing our end-to-end claim handling service, we will share your personal data with our local showroom or Virtual Boutique, so that our colleagues there can assist you in selecting replacement items. Any information we collect about you when you visit the showroom or Virtual Boutique and from that point onwards as our client, will be controlled by us and handled in accordance with this privacy policy.
Our Legal Basis: How and Why We Use Your Personal Data and What That Means For You
To use personal data, we must have a valid legal basis as set out in data protection law, and that is determined by why and how we intend to use that data. Our use of your data falls within four broad categories, each of which has a separate legal basis:
Data protection law gives you the right to ‘object’ to or opt out of the use of your personal data in certain circumstances, depending on our legal basis. The following section explains more.
Things We Need To Do To Provide Our Products and Services
There is a wide range of processes and activities that we have to carry out with your personal information including handling sales, refunds, repairs, and complaints, answering queries, maintaining registers of interest for high demand products, and making our websites work properly. Everything in this category is essential to enable you to shop, browse and communicate with us, and you cannot opt out of having your data used for these purposes and remain a client.
Things we do with your consent: marketing and cookies
If you have consented to marketing, we may contact you about any of our group companies or brands. You can opt out at any time by clicking the ‘unsubscribe’ link in our e-mails or emailing our Client Experience Team. We never sell or share your data for other organisations to use in their own marketing.
Our websites use cookies and, except where they are essential for the functioning and security of the sites, you can withdraw your consent to their usage easily at any time and continue to use those sites. Our cookie policy explains more about how we use cookies and how to exercise your choice over them.
Things we do to meet our legal and regulatory obligations
We have to comply with a range of requirements in respect of, for example, company and trading law, payment processing, complaint handling, tax and accounting, corporate governance, money laundering and fraud prevention, and the requirements of regulatory bodies such as the FCA to the extent that they apply to our business.
Some of these requirements involve using personal data and/or will affect how we use or how long we keep it. All the processes and activities that fall into this category are necessary for us to operate legally, responsibly and in line with the requirements of regulators, so you cannot opt out of having your data used for these purposes and remain a client.
Things that enable our business to operate effectively and efficiently: our ‘legitimate interests’
There are some things we do with personal data to help us run our business. We have a ‘legitimate interest’ in carrying out these activities and we do them in a way that minimises the impact on your privacy. The main activities that may involve your personal information are listed below. It is not an exhaustive list, and where we carry out other activities on the basis of ‘legitimate interests’ we will first assess their potential impact and put in place appropriate safeguards.
This category is important because data protection law gives you a ‘right of objection’ to activities carried out on the basis of ‘legitimate interests’ if their impact on your rights and freedoms outweighs our legitimate interest. We will always consider any objection request individually in context, but as these activities are central to our business and have minimal impact on your rights and freedoms, it is unlikely that we will uphold an objection request under normal circumstances.
We carry out anti-fraud and money laundering checks, and use online and physical measures to prevent and detect crime and to protect our clients, colleagues, property and business, such as the collection of basic information about your device and browser when you visit any of our websites, and the use of CCTV cameras in our showrooms. Where necessary we will share data with law enforcement and investigatory bodies for these purposes.
CCTV footage is held for either 30 or 60 days, as stated on the notice displayed in each store, unless it is required following an incident.
We collect personal data and carry out checks to detect reselling and protect the integrity and exclusivity of our brand partners. We may share data with the brands for these purposes.
We will send you important communications such as watch servicing or appointment reminders. If you are on a register of interest for a high-demand timepiece, we will contact you periodically to ask if you wish to remain on the register, to keep our records up to date.
If we invite you to an event hosted by or with ourselves, a brand partner or a third party, we will use and share your personal data as necessary to ensure it runs smoothly.
We carry out analytics to help us understand how, when, and why our clients shop with us, see how our business is performing, and help with planning and forecasting. We generally do this in a way that does not identify individual clients but may occasionally invite you to give feedback or take part in surveys or focus groups. We may use a third party for this purpose, in which case we will give them your contact details so they can invite you to take part. Your participation is always voluntary.
We will use any personal data we hold about you as necessary to assert, protect or defend our rights and interests or those of our brand partners and suppliers, to resolve disputes and to enforce agreements. To do this, we will share data as necessary with our external legal advisers, insurers, investigators, and other appropriate bodies.
We collect information about you to get to know you and build strong and lasting client relationships. We believe this benefits you because it helps us to give you a memorable and personal experience, but if you have any concerns about it, please contact our Client Experience Team, and we will accommodate your wishes as far as we can.
Sharing your information
We may share your data within our Group as necessary for any of the purposes in this policy and where we have a valid legal basis for doing so.
Other circumstances in which we may share your data are set out below. Except as set out in this policy, we do not share your personal information with third parties unless compelled or permitted by law. We may share with law enforcement and investigatory bodies, courts, HMRC and other government or regulatory bodies on receipt of valid proof of authority.
With companies that provide services on our behalf
Some of our services are provided wholly or partly by external companies. We carry out checks to ensure that the companies we work with will give your information the necessary level of care and protection. Both we and they have direct obligations under data protection law, and we reinforce those with the appropriate contractual measures. The main functions that may involve sharing personal data with third parties are:
Data protection laws and standards vary outside the UK and Europe. Some third-party providers we use are based, or carry out activities, in other countries, and where this is the case we put in place legal mechanisms to ensure that our data transfers comply with UK and European data protection law. We generally do this using standardised contractual clauses (sometimes known as the ‘EU model clauses’) that are approved by the European Commission and the UK and European privacy regulators, but there are other approved legal approaches which we may use instead.
With brands and manufacturers
We will share your personal data with our brand partners, manufacturers and their subsidiaries or agents as necessary to provide you with the product or service you have requested, e.g. to register a warranty or arrange a repair, or where we otherwise have a valid legal basis to do so.
We may share your data with our brand partners if you purchase, or express an interest in purchasing, a high-demand timepiece, to help them preserve the exclusivity and integrity of their brand.
On occasion, we may need to give a brand partner identifiable information about reselling activity, in support of our mutual commitment to minimising the grey market and preserving brand and industry integrity.
We don’t share data with our brand partners for them to use in their own direct marketing. In our Monobrand Boutiques we may offer you the option of signing up directly with the relevant brand to receive its marketing information. If you later wish to opt out, you can simply click the ‘unsubscribe’ link in one of the brand’s e-mails. You will find each brand’s privacy policy on its website.
Changes of ownership or business restructuring
If ownership of all or part of our business changes, or we undergo a reorganisation or restructure, we will transfer your personal information to the new owner or successor company and its agents and advisors to enable completion of the transaction, facilitate a smooth handover and ensure that we or they can continue to provide the services you have requested. The new data controller will contact you and provide you with its privacy policy.
How long do we keep your information?
We hold your information for as long as we have a valid legal reason to do so. Timescales for different types of data may vary according to our reason for processing them and the legal, regulatory, or business requirements that apply. We take these factors into account when deciding how long to keep data but, as a guide, we keep most of your details for 10 years after your last interaction with us. This reflects the typical pattern of client engagement and length of client relationship in our business and our industry.
Your privacy rights
Data protection law gives you certain rights over your personal data, as set out below. Should you wish to exercise any of these rights, please contact our Client Experience team. In some circumstances we may need to ask you for valid proof of identity before processing your request.
If you are a client of our Hallmark Claims Service, your insurer is the data controller of your personal data and we act on their instructions. You should contact your insurer in the first instance to exercise your data rights.
The right to opt out of direct marketing
We only send direct marketing with your consent, which you can withdraw at any time by clicking the unsubscribe link in any of our marketing emails.
The right of access
You have the right to know what personal data we hold about you and to see a copy of it. We will action your request within one month unless your request is particularly complex, in which case we will explain why. In some situations, the law may require or permit us to withhold some personal data, e.g. where providing it would adversely impact another person’s privacy rights or involve disclosing details that are legally privileged or commercially sensitive, and if this applies we will explain at the time. Your right of access also includes the right to know where we obtain our data, our legal basis for processing it, and how we use and share it, and this policy is designed to give you that information.
The right to have inaccuracies corrected
This is also known as the ‘right of rectification’. You can make simple corrections to your contact details online if you have an account. For more substantial changes, you should contact our Client Experience Team who will action your request within a month. If we do not intend to make the requested correction, e.g. where to do so would render our records inaccurate, we will tell you why and note our records to show your request and our rationale for refusing.
The right of objection
You have the right to object to activities involving your personal data that are based on our ‘legitimate business interests’ where your rights and freedoms outweigh those legitimate interests. The activities we carry out on this basis are set out here. Please ensure you have read that section before getting in touch. We will action all valid requests within a month.
The right to erasure
This is sometimes known as the ‘right to be forgotten’. It is the right to request the erasure of some of your personal data if we are found by the courts or a regulator to be processing it unlawfully (without a valid legal basis), or if any of the following applies and we have no other valid legal basis for continuing to hold the data:
As the right to erasure is closely linked to the legal basis on which we process your personal data, please read the relevant section of this policy carefully before getting in touch.
The right to data portability
This right aims to enable consumers to reuse some of their information online by making it available in a commonly used machine-readable format that can be passed to, and used by, other organisations. Currently, this is of limited practical application in the retail sector but, should you require it, we may be able to provide your contact details and purchase history as a CSV file.
The right of restriction
This is the right to have your personal data temporarily ‘ring-fenced’ from erasure, alteration, or other processing, pending a legal claim or while awaiting the outcome of an objection or rectification request.
Your right to complain to the regulator
If you believe we have infringed your privacy rights, or you disagree with a decision we have made, you have the right to complain to the Information Commissioner’s Officer (ICO). If you live in Ireland, Jersey, or Guernsey, you may choose to contact your local privacy regulator instead:
Who are ‘we’, and who controls your personal data?
In this policy, ‘we’, ‘our’, ‘our group’ or ‘Watches of Switzerland’ means The Watches of Switzerland Group including subsidiaries, affiliates, and joint ventures. Our registered address is Aurum House, 2 Elland Road, Braunstone, Leicester, LE3 1TT.
At the time of writing, our group comprises Goldsmiths, Mappin and Webb, Watches of Switzerland, our Monobrand Boutiques and Hallmark Claims Service. It includes Mayors, Betteridge and Analog: Shift in the USA, and these are covered by our US privacy policy, which you can find on each of the respective websites. You can always find up to date information about our Group on our corporate website.
Under UK data protection law, the legal entity that controls client personal data for our Group is The Watches of Switzerland Company Limited, which is registered as a ‘data controller’ with the information commissioner’s office (ICO). In Ireland, the data controller is WOSG (Ireland) Ltd.
In respect of Hallmark Claims service, we act as a ‘data processor’ for our insurance partners. If you are a Hallmark client, the data controller will be your insurer, to which you should direct any queries or requests about your personal data in the first instance.
Data protection law
When we refer to ‘data protection law’ in this policy, we mean the law that currently applies in the UK and Europe: The UK Data Protection Act 2018 and its local equivalents, the General Data Protection Regulation (‘GDPR’) and UK GDPR, The Privacy and Electronic Communications Regulations, and all applicable supporting law and regulation.
How to contact us
If you have any concerns about how Watches of Switzerland handles your personal information, you can contact our Data Protection Officer at DPO@thewosgroup.com. To exercise any of your data protection rights, please contact our Client Experience team.
The personal information we hold about you and where it comes from
We collect personal information about you whenever you interact with us in person or online. Some of this comes directly from you and is as you would expect, while some is collected indirectly over the course of your relationship with us, as set out below
Getting To Know You
We aim to get to know you well and build up a picture of who you are, what you like and what interests you, so that we can give you a truly personal experience every time you interact with us. To do this, we collect information from the conversations we have in our showrooms, at formal or informal social events, and when chatting with our showroom colleagues via messaging, social media, email, or over the phone.
This includes practical information like food or drink preferences or allergies and any additional needs you may have when you visit our showrooms, as well as your favourite brands, personal style, and items you’re interested in. If you’re already a watch enthusiast or collector, we’ll keep a note of anything you tell us about your collection and the pieces you have or aspire to. We also make a note of things you tell us about yourself, your lifestyle, family, hobbies and interests, work, and aspirations or achievements. Sometimes we might add to this with information from social media, for example if we hear of any special work or personal achievements. We will also note birthdays, anniversaries and other significant dates or events that you mention are coming up for you or family members.
We use all this to give you a personalised service, suggest items you might like and events we think you’ll enjoy, celebrate life’s milestones with you and give you the unique client experience on which we pride ourselves.
We don’t use it to ‘profile’ you for direct marketing purposes but, based on everything we know about you, our showroom colleagues may contact you informally to, for example, let you know if a watch you’ll like becomes available, suggest a gift for an anniversary, congratulate you on a special occasion or invite you to a social event.
What’s our legal basis for doing this?
High Value Purchases: Collecting Additional Information About You
When you buy high value items we will check and/or collect additional information to satisfy money laundering and fraud prevention requirements, including your date of birth and identification details such as a passport or driving licence. We may also verify information through commercially or publicly available sources like Companies House, the Land Registry, the Electoral Roll, insolvency registers, industry, or professional bodies of which you may be a member, and social media. Although this information is publicly available, we remain mindful of your privacy and use it only as needed for this purpose.
We are privileged to work with brands including Rolex and Patek Phillippe. To preserve the integrity and exclusivity of those brands, they may require us to provide biographical information about people purchasing or looking to purchase their high demand timepieces, which they then use in allocating items and arranging events for potential purchasers. This may include your date of birth or age group, occupation or employment, previous purchase history and any details we have about your watch collection or aspirations. We do not share data for them to use in their own direct marketing.
What’s our legal basis for doing this?
Checks We Carry Out To Identify Reselling
To protect our business and industry and the integrity of the brands we work with, we are committed to doing all we can to reduce the grey market in watches. We sell all timepieces to you as the ultimate consumer for you to use personally, gift to someone else or add to your personal collection.
We carry out checks to identify reselling, using the personal data we have about you and publicly available sources such as Companies House, social media, online marketplaces and auction sites, and watch forums. Resale of a timepiece, or any activity consistent with reselling, may lead to future purchases being refused. The information we find will remain on our records after you cease to be an active Watches of Switzerland Client.
What’s our legal basis for doing this?
Information We Get From Third Parties
We occasionally obtain personal data from third parties who have your consent to pass it to us, for example where you enter a competition or promotion that we’re running jointly with a brand or retailer.
Where we acquire another business in whole or part, this may include its client data. If that is how we obtained your personal information, we will have notified you and provided you with a link to this privacy policy. We will not send you marketing without your consent.
To keep our records accurate and up to date and learn more about our clients, we may supplement our own records with data from companies that collate and update address and household information from a range of sources and make it commercially available. If we do this, we will work only with reputable organisations that obtain their data legally.
Personal Data In Our Monobrand Boutiques
We operate Monobrand Boutiques for a number of watch and jewellery brands. At the time of writing these are Breitling, Cartier, TAG Heuer, ROLEX, OMEGA, Hublot, Longines, FOPE and TUDOR. The personal data we collect in those boutiques is controlled by us and used in accordance with this privacy policy, and we share it with the relevant brand only as necessary to provide you with your chosen products and services or where we have another valid legal basis for doing so.
While in the boutique, we may also offer you the opportunity to sign up directly with the brand itself to receive its own marketing material. This information will be registered directly on the brand’s system, controlled by the brand, and used in accordance with its privacy policy. A link to that policy will be available when you sign up and you can also refer to it on the relevant brand’s website at any time. To opt out of a brand’s own marketing, simply click on the ‘unsubscribe’ link in one of its marketing e-mails or refer to the details on its website.
Hallmark Claims Service: Using Your Personal Data
Hallmark handles claims on behalf of a number of insurers, acting as a ‘data processor’, which means we are legally and contractually obliged to use your personal data only as instructed by them to provide the agreed service. Your insurer remains ‘data controller’ of your data, and you should address any queries or concerns about the handling of that data, and any requests to exercise your data protection rights to the insurer in the first instance, although if you ask us to forward a request on, we will of course be pleased to do so. Your insurer will share your personal data with us, and we with them, as necessary in handling your claim and any queries that may arise. You will find your insurer’s privacy policy on its website.
Where applicable in providing our end-to-end claim handling service, we will share your personal data with our local showroom or Virtual Boutique, so that our colleagues there can assist you in selecting replacement items. Any information we collect about you when you visit the showroom or Virtual Boutique and from that point onwards as our client, will be controlled by us and handled in accordance with this privacy policy.
Our Legal Basis: How and Why We Use Your Personal Data and What That Means For You
To use personal data, we must have a valid legal basis as set out in data protection law, and that is determined by why and how we intend to use that data. Our use of your data falls within four broad categories, each of which has a separate legal basis:
Data protection law gives you the right to ‘object’ to or opt out of the use of your personal data in certain circumstances, depending on our legal basis. The following section explains more.
Things We Need To Do To Provide Our Products and Services
There is a wide range of processes and activities that we have to carry out with your personal information including handling sales, refunds, repairs, and complaints, answering queries, maintaining registers of interest for high demand products, and making our websites work properly. Everything in this category is essential to enable you to shop, browse and communicate with us, and you cannot opt out of having your data used for these purposes and remain a client.
Things we do with your consent: marketing and cookies
If you have consented to marketing, we may contact you about any of our group companies or brands. You can opt out at any time by clicking the ‘unsubscribe’ link in our e-mails or emailing our Client Experience Team. We never sell or share your data for other organisations to use in their own marketing.
Our websites use cookies and, except where they are essential for the functioning and security of the sites, you can withdraw your consent to their usage easily at any time and continue to use those sites. Our cookie policy explains more about how we use cookies and how to exercise your choice over them.
Things we do to meet our legal and regulatory obligations
We have to comply with a range of requirements in respect of, for example, company and trading law, payment processing, complaint handling, tax and accounting, corporate governance, money laundering and fraud prevention, and the requirements of regulatory bodies such as the FCA to the extent that they apply to our business.
Some of these requirements involve using personal data and/or will affect how we use or how long we keep it. All the processes and activities that fall into this category are necessary for us to operate legally, responsibly and in line with the requirements of regulators, so you cannot opt out of having your data used for these purposes and remain a client.
Things that enable our business to operate effectively and efficiently: our ‘legitimate interests’
There are some things we do with personal data to help us run our business. We have a ‘legitimate interest’ in carrying out these activities and we do them in a way that minimises the impact on your privacy. The main activities that may involve your personal information are listed below. It is not an exhaustive list, and where we carry out other activities on the basis of ‘legitimate interests’ we will first assess their potential impact and put in place appropriate safeguards.
This category is important because data protection law gives you a ‘right of objection’ to activities carried out on the basis of ‘legitimate interests’ if their impact on your rights and freedoms outweighs our legitimate interest. We will always consider any objection request individually in context, but as these activities are central to our business and have minimal impact on your rights and freedoms, it is unlikely that we will uphold an objection request under normal circumstances.
We carry out anti-fraud and money laundering checks, and use online and physical measures to prevent and detect crime and to protect our clients, colleagues, property and business, such as the collection of basic information about your device and browser when you visit any of our websites, and the use of CCTV cameras in our showrooms. Where necessary we will share data with law enforcement and investigatory bodies for these purposes.
CCTV footage is held for either 30 or 60 days, as stated on the notice displayed in each store, unless it is required following an incident.
We collect personal data and carry out checks to detect reselling and protect the integrity and exclusivity of our brand partners. We may share data with the brands for these purposes.
We will send you important communications such as watch servicing or appointment reminders. If you are on a register of interest for a high-demand timepiece, we will contact you periodically to ask if you wish to remain on the register, to keep our records up to date.
If we invite you to an event hosted by or with ourselves, a brand partner or a third party, we will use and share your personal data as necessary to ensure it runs smoothly.
We carry out analytics to help us understand how, when, and why our clients shop with us, see how our business is performing, and help with planning and forecasting. We generally do this in a way that does not identify individual clients but may occasionally invite you to give feedback or take part in surveys or focus groups. We may use a third party for this purpose, in which case we will give them your contact details so they can invite you to take part. Your participation is always voluntary.
We will use any personal data we hold about you as necessary to assert, protect or defend our rights and interests or those of our brand partners and suppliers, to resolve disputes and to enforce agreements. To do this, we will share data as necessary with our external legal advisers, insurers, investigators, and other appropriate bodies.
We collect information about you to get to know you and build strong and lasting client relationships. We believe this benefits you because it helps us to give you a memorable and personal experience, but if you have any concerns about it, please contact our Client Experience Team, and we will accommodate your wishes as far as we can.
Sharing your information
We may share your data within our Group as necessary for any of the purposes in this policy and where we have a valid legal basis for doing so.
Other circumstances in which we may share your data are set out below. Except as set out in this policy, we do not share your personal information with third parties unless compelled or permitted by law. We may share with law enforcement and investigatory bodies, courts, HMRC and other government or regulatory bodies on receipt of valid proof of authority.
With companies that provide services on our behalf
Some of our services are provided wholly or partly by external companies. We carry out checks to ensure that the companies we work with will give your information the necessary level of care and protection. Both we and they have direct obligations under data protection law, and we reinforce those with the appropriate contractual measures. The main functions that may involve sharing personal data with third parties are:
Data protection laws and standards vary outside the UK and Europe. Some third-party providers we use are based, or carry out activities, in other countries, and where this is the case we put in place legal mechanisms to ensure that our data transfers comply with UK and European data protection law. We generally do this using standardised contractual clauses (sometimes known as the ‘EU model clauses’) that are approved by the European Commission and the UK and European privacy regulators, but there are other approved legal approaches which we may use instead.
With brands and manufacturers
We will share your personal data with our brand partners, manufacturers and their subsidiaries or agents as necessary to provide you with the product or service you have requested, e.g. to register a warranty or arrange a repair, or where we otherwise have a valid legal basis to do so.
We may share your data with our brand partners if you purchase, or express an interest in purchasing, a high-demand timepiece, to help them preserve the exclusivity and integrity of their brand.
On occasion, we may need to give a brand partner identifiable information about reselling activity, in support of our mutual commitment to minimising the grey market and preserving brand and industry integrity.
We don’t share data with our brand partners for them to use in their own direct marketing. In our Monobrand Boutiques we may offer you the option of signing up directly with the relevant brand to receive its marketing information. If you later wish to opt out, you can simply click the ‘unsubscribe’ link in one of the brand’s e-mails. You will find each brand’s privacy policy on its website.
Changes of ownership or business restructuring
If ownership of all or part of our business changes, or we undergo a reorganisation or restructure, we will transfer your personal information to the new owner or successor company and its agents and advisors to enable completion of the transaction, facilitate a smooth handover and ensure that we or they can continue to provide the services you have requested. The new data controller will contact you and provide you with its privacy policy.
How long do we keep your information?
We hold your information for as long as we have a valid legal reason to do so. Timescales for different types of data may vary according to our reason for processing them and the legal, regulatory, or business requirements that apply. We take these factors into account when deciding how long to keep data but, as a guide, we keep most of your details for 10 years after your last interaction with us. This reflects the typical pattern of client engagement and length of client relationship in our business and our industry.
Your privacy rights
Data protection law gives you certain rights over your personal data, as set out below. Should you wish to exercise any of these rights, please contact our Client Experience team. In some circumstances we may need to ask you for valid proof of identity before processing your request.
If you are a client of our Hallmark Claims Service, your insurer is the data controller of your personal data and we act on their instructions. You should contact your insurer in the first instance to exercise your data rights.
The right to opt out of direct marketing
We only send direct marketing with your consent, which you can withdraw at any time by clicking the unsubscribe link in any of our marketing emails.
The right of access
You have the right to know what personal data we hold about you and to see a copy of it. We will action your request within one month unless your request is particularly complex, in which case we will explain why. In some situations, the law may require or permit us to withhold some personal data, e.g. where providing it would adversely impact another person’s privacy rights or involve disclosing details that are legally privileged or commercially sensitive, and if this applies we will explain at the time. Your right of access also includes the right to know where we obtain our data, our legal basis for processing it, and how we use and share it, and this policy is designed to give you that information.
The right to have inaccuracies corrected
This is also known as the ‘right of rectification’. You can make simple corrections to your contact details online if you have an account. For more substantial changes, you should contact our Client Experience Team who will action your request within a month. If we do not intend to make the requested correction, e.g. where to do so would render our records inaccurate, we will tell you why and note our records to show your request and our rationale for refusing.
The right of objection
You have the right to object to activities involving your personal data that are based on our ‘legitimate business interests’ where your rights and freedoms outweigh those legitimate interests. The activities we carry out on this basis are set out here. Please ensure you have read that section before getting in touch. We will action all valid requests within a month.
The right to erasure
This is sometimes known as the ‘right to be forgotten’. It is the right to request the erasure of some of your personal data if we are found by the courts or a regulator to be processing it unlawfully (without a valid legal basis), or if any of the following applies and we have no other valid legal basis for continuing to hold the data:
As the right to erasure is closely linked to the legal basis on which we process your personal data, please read the relevant section of this policy carefully before getting in touch.
The right to data portability
This right aims to enable consumers to reuse some of their information online by making it available in a commonly used machine-readable format that can be passed to, and used by, other organisations. Currently, this is of limited practical application in the retail sector but, should you require it, we may be able to provide your contact details and purchase history as a CSV file.
The right of restriction
This is the right to have your personal data temporarily ‘ring-fenced’ from erasure, alteration, or other processing, pending a legal claim or while awaiting the outcome of an objection or rectification request.
Your right to complain to the regulator
If you believe we have infringed your privacy rights, or you disagree with a decision we have made, you have the right to complain to the Information Commissioner’s Officer (ICO). If you live in Ireland, Jersey, or Guernsey, you may choose to contact your local privacy regulator instead:
Changes to our privacy policy
Our Company keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated in October 2024 Version 5
Changes to our privacy policy
Our Company keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated in October 2024 Version 5
