HUBLOT PRIVACY POLICY

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

HUBLOT websites or mobile sites/apps. Websites operated by or for HUBLOT, including sites that we operate under our own domains/URLs, their related features (for example, live chat) as well as mobile sites or applications operated by or for HUBLOT, such as smartphone apps. We have referred to these websites and apps together below as “Websites”.

Social media platforms. We collect information from pages that we administer on third party social media platforms such as Facebook, Instagram and X (ex-Twitter). We also collect information from social media platforms in connection with our marketing activities.

E-mail, text and other electronic messages. Electronic communications between you and HUBLOT.

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

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

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

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

CCTV or other surveillance technologies. We collect personal data via CCTV cameras or other surveillance technologies when you visit our stores or workshops.

Other sources when applicable, including for example through publicly available information.

Depending on (i) the products and services provided by HUBLOT and used by you, as well as (ii) how we collect your personal data and (iii) your choices (e.g. in relation to cookies and other tracking technologies), we collect and process the following personal data.

During the course of our relationship, we collect personal information such as:

•    Your name ;

•    Postal address ;

•    E-mail address ;

•    Telephone number ;

•    Payment details, including any bank account details (when you initially provide or update your payment information);

•    Your preferences and interests ;

•    Your date of birth; and

•    ID information (such as a copy of your ID card or passport) when necessary for anti-fraud purposes and compliance with applicable laws and regulations.

If you fail to provide us with necessary personal data that we have requested: Personal data that is necessary for us to fulfil the purposes that are described in this Policy (see clause 3) is marked with an asterisk on the various pages of the Websites and/or underlined as required upon any contact you have with HUBLOT. Should you not fill in these mandatory fields or otherwise provide us with this information, HUBLOT may not be able to take care of your requests and/or provide you with the requested products and services. Other personal data you would communicate to us is purely optional and allows us to know you better and to improve our communications and services accordingly.

We also collect and process information relating to:

•    Where you send us emails, texts or other electronic communications, all information and documents contained in the communication, in particular, to resolve your inquiries or otherwise assist you; 

•    Your purchases online or in HUBLOT boutiques (such as number and references of products purchased, prices, etc.) or the provision of after sales services; and

•    Your image when you visit our stores (when CCTV cameras or other surveillance technologies are in place) or your voice when you call our customer service (you will be informed beforehand and be given the possibility to let us know if you do not want the call to be recorded).

When you access, visit or browse our Websites, or receive and/or respond to an e-mail from us, we automatically collect information about what you have accessed and your actions.

The types of information collected when you access, visit or browse our Websites include your IP address, your device or browser type, the webpage you visited before accessing our Websites, identifiers associated with your devices, as well as any log information from servers and other network devices and activity on and interaction with our Websites. This information enables us to analyse how the Websites are being accessed and used, and to track performance of the Websites as well as of any service offered on or through the Websites and to enhance your experience when using our Websites.

When you receive and/or respond to an e-mail from us, we may collect information about whether you have opened the e-mail and whether you click on any links to measure engagement with our content.

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

Cookies and similar technologies: All of the information described above is collected automatically through cookies and other similar technologies. In particular, we use performance and tracking cookies, functional cookies, strictly necessary cookies, browser cookies and web beacons (see clause 4). We also use Google analytics cookies (see clause 5).

We receive information from your profile when you interact with us through a social media platform (e.g. when you like or comment on a social media post).

When you have a public social media profile (Facebook, Instagram, etc.), we may collect data that you publicly share on the social media platform as well as any information that is part of your profile or that you allow the social media platform to share (name, electronic address, gender, profile picture, user code, list of friends or contacts, etc.).

You should at all times be aware of the terms of use and privacy policy that applies to the third party social media platform.

We use the data and information collected on you for the purposes specified at the time of collection or hereafter in this Policy, including to:

•    Enable you to create and manage a HUBLOT account;

•    Contact you and manage our relationship with you, respond to your queries and complaints and otherwise assist you, including through our customer service;

•    Pass or answer and manage any order that you may have placed or otherwise done with HUBLOT, including in our HUBLOT boutiques or on our online shop;

•    Deliver products to you or provide you with products and services that you have ordered from us and fulfil any contract with you, including to provide you with repairs and after sales services;

•    Take steps to facilitate payments for products and services, including to prevent fraud and identify and prevent payment defaults;

•    Send you our newsletter and/or other direct marketing messages in relation to our products, offers, events, activities or services, in particular to inform you of any new products or services that may be of interest to you or of invitations and other publications (direct marketing messages will be send by email, text, telephone or post);

•    Identify and understand your preferences and wishes and those of others, including through the use of information about your transactions such as the type of products you buy, amount and value, as well as information relating to your profile, to improve and personalize your experience and communication with us and/or to suggest you offers tailored to your needs (e.g. to send you personalized marketing communications by emails, on our Websites or other places such as social media platforms);

•    Enable you to partake in a prize draw, competition or complete a survey;

•    Notify you of any changes in relation to our services and/or products and terms;

•    Prevent how many watches of a particular type you can purchase on our Website, if we have implemented restrictions on purchases of our watches (e.g. where we release limited editions). If you are prevented from purchasing a watch and you do not believe that you have exceeded the applicable purchase restrictions, you can contact Customer Services or mydata@hublot.com ;

•    Manage and operate our Websites, including to keep them updated and relevant, to develop our business and to inform our marketing strategy;

•    Monitor use of our Websites;

•    Personalize your use of the Websites;

•    Operate our pages on social media platforms;

•    Use data analytics to improve our Websites, products and services, marketing, customer relationships and experiences;

•    Track your behavior across different sites in order to display personalized advertising to you through the use cookies and other tracking technologies;

•    Monitor customer accounts to prevent, investigate and/or report fraud, misrepresentation, security incidents or crime, in accordance with applicable law;

•    Take appropriate measures where we become aware that a person has been involved in fraudulent or illegal activity in relation to our products, services, trademarks or otherwise, including to refuse access to an individual to our Websites and stores;

•    Verify your identity, notably for ensuring the security of our services and data or for complying with legal obligations ;

•    Bring or defend against legal proceedings, to assert or defend HUBLOT’s rights or to communicate with legal bodies and other authorities in relation to the same;

•    Ensure security in our stores and measure the traffic in our stores, including by implementing CCTV and other surveillance technologies; and

•    Comply with legal and regulatory requirements.

4.1 WHAT ARE COOKIES?

Cookies are small text files which are placed on your computer or mobile phone when you visit a website or app. They are widely used in order to make websites and apps work or to work more efficiently.

The cookies help websites and apps to recognize your device and remember information about your visit (e.g., your preferred language, font size and other preferences). Most web browsers are set up to accept cookies, although you can reset your browser to refuse all cookies or to indicate when a cookie is being sent, as mentioned under clause 4.3 hereunder. Note, however, that some portions of the Websites may not work properly if you refuse cookies.

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

We have referred to cookies and other similar technologies together as “cookies” in this Policy.

We use cookies to allow us to operate the services as you have requested, facilitate your navigation on our Websites and the use of their features, so as to provide you with a seamless experience.

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

We use a third party provider OneTrust to manage cookies and enable you to make choices in relation to cookies. You can choose the cookies that we use by accessing the OneTrust cookie preference centre when you first access our Websites or by clicking below.

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

•    Chrome 

•    Internet Explorer

•    Mozilla Firefox 

•    Safari 

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

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

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

As mentioned under clause 4 above, you may deactivate the use of cookies by using the button set out in clause 4.3 or through your browser settings.

If you want to opt out of Google Analytics, you can install the Google Analytics browser add-on at https://tools.google.com/dlpage/gaoptout.

We do not retain personal data longer than necessary for the purposes stated and to comply with legal requirements, unless otherwise agreed to by you. At the end of the applied retention period, we shall delete your data.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

Your personal data shall be processed by HUBLOT SA, and/or by any of its affiliates distributing HUBLOT products and services. It may be transferred or otherwise shared with HUBLOT SA and its affiliates distributing HUBLOT products and services, for purposes of managing and improving our customer and prospective customer relationships (for example, when you visit a HUBLOT store in another country, the HUBLOT affiliate in that country can access your customer account), as well as to send you information about the products, offers, events, activities or services in the limits of your consent or applicable lawful grounds.

It may also be transferred in case of a reorganization of HUBLOT, including merger, takeover, de-merger, and in general any reorganization operation, depending on the nature of the reorganization.

Your personal data may also be transferred to the following third-parties: 

•    Third-party providers we work with, including in relation to the services offered on the Websites, especially any IT service suppliers, consultants, providers of hosting and maintenance services of the Websites and any third party processing personal data on our behalf, as well as any postal and payment service providers, in order to fulfil and execute any order that you have placed on or through the Websites, or more generally in the context of our relationship. 

•    Third-party subcontractors, in order to provide you with the product, service or information you asked for, as well as assist us with customer service; such third-parties include for example carriers as well as payment and fraud management service providers. 

•    Third parties who assist us to display interest-based advertising based on the data collected from you and/or through your use of the Websites; 

•    Any person or entity required by law or judicial order: we may disclose your data to third parties if we determine that such disclosure is reasonably necessary to comply with the law, protect our rights or prevent fraud or abuse. When we receive law enforcement or national security requests for information, we scrutinize such requests carefully, especially if they are vague, overly broad or otherwise unlawful. When legally permitted and reasonably possible, we may provide you with notice that your information is being requested. In any case, both the assessment of the request as well as the possibility to inform you of it are at our sole discretion and may not make us liable from a civil, criminal or administrative point of view.

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

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

TRANSFER OF YOUR PERSONAL DATA TO SOCIAL MEDIA PLATFORMS AND OTHER MEDIA PLATFORMS

As mentioned above in clause 3, we display content and advertisements about HUBLOT products to individuals on social media platforms and other media platforms, including those operated by Meta (Facebook, Instagram), Tiktok, Snapchat, Pinterest, X (ex-Twitter), Google (Search, Shopping, Display, Youtube) and LinkedIn by using “custom audiences” services provided by those companies.

In order to do so, we will include your first name, last name, email and/or phone number in custom audience lists that we will create. Such lists will then be hashed (so that information are rendered unidentifiable at an individual level) and securely transferred to social media platforms so that it can be matched with the data already held by those platforms. If you are a user of certain of those social media platforms, you may then start seeing advertisement content regarding HUBLOT’s products on those platforms. We also target ads at individuals on those platforms who have a similar profile to our customers. In order to do this, we provide the personal data listed above to those platforms so that they can find individuals with a similar profile who may be interested in our products and services.

You can object to this processing at any time by contacting us at mydata@hublot.com (see clause 11. Your Rights). You will then be opted-out from our custom audience lists and you will therefore stop seeing targeted advertising about HUBLOT’s products on social media platforms. You can also object to the display of personalized advertising by visiting settings sections about advertising provided by these social media

We share your personal data with our affiliates distributing HUBLOT products and services. This will involve transferring your data outside Switzerland, the European Economic Area or the UK.

In this context, your personal data may in particular be accessible from the following countries: Australia, Canada, France, Austria, Germany, Japan, South Korea, Spain, Portugal, Switzerland, United Kingdom, United States and Italy.

Some of our external third parties are based outside Switzerland, the European Economic Area or the UK.

Whenever we transfer your personal data out of Switzerland, the European Economic Area or the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

•    We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

•    We may use specific approved contracts which give personal data the same protection it has in Switzerland, the European Economic Area or the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Switzerland, the European Economic Area or the UK.

We apply the principles of data protection by design and by default and implement appropriate technical and organizational measures to ensure that we process the minimum amount of personal data necessary for our purposes as well as to ensure the security of personal data that we process. Only personal data which are necessary for each specific purpose are processed by us and all access to your personal data are limited to what is required for the purposes detailed under clause 3 of this Policy.

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

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

Regarding cookies: you can click the button in clause 4.3 above to change your settings at any time. You can also set your browser to refuse all or some browser cookies, or to alert you when cookies are being used, as mentioned under clauses 4 and 5 above.

You may agree to receive marketing communications from HUBLOT, including information about products, offers, events, activities or services. If you decide that you no longer wish to receive such marketing communications, you can subsequently unsubscribe as follows:

•    By following the instructions provided in every emailing communication;

•    Through the CONTACT US page on the HUBLOT website;

•    Through your HUBLOT account; or

•    By contacting us at mydata@hublot.com.

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

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

You also have the right to request that we: 

•    Correct or erase your personal data or restrict the processing of your data; 

•    Transfer your personal data to a third-party in certain circumstances; • Where we are processing personal data based on your consent, you have the right to withdraw consent at any time; 

•    Stop using your personal data to build up your client profile; in this case you will no longer benefit from customized offers or services; 

•    Stop sending you marketing communications, including information about our products, offers, news, events or services; 

•    Stop using your personal data in relation with “custom audiences” services provided by social media platforms and other media platforms, as further explained in clause 7 above; or 

•    You have the right to object to our processing of your personal data for direct marketing purposes or where we are relying on the legitimate interests legal basis to process your personal data.

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

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

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

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

If the Regulation (EU) 2016/679 (“General Data Protection Regulation”) applies to the processing of your personal data, we have set out below a description of the legal bases that we rely on for each purpose. Where we have referred to more than one legal basis and you would like further information about the legal basis relied on, please contact us at mydata@hublot.com. You can also contact your data protection authority if you have any concerns regarding our processing of your personal data.