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PRIVACY POLICY


PRIVACY POLICY




PRIVACY POLICY

Daniel Wellington Inc. tax ID 46-4676897 (“Daniel Wellington,” “we,” “us” or “our”) will process your personal information when you are visiting and using the services provided at DanielWellington.com or purchase products in our stores. We strive to be transparent in what we do with our visitors’ and customers’ personal information and be compliant with applicable data privacy regulations (including the Californian Consumer Privacy Act (“CCPA”) and have therefore adopted this privacy policy. Below you will find information on what kind of personal information we process, why we do it, what we use it for and how we may share it.

The Daniel Wellington subsidiary stated above will be the controller in respect of any processing of your personal information, except in relation to the processing described under “Browsing”, “Analysis of Data” and “Targeted Messages on Third Party Advertising Platforms” below, where Daniel Wellington AB (our Swedish parent company, reg. no. 556875-5937) will be the controller. Please refer to Daniel Wellington AB’s Privacy Policy for more information on how they manage your personal information.


WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect personal information when you (i) purchase watches, accessories, watch bands, gift cards or other associated goods and/or services, (ii) sign up for news, invites and offers, (iii) request support and (iv) are browsing our website. Such personal information will include your name, e-mail address, telephone number, delivery address, payment details, IP address, behavior on the website and other information that you voluntarily provide us. If we deliver a gift card (or other product) to you which is purchased by someone else than you, we process your contact details as provided by the purchaser.

Daniel Wellington does not knowingly collect personal information about children under 16. If we become aware that a child under 16 has sent personal information without prior parental consent, we will remove his or her personal information from our records.


PURPOSE, LEGAL GROUND AND STORAGE PERIOD

We will only use your personal information for the business/commercial purposes and on the legal grounds set out below. Further, we will only use your personal information during the period set out under "Storage period".

PURCHASES

Purpose of processing: When you purchase watches, accessories, watch bands, gift cards or other goods and/or services, we will process your personal information to fulfil our contractual obligations towards you (see Terms of Use). Categories of personal information: Identity (first name and second name), delivery address/billing address, telephone number, e-mail address, order information, payment details, payment history, credit card information and payment reference number. Legal ground for processing : The processing is necessary for our performance of the contract with you (i.e. Terms of Use). Storage period: We will process your personal information during the term of our contract (including the statutory warranty period of three years) and we will thereafter erase your personal information. The storage period also applies to any unsuccessful purchase due to lack of funds in your account. We may save your personal information due to applicable legal requirements such as accounting legislation.


GIFT CARDS

If you purchase a gift card, we process your personal information as described under "Purchases" above. If you receive a gift card (or other product) which is purchased by someone else, we process your personal information as described below. Purpose of processing: When you receive a gift card we will process your personal information to fulfil our contractual obligations towards the purchaser of the gift card and to be able to let you use your gift card for purchases of our products. Categories of personal information: E-mail address (electronic gift cards only), shipping address and telephone number (physical gift cards only), first name and last name (optional for the purchaser to complete) and personal greeting (optional for the purchaser to complete). Legal ground for processing: The processing is necessary for (i) our legitimate interest to comply with our obligations towards the purchaser of the gift card and (ii) our and your legitimate interest to enable you to make purchases with your gift card. Storage period: We will process your personal information during the validity period of the gift card, we will thereafter erase your personal information. The validity period of gift cards vary, you can find information on the period applicable to your gift card on the card.

DIRECT MARKETING

Purpose of processing: When you sign up for news, invites and offers (direct marketing), we will process your personal information to provide the services as requested by you. Our direct marketing may be based on profiling, which means that we will customize the information that you receive from us based on certain factors. We use the following types of personal information to compile a profile: your gender, your location, your previous purchases, your behavior on our website, and/or your previous behavior when receiving direct marketing from us. Categories of personal information: Any data collected in connection with a purchase (see ”Purchase” above), e-mail address, location (based on the physical store or DW website that you use to sign up for our marketing communications), any communication sent to you, order history and the e-mails that you have clicked on and your interactions with our website if you have followed a link in any e-mails sent to you. Legal ground for processing: The processing is necessary for our legitimate interests to maintain good customer relations. Storage period: If you opt-out or unsubscribe from our marketing (including profiling), we will no longer process your personal information for this purpose. Unless there is another legal ground for keeping your data (such as a valid purchase contract), we will also erase your personal information if you have not actively engaged with any of our direct marketing communications for a period of thirty (30) months.


COMPETITIONS AND EVENTS

Purpose of processing : If you participate in a competition, lottery or event organized by us, we will process your personal information in order to be able to communicate with you (i) before or after participation in the competition, lottery or event (ii) for the purposes of identification and age control, or (iii) to elect a winner and to distribute the relevant benefit or price. Categories of personal information: Depending on which type of competition, lottery or event that that you participate in, we may collect your name, e-mail address, location and date of birth, as well as your shipping address for the purposes of distributing the relevant benefit or price. More details on exactly what data we are collecting will be provided in connection with each such competition, lottery or event. Legal ground for processing: The personal information is required for the legitimate interest we have to administrate your participation in connection with competitions, lotteries or events. Storage period: We will keep your personal information only during the competition, lottery or event (including a possible evaluation thereof).


SUPPORT

Purpose of processing: When you request support through our live chat or our other support channels, we will process your personal information to be able to assist you with the relevant matter. Categories of personal information: Your name, e-mail address and other contact details, order details, purchase amount, purchase history, place of purchase, invoice, payment method, our correspondence with you, technical data about devices and operating system used. At your initiative, we may also process personal information such as ID, bank account details, work place, phone number, health data (such as allergy reactions or other health data that you provide us with), pictures attached by you or social status, if provided by you in our dialogue. Legal ground for processing: If we provide this service on the basis of an agreement with you, we consider the processing of your personal information to be necessary for the performance of the contract to which you are party. In other cases, we consider the processing of your personal information in the above context to be based on our legitimate interest to provide you with the best customer service possible. Storage period : We will erase your data within three years after the relevant matter has been finally resolved, except for sensitive data (such as ID, bank account details, health data (such as allergy reactions or other health data that you provide us with), pictures attached by you, social status, if mentioned by you in our dialogue) which will be erased immediately after your case has been resolved.


REPAIR SERVICE

Purpose of processing: When you use our repair services, we will process your personal information to fulfil our contractual obligations towards you (see Repair Service Terms and Conditions). Categories of personal information: Identity (first name and second name), e-mail address, delivery address, any order information relating to the initial purchase, credit card information, payment reference number and photos of the product to be repaired (if requested by us in order to evaluate the possibility of performing the repair). Legal ground for processing: The processing is necessary for our performance of the contract with you (i.e. Repair Service Terms and Conditions). Storage period: We will process your personal information during the term of our contract (including the statutory warranty period of three years) and we will thereafter erase your personal information.


CHECKOUT REMINDER

Purpose of processing: If you have initiated a purchase at our website and if you have provided your e-mail address in connection therewith but have not completed the final step of your purchase, we will send you an e-mail with a link to your shopping cart for the purposes of reminding you of your uncompleted purchase. Categories of personal information: Any details that you have entered in your shopping cart in connection with the uncompleted purchase (please refer to “Purchases” above for more details on what details we collect in connection with any purchase). Legal ground for processing : The processing is necessary for our and your legitimate interest to remind you of your uncompleted purchase. Storage period : We will erase your data, within one month after the checkout reminder, unless there is another legal ground for keeping your data (such as a valid purchase contract). Opt-out is possible by contacting dataprotection@danielwellington.com.


BROWSING

Purpose of processing : When browsing our website, we may process your personal information to improve our website and for marketing purposes. Categories of personal information: Ip-address, user generated data from cookies (e.g. clicks, page viewed, page visits, time spent on pages, products viewed and clicked on, orders, average order value). Legal ground for processing : The processing is based on the consent that you provide to us if you accept our Performance Cookies and Targeting Cookies (see “Cookies” below). In relation to Strictly Necessary Cookies, our processing is necessary for our legitimate interest in being able to provide you with a functioning website when you visit and use the services provided at DanielWellington.com. Please see more under “Cookies”. Storage period : The storage period for each of our cookies can be found

FRAUD PREVENTION

Purpose of processing : We will process your personal information for the purposes of carrying out risk analysis, fraud prevention and risk management. Categories of personal information: Identity (first name and second name), delivery address/billing address, telephone number, e-mail address, order history, payment history, purchase- and user generated data (clicks and user history), information about how our digital services are used. Legal ground for processing : The processing is necessary for our legitimate interests to prevent fraud and to handle risks. Storage period : We will erase any personal information used for this purpose on a six-month basis, unless there is another legal ground for keeping your data. Upon a purchase that has been cancelled due to fraud prevention, we will delete your personal information two years after the unsuccessful purchase.

VIDEO SURVEILLANCE

Purpose of processing: When you visit one of our stores, we may conduct camera surveillance (if so, there are signs in the store informing of the surveillance) and thereby process moving pictures of you gathered through our surveillance cameras for the purposes of (i) preventing and investigating crime on property and towards employees and (ii) fire prevention. Categories of personal information: Images and video recordings related to visitors of our stores and the date, time and place thereof. Legal ground for processing: The processing is necessary for our legitimate interests to protect our property and ensuring a safe workplace for our employees. Storage period : We will process your personal information for 72 hours unless laws or regulations obliges us to continue the processing. The personal information will then be deleted.

ANALYSIS OF DATA

Purpose of processing : We may analyze your personal information, in order to compile aggregated tracking data (including to analyze visitors’ use of our sites by tracking information such as page views, traffic flows, search terms and click throughs) for the purposes of to continuously being able to offer a more user-friendly experience. Categories of personal information: Ip-address, user generated data from cookies (e.g. clicks, page viewed, page visits, time spent, products viewed and clicked on, orders, average order value), geographic location (country only), correspondence and feedback relating to our products and services, technical data (e.g. language, IP-address, device type, browser settings, time zone, operating system, platform), information about how you have interacted with us, i.e. how you have used our services, response times, page errors, how you reach and how you leave the site etc. Legal ground for processing : The processing is based on the consent that you provide to us if you accept our Performance Cookies (see “Cookies” below). Please see more under “Cookies”. Storage period : The storage period for each of our Performance Cookies can be found .

TARGETED MESSAGES ON THIRD PARTY ADVERTISING PLATFORMS

Purpose of processing : We use third-party advertising platforms, such as Facebook, Google, YouTube, Instagram, etc. to send you messages that are targeted at you, based on your behavior and browsing pattern, at specific times and locations of these platforms to increase the efficiency of our advertising campaigns. Your personal information is shared with the third-party advertising platforms, and they will attempt to match your profile in their database to determine the optimal time and place (the page you are browsing) to show you an advertisement from Daniel Wellington. We also need to analyze necessary information to understand the impact of our advertising. If you don’t accept that we track your data for this purpose, you may still see Daniel Wellington advertisements on other platforms at random. You can learn more about how our advertising partners help us achieve this purpose by visiting their sites (the relevant links can be found in our Cookie Settings (see link below under “Cookies”)). Categories of personal information: Ip-address, user generated data from cookies (e.g. clicks, page viewed, page visits, time spent, products viewed and clicked on, orders, average order value), geographic location (country only). Legal ground for processing : The processing is based on the consent that you provide to us if you accept our Targeting Cookies (see “Cookies” below). Storage period : The storage period for each of our Targeting Cookies can be found . Please note that the above storage periods do not apply to the extent Daniel Wellington is required to retain your personal data (partly or in full) under applicable mandatory law (e.g. accounting laws).

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

Only the people who need to process personal data for the purposes mentioned above have access to your personal data. We may need to share your personal data with our group companies. We may also disclose your personal information to an organization for a business/commercial purpose. When we disclose personal information for a business/commercial purpose, we enter into a contract that describes the purpose and requires the recipient organization to keep that personal information confidential and not use it for any purpose except performing the contract with us. Any transfer of data outside the EU/EEA (including transfers to our group companies and suppliers outside the EU/EEA) is made in line with data protection laws, such as through agreements based on the EU Commission’s standard contractual clauses. The standard contractual clauses may be found here.

PERSONAL INFORMATION REGARDING CALIFORNIAN RESIDENTS

We collect your personal information for the purposes described above.

In the preceding 12 months, Daniel Wellington have collected (from information you give us, information collected automatically and information from other sources such as other Daniel Wellington group companies) and disclosed (to our business partners and group companies) the following categories of personal information about California residents, in accordance with the categories of business/commercial purposes:

(1) Identifiers for the business/commercial purposes of: (i) security, (ii) debugging/repair , (iii) performing services on behalf of the business or service provider, and (iv) advance a person’s commercial or economic interests or enabling or effecting a commercial transaction.

(2) Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e) for the business/commercial purpose of (i) security, (ii) performing services on behalf of the business or service provider (iii) advance a person’s commercial or economic interests or enabling or effecting a commercial transaction.

(3) Characteristics of protected classifications under California or federal law, such as gender, for the business/commercial purposes of (i) security, (ii) performing services on behalf of the business or service provider, (iii) advance a person’s commercial or economic interests or enabling or effecting a commercial transaction.

(4) Commercial information for the business/commercial purposes of (i) performing services on behalf of the business or service provider (ii) advance a person’s commercial or economic interests or enabling or effecting a commercial transaction.

(5) Internet or other electronic network activity information for the business/commercial purposes of: (i) security, (ii), performing services on behalf of the business or service provider, (ii) auditing interactions, (iii) advance a person’s commercial or economic interests or enabling or effecting a commercial transaction.

(6) Geolocation data for the business/commercial purposes of performing services on behalf of the business or service provider.

(7) Audio, electronic, visual, thermal, olfactory, or similar information for the business/commercial purposes of performing services on behalf of the business or service provider.

(8) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes for the business / commercial purposes of: (i) performing services on behalf of the business or service provider, (ii) advance a person’s commercial or economic interests. In the preceding twelve (12) months, we have sold the following categories of personal information to the following categories of third parties: (1) Identifiers to service provides e.g. third party advertising platforms. (2) Internet or other network activity information to service provides e.g. third party advertising platforms. Daniel Wellington does not knowingly collect personal information from California residents between 13 and 16 years old.

YOUR RIGHTS

You are entitled to the following rights under applicable laws: If you are a California resident, you are entitled to the following rights under applicable laws:

The right to access: you may at any time request to access your personal information. Upon request, we will provide you with a list of: (i) the categories of personal information we have collected about you, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, (v) the specific pieces of personal information we hold about an individual, and (vi) in case we sell your personal information, or disclose it for a business purpose, you have the right to access the (i) categories of personal information that we collected about you, (ii) the categories of personal information that we sold and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold, and (iii) The categories of personal information that we disclosed for a business purpose. The right to erasure: you may request us to delete your personal information. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us. The right to opt-out of selling: you have the right to opt-out of having your personal information sold by clicking the “do not sell my data”-button in our Cookie Settings. The right against discrimination: you have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to access, erasure or opt-out of sales. If you are a EU member in US or a US member in EU, you are entitled to the following under applicable laws:

The right to access : you may at any time request to access your personal information. Upon request, we will provide a copy of your personal information in a commonly used electronic form. The right to rectification : you are entitled to obtain rectification of inaccurate personal information and to have incomplete personal information completed. The right to erasure (“right to be forgotten”) : under certain circumstances (including processing on the basis of your consent), you may request us to delete your personal information. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us. The right to object : to certain processing activities conducted by the us in relation to your personal information, such as our processing of your personal information based on our legitimate interest. The right to object also applies to processing of your personal information for direct marketing purposes. The right to restriction of processing : you may under certain circumstances request from us to restrict the processing of your personal information. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us. The right to data portability : you are entitled to receive your personal information (or have your personal information directly transmitted to another data controller) in a structured, commonly used and machine-readable format. Finally, you also have the right to lodge a complaint with the supervisory authority in Sweden, which currently is Datainspektionen. In order to invoke any of your rights, please see the “Contact Information” below.

COOKIES

As part of our approach to providing personalized services on our website, we use cookies to store and sometimes track information about you. A cookie is a small data file sent to your browser from a web server and stored on your hard drive that allows easier access the next time the same page is visited. For example, a cookie is sent when you sign-up to download products or information on our website. If you do not want your personal information to be stored by cookies, you can configure your browser so that it notifies you whenever a cookie is received. This way you can decide each time to accept cookies or not. However, the use of cookies may be necessary to provide certain features and choosing to reject cookies may reduce the functionality of our website. Your browser should include precise instructions explaining how to control the acceptance of cookies. To be transparent, we have summarized the cookies used on our website below. By clicking on the “cookie settings” button below, you will find a detailed list of the cookies we use on our website. Our website is scanned with our cookie scanning tool regularly to maintain a list which is as accurate as possible. We classify cookies in the following categories: • Strictly Necessary Cookies • Performance Cookies • Targeting Cookies • Functional Cookies • Social Media Cookies

You can opt-out of each cookie category (except strictly necessary cookies)


DATA SECURITY

We employ appropriate technical and organizational security measures to help protect your personal information against loss and to guard against access by unauthorized persons. Appropriate security measures we have taken include implementing secure private connections, traceability, disaster recovery and access limitations. We regularly review our security policies and procedures to ensure our systems are secure and protected.

CONTACT INFORMATION

If you have any questions relating to our handling of your personal information, our use of cookies or other questions and concerns about our privacy policy, or if you would like to invoke any of your rights under applicable privacy legislation, please contact us at:

email: dataprotection@danielwellington.com,

toll-free number: +1 888 857 4707

If required, we may ask you to verify your identity through providing us with proof of such, for example provide us with a picture/copy of your ID-card. You may also use an authorized agent to submit a request on your behalf provided that you give written permission to the authorized agent and verify your own identity directly with us. Please note that we may deny the request if you do not verify your identity or if the authorized agent does not submit proof that they have been authorized by you to act on your behalf unless the authorized agent presents a power of attorney.

CHANGES TO THIS WEBSITE PRIVACY POLICY

If we change how we handle your personal information or how we use cookies, we will promptly update this website privacy policy and publish it on this website.

Last updated: 2020-07-16

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