1. WHO WE ARE AND WHAT IS THIS PRIVACY POLICY

We are the Ineichen Zurich AG (“we”, “us”, “our”), and we are committed to protecting your privacy. Ineichen Zurich AG is the controller for the purposes of the Federal Act on Data Protection (FDAP) or General Data Protection Regulation (the “GDPR”) for EU, a company registered in Switzerland (Company No. CH-020.3.021.681-2), with its registered office located at Stadthausquai 11-13, CH-8001 Zürich (company registration number UID - CHE-101.038.023).

Like most businesses, we hold and process information about our clients and other persons who interact with us or who may be interested in any of the services or goods we offer (together the ‘Services’). This Policy sets out why we collect personal information and how we use that information. It explains the legal basis for this and the rights you have over the way your information is used. Ineichen Zurich AG operates www.ineichen.com and its subdomains (collectively, the "Website").

We are committed to protecting your Personal Information. We respect your privacy rights, and our policy is intended to ensure that your personal information is handled safely and responsibly. We collect, store, and use your Personal Information to comply with applicable laws and regulations.

Being an integral part of the Terms and Conditions, this Privacy Policy complements the Terms and Conditions of using the Website.

By accepting the Terms and Conditions and the Privacy Policy, you enter into an agreement with us, under which we process your Personal Information.

This Privacy Policy sets out the information that we collect, the reasons for which we collect that information, and how we can use and share that information.

Please read this Privacy Policy carefully and make sure that you understand it before using the Website. Please note that by using the Website, you agree to be bound by this Privacy Policy.

The Website and the services provided by Ineichen Zurich AG are not intended to be used by persons under 18 years of age. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, you can contact us at info@ineichen.com.

2. CAN THIS PRIVACY POLICY BE APPLIED TO THIRD PARTY WEBSIDES

Our Website can contain links to and from the websites of the watch retailers and brands, advertisers, and affiliates, amongst others. If you follow a link to any of these websites, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.

3. WHAT INFORMATION DO WE COLLECT, AND HOW

When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:

Information you give us:

You may give us information about yourself if you sign up for an account on our Website, place an order for watches, complete any online forms (such as registration forms, competitions, and surveys), opt in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions with our Website, or correspond with us (by email, telephone, instant chat, social media or otherwise). Depending on what you provide, this information can include your name, address or location, phone number and email address, purchase information, shopping preferences, images and financial information (including your credit or debit card details, although we do not hold them, our payment processors do). If you register an account on the Website, then you may choose to give us your nickname. From your account, you can also invite your friends to shop at our Website (including by email or Facebook). Although we will let them know that we received their details from you, please ensure that you have the permission of your friends before sharing their contact details with us.

Information we receive from other accounts or sources:

We can receive information about you from other sources, such as from your other accounts or other websites, including data brokers, social media providers like Facebook and Twitter, advertising networks and analytics partners, and payment and delivery service providers. By logging in to our mobile applications via Facebook or Google or linking your account on our Website to your Facebook or Twitter accounts, you are giving us permission to obtain certain information and content from these accounts. The specific types of information that we may obtain depends on your settings for that account or website and will be subject to their privacy policies. We supplement the data you provide to us with data from data append services such as public or social graph data to better serve you with content or promotions. We will append this data to our existing customer account information to understand customers’ interests and to provide more relevant product recommendations and advertising, to increase our customer’s security when using our Website and to comply with our legal obligations, such as sanctions laws. This information may include household size, household income, or profession. This information can be associated with your personal information such as name, email, address, physical address, or phone number. You can see more details about the third parties we use in the «WHO DO YOU SHARE MY INFORMATION WITH?» section.

Information our IT systems collect about you:

Each time you visit the Website, certain information will be created and automatically recorded by our IT systems. That information includes: Cookies: you can see more details about cookies below, but these small text files can help improve your experience with the Website and make it easier to interact with us. This may include storing your location or language preferences to save you from having to re-enter information when returning to or ensuring that items you wish to order don’t disappear as you navigate among pages on our Website. We also use cookies to provide you with tailored advertising. Device information: the information provided by your device will differ depending on which type of device you are using (whether it’s a PC, Mac, iPhone, Android, or otherwise) and the settings on that device, but includes the type of device you have (such as an iPhone 11 or Samsung Galaxy S10), the device’s IP address, the browser you are using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.

4. WHAT DO WE USE YOUR INFORMATION FOR

To provide you services and the Website, including to allow you to order and receive watches using our Website, administer your account and to optimize your experience we need to use the information that we collect in a number of different ways.

We use the information for marketing and advertising purposes. When you tell us you would like to receive marketing communications or when you make a purchase using our services, we will use your personal information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing customer information as described below), to tailor these messages to you. You may unsubscribe from our email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt out instructions in the promotional emails that are sent to you.

We use third-party service providers to serve advertisements most relevant to you across your different devices and on our own and others’ websites and mobile applications. In addition to the information about your visits to our website or usage of our mobile application, our service providers may also use the information about your interactions with other websites or applications to target advertisements for Services available from Ineichen Zurich. For information about opting out of targeted advertising and controlling the use of cookies, please see the cookies section of this Privacy Policy.

We also carry out research, analysis, and surveys on your use of our Website, and views. We use your information to confirm your identity and perform credit checks or anti-fraud checks, to ensure your, and our, financial security.

We collect your Personal Information:

To register and manage your account in our Website. We collect your name, email, password, and other additional details you may wish to add in your account, like phone number and addresses. The legal basis is the performance of a Contract with you.

• To fulfil the orders, you make through our website. We collect your name, addresses, phone number, order details, like the watches you are buying, the model and price. The legal basis is the performance of a Contract with you.
• To collect payment from you. We collect your payment information, which comprises the credit/debit card’s number, holder’s name and CVV. To issue an invoice for you, we collect your bank details or your credit card information, or your cryptocurrency wallet information. We do not store this information and only transfer it to our authorized payment providers. The legal basis is the performance of a Contract with you.
• To provide you with our customer services (including helping you to solve any issue you have with our services, updating you about any change to our terms of service, or contacting you to learn about your experience with us). We collect your name, email, password and addresses and your contact history with us (including phone records of our conversations). The legal basis is the performance of a Contract with you and our legitimate interests in retaining you as a customer.
• To monitor the quality of our customer services. We collect your name, email, password and addresses and your contact history with us. The legal basis is the legitimate interests in running our business.
• To administer, maintain and optimize our Website and our services. We collect your device information (such as your device IP address and device type), Cookie identifiers and browsing information. The legal basis is the legitimate interests in running our business.
• To perform fraud and credit checks and if we can do business with you. We collect your name, email, addresses, credit/debit card details, browsing history, purchase history, device information (such as IP address and device type), any national identifiers (like driver’s license or ID cards) and any publicly available information (like social media profiles or news). The legal basis is the legitimate interests to protect Ineichen Zurich and its customers from fraudulent activities and compliance with a legal obligation.
• To send you marketing communications and personalized offer. We collect your name, email, phone number, addresses, purchase history, browsing history and behaviour, device information, shopping preferences, cookie identifiers, internal identifiers, country. The legal basis is the legitimate interests to electronic direct marketing of similar products and services to that which you have acquired using our Website or, when such is not applicable, your Consent.
• To manage our loyalty programs. We collect your name, email, phone number, addresses, purchase history, browsing history and behaviour, device information, shopping preferences, nickname, cookie identifiers, internal identifiers, country, spent tier level and wealth. The legal basis is our legitimate interests in running our business and improve the shopping experience.
• To provide you with personalized recommendations and enhance your experience. We collect your name email, phone number, addresses, purchase history, browsing history and behaviour, device information, shopping preferences, nickname, cookie identifiers, internal identifiers, country spent tier level and wealth. The legal basis is our legitimate interests in running our business and improve our Website and your experience.
• Carry on research, analysis, enquiries, and surveys on your use of our website. We collect your name, addresses, email, device information. The legal basis is our legitimate interests in running our business and improve our Website and your experience.
• Advertising and retarget advertising of our watches. We collect your email, cookie identifiers and device information. The legal basis is our legitimate interests in running our business.
• To produce aggregated statistical reports. We use your order history, provided that the result of such reports does not identify you. The legal basis is our legitimate interests in running our business and improve our Website.

5. WHO DO WE SHARE YOUR INFORMATION WITH

To provide the Website and our services we may share your information with third parties in for following limited reasons:

To function properly, we rely on several carefully selected third parties to provide us with services and products. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products. Below you can find the types of third parties we use:

1. Courier companies, such as https://www.ysds.com/, that we use in order to deliver the watches to you and, as such, they need to have access to your order information, including your name and address. These providers have a global outreach, with many local companies that can be engaged depending on your shipping address.
2. Payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. These are based in Switzerland and are engaged depending on your location.
3. Anti-fraud and credit check providers to keep us and you secure. They have access to and process your information and associated orders to check for any fraudulent behaviour. Our current provider is based in Switzerland.
4. Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimization of the website. These providers are based in the United States and in Europe.
5. Marketing tools providers that help us to enable our marketing, such like Gelfman AG.
6. Performance marketing and recommendations providers that help us deliver advertising and recommendations of our Services tailored to your interests and needs. These providers are based in Europe and in the United States.
7. Research companies that we can engage to help us carry out surveys regarding your use of our Website and Services. These providers are mostly based in Europe or in the United States.
8. IT/technology providers that we use to support, maintain, and provide our technology and IT infrastructure that supports our Website and the storage of your information. These providers are based in Switzerland.
9. Advertisers for marketing purposes: we can provide your information to our advertising and social media partners (including Facebook and Twitter, where you choose) where they require the data to select and serve relevant adverts about our products to you and others.
10. Third parties where we are considering a corporate transaction: Ineichen Zurich AG (www.ineichen.com) is always looking for new opportunities and directions in which to grow. This means sometimes we may consider corporate transactions such as merger, acquisitions, reorganizations, asset sale, or similar. In these instances, we may transfer your information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, your personal information may be one of the assets that are transferred.

To comply with legal requests: we may be required to liaise with various regulators and law enforcement agencies in several different countries, whether because of law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands; and aggregated information with third parties: we may aggregate your information with the information of other customers, creating a dataset of information about the usage of our Website, purchase of watches, and other general, grouped information about our customers on the basis of our legitimate interest to understand the usage of our service and demand for our product. Although this dataset is aggregated and anonymized, meaning it cannot identify you as an individual, it provides a valuable insight into the use of our Website and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies to help measure traffic and other providers to allow them to better stock products, and our investors.

6. HOW IS YOUR DATA TRANSFERRED

To provide our Website and our services, in accordance with the purposes set out above, we may transfer and store the personal information that we collect from you to a destination outside of Switzerland.

When transferring personal information, we rely on the requirements of the applicable law, including Commission’s model contracts for the transfer of personal data to third countries (i.e. the standard contractual clauses) pursuant to Decision 2010/87/EU or Federal Act on Data Protection (FDAP).

Adequacy Decision: We transfer the personal data that we collect from you to conduct fraud checks to Israel, which was found to have an adequate level of protection for personal data under Commission Decision 2011/61/EU of 31 January 2011 or Federal Act on Data Protection (FDAP).

7. WHAT COOKIES DO WE USE

We use technology such as "cookies" to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.

We use the following categories of cookies on our Website:

CATEGORY 1: STRICTLY NECESSARY COOKIES
These cookies are essential to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided.

CATEGORY 2: PERFORMANCE COOKIES
These cookies collect anonymous information on how you use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse, or use our site and highlight areas where we can improve such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. You may opt-in to these cookies using your browser settings.

CATEGORY 3: FUNCTIONALITY COOKIES
These cookies remember choices you make such as the country you visit our website from, language and search parameters such as model, case material or type of bracelet. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites. You may opt-in to these cookies using your browser settings.

CATEGORY 4: TARGETING COOKIES OR ADVERTISING COOKIES
These cookies collect information about your browsing habits to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit, and that information is shared with other parties such as advertisers. For example, we use third party companies to provide you with more personalized adverts when visiting other websites. You may opt-in to these cookies using your browser settings.

CATEGORY 5: SOCIAL MEDIA COOKIES
These cookies allow you to share what you have been doing on the website on social media such as Facebook and Twitter. Please refer to the respective privacy policies for how their cookies work. If you want to delete any cookies that are already on your computer, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website.

You can withdraw your consent to these cookies at any time through the following options:

• Google Analytics cookies across all websites: please visit Google Analytics Opt-out Browser Add-on.
• Other third-party cookies relating to behavioural advertising: please go to www.youronlinechoices.eu.
• Any other type of cookies: you can clean the cookies through your browser settings.

Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.

8. IS YOUR INFORMATION SECURED

Keeping you and your personal information secure is very important to us. We take several reasonable steps to try to protect the personal information that you provide, including:

• Using a Transport Layer Secure (TLS) to encrypt the personal data that you send us during the order process (including any financial information such as credit or debit card details).
• Requiring you to establish a unique username and password to access your account on our Website.
• Not keeping details of your credit or debit card that would enable any third party to transact using that credit or debit card (such as your CVV number).
• Regularly monitoring our servers and IT systems for possible vulnerabilities and attacks.

Unfortunately, despite this, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal data transmitted to or through our Website, and any such transmission is at your own risk. Please keep in mind that if you voluntarily disclose personal information through other means of communication than the Website in a non-protected environment (such as through email, SMS, online messages) then that information can be collected and used by others outside of our or your control.

9. WHAT ARE YOUR PRIVACY RIGHTS

You have certain rights in relation to the personal data we hold about you, which we detail below. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights and that can include asking a set of security questions to ensure it is you. When you have appointed someone else to do the request on your behalf, that person and/or organization needs to show a valid power of attorney issued by you. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at info@ineichen.com or by writing to Data Protection Officer, at Stadthausquai 11-13, CH-8001 Zürich, Switzerland.

Access. You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with (including the categories of personal data we share with businesses for their direct marketing uses and the names and addresses of those businesses). Please note that in “Profile” section you can see information about you, namely your account details (such as name, email, phone number, the addresses you use for billing and shipping, your order history and shopping preferences).

You can also request a copy of your information. If you require more than one copy of the data, we hold about you, we may charge a reasonable administration fee.

We may not provide you with certain personal data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person) or where another exemption applies.

Portability. You have the right to receive a subset of the personal data we collect from you in a structured, commonly used, and machine-readable format and a right to request that we transfer such personal data to another party. The relevant subset of personal data is data that you provide us with your consent or for the purposes of performing our contract with you. If you wish for us to transfer the personal data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the third party. We also may not provide you with certain data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction. You have the right to correct any personal data held about you that is inaccurate. You can edit your personal information in “Profile” settings. You can also request the correction by emailing us. Please note that in some cases we can ask you to explain in detail why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that whilst we assess whether the personal data, we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

Erasure. You may request that we erase the personal data we hold about you in the certain circumstances. Please scroll down to know what those are:

• You believe that it is no longer necessary for us to hold the personal data we hold about you.
• We are processing the personal data we hold about you based on your consent, and you wish to withdraw your consent and there is no other ground under which we can process the personal data.
• We are processing the personal data we hold about you based on our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such personal data.
• You no longer wish us to use the personal data we hold about you to send you promotions and special offers.
• You believe the personal data we hold about you is being unlawfully processed by us.

Also note that you may exercise your right to restrict our processing the data whilst we consider your request as described below.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note, however, that we may retain the personal data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Where you have requested that we erase data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the data or providing links to the data to erase the data too.

Restriction of Processing to Storage Only. You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection). The cases where you may request, we stop processing and just store the personal data we hold about you are:

• You believe the personal data is not accurate for the period it takes for us to verify your claim.
• We wish to erase the personal data as the processing we are doing is unlawful, but you want us to retain the personal data for storage but not further process it.
• We wish to erase the personal data as it is no longer necessary for our purposes, but you require it to be stored for the establishment, exercise, or defence of legal claims.
• You have objected to us processing personal data we hold about you based on our legitimate interest, and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.

Objection. At any time, you have the right to object to our processing of data about you in order to send you promotions and special offers, including where we build profiles for such purposes, and we will stop processing the data for that purpose. You can do so by changing your marketing preferences at “Profile” or by ticking “unsubscribe” at the bottom of each marketing email we send you. Please note that you will still receive emails related with the orders you make through our Website or updates to our Terms & Conditions and Privacy Policy. You also have the right to object to our processing of data about you and we will consider your request in other circumstances as detailed below:

We are processing the data we hold about you (including where the processing is profiling) based on our or a third party’s legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the data whilst we make the assessment on an overriding interest.

Withdrawal of Consent. You can withdraw your consent at any time by changing your marketing preferences in “Profile” or by unsubscribing at the bottom of each email received or by writing emailing us as set out below.

10. WHO CAN I ADDRESS IF I HAVE MORE QUESTIONS OR COMPLAINTS?

If you have any questions or concerns about this Privacy Policy, please contact us:

• by emailing us at info@ineichen.com;
• by writing to the Data Protection Officer, at 11-13, CH-8001 Zürich, Switzerland.

All information regarding the personal data protection in Switzerland is available here.

11. CAN THIS PRIVACY POLICY BE CHANGED?

Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.