PRIVACY POLICY - UK

This Policy applies to personal data that we collect from or about you from the following sources:

HUBLOT websites or mobile sites/apps. Client-directed websites operated by or for HUBLOT, including sites that we operate under our own domains/URLs, their related features (for example, live chat) and pages that we administer on third party social networks such as Facebook, Instagram, Twitter, etc., as well as Client-directed mobile sites or applications operated by or for HUBLOT, such as smartphone apps (together “Websites”).

E-mail, text and other electronic messages. Electronic communications between you and HUBLOT (together “E-mail”).

HUBLOT call center. Calls to any customer service number operated by or for HUBLOT.

HUBLOT boutiques and workshops. Stores and workshops managed by HUBLOT or any HUBLOT affiliates.

HUBLOT events and HUBLOT desks, counters or booths at fairs or events, in particular through any questionnaire, survey or forms that you would fill in.

Other online or offline registration forms, for example, contests and promotions.

Other sources when applicable, including through publicly available information or the use of CCTV cameras.

Depending both on (i) the services provided by HUBLOT and used by you, as well as (ii) the source from which originates the processed personal data and (iii) your choices and configuration of your terminal (with respect in particular to cookies and other tracers), the following personal data may be collected and processed by HUBLOT.

When you Reach out to us, we may ask you to supply personal information such as:

• Your name ;
• Mailing address ;
• E-mail address ;
• Telephone number ;
• Payment details, including any bank account details (when you initially provide or update your payment information, we may transmit it via an encrypted connection to a third-party payment processor. Such a delegation is in particular justified in order to ensure compliance with security and legal standards);
• Your preferences and interests ;
• Your date of birth; and
• ID information (such as a copy of your ID card or passport) when necessary for anti-fraud purposes and compliance with applicable laws and regulations.

Personal data that is indispensable for us to fulfil the purposes that are described in this Policy (see clause 6) is marked with an asterisk on the various pages of the Websites and/or underlined as required upon any contact you have with HUBLOT. Should you not fill in these mandatory fields or otherwise provide us with this information, HUBLOT may not be able to take care of your requests and/or provide you with the requested products and services. Other personal data you would communicate to us is purely optional and allows us to know you better and to improve our communications and services accordingly.

We may also collect and process information relating to:

• Your purchases online or in HUBLOT boutiques (such as number and references of products purchased, prices, etc.) or the provision of after sales services; or
• Your image when you visit our stores (when CCTV cameras are in place) or your voice when you call our customer service (you will be informed beforehand and be given the possibility to let us know if you do not want the call to be recorded).

We may also collect data from publicly available sources, which shall be considered as data having been communicated by you

Data within E-mails: Should you send us an E-mail, we may keep all information contained in the E-mail, especially in order to resolve your inquiries or otherwise assist you.

When you access, visit or browse the Website, or receive and/or answer to E-mails from us, the Web server automatically registers details of your access and actions. This includes information about your activity on and interaction with the Websites and/or E-mails, such as your IP address, your device or browser type, the webpage you visited before coming to the Websites and identifiers associated with your devices, as well as any log information from servers and other network devices. This information enables us to analyse how the Websites are being accessed and used, and to track performance of the Websites as well as of any service offered on or through the Websites and to enhance your experience when using our Websites.

Location Information in particular: your devices (depending on your settings) may transmit location information to us, in particular through the Websites. We use this information to customize, improve and protect the Websites. For example, we may use your location information to determine local language preferences, to adapt our customer service to you, to geotag a post, or to present our closest point of sale.

Hypertext links to third-party websites or sources: we may propose hypertext links from our Websites to third-party websites or Internet sources. We do not control and cannot be held liable for third parties’ privacy practices and content. Please read carefully their privacy policies to find out how they collect and process your personal information.

Cookies and similar technologies: All this information and data is collected automatically in particular through cookies (performance and tracking cookies, functional cookies, technical cookies, browser cookies, etc.) and Web beacons (see clause 4). We also use Google analytics (see clause 5).

When you authorize a third party social network (Facebook, Instagram, etc.) to share information and data with us, we may receive any data that you publicly share on the social network as well as any information that is part of your profile or that you allow the social network to share (name, electronic address, gender, profile picture, user code, list of friends or contacts, etc.).

We also receive information pertaining to your profile when you use a social network functionality integrated to the Websites or that you interact with us through the social network. You should at all-time be aware of the terms of use and privacy policy that applies to the third party social network and are of its exclusive responsibility.

Cookies are small text files which are placed on your computer or mobile phone when you visit a website. They are widely used in order to make websites work or to work more efficiently. The cookies help website to recognize your device and remember information about your visit (e.g., your preferred language, font size and other preferences). Most Web browsers are set up to accept cookies, although you can reset your browser to refuse all cookies or to indicate when a cookie is being sent, as mentioned under clause 4.3 hereunder. Note, however, that some portions of the Websites may not work properly if you refuse cookies.

We also use web beacons (also known as an “action tag” or “clear GIF technology”), or similar technology, which helps analyse the effectiveness of websites by measuring, for example, the number of visitors to a site, how many visitors clicked on key elements of a site or what Web pages were visited.

We do not use cookies to track you individually or to identify you, but to allow us to operate the services as you have requested, facilitate your navigation on our Websites and the use of their features, so as to provide you with a seamless experience.

We may collaborate with other companies that place cookies, Web beacons or other tracking technology on the Websites. These companies help us in the management of the Websites and offer additional services and products. The use of these technologies by such third parties is subject to their own conditions, privacy rules and terms of use, which are not covered by this Policy and for which we do not have any responsibility.

Most browsers allow you to manage your cookies preferences by changing your browser settings. If you consent to our use of cookies but later wish to opt out, you may delete the cookies which have been set and change your browser settings to block any further cookies. The “Help” function of your browser should tell you how. Alternatively, the following links provide instructions for managing cookie settings of commonly used browsers:

• Chrome (https://support.google.com/chrome/answer/95647?hl=en)
• Internet Explorer (http ://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies)
• Mozilla Firefox (https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=en-US&redirectslug=Enabling+and+disabling+cookies)
• Safari (https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac)

We also use a third party provider OneTrust to manage cookies and enable you to make choices in relation to cookies.

In addition, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers.

Please note that if you block cookies, your experience on our Website may be impacted.

It is possible that some or all of the Websites use Google Analytics, an internet site analysis service supplied by Google Inc. (“Google”). Google Analytics uses cookies which are text files placed on your computer to help to analyse the use made of the Websites by its users. The data generated by the cookies concerning your use of the Websites (including your IP address) will be forwarded to, and stored by, Google on servers located in the United States. Google will use this information to evaluate your use of the Websites, compile reports on site activity for its publisher and provide other services relating to the activity of the Websites and the use of the internet. Google may release these data to third parties if there is a legal obligation to do so or when the third parties process these data for the account of Google including, in particular, the publisher of the Websites. Google will not cross-reference your IP address with any other data held by Google.

As mentioned under clause 4 above, you may deactivate the use of cookies by selecting appropriate parameters on your navigator. However, deactivation of this kind might prevent the use of certain functions of the Websites. By using the Websites, you specifically consent to the processing of your personal data by Google under the conditions and for the purposes described above.

If you do not want Google Analytics to be used in your browser, you can install the Google Analytics browser add-on at https://tools.google.com/dlpage/gaoptout

We use the data and information collected on you to:

• Offer you and allow the correct execution of all functions of the Websites;
• Personalize your use of the Websites as well as enhance the Websites and all of its functions;
• Contact you and interact with you and answer any of your questions or remarks, resolve your inquiries or otherwise assist you, including by notifying you of any changes in relation to our services and/or products;
• Answer and manage any order that you may have placed or otherwise done with HUBLOT and fulfil any contract with you, especially in relation to any products that you may have purchased or otherwise received, in particular through our customer service for repairs or after sales services;
• Set up and manage your HUBLOT account, including on our online shop to pass and/or manage any order, especially in order to offer you the best customer service and provide you with any information that you may request;
• Better identify and understand your preferences and wishes in relation to our products and services to improve and personalize your experience and communication with us;
• Proceed to anti-fraud, security and blacklist management for any case in which a person has been implicated in fraud regarding our products, services or trademarks, essentially in view of allowing, modifying or refusing that person’s access to services or products as well any entry into a contact with HUBLOT, and to communicate with and defend HUBLOT’s rights before state authorities;
• With your consent or within the applicable rules and regulations, send you our newsletter or other marketing E-mails or communications in relation to our products, offers, events, activities or services, in particular to inform you of any new products or services that may be of interest to you or of invitations and other publications. We may send you information using e-mail, text, telephone or post. You may at any time request to stop receiving newsletters by following the link that is given at the end of each newsletter. Should you wish to stop receiving other marketing E-mails or communications you may inform us by e-mail at mydata@hublot.com;
• Take all required measures in relation to your online transactions, especially to prevent fraud and payment defaults;
• Ensure security in our stores and buildings in relation with the use of CCTV cameras; and
• Comply with legal and regulatory requirements.

We do not, as a matter of business practice, retain personal data longer than necessary for the purposes stated and to comply with legal requirements, unless otherwise agreed to by you. At the end of the applied retention period, we shall delete your data without it being required that any further information be provided to you.

Your personal data shall be processed by HUBLOT SA, and/or by any of its affiliates distributing HUBLOT products and services. It may be transferred or otherwise shared with HUBLOT SA and its affiliates distributing HUBLOT products and services, for purposes of management and optimization of the customer relationship, as well as to send you information about the products, offers, events, activities or services in the limits of your consent or applicable lawful grounds.

It may also be transferred in case of a reorganization of HUBLOT, including merger, takeover, de-merger, and in general any reorganization operation.
Your personal data may also be transferred to the following third-parties:

• Third-party providers we work with, including in relation to the services offered on the Websites, especially any IT service suppliers, consultants, providers of hosting and maintenance services of the Websites and any third party processing personal data on our behalf, as well as any postal and payment service providers, in order to fulfil and execute any order that you have placed on or through the Websites, or more generally intervene in the context of your Reaching out to us.
• Third-party subcontractors, in order to provide you with the product, service or information you asked for, as well as any customer service, or for interest-based advertising based on the data collected from you and/or through your use of the Websites; such third-parties include carriers as well as payment and fraud management service providers.
• Any person or entity required by law or judicial order: we may disclose your data to third parties if we determine that such disclosure is reasonably necessary to comply with the law, protect our rights or prevent fraud or abuse. When we receive law enforcement or national security requests for information, we scrutinize such requests carefully, especially if they are vague, overbroad or otherwise unlawful. And when legally permitted and reasonably possible, we may provide you with notice that your information is being requested. In any case, both the assessment of the request as well as the possibility to inform you of it are at the our sole discretion and may not make us liable from a civil, criminal or administrative point of view.

We may transfer personal data to third parties when it is necessary to provide the product or service to you. In such cases, these third parties are prohibited to use these data beyond what is necessary to provide those product or service to you.

In any case where cross-border transfer is done, we ensure that an adequate protection is guaranteed for personal data to be transferred outside of Switzerland and the EEA. In some specific cases when this level of protection is not guaranteed, we will obtain your prior consent or establish with the recipient of personal data a contractual framework or sufficient safeguards that ensure an adequate level of protection abroad. You may request access to a copy of these safeguards by contacting us.

Please note that some of the abovementioned third parties receiving your personal data may be data controllers, which means that they are responsible for your data and that the processing of this data is subject to their own privacy policy, which you may obtain by contacting them. This also entails that you must contact them directly if you wish to assert any right with regards to this data. For example, this may be the case when it comes to payment, fraud, tax refund and financial management (notably for Adyen, Global Blue, CyberSource, Ekata) and for logistics partners (such as Swiss Post, UPS and FedEx, depending on the country).

We apply strictly the principles of data protection by design and by default and implement appropriate technical and organizational measures to limit to the maximum the processing of your data as well as ensure its security. In particular, and by default, only personal data which are necessary for each specific purpose of the processing are processed by us and all accesses to your personal data are limited to what is required for the purposes detailed under clause 6 of this Policy.

Regarding specifically any payment transactions that are done with your payment details, they are encrypted using SSL technology.

We strive to provide you with choices regarding the personal data that you provide to us or that is otherwise collected on you, in particular through our Websites. The following mechanisms give you the following control over your personal data.

Regarding Cookies and similar technologies: you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being used, as mentioned under clauses 4 and 5 above.

If you agree to receive marketing communications from HUBLOT, including information about products, offers, events, activities or services, you can indicate so through the relevant tickbox located on the registration form or by answering favorably to the question presented by our HUBLOT Boutique representatives. If you decide that you no longer wish to receive such marketing communications, you can subsequently unsubscribe as follows:

• By following the instructions provided in every emailing communication;
• Through the CONTACT US page on the HUBLOT website;
• Through your HUBLOT account; or
• By contacting us at mydata@hublot.com.

Please note that, even if you opt-out from receiving marketing communications, you may still receive administrative communications from us, such as order or other transaction confirmations, notifications about your account activities (e.g. account confirmations, password changes, etc.).

You have the right to request access to or information about the personal data related to you which are processed by us. Should you have a HUBLOT account, you can access, review, correct and update your personal data at any time by accessing such account on the Websites. Alternatively in any case you can contact us at mydata@hublot.com.

You may also have the right to request that we:

• Correct or erase your personal data or restrict the processing of your data;
• Transfer your personal data to a third-party;
• Stop processing your personal data, for the case in which we rely on your consent and do not have another legal basis to continue processing your data;
• Stop using your personal data to build up your client profile; in this case you will no longer benefit from customized offers or services; or
• Stop sending you marketing communications, including information about our products, offers, news, events or services.

All access, correction and removal requests sent to mydata@hublot.com must include your contact details (phone number and email address). We may ask you for proof of identity (an official identification document including your photo, date and place of birth).

The request is free of charge unless your request is unfounded or excessive (e.g. if you have already requested such personal data multiple times in the last twelve months or if the request generates an extremely high workload). In such case, we may charge you a reasonable request fee according to applicable data protection legislation.

We encourage you to contact us if you feel your personal data has been mishandled or if we have failed to meet your expectations.

For any question or request regarding your personal data, please contact our Data Protection Officer at mydata@hublot.com.