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Privacy Policy (Thailand) 

THAILAND GENERAL PRIVACY POLICY

This Thailand General Privacy Policy (“Privacy Policy”) applies to all personal data collected by  Swarovski (Thailand) Co. Ltd. and their related corporations ("Swarovski"), including without limitation, by way of this Website, and explains how we handle personal data and comply with the requirements of applicable privacy laws.

This Privacy Policy applies in addition to (where applicable) the privacy policies specific to the Swarovski Crystal Society (“SCS”) or Swarovski Club programs.

If there is any inconsistency between any of the provisions in this Privacy Policy and the provisions of the privacy policies specific to the SCS or Swarovski Club programs respectively, the provisions of this Privacy Policy shall prevail.


Collecting your personal data

We collect personal data from customers (existing and prospective), suppliers, contractors, employees and prospective employees, service providers, business partners, consumers, website users, visitors and other individuals for various business and other purposes further listed below. In this section, we explain the types of personal data which we usually collect as well as how we collect this information.

The type of information Swarovski may collect from you will depend on the circumstances in which that information is collected. It may include, for example, the following personal data:
•    General information: such as your name, surname, age, date of birth, gender, region of origin, picture/photo at events and/or special activities, signature, information on or a copy of government issued documents (e.g., national identification card, passport, house registration);
•    Contact details: such as email address, home address, shipping address, billing address, phone number, social networking profile details;
•    Information related to orders: such as products and services ordered, information on purchase orders/repair orders, respective contract;
•    Business related information: such as title, information on or a copy of company registration certificate, VAT registration certificate, power of attorney letter, scope of work, information on purchase orders;
•    Financial related information: such as bank account information, payment related information, credit/debit card information, where necessary to effect a purchase, exchange, return or similar transaction;
•    Behavior information: such as participation at events and special activities, purchase history, spending habits, responses to customer satisfaction survey;
•    Membership or loyalty program information: such as membership numbers, level, privileges redeemed, information related to membership (e.g., join date, expiration date);
•    Other information: such as feedback or complaints, correspondence, footage from CCTV (i.e. moving or still images, and voice of you or your belongings), relationship with us, information related to your visit to our premises or premises of our business partners (e.g., where you are our service provider assisting us in providing support services to our business partners); and
•    Sensitive personal data: data (as contained in the national identification card in certain cases) and] health information (i.e., COVID-19 screening information, including body temperature and ATK test results).

In particular, Swarovski may collect personal data:
•    when you contact us or our authorized retailers with queries or issues, such as through Service Now: our customer help desk;
•    when you participate in our promotions or competitions;
•    when you fill in questionnaires, surveys or contact forms;
•    when you register or provide your details with or to us or our authorized retailers;
•    when you submit information through this Website (such as when you set up a user account, retrieve log-in information, make online orders or purchases or enter into other online transactions), our social media channels or our procurement system;
•    when you join the SCS, Swarovski Club (or similar membership groups);
•    when you use this Website, in which case our system may automatically collect information relating to your visit to this Website, such as your IP address; 
•    when you visit our premises and/or offices (such as via CCTV); or
•    when you correspond with us and/or interact in the course of our businesses.

If you do not provide Swarovski with all requested personal data, we may be unable to assist you or provide you with our products and/or services, you may not be able to participate in our promotions or competitions or you may be unable to join the SCS, Swarovski Club (or similar membership groups), or we may not be able to continue business relationship we have with you.

Where practicable, we will collect personal data directly from you. In certain circumstances, we will collect your personal data from other sources, such as through companies in our Swarovski Group globally (“Swarovski Group”), including Swarovski Kristallwelten (Crystal Worlds), our business partner (e.g., partner department store, where you purchase our products and/or services through such business partner), our service provider, other third parties (e.g., banks and financial institutions), your reference persons or publicly available sources.

Personal Data of other individuals
In the event that you have provided personal data of any third party individuals to us (e.g., personal data of directors, manager or other persons who have executive power in your company or other employees of your company) or you request us to disclose personal data of such individuals to other third parties, you are responsible to inform such individuals of this Privacy Policy, and obtain consent where applicable or necessary when other legal basis cannot be relied on, in order to permit us to legally process their personal data in accordance with this Privacy Policy. You should ensure that the personal data provided to us is accurate and complete. You are also responsible for updating us on any changes to such personal data.  

Our use of cookies
Cookies are pieces of information that a website transfers to your computer's hard disk for record keeping purposes. Most web browsers are set to accept cookies. Swarovski uses cookies to make your use of this Website, resources and services as convenient as possible. Cookies in and of themselves do not personally identify users, although they do identify a user's browser. Cookies are useful to estimate our number of users and determine overall traffic patterns through this Website. We use the following cookies on our website:

Necessary Cookies: The data these services collect is necessary for the technical performance of the website, to provide basic shopping functions, as well as for security and fraud prevention purposes.

Statistics Cookies: Analytical cookies, including third-party cookies (like Google Analytics), help us to understand how users navigate and interact with our website. These cookies do not contain any information about your identity. The information is processed in an aggregated and anonymous form.

Personalization Cookies: Based on your interactions with the site, brand preferences, and shopping affinities, we can show you personalized content that fits your preferences.

Marketing Cookies: These cookies can be set by our advertising partners, via our website, and may be used to create a user profile based on your behaviour on our website in order to show you relevant advertisements on other websites. They work by clearly identifying your browser or your end device.

If you do not wish to receive any cookies, you may set your browser to refuse cookies, but this may mean you will not be able to take full advantage of the services and resources on this Website.

Use, processing and disclosure of your personal data
We will only collect, use, process and disclose your personal data in accordance with applicable privacy laws, this Privacy Policy and (where applicable) the privacy policies specific to the SCS or Swarovski Club programs (collectively, our “Privacy Policies”).

Except in limited instances where we can only use your personal data with your consent, we collect, use, process and disclose your personal data on the legal basis of (i) pre-contractual and contractual basis, for our initiation or fulfilment of a contract with you; (ii) legal obligation, for the fulfilment of our legal obligations (iii) legitimate interest, for the purpose of our legitimate interests and the legitimate interests of third parties, to be balanced with your own interest and fundamental rights and freedoms in relation to the protection of your personal data; (iv) vital interest, preventing or suppressing a danger to a person’s life, body or health; (v) the reason for an establishment and defence of legal claims; and (vi) the necessary for compliance with a law to achieve the purposes with respect to public interest in public health, for the purposes defined below.

Our purposes in collecting, holding, using and disclosing information about you are to:
•    develop, enhance, market and provide you with our products and/or services (including repairs and returns);
•    process and complete the transactions, including deposit orders (e.g., account registration, order confirmation, billing, products and services delivery, reparation, after-sales services);
•    issue and deliver relevant documents (e.g., invoice, tax invoice, purchase requisition, purchase order, etc.);
•    respond to your queries if you are seeking information about our products or services;
•    handle complaints, investigations, litigation, or other legal proceeding;
•    communicate with you or support you about our products and services, marketing campaigns, our business relationship or relationship with your company;
•    manage our relationship with you and/or comply with your request;
•    conduct promotions, competitions, events and special activities;
•    conduct market research and analysis;
•    conduct lead generation;
•    process and assess employment applications;
•    verify and authenticate identity/information/documents in relation to business operations;
•    enforce agreements between you and us;
•    keep you informed about our activities, products and services;
•    allow you to join and participate in the SCS, Swarovski Club and other similar Swarovski-related memberships and to ensure the fulfilment of your membership privileges;
•    Personalization of marketing content, offers and the customer experience across channels (Swarovski stores, swarovski.com, e-mail communication, social media) 
•    comply with legislative, regulatory requirements and/or internal policies;
•    support law enforcement organizations;
•    assist in the effective resolution of disputes;
•    conduct and maintain the internal business management (e.g., preparation of internal report);
•    operate our business efficiently;
•    create, develop, operate and deliver and improve our products and services;
•    create, develop, maintain and update information in relevant directories/databases;
•    facilitate customers in claiming benefits under the government's economic stimulus campaign, including report information required according to campaign terms and conditions to the relevant government authorities/officials;
•    manage access to our premises and/or offices, including the use of CCTV;
•    screen for COVID-19 when you visit our premises and/or offices;
•    establish, exercise, and defend legal claims;
•    detect and prevent any crime and fraudulent activities;
•    prevent or suppress danger to a person's life, body, or health;
•    perform, develop, implement, operate and maintain our IT system; and
•    transfer personal data in our possession or under our control in the event of business reorganization or other disposition of our business.

In addition, we also use, process and disclose your sensitive personal data for the following purposes:
•    Health information: to screen for COVID-19 when you visit our premises; and to disclose your health information to our business partners, who own the premises that you will visit as part of your responsibilities, to request entry approval according to the premises owner’s policy regarding the prevention of contagious diseases (e.g., where you are our service provider assisting us in providing support services to our business partners).

If you are our suppliers, contractors, service providers, business partners, or other persons who provide their products and services to us, your personal data will also be processed to:
•    process procurement procedures, including vendor check (e.g., check for qualification, financial status, conflict of interest, Anti-Money Laundering and Counter-Terrorist Financing Ordinance, etc.), vendor selection procedures, bidding procedures, negotiation prior to contract signing, entering into a contract (and/or relevant juristic act) and contract management, payment procedures, and deliverable inspection and signed-off;
•    create vendor blacklist (e.g., for those who abandoned the work);
•    facilitate vendor to work efficiently; and
•    where relevant, disclose your personal data to our business partners, who own the premises that you will visit as part of your responsibilities, to request entry approval according to the premises owner’s policy.

Swarovski may also use and/or process aggregated, anonymous data about its customers and/or website users as a group, for Swarovski's business purposes.

In carrying out our business, it may be necessary to share information about you with and between companies in Swarovski Group, [our authorized retailers], organizations that provide services to us (e.g., banks and financial institutions, payment service providers, SMS service providers, storage vendors, event organizer, social media agency), government authorities/officials (e.g., court, Police Department, Legal Execution Department, Thai Industrial Standards Institute (TISI)) and other third parties (e.g., individuals requesting CCTV footages, our advisors and auditors, our business partners and/or corporate customers who own the premises that you will visit to perform your tasks, other third parties in potential or actual legal proceedings, our assignee(s) of rights and/or obligations as part of a business reorganization or other disposition of our business). We would not otherwise disclose personal data to another organization unless:
•    the disclosure is for one of the purposes described in or otherwise permitted by our Privacy Policies;
•    the disclosure is required or permitted by law;
•    we believe the disclosure is necessary to provide you with products or services which you have requested;
•    we believe the disclosure is necessary to protect the rights, property or personal safety of another person or Swarovski; or
•    the assets and operations of Swarovski's business are transferred to a third party.

Retailers and service providers

Like most large organizations, we use a range of authorized retailers to sell and service our products and service providers to help us maximize the quality and efficiency of our services and our business operations. This means that individuals and organizations outside of our organization, such as third party retailers of Swarovski products, third parties that operate the personal data on behalf of and in accordance with Swarovski’s instructions (commissioned data processing) and third parties which Swarovski commissions for repairs or delivery of our products, will sometimes have access to personal data held by us and may use and/or process it on behalf of us. We require our service providers to adhere to strict privacy guidelines and not to use and/or process the information for any unauthorized purposes.

CCTV

Some premises and/or offices of Swarovski are under video surveillance (e.g., CCTV). Swarovski uses CCTV devices to ensure security on the premises and/or offices, and to protect the personal and public health and safety, the property of Swarovski or any relevant person, and for other purposes outlined in this Privacy Policy.  Personal data collected from surveillance recordings shall not be used by Swarovski for the purposes of making decisions automatically, including profiling. In general, Swarovski retains personal data for no longer than it is necessary for the purposes for which the personal data are processed. Recordings are overwritten after a lapse of a short period of time unless they include events that could be potentially subject of legal claims. In such a case, personal data shall be processed for a period of limitation of any claims.   

Using your personal data for marketing

We may use and/or process personal data you have provided to us, including your email address, to provide you with information in relation to new or updated products or services or special offers, promotions or competitions in which you may be interested. We will only do so in accordance with applicable laws or with your prior consent.
If at any time you do not wish to receive such information from us, you may ask us to remove your name from our list by contacting us using our contact details below. Alternatively, if we send you such information by email, you can use the unsubscribe function in the email to inform us that you do not wish to receive such information from us by email. In either case, please allow 5 business days for your request to be processed.

Disclosing your personal data overseas

The central database, in which all data described in the Privacy Policy is saved, is operated on behalf of and in accordance with Swarovski’s instructions by our related body corporate, D. Swarovski KG, Swarovski strasse 30, 6112 Wattens, Austria. Swarovski ensures compliance with the applicable privacy laws.

In order to deliver products and services to you and to improve our products, services, to enable responsible personnel to perform their relevant tasks, to manage our relationship with you (e.g., to send you the occasional gift), to ensure that your complaints or inquiries are handled by relevant entity, to comply with applicable laws or to protect our interests, we may sometimes disclose your personal data to another company within or related to the Swarovski Group (including but not limited to those located in Switzerland, the United States, Liechtenstein and Austria), affiliates,  service providers, foreign authorities and other parties in potential or actual legal proceedings.

Some recipients may be located in a country which the competent authority does not already prescribe to be the country that has the standard of personal data protection on the same level with the standard of personal data protection in Thailand. In such event, we will take steps and measures to ensure that your personal data is securely transferred, and that the receiving parties have in place an appropriate level of data protection standards or other measures as applicable with the applicable data protection laws.

Swarovski will not otherwise use, process or disclose any information about you without your consent, unless:
•    the use, processing or disclosure is for one of the purposes described in or otherwise permitted by our Privacy Policies;
•    the use, processing or disclosure is required or permitted by law;
•    we believe it necessary to provide you with products or services which you have requested;
•    we believe it necessary to protect the rights, property or personal safety of another person or Swarovski; or
•    the assets and operations of Swarovski's business are transferred to a third party.

Your data protection rights

Upon request, we will provide you with access to personal data that Swarovski holds about you, except in the limited circumstances in which it is permitted for us to withhold this information. To request access to your personal data, please contact us using our contact information below.

If at any time you wish to change personal data that is inaccurate, out of date or incomplete, please contact us using our contact information below and we will amend your record.

If you wish to have your personal data deleted, please let us know in the same manner as referred to above and we will take all reasonable steps to delete it unless we need to keep it for legal, auditing or internal risk reasons.

You are also entitled to ask us to restrict certain processing of your personal data, or to transfer some of this personal data to other third parties. In some cases, you can also object to certain processing of your personal data.  

Where Swarovski processes your personal data based on your consent, you can withdraw your consent at any time to the extent permitted under the applicable laws.
If you believe that our processing of your personal data is unlawful or non-compliant with applicable data protection laws, you may have the right to lodge a complaint to the competent authority. However, we would appreciate a chance for us to rectify your concern before you approach the competent authority. Please contact us using our contact information below.

Security and storage of your personal data

Swarovski will protect your personal data in its possession or under its control by making reasonable security arrangements to prevent any accidental, unlawful or unauthorized loss, access, collection, use, disclosure, copying, alteration, modification, disposal or similar risks. 

In particular, we have implemented measures on controlling access and use of devices for storing and processing personal data which are secured and suitable for our processing of personal data. We also have measures on restricting access to personal data and the use of storage and processing equipment by imposing users' access rights, users' permission rights to the authorized personnel, and users' duties and responsibilities to prevent unauthorized access, disclosure, perception or unlawful duplication of personal data, or theft of device used to store and process personal data. This includes measures on the re-examination in relation to access, alteration, erasure, or transfer of personal data which are in accordance with methods and channels used to process personal data. 
     
We will retain your personal data for the period necessary to allow us to achieve the purposes outlined in our Privacy Policies. When we no longer need to use your information, we will take steps to properly de-identify or destroy it, except where a longer retention period is required or permitted by law (such as where legal action or proceedings is initiated).

Unfortunately, however, no data transmission over the internet can be guaranteed secure. As a result, while we strive to protect your personal data, we cannot guarantee the security of any information you transmit to us through this Website and you use this Website at your own risk.

Your personal data is stored on secure servers that are protected in controlled facilities. We require our employees and data processors to respect the confidentiality of any personal data held by Swarovski.

Usernames and passwords

You can play an important role in keeping your personal data secure by maintaining the confidentiality of any password and accounts used on this Website. Please notify Swarovski immediately if there is any unauthorized use of your account by any other Internet user or any other breach of security.

You are responsible for the security of your user name and password (or other log-in information) and you take responsibility to ensure the confidentiality of this information.

Links to other websites

Swarovski provides access to third party websites through this Website. These linked websites are not under the control of Swarovski, and we are not responsible for the content or the conduct of the organization accessed via a link on this Website. Before disclosing your personal data on any website, we suggest you examine the terms and conditions and privacy policy of that website.

What to do if you have a problem, question or complaint

If you have any further queries relating to our Privacy Policies, or you have a problem or complaint, please contact us at:

1) Swarovski (Thailand) Co. Ltd.

Contact person: Data Protection Team

                  Swarovski (Thailand) Limited
849 Vorawat Building, Unit 1603-1604, 16th Floor, Silom Road, Bangrak, 
Bangkok 10500
Telephone number: +66 2016 1899 (Monday-Friday) during 09.00 – 18.00 Email: sth.dpo@swarovski.com 

In most cases we will ask that you put your request in writing to us. We will investigate your complaint and will use reasonable endeavors to respond to you in writing within 30 days of receiving the written complaint.

Future changes

From time to time, Swarovski's policies will be reviewed and may be revised. Whilst Swarovski seeks to minimize changes to its policies, Swarovski reserves the right to change its Privacy Policies at any time by posting an updated version on this Website. Please therefore keep checking these policies to ensure you are aware of the current terms. If at any point Swarovski decides to use and/or process personal data in a manner materially different from that stated at the time it was collected we will notify you by email or via a prominent notice on this Website, and where necessary we will seek your prior consent.
 
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)
The PERSONAL DATA in connection with the membership at SCS is processed by two joint controllers, in particular (i) the controller of the respective local Swarovski company which issues the membership according to the application form and which receives the membership fees, and (ii) the controller of Swarovski Aktiengesellschaft, Dröschistrasse 15, 9495 Triesen, Liechtenstein. The collected personal data will be shared with other companies of the Swarovski Group of companies and certain third parties as described in this Privacy Policy.  

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 
•    Non-marketing communication including but not limited to: changes related to our Privacy Policy, General Terms and Conditions and/or Terms of Use; general changes to product and service offering; account verification; password reset; or an information related to incidents that could affect our services   
•    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) or to any other SWAROVSKI companies to comply with your specific request (e.g., request for relocation of local Swarovski company who operate SCS membership).

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 or delete their personal information, ask to object to or restrict the processing of the personal data, ask for a copy of the personal information, or ask for the transfer of their personal data to other third parties. 

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 or other rights of data subjects as mentioned above, please do not hesitate to contact our Customer Service team at Customer_Service_TH@Swarovski.com 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.

You may have the right to lodge a complaint to the competent authority where you believe our processing of your personal data is unlawful or non-compliant with applicable data protection laws.

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
For updates to the information provided in this Data Privacy Policy and, as the case may be, further country-specific mandatory information and mandatory information based on the EU Data Protection Regulation and/or other applicable data protection laws, and for any uncertainties regarding the transfer of personal information overseas, the storage, security of your personal information and other privacy issues that are not explicitly stipulated under this Data Privacy Policy, please refer to the Privacy Policy on www.swarovski.com where applicable.

2.    SWAROVSKI CLUB
The following provisions shall be applicable for the processing of data by SWAROVSKI in connection with the customer loyalty program Swarovski Club. 
a.    Responsible for the Personal Data (Controller)
The PERSONAL DATA in connection with the membership of Swarovski Club is processed by two joint controllers, in particular (i) the controller of the respective local SWAROVSKI company which issues the membership according to the sign-up form, and (ii) the controller of SWAROVSKI Aktiengesellschaft, Dröschistrasse 15, 9495 Triesen, Liechtenstein. Other companies and affiliates of SWAROVSKI may however use the collected personal data for their purposes according to Section 'Use, processing and disclosure of your personal data' of the General Privacy Policy above.

b.    Processing of Personal Data and Source
SWAROVSKI collects and retains the personal obligatory data provided on the Swarovski Club sign-up form (including but not limited to: title, name and address, and e-mail address) plus any personal data provided voluntarily by Swarovski Club Members on the member page: date of birth as well as styles/interests (e.g. in Jewellery and Accessories, Home and Style, Wedding, Figures and Collectables and/or Watches; Classic style) (“Form Data”). Swarovski also saves data on Members’ purchase history in the form of items purchased (product designation, price, discount), place and time of purchase and membership number. The purchase history is recorded if the Swarovski Club membership number is communicated at the checkout for purchases in stores participating in the Swarovski Club program. In the online store Members’ purchase history is recorded if the membership number is quoted when making a purchase or the Member makes a purchase when logged into an online account associated with a Swarovski Club membership. Swarovski also collects and saves all vouchers sent to the Swarovski Club Member and, as the case may be, further data about the Swarovski Club 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 Swarovski Club Memberships belong to the same individual, or where a valid request is received, Swarovski may merge them.

At the start of their membership, Members receive an e-mail containing a link to an overview of all currently participating stores in the Swarovski Club program. This overview of participating stores is also available to view online at swarovski.com/club.

c.    Purpose of Processing
As far as Swarovski Club is concerned, SWAROVSKI namely collects and processes the personal data of Members of the customer loyalty program according to Section 'Use, processing and disclosure of your personal data' of the General Privacy Policy above and as specified below for the PURPOSES listed under that respective provision, and in particular also for the following PURPOSES:
•    administration of Swarovski Club memberships;
•    operation of the Swarovski Club, namely personalized offers, advice and communications regarding products and services of Swarovski, providing of advantages and awarding special conditions (e.g. vouchers), invitations to special events and promotions reserved for members, participating in surveys, requiring feedback and act in social media.

The personal data collected is used by Swarovski to administer and manage the membership (including also for accounting purposes), to provide the Member with the benefits and other services that come with the Membership (the legal basis for this is the Membership).

In participating stores, the Swarovski Club allows Members to take advantage of an extended customer advice in which, upon presentation of the membership number, the store employee can call up the Member’s purchase history data and provide the Member with additional sales advice based on his or her past purchases, style/interests selected or wish list.

On presentation of the Swarovski Club membership number, e-mail address or the Member’s name and date of birth (or another unique authentication attribute), the relevant store employee has access to the relevant Member’s saved purchase history data and wish list. 

SWAROVSKI may also use the PERSONAL DATA to invite selected Members to special events and promotions, such as the presentation of new products or discount promotions. In addition, SWAROVSKI also uses the PERSONAL DATA to send Members birthday congratulations.

SWAROVSKI also uses the data collected in the purchase history to grant Members membership benefits in the form of Discount or Loyalty Gift vouchers. Based on the data saved in the purchase history, SWAROVSKI evaluates what type of voucher the Member is granted. 

If a Member has given SWAROVSKI his or her consent, SWAROVSKI may send the Member further information about SWAROVSKI, product information, services and exclusive offers by e-mail or in any other way chosen by SWAROVSKI. Based on the Form Data and the purchase history reported by participating stores, interaction variables (such as click rates, time of interaction or social media interaction), style/interests selected as well as other information voluntarily disclosed to SWAROVSKI by the Swarovski Club Member, SWAROVSKI may personalize the information sent to the Member so that the Member particularly receives, where possible, information which SWAROVSKI seems interesting for the Member. For this purpose, SWAROVSKI analyses the Form Data collected at the start of Membership and, in particular, takes account of the saved information relating to age, sex, interests and preferences, interaction variables as well as the vouchers received, and other information that can be gleaned from the purchase history or has been given to SWAROVSKI by the Member voluntarily at any later time.   

d.    Disclosure of Personal Data
In the course of processing personal data in connection with Swarovski Club, SWAROVSKI may namely disclose PERSONAL 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 Swarovski Club, 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 SWAROVSKI Club 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 according to Section 'Disclosing your personal data overseas' of the General Privacy Policy above.

e.    Rights of Data Subjects
Swarovski Club Members 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. Further information about the RIGHTS of Swarovski Club Members is provided in Section 'Your data protection rights' of the General Privacy Policy above.

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 recorded for five years.

Further information regarding Swarovski Club can be found in the General Terms and Conditions of the customer loyalty program on www.swarovski.com


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