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OUR APPROACH
This Privacy Policy (the “Policy”) sets out how Watches of Mayfair Limited(further referred to as “we”, “our” or “us”) process the personal data of our website visitors and customers in the European Union (“User”).
If you have any questions about this Policy, please contact our data privacy manager (“DPM”) at info@watchesofmayfair.com.
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WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND HOW DO WE COLLECT IT?
Personal data or personal information means any information relating to a person who can be identified either directly or indirectly; it may include name, address, email address, phone number, credit / debit card number, IP address, location data and purchase history (“Personal Data”). It does not include data where the identity has been removed (anonymous data). .
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, marital status/salutation, username or similar identifier, title, date of birth, gender, photograph and nationality.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.
We collect your Personal Data when you give it to us by filling in forms and questionnaires on our website or corresponding with us in-store, on the website, by phone, post or email. As you interact with our website, we may also collect Technical Data about how you use our website and interact with us. We collect this data by using cookies and other similar technologies including analytics providers such as Google who are based outside Hong Kong.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
FAILURE TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel a product order that you have with us, but we will notify you if this is the case at the time.
PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
We will only process your Personal Data in accordance with applicable law, for the following purposes:
- creating and maintaining your Customer account if you become our registered Customer;
- offering our goods and providing our services to you in a personalised way, where legally permitted, for example, we may provide suggestions based on your previous searches to enable you to identify suitable goods and services quicker. This may also include, where legally permitted, processing data related to your location;
- handling and fulfilling your orders and booking requests if you request goods or services from us. This may also include processing information that we receive from third parties, for example, address data to verify your correct address;
- obtaining payment from you if you purchase any of our goods and/or services;
- enabling our suppliers and service providers to carry out certain functions on our behalf, including payment processing, verification, technical, logistical or other functions as may be required in order to fulfil your orders;
- resolving any returns, refunds or disputes and processing VAT refunds if you lawfully exercise your rights or if you wish to dispute any part of our offering;
- sending you personalised marketing communications, where you have agreed that we may do so in order to keep you informed of our and our selected partner’s products and services, which we consider may be of interest to you. You can ask us to stop sending you marketing messages at any time by contacting us at marketing@watchesofmayfair.com;
- serving personalised advertising to your devices, delivering ads based on your interests ascertained from your past searches, visits of subpages and purchases on our websites, and other data obtained through the use of "cookies" placed on your devices. Please see our Cookie Statement;
- ensuring the security of your account and our business, preventing or detecting fraud or abuses of our website, for example, by requesting verification information in order to reset your account password;
- developing and improving our products and services, for example, by reviewing visits to our website and its various subpages, demand for specific goods and services and User comments; and
- to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.
Your consent, as the Data Subject, to the processing as specified in this Policy is the primary legal ground for our processing of your Personal Data. However, there may be circumstances where we may also rely on other valid legal grounds for the processing of your Personal Data, such as: your request for content, goods or services necessitating steps including processing of your Personal Data to be taken prior to entering into contract with you and any processing that is necessary for the performance of such contract; and legitimate interests pursued by us as a business, except where such interests are overridden by your interests and fundamental rights. We will rely on this legal ground in relation to the processing set out in paragraphs 3(i) and 3(j), in which we have a legitimate interest; and in compliance with a legal obligation to which we are subject, such as, for example, the processing for the purposes set out in paragraph 3(k). Please contact us if you need details about the specific legal ground that we are relying on to process your Personal Data.
We will only use your Personal Data for the purposes for which we originally collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF CUSTOMER INFORMATION
There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:
- to our subsidiaries, branches or associated offices;
- to our outsourced service providers or suppliers to facilitate the provision of our services or goods to our Users, for example, the disclosure to our payment and logistics service providers to ensure your orders are successfully processed and delivered;
- to our advertising partners who enable us to deliver personalised ads to your devices or similar advertising if you have made a purchase with us and you have not opted out of receiving personalised advertising;
- subject to your express opt-in consent, to our marketing partners, who may contact you by post, email, telephone, SMS or by other means. If you do not wish to be contacted, you may unsubscribe by sending an e-mail to marketing@watchesofmayfair.com;
- to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
- to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Data will be permanently transferred to a successor company and the new owners may use your Personal Data in the same way as set out in this privacy policy;
- to public authorities where we are required by law to do so; and
- to any other third party where you have provided your consent.
You can ask us or third parties to stop sending you marketing messages or personalised advertising at any time by logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the relevant opt-out links on any marketing message sent to you. Where you opt out of receiving marketing messages, this will not apply to Personal Data provided to us as a result of product purchase, warranty registration or product experience.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the applicable law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFER OF PERSONAL DATA
We may transfer your Personal Data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out in paragraph 3 above. In particular, your Personal Data may be transferred throughout the Watches of Mayfair group and to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisational, contractual or other lawful means.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
RETENTION OF PERSONAL DATA
Your Personal Data will be retained until your last use or purchase of our services or goods and normally for a period of six years thereafter, unless longer retention is required by applicable local law or where we have a legitimate and lawful purpose to do so. In some circumstances you can ask us to delete your data (see “Data Subject Rights"). We will not retain any of your Personal Data beyond this period if it is no longer required for the purposes set out in this Policy. We may retain your personal data for a longer period in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
The retention of your Personal Data will be subject to periodic review. We may keep an anonymised form of your Personal Data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
DATA SUBJECT RIGHTS
Data protection law provides Data Subjects with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, their Personal Data. Data Subjects also have the right to lodge a complaint with the relevant data protection authority if they believe that their Personal Data is not being processed in accordance with applicable data protection law.
- Right to make subject access request (SAR). Data Subjects may, where permitted by applicable law, request copies of their Personal Data. If you would like to make a SAR, i.e., a request for copies of the Personal Data we hold about you, you may do so by writing to the DPM at info@watchesofmayfair.com. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and pay a fee.
- Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete Personal Data though we may need to verify the accuracy of the new data you provide to us.
- Right to request restriction of processing. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
- - if you want us to establish the data's accuracy;
- - where our use of the data is unlawful, but you do not want us to erase it;
- - where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- - where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your Personal Data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your Personal Data is essential.
- Right to object to processing. You may, as permitted by applicable law, request that we stop processing your Personal Data
- Right to erasure. You may request that we erase your Personal Data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your Personal Data, such as a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.
- Right to data portability. In certain circumstances, you may request that we provide your Personal Data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services. We will comply with such transfer as far as it is technically feasible. Please note that a transfer to another provider does not imply erasure of your Personal Data which may still be required for legitimate and lawful purposes.
- Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your Personal Data.
- If you wish to exercise any of the rights set out above, please contact us at info@watchesofmayfair.com.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CHILDREN
Please note that this website is not intended for children under the age of 13 and we do not knowingly collect data relating to children.
LINKED WEBSITES
Please note that any websites that may be linked to our websites are subject to their own privacy policy.