Privacy Notice

We may collect the following information about you:

• your name, age/date of birth and gender;
• your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
• purchases and orders made by you;
• your social media handles;
• your online browsing activities on any of our websites including what items you store in your shopping bag;
• your password(s);
• information about the device you use to browse our websites including the IP address and the device type;
• when you make a purchase or place an order with us, your payment card details;
• your communication and marketing preferences;
• your interests, preferences, feedback and competition and survey responses;
• your location;
• your correspondence and communications with us; and
• other publicly available personal data, including any which you have shared via a public platform (such as Instagram, YouTube, Twitter or public Facebook page).

This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Notice. Some personal data are collected directly, for example when you set up an online account on our websites, or send an email to our Customer Relations team. Other personal data are collected indirectly, for example, when you browse our websites or undertake online shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.

We may anonymise and aggregate personal data for insight and research but this will not identify anyone.

Our websites are not intended for children and we do not knowingly collect data relating to children.

General

Watches of Switzerland Company Limited (and trusted partners acting on our behalf) use your personal data:

• to provide goods and services to you;
• to make a tailored website available to you;
• to manage any account(s) you hold with us;
• to verify your identity;
• for crime and fraud prevention, detection and related purposes;
• to contact you electronically about promotional offers, events, products and services which we think may interest you;
• to arrange appointments with you;
• for analysis, insight and market research purposes to better understand your needs and ensure we are giving you what you like;
• to administer competitions and identify and contact competition winners;
• to enable us to manage customer service interactions with you;
• to ensure our, and our suppliers’, compliance with laws and regulations such as anti-modern slavery, anti-bribery and health and safety requirements ; and
• where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).

Marketing

Watches of Switzerland Company Limited use your personal data for marketing purposes and may send you postal mail, texts and/or emails to update you on our latest offers and events.

We aim to update you about products and services of interest and relevance to you as an individual.

You have the right to opt out of receiving promotional communications at any time, by:

1. contacting our Customer Relations team via email customer.relations@thewosgroup.com or by telephone on 0800 085 8250 or post to Customer Relations, Watches of Switzerland Company Limited, Aurum House, 2, Elland Road, Braunstone, Leicester LE3 1TT United Kingdom; or
2. making use of the simple "unsubscribe" link in our emails or the "STOP" number for texts; and/or
3. contacting our Data Protection Officer to indicate that you wish to change your marketing preferences by emailing dpo@thewosgroup.com or by post to The Data Protection Officer, Watches of Switzerland Company Limited, Aurum House, 2, Elland Road, Braunstone, Leicester LE3 1TT, United Kingdom;

This may not stop service messages such as order updates.

Personalisation and Automated Decision Making

In order to improve your shopping experience with us, when you visit any of our websites, you may receive personalised banner advertisements whilst browsing websites of other companies. Any banner advertisements you see will relate to your browsing activity on our websites from your computer or other devices.

These advertisements are provided by us via external market leading specialist providers using 'cookies' placed on your computer or other devices (see further information on the use of cookies in our Cookie Policy ). You can remove or disable cookies at any time - see here for further information.

We may collect data directly from you, as well as analysing your browsing and purchasing activity, both online and in store, and your responses to marketing communications. The results of this analysis, together with other demographic data, allow us to ensure that we contact you with information on products, services, events and offers that are relevant to you. To do so, we use software and other technology (automated decision-making including profiling).

We may do this to decide what marketing communications are suitable for you and this activity is based on our legitimate interests to develop and improve our products and services for you.

You have the right to opt out of any automated decision-making processes including profiling at any time by:

1. contacting our Customer Relations team via email customer.relations@thewosgroup.com or by telephone on 0800 085 8250 or post to Customer Relations, Watches of Switzerland Company Limited, Aurum House, 2, Elland Road, Braunstone, Leicester LE3 1TT United Kingdom; or
2. contacting our Data Protection Officer to indicate that you wish to change your marketing preferences by emailing dpo@thewosgroup.com or by post to The Data Protection Officer, Watches of Switzerland Company Limited, Aurum House, 2, Elland Road, Braunstone, Leicester LE3 1TT United Kingdom;

In order to provide more personalised services and experiences, we may also ask your permission to review third party data about you, for example, your Twitter or Facebook feeds, to get to know you better and to provide more effective personalisation. Some of our services enable you to sign-in via a third party service, such as Facebook. If you choose to sign-in via a third party app, you will be presented with a dialog box which will ask your permission to allow us to access your personal information (e.g. your full name, date of birth, email address and any other information you have made publicly accessible).

For full information on the use of cookies on our website, please view our Cookie Policy.

While navigating on the Rolex section of our website, some cookies are controlled by ROLEX SA which applies the following Cookies Policy.

We will never sell or rent your personal information to other organisations for marketing purposes.

We will not disclose your personal information to any third party, except for those referred to below.

We may share your data with:

• other companies within our group;
• purchasers, investors, funders and advisers if we sell our business or assets or restructure whether by merger, re-organisation or otherwise;
• our legal and other professional advisers, including our for financial and compliance purposes;
• credit reference agencies where necessary for card payments;
• governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:-
  to comply with our legal obligations and/or the administration of justice;
  to exercise our legal rights (for example in court cases);
  for the prevention, detection, investigation of crime or prosecution of offenders; and
  for the protection of our employees and customers, our service providers and suppliers.
• our service providers and suppliers.

In order to make certain services available to you, we have partnered with certain trusted third parties including IT, mailing, payment services, delivery, analytics and search engine providers and marketing service providers. We may need to share your personal information with some of our service partners. We only allow our service providers to handle your personal information when they have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your information to provide services to us and to you, and for no other purposes.

Please see here for the types of service providers with whom we share personal data:

Type of External Service Provider	Reason For Sharing Your Information
Database Administrators	Administration of our Marketing databases
Mailing Houses	Delivery of Postal Mailings
Electronic Mail Administrators	Provision of email system ,Delivery of email campaigns including electronic newsletters and administration of on-line competitions
Couriers and Logistics service providers	Goods delivery
Delivery Tracking system providers	tracking mail and deliveries
Software Providers	Administration of sales and returns
Marketing Consultancies and Advertising Services Providers	Analysis of marketing data and customer insight for the development and administration of marketing campaigns
Postcode look up software providers	administration of goods and service provision, Delivery of offers, promotions and other marketing campaigns
Electronic Appointment Schedulers	administration of appointments
Website trackers	to assist with personalising your on-line buying experience
Customer experience management software	analysis of customer feedback and facilitate customer product and service reviews
Digital Form Builders	administration of Register of Interest
Insurers and repair handlers	Provision of insurance cover on products purchased from us and to facilitate certain types of insurance claim administration
Finance Companies	Provision of interest free and interest bearing credit for our customers
Credit Check agencies:	identity verification/creditworthiness checks
Tax Compliance and e-invoice software providers	tax determination, invoicing and reporting
Watch and Jewellery Manufacturers	Legal compliance audits, Administration of Guarantees, Repairs and Marketing communications. No marketing communications will be sent by a 3rd party brand without your explicit opt in. Opt out information will be given through each of the 3rd party supplier's communications. Alternatively, please contact our customer services who will manage this process on your behalf.
Call recording providers	Call recording to facilitate Customer Care, administration of enquiries, complaints and insurance claims
Electronic platform providers	To create on-line accounts, to fulfil website orders and electronic newsletter distribution
Independent Valuers:	Jewellery and watch valuations
Live Engagement Platform Providers	Delivery of On-Line Live Chat environment
Digital location software suppliers	delivery of “near me now” digital content
Payment Service Providers	payment services
Website Hosting Service providers	Administration of our websites, fulfilment of on-line orders and electronic marketing campaigns
Order fulfilment providers	Facilitate fulfilment of orders on websites and customer care
Electronic Repair administrators	Repair processing and workshop administration. Facilitating watch repairs by post, Facilitating communications with our repair services
Document Management system suppliers	payment of suppliers and general administration
Document Disposal Managers	Document disposal
CCTV capture and monitoring service providers:	security of people and premises
Automatic Number Plate Recognition System providers	security of people and premises
Visitor management software providers:	monitoring employee/visitor/supplier/contractor flow to and from premises
Talent Acquisition software	recruitment

Watches of Switzerland Company Limited has partnered with certain trusted third parties to make additional products and services available to you online through the relevant third party's "microsite". These websites, and others linked to from our websites are owned and operated by a third party and they are responsible for processing personal data in accordance with their own privacy policies. These are:

We are required to set out the legal basis for our 'processing' of your personal data.

We collect and use customers' personal data:

1. as necessary to perform our contract with you
   - for the purposes of complying with our duties and exercising our rights under contracts for the sale of goods or services to customers; and/or
2. as necessary for the pursuit of our legitimate interests including:
   - selling and supplying goods and services to our customers;
   - promoting, marketing and advertising our products and services;
   - sending promotional communications which are relevant and tailored to individual customers (including administering loyalty schemes);
   - to administer competitions and promotions and identify and contact competition winners;
   - understanding our customers' behaviour, activities, preferences, and needs;
   - improving existing products and services and developing new products and services;
   - protecting customers, employees and other individuals and maintaining their safety, health and welfare;
   - good governance, accounting and managing of our operations and complying with our legal obligations;
   - preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
   - handling customer contacts, queries, complaints or disputes;
   - managing insurance claims by customers;
   - protecting our company, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us;
   - handling any legal claims or regulatory enforcement actions taken against us; and
   - fulfilling our duties to our customers, colleagues, shareholders and other stakeholders or
3. as necessary for complying with our legal obligations including
   - where you exercise your rights under data protection laws;
   - for compliance with legal and regulatory requirements; or
   - to establish or defend our legal rights; or - based on your consent

You have the right to withdraw consent at any time. Where consent is the only legal basis for processing your personal data, we will cease to process your personal data for that purpose after consent is withdrawn.

Our controls

Watches of Switzerland Company Limited is committed to keeping your personal data safe and secure.

Our security measures include:

• encryption of data;
• regular cyber security assessments of all service providers who may handle your personal data;
• regular planning to ensure we are ready to respond to cyber security attacks and data security incidents;
• daily penetration testing of systems;
• security controls which protect the our IT systems infrastructure and our premises from external attack and unauthorised access; and
• internal policies setting out our data security rules for our personnel and
• regular training for our employees.

You should always be cautious when sharing your personal data. No one from our company will ever ask you to confirm any bank account or credit card details via email or text or invite you to transfer money to use by bank transfer. If you receive an email claiming to be from Watches of Switzerland Company Limited asking you to do so, please ignore it and do not respond.

If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.

In addition, we recommend that you take the following security measures to enhance your online safety:

• keep your account passwords private because anyone who knows your password may access your account or be compromised if your account is accessed without authority.
• when creating a password, use a difficult word/number combination of at least 8 characters and something that is not easily guessed by hackers such as dictionary words, your name, email address, or other personal data that can be easily obtained. Also, frequently change your password. You can do this accessing your account, clicking 'your account', clicking 'your data' and selecting 'change password'.
• avoid using the same password for different online accounts.

We will not retain your data for longer than necessary for the purposes set out in this Notice. Different retention periods apply for different types of information, and our Data Retention Policy sets out the length of time we will usually retain personal data and where these default periods might be changed.

In summary, various laws, accounting and regulatory requirements applicable to us require us to retain certain records for specific amounts of time. In relation to your personal data, we will hold this only for so long as we require that personal data for legal or regulatory reasons or for legitimate organisational purposes and we will not keep your data for longer than is necessary for the purposes for which we collect them.

For more detail on typical retention periods, please see below.

Record Retention Periods

Record	Type of Personal Data	Retention Period
Contracts with Suppliers	Names	10 years after expiry
Supplier details	Names,addresses,email addresses, telephone numbers	As long as we are trading
Rental and hire purchase agreements	Names	10 years after expiry
Payment Services agreements	Names	10 years after expiry
Cookies	Webtracking information including IP addresses	5 years
Customer Deposits	Names	As long as we are trading
Contracts with Customers	Names,addresses, telephone numbers, transactional details	10 years from date of transaction
For "By Appointment"	N/A	As long as we are trading
Contracts with Customers - bank transfers	Names, addresses, telephone numbers, bank and branch	14 days
Contracts with Customers - Register of Interest	Names and products	Until Purchase or as long as customer requires
Contracts with Customers - Pre-Owned Watches	Names addresses, age and product	3 years
Contracts with Customers	Email addresses	Website email - 7 years Customer care emails - 3 years Store support emails - 3 years
Customer complaints	Names, addresses, telephone numbers, email addresses	7 years
Interest Free Credit applications	Customer emails, names, addresses, dates of birth, marital status, employment details, financial details such as income and major outgoings, bank account details	14 days
Interest Bearing Credit Applications	Customer emails, names, addresses, dates of birth, marital status, employment details, financial details such as income and major outgoings, bank account details	14 days
Promotional Materials	Names and Customer images	3 years
Customer listings for Promotional communications	Names and Addresses, email addresses	30 days
Marketing Databases	Names and Addresses, email addresses	15 years
Social Media communications	Names, addresses, email addresses, transactional data, hobbies, interests, payment reference	As long as we are trading
Product and Service Reviews by Customers	Names, emails and products services purchased	Personal Data: 12 months
Review Content	N/A	As long as we are trading
Records of Administration of Watch and Jewellery insurance Claims for Insurance Companies	Names, addresses, telephone numbers, email addresses, insurance policy number, item claimed for, call recordings, bank sort code details	As long as we are trading
Mappin & Webb Care, Goldsmiths Care and Watches of Switzerland Protection	Names, addresses, telephone numbers, email addresses, insurance policy number, item claimed for, call recordings	As long as we are trading
Call recordings	Telephone numbers, call recordings	28 days
Repair Records with Watches of Switzerland, Goldsmiths and Mappin & Webb	Names, addresses and watch and damage/repair details, watch photo, contact details, repair reference number and guarantee number	As long as we are trading
Customer Live Chat Forum	Voice recordings images and messaging	3 years
CCTV	Images of Attendees at our premises	As long as required for security purposes
Visitor Records	Names and Images of Attendees at our premises	As long as required for security purposes
Automatic Number Plate Recognition System	Vehicle Registration Plates of Visitors, suppliers and other attendees at our HQ	As long as required for security purposes

To deliver products and services to you, it is sometimes necessary to share your personal information outside of the European Economic Area (the EEA). This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.

If we transfer your personal information outside the EEA, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to assess the laws and practises of the destination country and relevant service provider and the security measures that are to be taken as regards the data in the overseas location; Alternatively, we use standard Government approved model contractual data protection clauses in our contracts with our processors..

You have the following rights:

• The right to be informed about our processing of your personal data which is the aim of this Notice;
• The right to access – You have the right to request Our Company for copies of your personal data. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.
• The right to erasure – You have the right to request that Our Company erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions.;
• The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you wish to exercise any of the above rights, you can always:

1. call our Customer Relations Team on telephone 0800 085 8250 but we will ask you to put your request in writing
2. email us at either customer.relations@thewosgroup.com or dpo@thewosgroup.com or
3. contact us by post to either Customer Relations or the Data Protection Officer, Watches of Switzerland Company Limited, Aurum House, 2, Elland Road, Braunstone, Leicester LE3 1TT, United Kingdom.

You have the right to lodge a complaint with the Information Commissioner's Office at Wycliffe House, Water Lane, Wilmslow SK9 5AF, United Kingdom if you believe we have not handled your personal data in accordance with the law. Further information, including contact details, is available at https://ico.org.uk.