Version: February 2022
1. Primal Policy:
Swarovski Japan (hereinafter `SW-J`) places a high management priority to protect customers‘ personal Information, understanding the importance of properly protecting it, with the following policies.
SW-J will handle Personal Information only within Purpose(s) of Use below and will endeavor to handle it appropriately to comply with the applicable laws and regulations.
3. Consent to Handling of Personal Information Submitted through the Swarovski website/Online Shop
4. Purpose of Use of Personal Information:
Personal Information is stored and processed by SW-J and Swarovski group companies (hereinafter “Swarovski”) including Swarovski headquarters in Europe.
Swarovski may use Personal Information for the following purposes: (1) processing and delivering customers’ purchased goods or awards, (2) offering its related aftercare services, (3) keeping customers informed about Swarovski and Swarovski Group’s market activities, goods, and services, open transactions, (4) conducting questionnaire and market research to improve our website, products and services, and (5) delegating repairs or other logistical tasks to third parties.
In case there is need for other purpose(s) than the ones stated above, except for cases following applicable ministerial guidelines, Swarovski will obtain in advance consent from the customers who provide his/her Personal Information based on the purpose(s) of use.
5. Restriction of use and providing Personal Information:
Swarovski will not use or provide Personal Information for purposes of use which are not specified in Article 3 above, except for cases of legal enforcement for disclosure or for crisis handling such as unauthorized accesses or intimidations.
6. Safety security:
(1) Security Control Measures
Swarovski will take necessary and appropriate security control measures, and will implement corrective actions as needed to protect entrusted Personal Information from leakage, loss, modification, destruction, etc.
(2) Shared use
Swarovski may share Personal Information for the purposes stated in Article 3 with Swarovski Group companies. The information provided by customers will be properly managed by responsible parties respectively.
Moreover, SW-J may share Personal Information (such as name, address, telephone number, etc ) with the department stores or shopping malls (hereinafter “department stores”) where SW-J has its stores.
In the shared use with department stores, in addition to the purposes stated in Article 3, Personal Information may be used for the purposes of shared use stated by the department stores. The shared Personal Information shall be properly managed under the responsibility of SW-J.
Swarovski may subcontract the processing of entrusted Personal Information to a third party within the scope necessary for the achievement of the purposes of use. Such third party will be selected after confirming sufficient level of information security, and Swarovski will exercise necessary and adequate supervision on the party by such means as making contracts.
7. Disclosure of Personal Information
Swarovski will properly respond to comments and requests from customers regarding handling of Personal Information such as to review, to correct, to add, and to delete Personal Information of their own after confirming their identity.
8. Contact address
For information on Swarovski’s personal information data, request for disclosure/correction/suspension, and/or questions/opinions on Swarovski’s data use, please contact the following:
Swarovski Japan Ltd.
Sumitomo Fudosan Fukuoka Hanzomon Bldg. 4F, 1-12-1 Kojimachi, Chiyoda-ku, Tokyo 102-0083
Toll free number: 0120 (10) 8700
9. Continuous Improvement of Internal System
Swarovski will continuously endeavor to improve internal compliance systems.
This policy may be revised without preliminary announcement.
12. SWAROVSKI CRYSTAL SOCIETY (SCS)
The following provisions shall be applicable for the processing of data by SWAROVSKI in connection with the customer loyalty program Swarovski Crystal Society (SCS).
a. Responsible for the Personal Data (Controller)
b. Processing of Personal Data and Source
Swarovski collects and retains the personal obligatory data provided on the SCS application form (including but not necessarily limited to the title, name, contact details, birth date, pre-existing SCS membership number, language preference, order information, as well as the name, contact details and SCS membership number of the gift giver, where applicable) by the SCS Member him or herself or by the person that buys the SCS Membership as a gift and provides Swarovski with the PERSONAL DATA of the SCS Member (“Form Data”). In addition, Swarovski also collects any Personal Data provided voluntarily by the customer in the online member area or when interacting with us: styles/interests (e.g. in Jewellery and Accessories, Home, Figures and Collectables and/or Watches; Classic style), social media accounts (and related information collected through social log-in), gender, IP address and online identifiers.
Swarovski receives such PERSONAL DATA from the points of sale where the membership is ordered and paid. It assigns to each new SCS Member, a unique membership number, tracks the membership start and renewal dates, service and mailing options chosen by the SCS Member, services provided (including gifts sent), and, as the case may be, further data about the SCS Member's use of the Swarovski Group's online offerings and mailings (e.g., newsletter open rate, click rate, visited online web pages, social media interactions), interaction variables (such as click rates, time of interaction or social media interaction). Swarovski may also process payment information, directly or through a third party, where necessary for the payment of SCS Membership fees. Additionally, Swarovski records the purchase history of each SCS Member, in the form of items purchased (product designation, price) and place and time of purchase. The purchase history is recorded only if the SCS Membership number is communicated at the checkout for purchases in stores offering the SCS program. In the online store, a registered customer must activate their account online by setting up an online account. A registered customer’s purchase history is recorded if the account number is quoted when making a purchase or the registered customer makes a purchase when logged into their online account. Swarovski also collects and saves any vouchers sent to the SCS Member and, as the case may be, further data about the SCS member’s use of the Swarovski Group's online offerings and mailings (e.g., newsletter open rate, click rate, visited online web pages, social media interaction). Where Swarovski believes that two different SCS Memberships belong to the same individual, or where a valid request is received, Swarovski may merge them.
c. Purpose of processing
SWAROVSKI collects and processes the personal data of members of the customer loyalty program in particular also for the following purposes:
• administration of SCS memberships;
• operation of SCS, namely providing of advantages and awarding special conditions, participating in surveys, requiring feedback and act in social media,
• Personalization and unification of customer experience across channels (Swarovski stores, swarovski.com, e-mail communication, social media)
• Provision of relevant information and a personalized marketing content
• Provision of personalized offers, assistance and advice regarding products and services
• Provision of invitations to special events and promotions reserved for registered customers
• Participation in surveys, requiring customer feedback across channels (Swarovski stores, swarovski.com, e-mail, social media)
In participating stores, the SCS membership allows SCS members to take advantage of an extended customer advice in which, upon presentation of the account number, the store employee can call up the registered customer’s data and provide the registered customer with additional sales advice based on his or her past purchases, style/interests selected or wish list.
On presentation of the SCS membership number, e-mail address or the registered customer’s name and date of birth (or another unique authentication attribute), the relevant store employee or customer service representative has access to the relevant registered customer’s saved purchase history data and wish list.
The personal data collected is used by Swarovski to administer and manage the Membership (including also for accounting and payment purposes), to provide the Member with the benefits and other services that come with the Membership (the legal basis for this is the Membership) and to provide the SCS Member with commercial communications (such as newsletters, product information, services and exclusive offers of the Swarovski Group) by e-mail, mail, mobile messaging or a phone call based on the contact information provided by the Member (for which Swarovski relies on the SCS Member's consent). In all these cases, SWAROVSKI may personalize the information sent to the Member so that the Member particularly receives, where possible, information which SWAROVSKI considers interesting for the Member. For this purpose, SWAROVSKI analyses the Form Data (and in particular, information as to age, gender, interests and preferences) and other information that can be gleaned from the purchase history, or inferred from interaction data, or has been given to SWAROVSKI by the SCS Member voluntarily at any later time. Furthermore, SWAROVSKI may use the personal data for compliance with its legal obligations and, where it has a legitimate interest, for statistical and research purposes, including for better understanding of SCS Members, consumer and market analysis, improvements to the SCS Program and the development of new products and services.
Non-marketing communication may still be sent if you have opted-out from certain marketing communication as this may be necessary for us to perform a contract with you, to comply with legal obligations or security requirements. Also, we will send you a personal note on your birthday, if you share your date of birth with us.
d. Disclosure of Personal Data
In the course of processing personal data in connection with SCS, SWAROVSKI may namely disclose data to the following categories of recipients:
• PARTNERS, including business, marketing and promotion partners (including social media partners) and all participating retail shops or other authorized specialists dealers, irrespective of whether the company is run by SWAROVSKI or another sales or cooperation partner; whereas these stores may be located within any country worldwide and they may use data received from SWAROVSKI only for the purpose of operating SCS, including personalized offers to and communication with Members on behalf of SWAROVSKI;
• to a SWAROVSKI company to whom the processing of data (operation of the database) regarding SCS has been outsourced in technical respect (processors).
Each recipient may be located in a country without an adequate level of data protection. If that is the case, SWAROVSKI will ensure an adequate level of protection.
e. Rights of Data Subjects
SCS Members and membership gift givers are entitled at any time to ask SWAROVSKI for information relating to their saved personal data, and other information as provided for by applicable data protection law. They also have the right to ask to amend, limit or delete their personal information, or ask for a copy of the personal information.
Swarovski registered customers may also revoke any consent they have provided to Swarovski (e.g. to be used for promotional, advertising purposes and receive newsletters and other commercial communications) for the future.
If you want to exercise any of your rights regarding newsletter subscriptions, data access or data deletion, please do not hesitate to contact our Customer Care team at firstname.lastname@example.org, who will be happy to answer any questions you may have. Please note that we may require you to verify your identity before allowing you to access your personal information.
f. Data Retention
Personal Data will be held and used for the duration of the Membership; thereafter, it will be retained as long as necessary for the aforementioned purposes, but not for more than five years, unless required for legal reasons. The purchase history is generally recorded for five years. As exception to this rule, the purchase history on SCS exclusive products will be kept during the entire duration of the Membership in order to recognize member life-time value to the Society. Should a SCS Member not wish to have his or her SCS exclusive product history stored above 5 years, he/she can request deletion by contacting informing of his/her explicit wish to have this history deleted Further information regarding SCS can be found in the General Terms and Conditions of the customer loyalty program on www.swarovski.com.
g. Updates and Additional Information