Last updated: December 2024

About Enquirus

Richemont International SA (“Richemont”, “we”, “us” and “our”) has its registered offices at Route des Biches 10, 1752 Villars-sur-Glâne, Switzerland. This is considered to be the “data controller” for the purposes of certain data protection laws and regulations.

Our Privacy Commitments

Our Privacy Policy is centred around the following three privacy commitments:

Commitment 1: Transparency & Trust - Privacy is built into Enquirus by design and by default. We respect the trust you place in us with your personal information. We will be fully transparent with you regarding the purposes for which we use your personal information and will only use it for those specified purposes when we have a right to do so. This will include, where necessary, obtaining your explicit consent. Any material changes to how we process your personal information will be notified to you.

Commitment 2: Protecting Your Personal information - We commit to implementing leading data protection, privacy and security standards so that you feel comfortable that your personal information is protected – if there is an incident impacting your personal information, we commit to notifying you and/or relevant regulators in accordance with data breach notification requirements. Your personal information will be handled with the same protection when it is shared with third parties or when it is transferred internationally. We will only retain your personal information for as long as is necessary or for as long as required by law.

Commitment 3: Respecting Your Rights - We will respect the choices you make in relation to your personal information. We will respect the legal rights you have in relation to accessing, erasing and updating the personal information that we hold about you. We will also respect the choices you make in relation to objecting to how we process your personal information and will provide channels for you to contact us with questions or complaints.

This Privacy Policy & Updates

Please take a moment to read the following policy as well as our Cookie Policy that explains how we collect, use, disclose and transfer the personal information collected about you at any touchpoint, including on our websites, mobile applications and other digital platforms relating to a lost and stolen database (together referred to as the “Enquirus”). Our Cookie Policy explains how we collect information through the use of cookies and related technologies when you use Enquirus.

From time to time we may update this Privacy Policy. When we do, we will publish the changes on Enquirus.

General Data Protection Regulation Representative

For the purpose of the General Data Protection Regulation in the European Union, we have appointed the following entity as our legal representative:

Data Protection & Privacy Team

RLG EUROPE B.V.

Herengracht 436

1017BZ Amsterdam

The Netherlands

For general questions, please see “Contact us” below.

Commitment 1: Transparency & Trust

Information that you provide to us or we collect about you

We collect the following personal information about you as detailed below:

General personal & user account information: To benefit from our Enquirus services, you may need to provide your contact details or create an account with us. You may provide personal information about yourself, including name and address, date of birth, e-mail address, telephone number, nationality and gender. Your account will store information about yourself and details of your watch(es) and/or piece(s) of jewellery and any conversation history. You may also provide us documents that contain personal information including your warranty card / invoice, proof of purchase, photographs of your watch(es)and/or piece(s) of jewellery, proof of ownership, insurance details, police report and date of theft to the extent that your watch or piece of jewellery is reported as lost or stolen

Correspondence, call recordings, online or video chat: We collect personal information from you when you correspond with us (for example, if you contact us with a query about Enquirus), when you provide your details when you contact us by contact form or otherwise participate in phone, online or video chat. Please note that phone calls, online or video chat or other correspondence will on occasion be recorded for security, evidence, training, quality control, analysis and development purposes.

Social media platforms data: If you choose to interact with us via a social media platform or other third party service, we will collect the information you have provided to us through that platform, which may include behavioural data such as your browsing records and purchase history on that platform. In addition, you may grant us access to certain data from your social media profiles for social log-in purposes.

Cookie data: We also collect certain information automatically about visitors to Enquirus, described in our Cookie Policy. This may include data relating to advertising IDs, pixel tags or your unique online personal identifier.

Location data: We will collect information about your location to the extent that we provide any location services.

Use of Enquirus: Allow prospective purchasers, law enforcement agencies or insurers to check the status of a watch or piece of jewellery to confirm whether it is on Enquirus;

Surveys and market research: We carry out surveys and market research and we will collect your response data.

Information you provide about third parties: You may provide personal information about a third party (such as your partner or child), including name and address, date of birth, e-mail address, telephone number, marital status, wish list, hobbies and preferences.

Information we collect from third parties about you: We also may collect any of the above information about you from third parties, social media platforms, advertising and marketing partners, analytics providers, and third parties that provide technical or strategic data services to us and we may collate such information with other information that we have. We may also collect personal information about you from publicly-available sources.

Purposes of processing and our legal justification for processing

We may process your personal information for the purposes listed below on the basis of the following justifications:

Consent: this is the legal basis when you have given clear consent for us to process your personal information (for example, where you consent to receiving marketing information).

Performance of a contract: the processing is necessary for a contract we are entering into with you (including compliance with our Terms of Use), or because we have asked you to take specific steps before entering into a contract.

Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party (for example, for the running of our business, protecting against fraud, or Platform security), unless there is a good reason to protect your personal information which overrides those legitimate interests.

Legal obligation: the processing is necessary for us to comply with the law (for example, a court order).

Other grounds: the processing may on occasion be necessary for other legal reasons such as to prevent and detect crime, to protect life or the processing is otherwise in the public interest.

The purposes of processing and justifications are as follows:

Service-related processing: We process your personal information for service-related purposes, including operation of Enquirus and use of Enquirus tools, service communications, updates, announcements and administrative messages, such as changes to your account as well as to notify you about changes to our terms or privacy policy. Our primary justification is for the performance of a contract but we may also rely on legitimate interests (for example, to ensure you are content with Enquirus and that we are providing Enquirus to you in a secure, effective and efficient manner), legal obligation or consent.

Marketing-related communications and digital advertising:

We process your personal information for marketing-related purposes, including sending you marketing communications (including by telephone, e-mail, post and electronic or text messages, and delivering personalised messages or advertising on social media or other digital platforms) relating to us and other third party partners that we think may be of interest to you. We may also share your personal information (such as your e-mail address, usually in an encrypted or ‘hashed’ form, or specific cookie data) with social media and other platforms or other service providers for the purposes of custom audience or lookalike matching, or intra-group client/prospect matching for marketing purposes – our primary justification for marketing-related communications and digital advertising processing is either

consent

or

legitimate interests

(for example, to recommend certain products to you). Where we rely on

consent, you may withdraw your consent at any time by e-mailing the address below in the section headed “Contact us” or clicking on the ‘unsubscribe’ link in any marketing e-mails or text messages. Where we request your consent at multiple touchpoints (for example, in-store or on the Platforms) and at different times, any consent collected will remain valid unless you expressly opt-out.

Accounts & records: We process your personal information for the purposes of managing our accounts and records – our primary justification is for the performance of a contract but we may also rely on consent, legitimate interests (for example, to prevent fraud) or legal obligation.

Enquiries: We process your personal information for the purposes of dealing with your enquiries and requests, and offering our services to you – our primary justification is for the performance of a contract but we may also rely on legitimate interests (for example, to respond to your queries in an effective manner) or consent.

Market research, analysis of feedback and user engagement: We process your personal information for the purposes of conducting market research (including surveys) and analysis and improve consumer engagement as a result of user feedback, comments, preferences and general use of Enquirus so that we can continuously improve our offerings and the services we provide to our user – our primary justification is legitimate interests (for example, to improve Enquirus) but we may also rely on consent.

Location services: We process your personal information for the purposes of providing you with location-based services when we are able to use information about your location. For these services, which are typically available on mobile devices or applications, you are provided with the opportunity to provide your consent to the use of location services, which, for example, process information deriving from GPS, sensors, beacons or Wi-Fi access points in order to allow you to benefit from a more personalised service. Your device will have settings that allow you to turn off these services should you no longer wish to benefit from them – our primary justification is consent.

Platform support, maintenance and security: We process your personal information in connection with administering and protecting our business and the Enquirus (including troubleshooting, dealing with error messages, data analysis, testing, system maintenance, support, reporting and hosting of data) – our primary justification is legitimate interests (for example, to ensure Enquirus runs effectively and securely) but we may also rely on legal obligation or consent.

Receipt of products and services from suppliers: We process your personal information for the purposes of benefiting from any products or services provided by you or your organisation, where you are, or your organisation is, a supplier – our primary justification is performance of a contract but we may also rely on legitimate interests (for example, to receive services) or consent.

Business administration and legal compliance: We process your personal information for the purposes of the administration of our business or to comply with our legal obligations – our primary justification is legal obligation but we may also rely on legitimate interests (for example, to maintain our records) or consent.

Enable a corporate transaction such as a merger or acquisition: We process your personal information for the purposes of any merger or acquisition activity and we will disclose your personal information to any third party that purchases, or to which we transfer, all or substantially all of our assets and business – our primary justification is legitimate interests (for example, to facilitate discussions with third party stakeholders) but we may also rely on legal obligation or consent.

Cookie and other automated technologies: We process your personal information in accordance with our Cookie Policy – our primary justification is consent, performance of a contract and legitimate interests (for example, where cookies are strictly necessary).

Material changes

Where we materially change the way in which we process your personal information, or if we plan to use your personal information for a new purpose not set out in the section above, we will take the appropriate measures required under applicable law, such as to notify you by e-mail or other suitable means.

Our Cookie Policy

This website uses cookies according to our Cookie Policy. This Cookie Policy is available to users on each page of the website linked to this Privacy Policy and on each information banner regarding cookies.

Commitment 2: Protecting Your Personal Information

Protecting your personal information

We want you to feel confident about sharing your personal information with us, and we are committed to protecting the personal information we collect by implementing leading data protection, privacy and security standards. We limit access to personal information about you to employees who reasonably need access to it, to provide Enquirus to you or in order to do their jobs. We have appropriate technical and organisational physical, electronic, and procedural safeguards to protect the personal information that you provide to us against unauthorised or unlawful processing and against accidental loss, damage or destruction. However, where we ask you to choose a password in order to access certain parts of our Enquirus, you are responsible for selecting a secure password and keeping that password confidential. You should choose a password which you do not use on any other site, and you should not share it with anyone else.

Sharing your personal information

We only share personal information with others when we are permitted by law to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information shared and to comply with our data protection, confidentiality and security standards and obligations. We share your personal information with third parties in the following circumstances:

Our affiliated group companies: We may share your personal information with our affiliated group companies for the purposes specified above, where we are permitted by law to do so (including where we have a lawful basis to do so).

Service providers (including data processors): We will disclose your personal information to our appointed third party service providers (which may process your personal information as data processors on our behalf), in order for us to use your personal information for the purposes specified in this Privacy Policy.

Police disclosures. We will disclose crime reference numbers and police reports to law enforcement and police authorities (both nationally and internationally) in order to allow them to process your information in connection with your stolen watch or piece of jewellery and for their own purposes, including verifying authenticity of the police reports. Please note that these third parties will become independent data controllers of your personal data and their processing of your personal data will be subject to the terms of their own privacy policy.

Regulatory, authority and other third party disclosures: We will disclose your personal information to any law enforcement agency, court, police, regulator, government authority or any other third party, including a relevant financial institution, where we believe this is necessary to comply with a legal or regulatory obligation, to protect our rights or the rights of any third party, or where it is otherwise in the public interest or our legitimate interests or those of a third party (for example to respond to a request from a third party to disclose personal information to investigate an alleged crime, to check that we are complying with applicable law and regulations, or to establish, exercise or defend legal rights).

Mergers & acquisitions: We will disclose your personal information to any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Policy.

Transferring your personal information globally

If the country we transfer your personal information to does not provide an adequate level of data protection, we have implemented standard contractual clauses to ensure adequate safeguards are in place to protect your personal information where it is transferred to our affiliated companies, boutiques or third party service providers in territories outside the European Economic Area, the United Kingdom and Switzerland. While other territories may not have the same standards of data protection as those within your home country, we will continue to protect the personal information we transfer in accordance with this Privacy Policy.

Privacy risk assessments

We may periodically conduct risk assessments related to the processing of your personal information, especially when introducing new technologies or functionalities. In certain circumstances, these new technologies or functionalities may require us to provide enhanced privacy notices and/or consent forms to ensure that we continue to meet our privacy commitments towards you.

Retaining your personal information

We keep your personal information only for as long as is necessary for our purposes of processing, and in particular to protect ourselves in the event of a legal claim (for example, information relating to a contract with you will be kept for the lifetime of the contract and up to ten years after) as well as necessary to comply with statutory retention obligations. After this period it will be deleted or in some cases anonymised. Where we have your consent to process your personal information and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent we will delete your personal information.

If you request that we no longer send you direct marketing communications or you exercise your right to be forgotten, we will keep a record of your request and contact details to ensure that your request is respected.

Commitment 3: Respecting your rights

We commit to respecting your rights. If you wish to exercise any of the rights set out below, which are available to you under applicable law, please write to us at the address listed below.

Right of access

You have the right to ask for access to any personal information that is being processed by us.

Right to erasure / restriction of processing

In some circumstances, you have the right to request the erasure of your personal information or to restrict how we use it.

Right to update or correct

You have the right to ask us to correct any inaccurate personal information and to update any out-of-date personal information.

Right to object

You have in certain circumstances the right to object, on grounds relating to your particular situation, at any time to the processing of personal information concerning you which is carried out on the basis of legitimate interests or in the public interest.

Furthermore, you have the right to object where your personal information is processed for direct marketing purposes.

Right to data portability

In some circumstances, you have the right to request from us the personal information concerning you that you have provided to us in a structured, commonly used, machine-readable format.

Right to withdraw consent

If you have given us consent to process your personal information, you can withdraw this consent at any time with effect for the future. The withdrawal does not affect the lawfulness of the processing carried out on the basis of this consent until the withdrawal.

Right to complain

If you have a concern about how we use your personal information, as a first step please contact us using the details set out below and we will do our best to resolve your concern. After investigating your concern, we will respond to you in writing within a reasonable time setting out our proposed remedial action.

If you think we have processed your personal information in a manner that is unlawful or breaches your rights, you also have the right to complain to a relevant data protection authority, for example in your place of residence, or the jurisdiction in which the processing took place.

Right to object to advertising using e-mail

In the event that we have obtained your e-mail address in connection with the sale of a product and/or service and use your e-mail address for direct advertising of our own similar products and/or services, you may object to such use of your e-mail address at any time with effect for the future by e-mailing the address below in the section headed “Contact us” or clicking the ‘unsubscribe’ link in any of our marketing e-mails.

However, please note that we may continue to send you service-related (i.e. non-marketing) communications, such as e-mail updates on your account.

Children

Enquirus are not directed at anyone who we know to be a child in the relevant country of data collection (for example, in the US this is under 13 and in certain European countries this is under 16), nor do we collect any personal information from anyone who we know to be a child unless we have parental or guardian consent. Children should not use Enquirus and should not submit any personal information to us without parental or guardian consent.

Contact us

If you have any questions, comments or complaints about this Privacy Policy or Cookie Policy, or privacy matters generally, please contact us at the address provided below. You can also use this address if you wish to request access to the personal information about you that we process or to unsubscribe from any further e-mail marketing communications: contact@info.enquirus.com

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