1. About this Privacy Notice
1.1. This is the privacy notice (“Notice”) of The Swatch Group (UK) Limited, Division TISSOT, Building 1000, The Royals Business Park, London E16 2QU, United Kingdom (“SG UK”, “we", “us”, “our”). SG UK is the data controller for the purpose of this Notice.
1.2. This Notice sets out the basis on which we will process any personal data obtained from and about you.
1.3. We may change this Notice at any time. Should we have the right to contact you and should the changes significantly affect you, then we may communicate them to you by the means appropriate and accepted by you.
1.4. The Notice currently in place dates of 1 July 2018.
2. What personal data do we collect from you?
2.1. We collect personal data, that you provide to us, such as by filling out a form, leaving a business card, registering your watch, subscribing to an event, making a reservation or appointment, and personal data that we are provided by third parties, including without limitation, by tour guides or tour operators, which may consist of:
2.1.1. contact information (such as name, postal address, email address, and mobile or other telephone number);
2.1.2. passport data (such as passport number, date/place of issue or date of birth);
2.1.3. purchase and transaction information;
2.1.4. payment information (such as your payment card number, expiration date, authorization number or security code, delivery address, and billing address);
2.1.5. customer service information (such as customer service inquiries, comments, and repair history);
2.1.6. information regarding your personal or professional interests, date of birth, marital status, demographics, and experiences with our products and contact preferences;
2.1.7. comments and other content you provide; and
2.1.8. other information we may obtain from our third-party service providers.
3. On which basis do we process your personal data?
3.1. We process your personal data for the purposes indicated or obvious at the time of collection and
3.1.1. to which you have agreed, for example by signing a form; or
3.1.2. for which we are required by applicable laws, for example to comply with data retention requirements regarding data relevant for financial reporting; or
3.1.3. which is necessary for the performance of a contract, for example if you purchase items in our stores; or
3.1.4. for which we rely on other legitimate interests, which include:
- gathering market intelligence, promoting products and services, communicating with and tailoring offers to individual customers;
- delivering and improving our products or services;
- management of customer, client, vendor and other relationships, sharing intelligence with internal stakeholders, implementing safety procedures, and planning and allocate resources and budget;
- monitoring, detecting and protecting the organisation, its systems, network, infrastructure, computers, information, intellectual property and other rights from unwanted security intrusion, unauthorised access, disclosure and acquisition of information, data and system breaches, hacking, industrial espionage and cyberattacks;
- protecting and developing industry standards; sharing intelligence about individuals or concerns that may have a negative or detrimental impact; and following industry best practices; or
- complying with industry standards, regulators’ requirements and other requirements related to fraud prevention and anti-money laundering.
4. For which purposes do we process your personal data?
4.1. We process your personal data for the following purposes:
4.1.1. If you fill out a form, make a reservation or appointment, register your watch, leave a business card, providing your name, email-address, telephone number, preferences, etc., we use your data for answering your questions, sending you information or performing other tasks you ask us to.
4.1.2. If you are an existing customer, we may send you advertisement about our products and services using, for example, your name and postal address.
4.1.3. If you subscribe to a service like our newsletter by providing us with your email-address and name, then we use this data for sending you our newsletter.
4.1.4. If you join an organized travel tour that includes visiting points of sale, operated by us, where the tour operator or tour guide shares your personal data with us, then we process this data for fraud prevention, calculating and paying the commission and for accounting and financial reporting.
4.1.5. If you participate in a marketing promotion, then we use the data we require from you to allow your participation, for example, to manage your invitation for an event or to determine and contact the winner of a contest.
4.1.6. If you order or purchase a product, material or a service, we need and process the data required to fulfill your order, such as your name, telephone number, delivery address, credit card information, email-address, etc., for example to confirm your order, process your payment, check credit scoring, deliver the ordered items and contact you for delivery purposes.
4.1.7. If you consent to receive marketing information, then we use your data to send you promotional materials and other communications, to communicate with you about, and administer your participation in, special events, contests, sweepstakes, programs, offers, surveys and market research, to provide advertisements to you about our products and services, marketing experience, and communications according to your preferences and our terms
4.1.8. We process your personal data also to comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.
4.2. We may process your personal data in a centralized system that allows enhancing your brand experience by tailoring our communication and marketing efforts to make them as relevant and useful as possible for you (direct marketing profiling). For this we may process, match and enrich your personal data with data received from your interaction with us or from third parties. For example, if you tell us your age, income, hobbies or travel activities then we may mirror this data against your purchase behavior and other information we have obtained from you in order to approach you with offers, invitations or promotions that we believe specifically fit your interests.
5. To whom do we disclose and transfer your personal data?
5.1. We may disclose your personal data to the following recipients or categories of recipients for them to use the data on their own behalf and under their own control (joint controllers):
5.1.1. Our parent company The Swatch Group Ltd, Seevorstadt 6, 2501 Biel/Bienne, Switzerland (“Swatch Group”);
5.1.2. The brand headquarters of the brand you are interacting with at the time of data collection which is Tissot S.A., Chemin des Tourelles 17, 2400 Le Locle, Switzerland (“Brand HQ”);
5.1.3. Our affiliates within Swatch Group of companies in the countries where the brand is represented as indicated when we collect your personal data.
5.2. We may disclose your personal data to the following recipients or categories of recipients acting on our behalf and/or as partners (processors), limited to the purpose of the execution of their obligations, which are contractually bound to adhere to an adequate level of data protection when processing your personal data (for example to fulfil orders, deliver packages, process credit card payments, provide customer service, send postal mail and e-mail, store and process data, host websites, remove repetitive data from customer lists, analyse data, provide marketing assistance, execute customer satisfaction surveys, provide customized advertising):
5.2.1. Swatch Group;
5.2.2. Brand HQ;
5.2.3. Our data processing center in Switzerland;
5.2.4. Our affiliates within Swatch Group of companies;
5.2.5. Our third party service providers.
5.3. We may disclose your personal data to an acquirer if SG UK or substantially all of its assets or Swatch Group or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
5.5. We may internationally transfer your personal data, including to countries that are not considered providing an adequate level of data protection by the relevant regulatory bodies, for example to countries not considered by the European Commission to be providing such level. In such case, we ensure the adequate protection of your personal data by having the recipients adhere to binding contractual obligations in accordance with applicable standards approved by the relevant regulatory bodies or by relying on other safeguards, such as self-certifications, approved by the relevant regulatory bodies. You may contact us for a copy of the contractual and other safeguards in place (see section 10 below).
6. For how long do we process your personal data?
6.1. We may store your personal data on our servers and the servers of the recipients for as long as you have consented to it, implicitly or explicitly, or legitimate interests allow us, or laws require us (for example legal retention obligations based on bookkeeping or tax laws and regulations), and we are therefore allowed to process it for the purposes indicated or obvious at the time of collection, plus three years thereafter.
7. When do we require your personal data?
7.1. If you wish to conclude a contract with us, for example if you order products or services from us on our Website, then we are required to obtain from you certain personal data to allow us to enter into this contract, for example, your name, delivery address, place of residence, payment information or contact information. Should you decide not to provide us the required information, we may not conclude this contract with you.
8. What are your rights?
8.1. You have the right:
- to request from us access to and rectification or deletion of your personal data;
- to request us to restrict the processing of your personal data, in particular to object to the processing of your personal data for direct marketing purposes; and
- to request from us to provide you or any person or entity you appointed with a digital file of your personal data (data portability).
8.2. You may withdraw your consent that allows us to process your personal data for the indicated purposes at any time.
8.3. To exercise the above rights, you may contact us as indicated below.
8.4. You also have the right to lodge a complaint with the competent authority.
9. How can you contact us?
For any questions or to exercise your rights, you may contact us as follows:
Postal address: The Swatch Group (UK) Limited, Division TISSOT, Building 1000, The Royals Business Park, London E16 2QU, United Kingdom
Telephone number: 0845 899 0100