Privacy Policy

Last updated: September 2024

About Richemont 

Compagnie Financière Richemont SA (“Richemont”, "we", "us" and "our") has its registered offices at 50, Chemin de la Chênaie, CP30, 1293 Bellevue, Geneva, 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 all of our products and services 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 (together referred to as the “Platforms”), when you visit us or our events, contact us by e-mail, telephone or online chat, or when you interact with us over social media platforms or other channels. Our Cookie Policy explains how we collect information through the use of cookies and related technologies when you use our Platforms.

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

 

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.

Richemont Careers

If you are applying for a role via the Richemont Careers portal or otherwise contact us regarding an advertised role or existing application, please refer to the information made available when applying online for further details as to how your information is collected, processed and how long it is retained for. For country specific privacy notices please see our Talent Privacy Policy.

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 services, events, appointments and/or other programmes, 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, marital status, nationality and gender. Your account will store information about yourself, username, password, time zone, as well as any conversation history.

Shareholder information: If you are a shareholder of Richemont, we will collect information relating to that shareholding, such as your name, contact details, number of shares held, and voting instructions.

Identification information: We may collect identification information from you, such as passport data or national ID data, in circumstances where we need this to provide services to you.

Correspondence, call recordings, online or video chat: We collect personal information from you when you correspond with us, contact us by e-mail, telephone or contact form, or otherwise participate in 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. 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 our Platforms, described in our Cookie Policy. This may include data relating to your unique online personal identifier.

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

CCTV, video surveillance data & Wi-Fi data: In our corporate premises or other areas, we collect data using CCTV or other video surveillance technology. If you register for our free Wi-Fi service at our events or other premises, we may collect certain information about your device, including device or IP address, connection date and time and the location(s) at which you connected to our Wi-Fi service.

Photos & video recordings: We may take photographs or make video or voice recordings of you at one of our events.

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.

Information we collect from third parties about you: We also may collect any of the above information about you from third parties, including social media platforms, 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.

Sensitive or special categories of data: We may ask you to provide sensitive or special categories of data (for example, allergens or accessibility requirements for events), in which case we will provide you with enhanced privacy information and ask for your explicit consent at the time of our request. Otherwise, if you provide such data to us without us asking you for it, we will take the fact you have provided such data as your explicit consent for us to process it.

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 (for example, processing your contact information relating to the purchase of shares).

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 general communications, updates, announcements and administrative messages – our primary justification is for the performance of a contract but we may also rely on legitimate interests (for example, to ensure that we are providing our services to you in a secure, effective and efficient manner), legal obligation or consent.

Marketing-related communications: We process your personal information for marketing-related purposes, including sending you marketing communications by e-mail relating to us and our Maisons, academies and other initiatives that we think may be of interest to you – our primary justification for marketing-related communications processing is either consent or legitimate interests (for example, where you are a corporate subscriber). Where we rely on consent, you may withdraw your consent at any time by contacting us at the address in the section headed “Contact us” or clicking on the ‘unsubscribe’ link in any marketing e-mails. Where we request your consent at multiple touchpoints (for example, in person 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, including for the purposes of maintaining our corporate registers, and facilitating the running of any relevant meetings – our primary justification is for the performance of a contract but we may also rely on consent, legitimate interests (for example, to facilitate shareholder registration) or legal obligation.

Enquiries: We process your personal information for the purposes of dealing with your enquiries and requests, and providing 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.

Events: We process your personal information for the purposes of organising and running events, including registering you as a member, attendee or speaker, or reporting or logging a health and safety incident that you may have suffered or assisted with. We may also take photographs or make video or voice recordings of you at one of our events for promotional purposes – our primary justification is for the performance of a contract but we may also rely on consent, legitimate interests (for example, to respond to your queries or to manage and administer events) or legal obligation.

Regulatory compliance and prevention of prohibited activities: We process your personal information for the purposes of undertaking anti-money laundering or international sanctions compliance, prevention of any prohibited or illegal activities as part of our efforts to keep our Platforms and services secure or as otherwise required to respond to a legitimate request from a third party (for example, a regulatory or police authority or financial institution) – our primary justification is legitimate interests (for example, to prevent crime) but we may also rely on legal obligation or 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.

CCTV, video surveillance & WiFi processing: We process your personal information using CCTV and video surveillance data for the prevention and detection of crime, assisting law enforcement agencies in the apprehension, investigation and prosecution of offenders, ensuring the safety of our staff, visitors and property and, occasionally, to monitor WiFi browsing activity – our primary justification is legitimate interests (for example, to secure our premises) and legal obligation but we may also rely on consent.

Platform support, maintenance and security: We process your personal information in connection with administering and protecting our business and the Platforms (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 our Platforms run 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

Our Platforms use 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 services 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 Platforms, 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), including for the purposes of providing services, cloud storage and any other services required in order for us to use your personal information for the purposes specified in this 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 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.

Unsubscribing from company announcements

If you registered on the Platform to receive company announcements, reports, news or press releases, you may unsubscribe at any time by clicking on the ‘unsubscribe’ link in any company announcement e-mails (however, please note if you are a shareholder of Richemont, you may continue to receive relevant information, such as annual reports and notices of meetings).

Children

The Platforms 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 the Platforms and should not submit any personal information to us without parental or guardian consent.

California Privacy Rights

This section applies solely to the personal information collected online and offline of California consumers. This section is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), and uses certain terms that have the meaning given to them in the CCPA.

• Your information, sources and purposes: Please refer to the sections above headed “Information that you provide to us or we collect about you” for a description of the personal information we may collect about you (or have collected in the preceding 12 months) and the sources of such information (such as directly from you and your device or through certain third parties). These sections also describe the purposes for which we may use or have used such information. We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
• Retaining your information: We will retain your personal information for the time period reasonably necessary to achieve the purposes described in this Privacy Policy, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.
• Disclosing your information: We may have disclosed your personal information to certain categories of third parties, as described in the section headed “Sharing your personal information” above.
• Selling your information/sharing your information for cross-context behavioural advertising: We do not sell or share your personal information in exchange for monetary compensation. As described in our Cookie Policy, we may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our Platforms in an effort to serve you content and advertisements that may be of interest to you. We also may share your personal information, such as your e-mail address, with third parties to help support our marketing activities. This kind of sharing may be considered a sale or sharing for cross-context behavioural advertising under the CCPA. You have the right to opt out of this disclosure of your personal information, as described below
• Your rights: Subject to exceptions under applicable law, you may have certain choices regarding our use and disclosure of your personal information, as described below:
  
  • Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
  • Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
  • Deletion: You have the right to request that we delete certain personal information we have collected from you.
  • Opt-out of Selling or Sharing: You have the right to opt out of the sale of your personal information or sharing of your personal information for cross-context behavioural advertising. You can opt out of cookie-based selling/sharing by clicking here or broadcasting the Global Privacy Control signal. For more information about how to use the Global Privacy Control signal, please see https://globalprivacycontrol.org/. In addition, you can opt out of other types of selling/sharing as further described in the CCPA Opt-out Page. Your opt-out will be specific to the browser and device you are using and will apply to the website domain on which you submit the request. If you clear your cookies or use a new browser or device to access the site, please submit a new request to re-apply your opt-out choice. Note that even if you opt out of selling or sharing, you may still be served advertisements and receive marketing e-mails from us and our service providers.

To exercise your rights on behalf of yourself or another individual, please contact us as described in the section headed “Contact us” below. If you exercise your rights, we may require you to provide certain information to verify your identity (such as your name, e-mail address, phone number and/or address) or the authority of any third person acting on your behalf.

No discrimination: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. This section is available in alternative formats upon request by contacting us as described in the section headed “Contact us” below.

Personal, family and household clients: In addition, under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an e-mail message to our e-mail address below with “Request for California Privacy Information” in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide you, by e-mail, a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties’ names and addresses. Please note that not all personal information sharing is covered by Section 1798.83’s requirements.

Privacy: Other States​

Your rights: If you are a New Jersey, Texas or Virginia resident and you interact with us in an individual or household capacity (and not in a commercial or employment context), subject to exceptions under applicable law, you may have certain choices regarding our use and disclosure of your personal information, as set forth above in ‘Commitment 3: Respecting your rights’ (including the rights to access and data portability, and to correct or delete certain personal information).

In addition, you have the right to opt-out of cookie-based selling/targeted advertising by clicking here or broadcasting the Global Privacy control signal. For more information about how to use the Global Privacy Control signal, please see https://globalprivacycontrol.org/. You can opt-out of other types of selling/targeted advertising as further described in the Opt-out page. ​

To exercise your rights on behalf of yourself or another individual, please contact us as described in the section headed ‘Contact Us’ below. If you exercise your rights, we may require you to provide certain information to verify your identity (such as your name, email address, phone number and/or address) or the authority of any third person acting on your behalf. ​

You may appeal our decision with respect to a request you have submitted by contacting us as described in the section headed ‘Contact Us’ below. ​

Canada Privacy Disclosures

We provide these additional privacy disclosures (hereinafter “Privacy Policy for Canada”) to inform you about our collection, use and disclosure of personal information when individuals (“you”) use our Canadian website and any other properties that link to this Privacy Policy for Canada.

This Privacy Policy for Canada contains additional disclosures required by the Personal Information Protection and Electronic Documents Act and substantially similar provincial privacy laws in Canada. The Privacy Policy for Canada supplements the information contained in this Privacy Policy.

Consent. Where you have agreed to a particular use of your information, we process it strictly on the basis of your consent or as otherwise permitted or required by law. By using our services, you agree to the collection and use of your personal information in accordance with this policy. You may withdraw that consent at any time by contacting us (see contact details below).

Children. The Platforms are not directed at anyone who we know to be under the age of 14, nor do we collect any personal information from anyone who we know to be under the age of 14. If you are under the age of 14, you should not use the Platforms and should not submit any personal information to us.

Cross-jurisdictional Transfers. By providing us with personal information, you acknowledge and agree that your personal information may be transferred to other jurisdictions for processing and storage, namely on servers located across Canada, the United States, the European Economic Area, and Switzerland, where laws regarding the protection of personal information may be less stringent than the laws that apply in your jurisdiction. Further, your personal information may be accessible to law enforcement, national security authorities, and the courts of such jurisdictions. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal information.

Contact for More Information. We have appointed a Data Protection Officer (Canada) who is responsible for overseeing questions in relation to this Privacy Policy for Canada. If you have any questions about this Privacy Policy for Canada, including any requests to exercise your legal rights, please contact the Data Protection Officer (Canada) using the details set out below:

Data Protection Officer (Canada)
Richemont Canada, Inc.
4610 Eastgate Pky 
Mississauga ON L4W 3W6
dpo.canada@richemont.com

 

You have the right to make a complaint at any time to the relevant supervisory authority for personal information protection issues. In Canada, you can contact the Office of the Privacy Commissioner of Canada or the relevant provincial privacy commissioner for your province of residence. We would, however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us first.

Japan Privacy Rights

Transferring your personal information globally. In a case falling under any of the following items, information that we collect may be transferred to, stored and processed in any country or territory where one or more of our affiliated group companies or third party service providers are located or maintain facilities. Some of these third parties will use cloud-based storage solutions. 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: (i) if our affiliated group companies or third-party service providers are located in a foreign country prescribed by rules of the Personal Information Protection Commission as a foreign country, establishing a personal information protection system recognised to have equivalent standards to those in Japan with regard to the protection of an individual’s rights and interests; or (ii) if necessary, measures are taken with the relevant affiliated group companies or third-party service providers to ensure the continuous implementation of measures equivalent to those that should be taken by the business operator handling personal information. For details, please contact us at the address provided in the “Contact us” section.

Sharing your personal information. We do not share personal information about you with other people or non-affiliated companies except to our affiliated group companies.We will share your personal information among our affiliated group companies all over the world. We disclose information about the use of personal information among our affiliated group companies according to the Japanese Act on the Protection of Personal Information as follows: all companies affiliated to us in the world.

Right of access. In addition to the rights of access identified above, you also have the right to ask for disclosure of records of provision of the same to a third party in certain cases.

Mexico Privacy Rights

This section contains supplementary information to the Privacy Policy in light of the requirements established by the Federal Law for the Protection of Personal Data in Possession of Private Parties (“LFPDPPP”), its Regulations (“RLFPDPPP”) and the Privacy Notice Guidelines (collectively “Mexican Data Protection Legislation”).

Commitment 1: (a) Information that you provide to us or we collect about you - In addition to the personal data stated in this section of the Privacy Policy above, please also bear in mind the following notes: “Sensitive or special categories of data (…)”: In this regard, we could collect limited special categories of data, such as gender, demographic data, only as necessary, and we will take the fact you have provided to us such data as your written and express consent for us to process that data. (b) Purposes of processing and our legal justification for processing. From the list of purposes described in the main Privacy Policy above, bear in mind that the following purposes are to be considered secondary as opposed to primary (meaning that they are not necessary to provide you with our services, and so we rely on your tacit consent in order to perform these purposes): “Location services”; “Enable a corporate transaction such as a merger or acquisition”. We remind you that you may object to secondary purposes at any time through the means and procedures indicated in the " Commitment 3 " section.

Commitment 2: (b) Sharing your personal information. In accordance with Mexican Data Protection Legislation, we inform you that of the transfers mentioned in this section of the Privacy Policy above, the following are based on your consent: “Mergers & acquisitions”.  Please be advised that you have the option to object the transfers that require your consent by the means indicated in the "Commitment 3" section.

Commitment 3: In addition to the rights mentioned in this section of the Privacy Policy, please note that you also have the following rights: if and insofar as you have given us your consent, you may limit the use or disclosure of your data when it is deemed appropriate or revoke the consent you have given for the processing of your data. (c) Rights to update or correct. This specific right includes that when you consider that any of the personal data used is inaccurate or incomplete, you can request a reconsideration of the decision taken. (f) Children. The Platforms are not directed at anyone who we know to be a child in the relevant country of data collection (e.g. in Mexico this is under 18), 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 the Platforms and should not submit any personal information to us without parental or guardian consent. You may exercise, and/or obtain information related to the procedure to exercise, your data protection rights, by sending an e-mail directly to the e-mail address of the Data Protection Officer at dpo.mexico@richemont.com.

Consent. Where you provide us your personal data, interact with our Platforms or our services, it is understood that you have read this Privacy Policy and that you expressly agree to the processing of your personal data in accordance with its terms, including data transfers that require your consent. Where you have agreed to a particular use of your information, we process it strictly on the basis of your applicable consent or as otherwise permitted or required by law. By providing personal data from third parties, you guarantee that you have obtained their authorization, and that you have communicated this Privacy Policy to such third parties.

Contact for More Information. We have appointed a Data Protection Officer (Mexico) who is responsible for overseeing questions in relation to this Privacy Policy for Mexico. If you have any questions about this Privacy Policy for Mexico, including any requests to exercise your legal rights, please contact the Data Protection Officer (Mexico) using the details set out below:

Data Protection Officer (Mexico)
Richemont de México S.A. de C.V.
Manuel Ávila Camacho, Number 138, Floor 12
Col. Lomas de Chapultepec, 1ra sección
Alcaldía Miguel Hidalgo, Mexico City, Postal Code 11000
dpo.mexico@richemont.com 

Brazil Privacy Rights

This section (hereinafter “Privacy Policy for Brazil”) contains supplementary information to the Privacy Policy in light of the requirements established by the Brazilian General Data Protection Law (“LGPD”), in order to inform you about our collection, use and disclosure of personal information when you are located in Brazil.

Rights. Under the LGPD, when we act as controller of your personal information, you may exercise certain additional rights, as described below:

(i) Right of confirmation

You have the right to obtain confirmation as to whether or not your personal information is being processed by us.

(ii) Right of anonymization, blocking or erasure

You may request anonymization, blocking or erasure of unnecessary or excessive personal information, or of personal information processed in breach of the provisions of the LGPD.

(iii) Right of portability

You have the right to have your personal information transmitted to another service or product provider, subject to the protection of our commercial or industrial secrets.

(iv) Right of erasure of data processed on the basis of consent

You may request the deletion of your personal information where it is being processed on the basis of your consent. This right does not arise to the extent that we use another legal basis for processing, such as where processing is necessary for performance of a contract or compliance with a legal or regulatory obligation.

(v) Right to obtain information about shared data

You have the right to obtain information about the entities with which we have shared your personal information.

(vi) Right of withdrawal

Where we are processing your personal information on the basis of your consent, you may withdraw your consent at any time (without incurring any fees or charges) by contacting us as described below. The exercise of this right will not affect the lawfulness of any data processing carried out before such right is exercised.

(vii) Right to obtain information about the possibility of not giving your consent

You have the right to be informed about the possibility of not giving your consent and about the consequences of such refusal.

(viii) Right to review of automated decisions

You may request the review of any decisions that we have taken solely on the basis of automated processing of your personal information affecting your interests.

Contact for More Information. We have appointed a Data Protection Officer (Brazil) who is responsible for overseeing questions in relation to this Privacy Policy for Brazil. If you have any questions about this Privacy Policy for Brazil, including any requests to exercise your legal rights, please contact the Data Protection Officer (Brazil) using the details set out below:

To Reach the Data Protection Officer (Brazil): 

Richemont do Brasil Distribuição Ltda.
Av Dr. Cardoso de Melo 1184 andar 17 Conj 171 and 172
Zip Code 04.548-004 – Vila Olimpia – São Paulo City / Sate of São Paulo.
privacidade.brasil@richemont.com

You have the right to make a complaint at any time to the relevant supervisory authority for personal information protection issues. In Brazil, you can contact the National Data Protection Authority (ANPD). We would, however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us first.