Personal data policy
© Hublot 2015
We respect the confidentiality of any personal information that you may provide to us. This personal data policy ("the Policy") applies to the www.hublot.com website (the "Website") and covers the processing of personal data carried out by HUBLOT S.A. (the "Company") which owns and operates the Website. User data will be collected during user visits and according to his/her interaction with the services and features offered on the Website. The Policy was drafted in compliance with the provisions of the Swiss personal data protection act (the "DPA"). The Policy states below the identity of the party responsible for processing (the "Party Responsible for Processing") who controls and manages the personal data collected and processed through this Website, the objectives of the processing and its conditions, the scope of communication of personal data to third parties, the data protection measures taken to protect and save data, and how the user can check the processing of their data and enforce his/her rights pursuant to the DPA.
Party Responsible for Processing [and subcontractor: if applicable]
The Party Responsible for Processing is HUBLOT S.A.
Nature of the Data Processed and Processing Objectives
Generally speaking, the simple fact of visiting the Website does not imply the collection and processing of the user's personal data.
The Company collects and processes personal data voluntarily communicated by the user when he/she subscribes to the activities offered by the Website, registers for the Website, requests information about the Company or asks a question.
When provided by the DPA, the Company will request the consent of the user prior to the processing of his/her data. With his/her consent, the Company may process the user's personal data for marketing purposes, and may be sent promotional information and information about the Company's products, such as price, promotions, special events, exhibitions and fairs organized by the Company or in which it participates by email, SMS and MMS. The user can simply withdraw his/her consent at any time and free of charge regarding the processing of his/her data for marketing purposes. In each exchange with the user, a specific tab will specify the consent withdrawal procedure. The personal data collected by the Company is mainly processed via automatic electronic procedures pursuant to the processing objectives noted above, but also via non-electronic procedures for the duration strictly necessary to fulfill the processing objective in question and pursuant to applicable law.
Data Retention Site
Personal data collected will be retained and processed via an electronic system managed by the Company, located on the premises of the Company as indicated above. Moreover, the Company may provide technical management and maintenance services for the Website. Other companies belonging to the group may participate in the processing of data as part of the functioning of the Website and the provision of services and features offered by the Website. The user is invited to read the section of this Policy entitled "Methods of Communicating Personal Data".
Personal Data Security and Quality
The Company undertakes to protect the security of the user's personal data. Personal data is processed by the Company pursuant to the security provisions provided by applicable law in order to prevent the loss and destruction, even accidental, of data, unauthorized access to the data, and illicit or dishonest use of the data. Moreover, the information systems and software are configured so that the personal and identifying data is only used if necessary for the processing objectives in question. The Company deploys all advanced security procedures and technology to help protect the user's personal data against the risks described above.
The user must put forth his/her best effort to help the Company to keep updated and maintain the accuracy of the personal data that he/she communicates to the Company by notifying it of any change in his/her address, title, telephone number or email address. The registered user may carry out these operations online by following the instructions appearing on his/her profile pages of the Website.
Scope of Data Communication
In all cases where the Company communicates the user's personal data to a third party for the purposes of managing customer relations, the Company will implement, pursuant to applicable law, the appropriate security measures to guarantee users an adequate level of protection for the personal data concerning him/her. The Company shall communicate the user's personal data within the limits and circumstances provided under this Policy and, if applicable, in the information note published on the parts of the Website that collect data. In any case, the communication of data is completed pursuant to the consent given by the user when his/her data is collected, when the DPA so stipulates. The user's personal data will be accessible to in-house and external Company personnel needing to access it as part of his/her job in connection with the processing objectives specified herein, and by the Company's subcontractors if applicable. The user's personal data may be communicated to professionals, independent consultants, including collaborators,commercial partners and third party service providers that the Company may hire to provide professional, technical and organizational services as part of the management of the Website and the activities associated thereto.
Users' personal data may also be communicated to other Companies belonging to the Group that will process the data pursuant to the applicable legal provisions, and to third parties in the event of merger, acquisitions, capital, product, site or operations transfers or any other similar transaction. Third parties will only communicate the data necessary for the performance of the services for which they are responsible. They undertake to only use the data received for the purposes provided and to ensure security and confidentiality. With the exception of the foregoing, the user's personal data shall not be shared with third parties, individuals or legal entities that are not concerned with or that do not carry out any commercial, professional or technical function for the Company. The user's personal data may also be communicated to any person
who is the legitimate recipient of communications, pursuant to the applicable laws and regulations, for example, in the case of legal proceedings, requests made by the courts and competent authorities or any legal obligation, under the protection and defense of the Company's and the Website's rights and assets.
Disclosure of Personal Data
With the exception of the foregoing concerning browsing data, the disclosure of personal data by the user is necessary for the provision of the services and features offered by the Website and that the user requests, for example, the registration of the user with the Website, the management of products purchased by the user via the Website and related activities, the interaction of the user with the call center and the communication to the Company of information allowing it to respond to its information delivery requests. In the aforementioned cases, the refusal of the user to communicate its personal data will prevent the Company from respecting its contractual obligations or providing the user with the services, products or information requested as specified above. The communication by the user of his/her personal data for marketing purposes is optional. The user's refusal to disclose personal data under these circumstances shall have no consequences.
At any time, the user may exercise his/her rights provided by the DPA, including the right to obtain confirmation that the personal data concerning him/her was collected, to verify its content, origin and accuracy and request its addition, update, modification, deletion, anonymization or blocking in compliance with the law. The user may only oppose the processing of data for legitimate reasons. To exercise his/her rights under the DPA and for any question concerning the processing of personal data by the Company, the user may contact the Company as follows
Chemin de la Vuarpillière 33
Entry into Force of this Policy: 05.06.2014