ADVISORY ON THE PROCESSING OF PERSONAL DATA

WHO WE ARE

Hausmann & Co. S.r.l., with registered office in Via del Corso 406, Rome (hereinafter the “Company”), in the conduct of its business, pays the utmost attention to the security and confidentiality of the personal data of its customers.

This Policy is issued, in accordance with article 13 of the Regulation (EU) 2016/679 (General Regulation on the Protection of Data, hereinafter “GDPR”), by the Company also in the name and on behalf of the other companies of its group (hereinafter, collectively “ Hausmann”) and is intended to illustrate the methods and purposes of the processing of personal data collected by Hausmann through this internet site (hereinafter “Website”) or in the conduct of its relations with customers (including by telephone), at its sales outlets or as part of events organised or managed by Hausmann.

WHICH PERSONAL DATA CONCERNING YOU MAY BE COLLECTED

The following categories of personal data concerning you may be collected:

• Personal and contact details – information about your name, surname, place and date of birth, tax code, address, telephone number, mobile number, email address.

• Identity document – in the purchase phase or managing repairs, we may have to collect the data given on your identity card or another identifying document in accordance with the applicable regulations.

• Bank details – information regarding the payment system chosen by you (including cheque, current bank account, credit card) in the purchase phase of your merchandise from Hausmann or the management of payment for the sale of a product or service offered by Hausmann.

• Interests – information that you give us regarding your interests, including the products in which you are interested.

• Use of the Website – information regarding the methods by which you use the Website, open or forward our communications, including the information collected through cookies (you can find our advisory on cookies here, which regulates the details).

HOW WE COLLECT YOUR PERSONAL DATA

Hausmann collects and processes your personal data under the following circumstances:

• if you access the Website or download our APP to use the respective functions;

• if you request information or one of our services (including sale, repair or purchase) at one of the Hausmann sales outlet or our Assistance Centre;

• if you contact us through any channel used by Hausmann (including telephone calls, emails, social networks);

• if you take part in one of the events organised or managed by Hausmann;

If you provide personal data on behalf of anyone else, you must ensure, in advance, that those concerned have seen this Privacy Advisory.

We ask you to help us keep your personal data up to date by informing us of any changes.

FOR WHICH PURPOSES YOUR PERSONAL DATA MAY BE USED

The processing of personal data must be authorised by one of the legal prerequisites laid down by the current regulations on matters of the protection of the personal data as described below.

1. Operational management and purposes connected to this in order to enable access to and navigation on the Website.

Hausmann collects the usage data of the Website and any personal and contact details (email address) granted by you through the Website in order to allow you to access and navigate the various sections of the Website as well as sending us your requests.

Prerequisite for the processing: fulfilment of contractual obligations.

The granting of the data is mandatory in order to allow you to access and navigate the Website and to respond to your requests; failing this, we will be unable to do so.

2. Management of relations with the customers as part of the performance of Hausmann’s services.

Hausmann collects the personal and contact details and, in the case of sales, the Bank Data, as well as, where imposed by the applicable regulations, a photocopy of your Identity Document, in order to handle your requests and be able to provide you with our sale, repair and assistance services (including, by way of limited example, billing, credit protection and other administrative, managerial and organisational services required for the execution of the services requested).

As part of this processing activity, in order to handle your requests and provide your with our services (including estimates or repairs), we may need to communicate the aforementioned personal data to the other companies of our Group, such as our Assistance Centre, as well as third parties such as, for example, the watch manufacturing companies that make the products marketed by us, including those with branches abroad.

Prerequisite for the processing: fulfilment of the contractual and legal obligations.

The granting of the data is mandatory in order to allow Hausmann to provide you with the services requested; failing this, we will be unable to do so.

3. Marketing in order to respond to your requirements and provide you with promotional offers in line with your interests

As part of the services referred to in the previous letter b), Hausmann may process your personal and contact details in order to send you marketing communications in line with your interests, by means of automated methods (emails, SMS and other messaging tools etc.) and traditional contact methods (for example, telephone calls with operator) or for market research or statistical surveys, should you grant us the appropriate consent.

It is made clear that Hausmann does not submit your data to completely automated decisions, which produce legal effects that concern you or that impact in a significantly similar way on you, but collects and analyses, through the actions of the personnel assigned to and instructed in the respective processing, the personal data granted by you or deduced from your interests, in order to provide you with the services requested.

Prerequisite for the processing: consent, the failure to provide which shall not lead to any consequences on the contractual relations.

Consent may be revoked at any time by contacting the Company at the addresses given below.

4. Sending Newsletters to provide you with updates on all the news regarding Hausmann’s activities.

Hausmann may process your personal and contact details to send you, via email, generic newsletters on our products, services, activities and initiatives in order to respond to your express request.

Prerequisite for the processing: consent, the failure to provide which shall not lead to any consequences on the contractual relations.

You can at any time ask to no longer receive the newsletter or revoke your consent by contacting the Company at the addresses indicated below.

5. Management of exclusive events organised or managed by Hausmann

Hausmann may process your personal and contact details in order to invite you to exclusive events organised or managed by it in partnership with other watch companies, as well as to enable you to take part in these events.

As part of the aforementioned events, photographs may be taken that could portray you, which Hausmann may publish on its Website or its social channels (for example, Facebook, Instagram, Flickr): in the event you do not intend grant these data to Hausmann, you can decide not to take part in the event, it remaining the case that you may at any time request their deletion by contacting the Company at the addresses indicated below.

Prerequisite for the processing: Hausmann’s legitimate interest in maintaining an exclusive and dedicated relationship with its customers.

You can at any time ask to no longer receive the newsletter or revoke your consent by contacting the Company at the addresses indicated below.

f) Compliance with legally binding requests in order to fulfil a legal or regulatory obligation or provisions of the judicial authority, as well as to defend a right before a court.

Hausmann collects your personal and contact details and your Identity Document data in order to fulfil a legal obligation and/or to defend its rights before a court and, in the cases laid down by the applicable regulations or on the request of the Authority, to communicate the aforementioned data to the latter.

Prerequisite for the processing: legal obligations, by which Hausmann is obliged to abide.

HOW WE KEEP YOUR PERSONAL DATA SECURE

Hausmann uses a vast range of security measures for the purpose of improving the protection and maintenance of the security, integrity and accessibility of your personal data.

Although transmission of data via the Internet or websites cannot be guaranteed to be secure from intrusions, we will act to maintain the physical, electronic and procedural security measures in place to protect your personal data, in compliance with the requirements laid down by the regulations protecting data.

All your personal data are stored on our secure servers (or secure paper copies) and on those of our suppliers or commercial partners, and can be accessed and used on the basis of our standards and our security policies (or equivalent standards for our suppliers or commercial partners).

FOR HOW LONG WE WILL RETAIN YOUR INFORMATION

We retain your personal data only for the time necessary to attain the purposes for which they were collected or for another legitimate, connected purpose. Therefore, if personal data are processed for two different purposes, we shall retain these data until the purpose with the longest term ceases to apply, however we will no longer process personal data for the purpose for which the retention period has expired.

We shall limit access to your personal data only to those who require to use them for relevant purposes.

Your personal data that are no longer necessary, or for which there is no longer a legal prerequisites for their respective retention, shall be irreversibly made anonymous (and, in this way, may be retained) or destroyed in a secure way.

WITH WHOM WE MAY SHARE YOUR PERSONAL DATA

Access to your personal data may be given to duly authorised employees, as well as external suppliers, appointed, if necessary, as data managers, who provide support for the delivery of the services.

Access to your personal data may also be given to other companies of the Hausmann group, for purposes connected to the management of the IT infrastructure, as well as the processing and management of your requests, on the basis of appropriate contractual agreements, subject to your consent (see the previous letters c) and d) of the purposes of the processing), for marketing purposes.

Furthermore, for the purpose of providing you with the Services requested, including the sale and repair of the products marketed by us, we may have to communicate your data to third-party companies, such as watch manufacturing companies, including those with branches abroad (for example, Switzerland).

Please contact us at the addresses given below if you wish to ask to see the list of data managers and the other subjects to whom we communicate your data.

TRANSFER ABROAD

Your data shall mainly be processed by Hausmann within the European Economic Area. In certain cases, however, they may be transferred outside the European Economic Area, should this be necessary for the management of the service requested by you. In this case, obligations will be imposed on subjects receiving the data to arrange equivalent protection and security to that guaranteed by the Data Controller. In any case, only data required for the pursuit of the purposes laid down shall be communicated and, where requested, the guarantees applicable to the transfer of data to third-party countries shall be applied (for example, signing Standard Contractual Clauses).

In this regard, it is made clear that the European Commission has deemed that Switzerland, while being a country outside the European Economic Area, offers similar protection to that laid down by the regulations of the EEA on matters of data protection, and therefore supplementary legal protections are not necessary for the transfer of personal data to that country.

CONTACTS

The contact data of the Company (Data Controller, jointly with the other companies of the Group) to which any request concerning the processing of your personal data by Hausmann can be forwarded are given below:

Hausmann & Co. S.r.l., with registered office in Via del Corso 406, Rome.

email: corso@hausmann-co.com

YOUR RIGHTS IN MATTERS OF DATA PROTECTION AND YOUR RIGHT TO MAKE COMPLAINTS TO THE CONTROL AUTHORITY

Under certain conditions, you have the right to request:

• access to your personal data

• a copy of the personal data that you provided to us (so-called portability)

• the correction of the data in our possession

• the deletion of any data for which we no longer possess the legal prerequisite for the processing

• objection to the processing where laid down by the applicable regulations

• the revocation of your consent, in the case in which the processing is based on consent;

• the limitation of the way in which we process your personal data, within the limits laid down by regulations protecting personal data.

The exercise of these rights is subject to certain exceptions aimed at safeguarding the public interest (for example, the prevention or identification of crimes) and our interests (for example, the maintenance of professional secrecy). In the event you exercise any one of the aforementioned rights, we shall be obliged to check that your are authorised to exercise it and, as a rule, we shall give you a response within a month.

For any complaints or notifications on the processing methods of your data, we shall make every effort to respond to your concerns. However, should you so wish, you can forward your complaints or notifications to the Italian Data Protection Authority, using the relevant contact details, which can be found on the respective website.

This Advisory may be periodically updated and therefore users are advised to consult the document every time they access the Website, for the purpose of being correctly informed about the methods by which the Data Controller uses the personal data and their respective purposes.

The date of the last revision of the most recent version of this Advisory is given below.

Last updating: 30 October 2018