Effective Date: 24 October 2018
We at Movado Group, Inc. (“MGI”) along with our subsidiaries and affiliates (collectively, “Movado Group”), respect your concerns about privacy.
This website is not intended for children, and we do not knowingly collect data relating to children.
- Important Information and Who We Are
- The Data We Collect About You
- How We Collect Your Personal Data
- Bases for Using Your Personal Data
- Sharing Your Personal Data
- International Transfers
- Data Security
- Data Retention
- Your Rights and Choices
- Cookies and Other Automated Means
- Notice to California Residents
- Movado Group Companies that Process and Share Personal Data
1. IMPORTANT INFORMATION AND WHO WE ARE
It is important that the personal data we hold about you is accurate and current. Please update your account or Contact us if your personal data changes during your relationship with us.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) or is otherwise not ascertainable.
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, and title.
- Contact Data includes first name, last name, billing address, delivery address, email address, and mobile or other telephone numbers.
- Payment Data includes bank account and payment card details, expiration date, authorization number or security code, and billing address.
- Transaction Data includes Contact Data, Payment Data, and details about products and services you have purchased from us.
- Customer Service Data includes service inquiries, comments, and warranty and repair history.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on devices you use to access this website. For further details, see Cookies and Other Automated Means.
- Profile Data includes username or similar identifier, password, date of birth, gender, marital status, demographics, Transaction Data, and your interests, preferences, feedback, and survey responses .
- Usage Data includes information about how you use our website, products, and services.
- User Content includes photographs, comments, and other content you provide.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties.
- Friends Data includes contact information you provide about friends or other people you would like us to contact.
Please keep in mind that many of the data elements mentioned above do not by themselves constitute personal data but instead only constitute personal data when combined with other data elements. For example, demographics data, Usage Data, and details about products and services you purchase from us do not constitute personal data unless combined with Identity Data or other data that connects such information to your identity.
When permissible, we may collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offenses. We do not seek to collect any Special Categories of Personal Data in respect of residents of the European Economic Area (“EEA”) (which includes the member states of the European Union plus Iceland, Lichtenstein and Norway) and Switzerland or under other circumstances in which the General Data Protection Regulation applies (please see Bases for Using Your Personal Data, below).
When you provide us with User Content or other data, please do not include any of these Special Categories of Personal Data, especially with reference to another person. If we become aware that you have provided any of this type of information to us when submitting User Content, we will either delete the information from our records or communicate with you concerning your intentions for our use of the information you provided.
When we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your Identity, Contact, Payment, Transaction, Customer Service, Profile, User Content, and/or Marketing and Communications Data by filling in forms or by corresponding with us by mail, telephone, email, social media, or otherwise. This includes personal data you provide when you:
- Create an account;
- Seek to purchase our products;
- Apply for our services (such as warranty or after-sales service);
- Subscribe to our newsletter;
- Request marketing to be sent to you;
- Enter a competition, promotion or survey;
- Interact with us on social media; or
- Give us some feedback.
- Automated technologies or interactions. As you interact with our website, apps, social media platforms, physical stores, and “smart” watches, we may automatically collect Technical, Profile, and/or Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, location-sensing technology, and other similar technologies. We may also receive Technical, Profile, and/or Usage Data about you if you visit other websites employing our cookies. Please see Cookies and Other Automated Means for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, including the following:
- Identity and Contact Data from publicly available sources;
- Contact, Payment and Transaction Data from payment processor and fraud detection and prevention companies;
- Identity and/or Contact Data from friends or people you know and who have asked us to contact you;
- Technical Data from analytics providers like Google;
- Technical Data from search information providers;
- Identity, Contact, Profile, Usage, User Content, and/or Friends Data from social media channels like Facebook, Instagram, Pinterest, and Twitter.
- Identity, Contact, Profile, and/or Usage Data from advertising networks and marketing lists; and
- Identity, Contact, and/or Profile Data from marketing insights companies like Experian.
4. BASES FOR USING YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party, where permissible).
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data. However, we strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can change those choices at any time by clicking the “unsubscribe” link on the communication sent to you or by Contacting us. When you unsubscribe we will stop sending you direct marketing communications but may continue using your personal data for other purposes for which a different lawful basis for processing exists. If you choose to provide us with your email address to receive our newsletter or other direct marketing materials, we will not share that information with unaffiliated entities for those third parties’ own purposes, although as described below we may share that information with unaffiliated third parties to help facilitate and improve our own communications with you.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We may use your personal data and other information for any purpose permitted by law.
On 25 May 2018, the General Data Protection Regulation (GDPR) promulgated by the European Union came into effect. The GDPR limits the legal bases upon which we may collect and use personal data and requires us to explain which legal bases we rely on for the processing of data when the GDPR applies.
We have therefore set out below in table format (the “GDPR Table”) a description of the ways we plan to use your personal data and which of the legal bases we rely on to do so if and when the GDPR applies, including whenever the subject of the personal data is a resident of the EEA or Switzerland. In the GDPR Table “legitimate interests” means our interest in conducting and managing our business to enable us to give you the best products and services and the best and most secure experience and to grow our business. Although many things go into making this happen, to help you better understand what our legitimate interests are we have identified in the GDPR Table certain examples. Since we do not seek to collect any Special Categories of Personal Data when the GDPR applies, the GDPR Table does not include examples of the use of Special Categories of Personal Data.
Note that under the GDPR we may process your personal data for more than one lawful ground depending upon the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the GDPR Table below.
On our websites, apps, social media pages, and other tools and when you use one of our “smart” wearable devices or visit one of our physical stores, we may collect information about your online activities and geolocation information for use in providing you with advertising about products and services tailored to your individual interests.
If automatic technologies have been enabled, you may see certain ads on other websites because we engage third-party ad buying networks. Through such buying networks, we can target our messaging to users through demographic, interest-based, and contextual means. We can track your online activities over time by collecting information through automated means, including through the use of third-party cookies, web server logs, pixels and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests. The information our ad networks may collect on our behalf includes data about your visits to websites that serve Movado Group advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts.
To learn how to opt-out of some or all of this ad network interest-based advertising, please visit the consumer opt-out page at HTTP://WWW.ABOUTADS.INFO/CHOICES/. For more information about our use of automatic technologies and third-party analytics services, see Cookies and Other Automated Means.
5. SHARING YOUR PERSONAL DATA
We may share your personal data within the Movado Group of affiliated companies worldwide. See Movado Group Companies that Process and Share Personal Data for a list of Movado Group companies that process and share personal data.
We also may share your personal data with external third parties, including service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or to disclose the data except as necessary to perform services on our behalf or to comply with legal requirements. Examples of these service providers include entities that process credit card payments, manage and reduce our credit risk, verify information, fulfill orders, and provide web hosting, analytics, and marketing services.
Where permitted by law, we may share your personal data with other third parties for those parties’ own purposes, such as to offer products or services that may interest you. For example, as described in Cookies and Other Automated Means, we allow carefully-selected third parties to set cookies during your visit to our website that enables them to provide you with relevant messaging on other websites. However, as explained above, we will not share your email address with unaffiliated parties for their own direct marketing purposes. You may tell us that you do not wish any other personal data to be shared with third parties for those parties’ own purposes by Contacting us.
In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity, (iv) to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, and/or (v) to new owners who have acquired or have merged with our business.
6. INTERNATIONAL TRANSFERS
Consistent with its commitment to protect personal privacy, MGI has entered into agreements with its subsidiaries resident in the EEA and Switzerland to ensure that adequate protection be given to personal data transferred from the EEA and Switzerland to the United States. These agreements are based on “standard contractual clauses” promulgated by the EU and Swiss governments. Copies of the non-confidential provisions of these agreements are available byContacting us.
If you are a resident of the EEA or Switzerland, please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or Switzerland.
7. DATA SECURITY
We maintain administrative, technical, and physical safeguards designed to protect the personal data you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use. While no safeguards are infallible, we take data security seriously and believe that we have implemented robust measures to minimize the risk of data breaches. However, we cannot guarantee the security of your data transmitted over the internet, and we do no warrant the security of ay information, including personal data, which you transmit to us over the internet.
8. DATA RETENTION
We will retain your personal data for as long as we believe it is needed to fulfill the purpose(s) we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for analytical, statistical, or other purposes, in which case we may use or share this information indefinitely without further notice to you. Similarly, we may use or share Aggregated Data indefinitely without further notice to you. In general, we will retain your personal data for as long as we engage with you and, following that period, we will only retain your personal information for as long as is reasonably necessary under the circumstances.
Where the GDPR applies, you can ask us under certain circumstances to delete your data: see Your Legal Rights Under the GDPR below for further information.
9. YOUR RIGHTS AND CHOICES
We offer you certain choices in connection with the personal data we collect about you, such as how we communicate directly with you. To update your preferences, to ask us to remove you from our mailing lists, to exercise your rights, or to submit a request, please Contact us. You can also unsubscribe from our mailing lists by following the “Unsubscribe” link in our emails.
To the extent permitted by law, you also may Contact us to request access to the personal data we maintain about you or request that we correct, amend, delete, or block the information.
If you are a resident of the EEA or of Switzerland, you have the right to make a complaint at any time to the European Data Protection Supervisor, to the Data Protection Authority in the applicable EU Member State, or to the Swiss Federal Data Protection and Information Commissioner. A list of EEA authorities is available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. We would, however, appreciate the chance to respond to your concerns before you approach these governmental agencies, so please contact us in the first instance.
YOUR LEGAL RIGHTS UNDER THE GDPR
Where the GDPR applies, under certain circumstances you have rights in relation to your personal data, including the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If we provide you with access to the information we hold about you, we will not charge you unless permitted by law. If you request further copies of this data from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will tell you our reasons for doing so.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If we have shared this personal data with third parties we will notify them about your correction request unless this is impossible or involves disproportionate effort. You also may request details of the third parties to whom we have disclosed the inaccurate or incomplete personal data. Where we think that it is reasonable for us not to comply with your request, we will explain our decision to you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. Where we are processing your personal data for direct marketing purposes you have the right to object to processing. You also have the right to object to processing in the event we do so to enable us to perform a task in the public interest or exercise official authority, or for scientific, historical, research, or statistical purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. If we have shared your personal data with third parties, unless it is impossible or involves disproportionate effort we will use reasonable efforts to notify them about your request to restrict processing.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you seek to withdraw your consent. In the event you withdraw your consent, we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your information for this purpose, in which case we will inform you of this legal basis.
10. COOKIES AND OTHER AUTOMATED MEANS
When you visit our websites, open our emails, use our apps or “smart” wearable devices, or interact with Movado Group-related social media sites or tools, widgets, or plug-ins, we may collect certain information by automated means, such as cookies, web beacons, and web server logs.
WHAT ARE COOKIES, WEB BEACONS, AND OTHER AUTOMATED MEANS?
A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag, or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. We may link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you.
WHAT PURPOSES DO AUTOMATED MEANS SERVE?
- Cookies Support Basic Website Functionality: Some cookies are functional and necessary cookies that support essential features of our website, such as storing your shopping cart selections while you continue to shop and navigate to different pages of our website. Functionality cookies also are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region). Cookies also help us direct consumers to their appropriate website and to determine whether an order is valid.
- Cookies Can Help Improve the Quality of Our Website and Services: Some cookies collect information to assess how you use our website so that we can improve the navigability of our site and provide you with better service. This is known as website analytics, and we use Google Analytics tools for this function. We use Analytics Cookies to:
- Provide aggregate and anonymous statistics on how our site is used;
- See how effective our advertisements are by identifying where you click and from which website you arrived;
- Provide feedback to carefully selected third party partners that one of our visitors also visited their website;
- Help us improve the site by capturing errors in your browsing experience;
- Provide you with improved site functionality by allowing access to additional services or restoring your shopping bag if you wish to return on a subsequent browsing session
- Cookies Allow Us to Personalize Your Experience: Certain cookies record your visit to our website, the pages you have visited, and the links you have followed. We use this information to make our website and the advertising displayed on it more relevant to your interests.
WHAT INFORMATION DO WE COLLECT THROUGH COOKIES?
Most of the information captured by cookies or other automated means will not identify you personally. The data we collect through cookies and other automated means may include unique device identifier; browser characteristics; device characteristics; operating system; language preferences; referring URLs; information on actions taken on our site; dates and times of website visits, downloads, and activations. In certain circumstances we also may collect your IP address or data collected through usage of our apps and “smart” wearable devices, such as geolocation.
MANAGING YOUR COOKIE PREFERENCES
To manage third-party cookies served on our site, please visit Google Analytics: http://www.google.com/analytics/learn/privacy.html. Through this link you may opt-out of some or all third-party cookies. This will not affect or disable the cookies served by the Movado Group.
To manage all cookies on our site, including those that are served by the Movado Group, you can change your browser settings. For additional information on how to manage all cookies please visit http://www.allaboutcookies.org/. Please note that disabling, blocking, or deleting cookies in your browser settings may impact your ability to fully use both our website and other websites.
Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. When we recognize a relevant DNT signal we aim to suppress the third-party tags that are used to recognize your computer once you navigate away from our site and which are used to present you with Movado Group advertisements. However, currently there is no uniform standard for DNT signal recognition, and our technology may not recognize all DNT signals. Thus, if you do not wish for cookies or other automated means to be enabled, we encourage you to manage cookies through the other means noted above.
11. NOTICE TO CALIFORNIA RESIDENTS
Subject to certain limitations under California Civil Code §1798.83, California residents may ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request, California residents may Contact us.
12. MOVADO GROUP COMPANIES THAT PROCESS AND SHARE PERSONAL DATA
We set forth below details of the Movado Group companies that process and share personal data.
When you visit one of our after sales service websites (mgiservice) you will be given directions about where to send your watch for service or repairs. The entity to which you are directed will be the controller of your personal data.
When you visit one of our other websites, the controller of your personal data will be as identified below.
Movado Group, Inc.
650 From Road
Paramus, NJ 07652
[controller for US ecommerce and all non-ecommerce websites]
Movado Retail Group, Inc.
650 From Road
Paramus, NJ 07652
Movado Group of Canada Inc.
One Main Street West
L8P 4Z5 Canada
[controller for Canadian websites]
MGI Luxury Trading (Shanghai) Co., Ltd.
Room 20F02, Plaza 889
1111 ChangShou Road
Peoples Republic of China
Movado Group France SAS
47 rue de la Chaussee d’Antin
[controller for French websites]
MGI Luxury Group GmbH
Landsberger Str. 94
Movado Group Deutschland GmbH
[controller for German websites]
Swissam Products Ltd.
5th Floor, Alexander House
18 Charter Road
MGI Luxury Asia Pacific Limited
29th Floor, Citicorp Centre
18 Whitfield Road, North Point
MGI Luxury Malaysia Sdn.Bhd.
Level 30, The Gardens North Tower
Mid Valley City
Lingkaran Syed Putra
59200 Kuala Lumpur
MGI Distribución, S. de R.L. de C.V.
Torre Esmeralda III
Blvd Manuel Ávila Camacho #32
Piso 6 Oficina 687
Col. Lomas de Chapultepec CP 11000
MGI Luxury Group B.V.
Prins Bernhardplein 200
1097 JB Amsterdam
Movado Group Nederland B.V.
Prins Bernhardplein 200
1097 JB Amsterdam
MGI Luxury Singpore Pte Ltd
#06-02 Tong Building
302 Orchard Road
Movado Watch Company SA
MGI Luxury Group SA
Concord Watch Company SA
c/o MGI Luxury Group SA
Ebel Watches SA
c/o MGI Luxury Group SA
MOVADO Group UK Limited
[controller for UK websites and Olivia Burton EU and International websites]