HUBLOT PRIVACY POLICY - USA

This Privacy Policy (the “Policy”) is intended to explain to “You” HUBLOT S.A.’s (“the Company,” “our,” “us,” or “we”) practices concerning the protection and collection of personal data collected in our stores located in the U.S. (“Stores”) and our websites and apps owned and operated by the Company in the United States (collectively “the Website”). This Policy does not apply to any non-U.S store, websites, or applications operated by HUBLOT. This Policy allows you to learn more information about how we use the personal data you provide to us, the nature and use of navigation information processed when you visit the Website, and about your rights.

This Policy, along with the Terms and Conditions of the Website, govern the use we make of your personal data and personal data collected and processed when you visit the Website. By using the Website, you fully accept the terms of this Policy.

The Company reserves the right to modify or update the Policy from time to time and the changes will be applicable immediately. The date of the last version of the Policy is displayed at the bottom of this Policy.

PROTECTION OF YOUR PERSONAL DATA

HUBLOT undertakes to preserve the confidentiality of any information provided by you. Furthermore, you may have the right to gain access to any information that concerns you, to have that information rectified and to have that information removed by sending an email to the following address: mydata@hublot.com.

GENERAL INFORMATION

We respect the confidentiality of any personal data that you may provide to us. “Personal data” refers to any information that identifies or could reasonably identify you, and may include things such as your email address, physical or mailing address, or mobile phone number.

Personal data will be collected during visits to the Website and Stores according to your interaction with our services and features. The Company is the party responsible for processing your personal data and is also the party who controls and manages the personal data collected and processed, the objectives of the processing and its conditions, the scope of communication of personal data to third parties, the data protection measures taken to protect and save data, and how you can check the processing of your data and enforce your rights.

THE PERSONAL DATA WE COLLECT

The following provides examples of the type of information that we collect from you and how we use that information.

Account Registration. We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account. We use this information to provide account related functionalities to our users. Accounts can be used for easy checkout and to save your preferences and transaction history.
Client Information. We collect the name, and contact information, of our clients and their employees with whom we may interact. We use this information to contact our clients and communicate with them concerning normal business administration such as projects, services, and billing.
Cookies and first party tracking. We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our Cookie Policy for more information. We use this information to ensure our website operates efficiently.
Cookies and third party tracking. We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. See our Cookie Policy for more information. We use this information to engage in behavior-based advertising and capture website analytics.
Demographic Information and Preferences. We may collect personal information, such as your age, location, gender, and interests. We use this information to better understand our customers and offer more personalized experiences.
Distance Information. When you use our Website we may collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location and your distance from a store that sells our products. We use this information to understand our users and provide tailored services. In some contexts our use is also based upon your consent to provide us with geo location information.
Email Interconnectivity. If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. We use this information to understand how you interact with our communications to you.
Feedback/Support. If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. We use this information in order to receive, and act upon, your feedback or issues.
Mailing List. When you sign up for one of our mailing lists we collect your email address or postal address. We share information about our products and services with individuals that consent to receive such information. We also use this information to share information about our products or services.
Mobile Devices. We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or when using our application. We use this information to identify unique visitors and understand how users interact with us on their mobile devices.
Order Placement. We collect your name, billing address, shipping address, e-mail address, phone number, and credit card number when you place an order. We use your information to perform our contract to provide you with products or services.
Photographs. We may collect your photograph when you create an account. We use this information to personalize your account.
Website interactions. We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. We use this information to understand how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also use this information to detect and prevent fraud.
Surveys. When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. We use this information to understand your opinions and collect information relevant to our organization.
Video Footage. We may collect audio and visual information when you visit one of our stores. We use this information to understand your opinions and collect information relevant to our organization.>
Web logs. We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. We use this information to monitor our networks and the visitors to our websites. Among other things, it helps us understand which of our products or services is the most popular.

HOW WE COLLECT PERSONAL DATA

The Company collects and processes personal data voluntarily communicated by you when you:

• Visit the Website
• Make a purchase on the Website
• Visit our Stores
• Make a purchase in our Stores
• Participate in any of our events
• Participate in any of the activities offered by the Website (such as a survey or posting to a chat area)
• Register for an account on the Website
• Request information about the Company or
• Request information or ask a question about our products.

The Company also collects and processes personal data through our use of in-store video footage as well as through cookies and other tracking technologies. See the Cookies section below for more information.

HOW WE USE YOUR PERSONAL DATA

Some of the personal data we collect is essential for processing your requests (mainly your first and last names, postal addresses, email addresses and telephone number). With your consent, the Company also may use your personal data for marketing purposes which means you may be sent promotional information and information about the Company’s products, such as promotions, special events, exhibitions and fairs organized by the Company or in which it participates, and to conduct surveys and polls. These marketing communications are sent by email, SMS and MMS.

The Company also uses your personal data to:

• Improve the services on the Website
• Improve our Stores
• Manage your newsletter subscription
• To compile anonymous statistics on visits to our Website
• Enable access to certain functionalities on our Website
• Conduct certain customer profiling or analysis
• To manage customer satisfaction regarding products, services or contents
• To protect against fraud and identity theft and to comply with and enforce applicable legal requirements, relevant industry standards, and our policies, including our Terms and Conditions.

You can withdraw your consent at any time and free of charge regarding the use of your personal data for marketing purposes, either by clicking on an unsubscribe link in any email communication or by sending an email to mydata@hublot.com.

The personal data collected by the Company is mainly processed via automatic electronic procedures for the uses noted above, but also via non-electronic procedures for the duration strictly necessary to fulfil the processing objective in question and pursuant to applicable law.

COOKIES

The Website uses "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Website server. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you register with the Website, a cookie will help the Company recall your specific information on subsequent visits. This simplifies the process of recording your personal data, such as billing addresses, shipping addresses, and so on. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the Website features that you customized.

We may use the following types of cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our Website. This includes, for example, cookies that enable you to log into secure areas of our Website.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. Functional cookies 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.
• Targeting cookies. These cookies record your visit to our Website, the pages you have visited, and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. For more information on tracking cookies, please visit the Internet Advertising Bureau’s guide at http://www.youronlinechoices.eu.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Company’s services or the Website.

DATA RETENTION SITE

Personal data collected will be retained and processed via an electronic system managed by the Company, located on the premises of the Company as indicated above. The Company currently uses a third party for hosting and your personal data is currently collected, stored and maintained on the third party’s servers in the European Union although this location may change over time. For up to date information on the location of our servers (or those of our service providers), please email us at mydata@hublot.com. Moreover, the Company may, directly or through third parties, provide technical management and maintenance services for the Website. Other companies belonging to the Hublot group may participate in the processing of data as part of the functioning of the Website and the provision of services and features offered by the Website.

PERSONAL DATA SECURITY AND QUALITY

The Company undertakes to protect the security of the user’s personal data. Personal data is processed by the Company pursuant to the security provisions provided by applicable law in order to prevent the loss and destruction, even accidental, of data, unauthorized access to the data, and illicit or dishonest use of the data. Moreover, the information systems and software are configured so that the personal and identifying data is only used if necessary for the processing objectives in question. The Company deploys all commercially reasonable security procedures and technology to help protect the user's personal data against the risks described above. However, the Company cannot control all risks associated with the operation of the Internet, and draws your attention to the likelihood of risks incurred in its use and operation. As a result, we cannot ensure the security of any information you submit and you transmit all information at your own risk. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

You must put forth your best effort to help the Company to keep updated and maintain the accuracy of the personal data that you communicate to the Company by notifying us of any change in your address, title, telephone number or email address. Please email any changes to mydata@hublot.com

We will keep your personal. data for as long as we have a business need and purpose to retain your personal data, including storage for archival purposes. When we believe we no longer need such personal data, we will destroy or otherwise dispose of your personal data in a manner intended to preserve your privacy and security and as required by applicable law.

SCOPE OF DATA COMMUNICATION/DATA RECIPIENTS

In all cases where the Company communicates your personal data to a third party (as permitted hereunder), the Company will implement, pursuant to applicable law, reasonable and appropriate security measures to guarantee users an adequate level of protection for the personal data concerning him/her. The Company shall communicate the user's personal data within the limits and circumstances provided under this Policy.

Your personal data will be accessible to in-house and external Company personnel needing to access it as part of his/her job in connection with the processing objectives specified herein, and by subcontractors or independent contractors to the Company, if applicable. Your personal data may be communicated to professionals, independent consultants, including collaborators, commercial partners and third party service providers that the Company may hire to provide professional, technical and organizational services as part of the management of the Website and the activities associated therewith (including marketing or advertising assistance, analyzing user content, and processing payment card information).

When you choose to “find a boutique” near you, we will share your personal data with Google Maps, which is subject to the current versions of the: (1) Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html; and (2) Google Privacy Policy at https://www.google.com/policies/privacy/.

Your personal data may also be communicated to other companies belonging to the Company’s group that will process the data pursuant to the applicable legal provisions, and to third parties in the event of merger, acquisitions, capital, product, site or operations transfers or any other similar transaction, including at the negotiation stage.

Third parties to whom we disclose data have agreed with us that they will only use the data received for the specific purposes relevant to them and will ensure security and confidentiality.

We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.

With the exception of the foregoing, your personal data shall not be shared with third parties, individuals or legal entities that are not concerned with or that do not carry out any commercial, professional or technical function for the Company. The Company will not sell personal data.

Your personal data may also be communicated to any person who is the legitimate recipient of communications, pursuant to the applicable law and regulation, for example, in the case of legal proceedings, requests made by the courts and competent authorities or pursuant to any legal obligation of the Company, or to exercise, protect or defend the Company’s rights and assets. We may also share personal data with law enforcement agencies if we reasonably believe unlawful activities have occurred or the personal data may aid in an ongoing investigation. We may also share personal data with law enforcement if we determine, in our sole judgment, that you have violated our agreements or policies or that the release of your personal data may protect the rights, property, interests, or safety of the Company or any third party.

SOCIAL MEDIA SHARE BUTTONS

You can share some information or content found on the Website on social media (like a product sheet). By clicking on the “like” or “share” buttons on Facebook or any other share button of any other social media site (Twitter, Pinterest, Instagram, etc.), the content is exported from the Company’s servers and uploaded on that social media’s website.

The use of that content is then governed by the privacy policy and terms and conditions of that third party social media site and not by the Company. We encourage you to consult the terms and conditions and privacy policy of that social media site carefully. Export of content from our Website to another social media site is done at your own risk. In no event, shall the Company be held liable for any use or action of that content once it is exported.

This Policy does not apply to websites or applications offered by other organizations or individuals that may be displayed as content in a search on the Website. The Company encourages you to read the privacy policy and terms of use applicable to any such third party website or application before transmitting any personal data.

DISCLOSURE OF PERSONAL DATA

With the exception of the foregoing concerning browsing data, the disclosure of personal data by you is necessary for the provision of the services and features offered by the Company that you request, for example, your registration with the Company, the management of products purchased by you and related activities, the interaction of the user with the call centre and the communication to the Company of information necessary for the Company to respond to information requests. In the aforementioned cases, your refusal to communicate personal data will prevent the Company from respecting its contractual obligations or providing you with the services, products or information requested as specified above. The communication by you of your personal data for marketing purposes is optional and your refusal to disclose personal data for marketing purposes shall have no consequences. We do not knowingly sell the personal information of minors under 16 years of age without affirmative authorization.

USER RIGHTS

At any time, you may exercise your rights under applicable law, including:

1. Access To Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
2. Changes To Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
3. Deletion Of Your Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
4. Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below. You may only oppose the processing of data for legitimate reasons.
5. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
6. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
7. Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
8. Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us at the address below. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
9. Revocation Of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

Note that, as required by law, we will require you to prove your identity. We may conduct an identity verification by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

Authorized Agent

You may use an authorized agent to submit a request to access your information, delete your information, or opt out of the sale of your information. To designate an agent for these purposes:

1. You must provide us with a copy of a written and signed permission given to your authorized agent; and

2. You must verify your own identity directly with us.

To exercise you rights and for any question concerning the processing of personal data by the Company, please may contact the Company by email at mydata@hublot.com.

NOTICE TO CALIFORNIA RESIDENTS

Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with the Company are entitled to ask us for a notice describing what categories of personal data we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with third parties and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to us by post or email at the address listed above.

California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose”(as those terms are defined under California law). You can find a list of the categories of information that we collect and share in the California Information Sharing Disclosure appendix available below. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.

If you are a California resident under 18 years old and a registered user of the Website, you can request that we remove content or information that you have posted to our Website. Please note that responding to your request may not ensure complete or comprehensive removal from our Website (e.g., if the content or information has been reposted by another user). To request removal of content or information, please contact us at the address or email above.

Policy Last Updated: April 2020