Effective Date: June 22, 2015
INFORMATION WE COLLECT
We may collect personal information about you in various ways, such as when you provide it at our stores, on our websites, through our apps and social media channels, at our events, through surveys, via text messages or on the telephone. The types of personal information we may collect include:
- Contact information (such as name, postal address, email address, and mobile or other telephone number);
- username and password;
- payment information (such as your payment card number, expiration date, authorization number or security code, delivery address, and billing address);
- purchase and transaction information;
- customer service information (such as customer service inquiries, comments, and repair history);
- photographs, comments and other content you provide;
- information regarding your personal or professional interests, date of birth, marital status, demographics, and experiences with our products and contact preferences;
- contact information you provide about friends or other people you would like us to contact; and
- information we may obtain from our third-party service providers.
In addition, when you visit our websites, open our emails, use our apps or interact with MGI-related tools, widgets or plug-ins, we may collect certain information by automated means, such as cookies, web beacons and web server logs. The information we collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, and dates and times of website visits. A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. We may link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our websites or apps.
The providers of third-party apps, tools, widgets and plug-ins on our websites and apps, such as Facebook “Like” buttons, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, MGI is not responsible for these providers’ information practices.
HOW WE USE THE INFORMATION WE COLLECT
We may use the information described above to:
- Provide products and services to you;
- process your payments;
- create and manage your account;
- send you promotional materials and other communications;
- communicate with you about, and administer your participation in, special events, contests, sweepstakes, programs, offers, surveys and market research;
- respond to your inquiries;
- operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products and customer base; performing data analytics; and performing accounting, auditing and other internal functions);
- reduce credit risk and manage collections;
- verify your identity;
- protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities; and
- comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.
We also may use the information in other ways for which we provide specific notice at the time of collection.
In addition, we use information collected through cookies, web beacons, pixels, web server logs and other automated means for purposes such as (i) customizing our users’ visits to our websites and apps, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our websites and apps, and (iii) managing our websites, apps and other aspects of our business. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.
We may use third-party analytics services on our websites and apps, such as Google Analytics. The analytics provider that administer this service use technologies such as cookies, web server logs and web beacons to help us analyze your use of our websites and apps. The information collected through these means (including IP address) may be disclosed to this analytics provider and other relevant third parties who use the information, for example, to evaluate use of the website or app. To learn more about this analytics service and how to opt out, please visit the relevant websites listed here:
- Google Analytics: http://www.google.com/analytics/learn/privacy.html
You may see certain ads on other websites because we engage third-party ad buying networks (such as Facebook, Rubicon and Twitter). Through such buying networks, we can target our messaging to users through demographic, interest-based and contextual means. We can track your online activities over time by collecting information through automated means, including through the use of third-party cookies, web server logs, pixels and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests. The information our ad networks may collect on our behalf includes data about your visits to websites that serve MGI advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising, click here. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
INFORMATION WE SHARE
In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
YOUR RIGHTS AND CHOICES
We offer you certain choices in connection with the personal information we collect about you, such as how we use the information and how we communicate with you. To update your preferences, ask us to remove your information from our mailing lists, exercise your rights or submit a request, please contact us as indicated in the “How to Contact Us” section of this Global Privacy Notice. You can also unsubscribe from our mailing lists by following the “Unsubscribe” link in our emails. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.
To learn more about how to opt out of ad network interest-based advertising, please visit the consumer opt-out page at http://www.aboutads.info/choices/.
ONLINE TRACKING AND HOW WE RESPOND TO DO NOT TRACK SIGNALS
When you use our websites and apps, both we and certain third parties (such as our advertising networks, digital advertising partners and social media platforms) may collect personal information about your online activities, over time and across third-party websites. Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. At this time, our websites and apps are not designed to respond to all types of DNT signals or similar mechanisms from browsers as there is no common, industry-accepted standard for doing so. Thus, information about your online activities may continue to be tracked on our site and used to maintain our website’s functionality and for our own analytics purposes described in this Privacy Notice even if your browser sends us a DNT signal. However, when we recognize a relevant DNT signal, we aim to suppress the third-party tags that are used to recognize your computer once you navigate away from our site and which are used to present you with Ebel advertisements. As noted, since there is no uniform standard for DNT signal recognition, we may update our policy and practice as new technologies and solutions emerge. As indicated in the “Your Rights and Choices” section above, we offer you certain choices in connection with the personal information we collect about you and our interest-based advertising activities.
NOTICE TO CALIFORNIA RESIDENTS
Subject to certain limitations under California Civil Code § 1798.83, California residents may ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request, California residents may contact us as specified in the “How to Contact Us” section below.
HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
LINKS TO NON-MGI SITES AND SERVICES
For your convenience and information, our websites and apps may provide links to non-MGI sites, apps and services that may be operated by companies not affiliated with MGI. These companies may have their own privacy notices or policies, which we strongly suggest you review. Our products and services also may be made available to you through third-party platforms (such as providers of app stores) or through other third-party channels. We are not responsible for the privacy practices of any non-Ebel sites, apps or services.
HOW TO CONTACT US
Chief Privacy Officer
c/o Legal Department
Movado Group, Inc.
650 From Road
Paramus, NJ 07652
- We may collect certain personal information by automated means, such as cookies, web beacons and web server logs. Information about these practices is available here.
- We may share your personal information within the MGI group of affiliated companies worldwide, which is composed of the affiliates listed here.
- We may disclose information about you (i) to law enforcement authorities and other government officials based on a lawful disclosure request and (ii) when the disclosure is in our legitimate interest and in accordance with applicable data protection law.
- MGI has submitted simplified registrations with the French Data Protection Authority and has obtained an authorization for its data transfers outside of the EEA.
- To exercise your rights, you may write to the relevant MGI entity that is the data controller for your jurisdiction via the contact details listed here.
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under EU law that adequate protection be given to personal information transferred from the EEA to the United States (U.S.- EU Safe Harbor). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection. The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (U.S.-Swiss Safe Harbor). Consistent with its commitment to protect personal privacy, MGI adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (Safe Harbor Principles).
This Safe Harbor Policy applies to all personal information received by MGI in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal.
For purposes of this Safe Harbor Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, MGI or to which MGI discloses personal information for use on MGI's behalf.
“MGI” means Movado Group, Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of MGI to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, MGI will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Safe Harbor Policy have been developed based on the Safe Harbor Principles.
NOTICE: Where MGI collects personal information directly from individuals in the EEA or Switzerland, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which MGI discloses that information, the choices and means, if any, MGI offers individuals for limiting the use and disclosure of personal information about them, and how to contact MGI. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to MGI, or as soon as practicable thereafter, and in any event before MGI uses or discloses the information for a purpose other than that for which it was originally collected.
Where MGI receives personal information from its subsidiaries, affiliates or other entities in the EEA or Switzerland, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
CHOICE: MGI will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
MGI in the U.S. particularly receives, holds and processes the following personal data from the EEA and/or Switzerland:
In connection with its retail sale activities and its after-sales service, MGI may receive, hold, and process personal information from clients within the EEA and/or Switzerland, including payment card data provided by clients for the purpose of merchandise transactions and client information relating to services agreements and watch repairs.
In addition, MGI’s goal is to provide its clients with a personalized Internet experience and deliver services that are most relevant and helpful to its users. In order to achieve these goals, MGI may collect information and process personal information during user’s visits to its web- sites and, in particular, during a user’s visit to Ebel.com and/or movadogroupinc.com web-sites. As a consequence, MGI may receive, hold, and process personal information from clients within the EEA and/or Switzerland while providing web-site services such as a searching listing of authorized MGI retailers. MGI’s collection and use of personal information varies based on the web-site services requested by the users and the user's choice of privacy options within the relevant web-site services.
Further MGI receives, holds, and processes personal information from employees of MGI’s wholly owned European subsidiaries, which are transferred to MGI in the U.S. for purposes of human resource administration. Any such personal information is collected and processed solely for job related purposes, for other legitimate purposes reasonably related to an individual’s employment, their performance of job responsibilities and MGI’s ability to make employment services and benefits available to them. MGI particularly collects and uses personal information for the proper management of global operations, including for payroll management, headcount, promotions and performance reviews, vacation, tax and social security withholding, enrollment in company benefit programs, stock purchase and stock incentive programs as well as other compensation plans, relocation or immigration assistance, and the mandatory compliance with all applicable labor, employment, tax and other laws.
For sensitive personal information, MGI will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
MGI will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY: MGI will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. MGI will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: MGI will obtain assurances from its agents that they will safeguard personal information consistently with this Safe Harbor Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where MGI has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, MGI will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, MGI will grant individuals reasonable access to personal information that it holds about them. In addition, MGI will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: MGI will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Accordingly, MGI has put in place appropriate physical, electronic and managerial security measures to safeguard and secure any personal data under MGI’s control. However, MGI cannot guarantee the security of personal data on or transmitted via the Internet.
ENFORCEMENT: MGI will conduct annual compliance audits of its relevant privacy practices to verify adherence to this Policy and will have a program in place to oversee the daily functions of the privacy program. Any employee that MGI determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the MGI Privacy Officer at the address given below. If the question or concern relates to personal information of any employees of MGI or any of MGI subsidiaries the MGI Privacy Officer will refer the matter to MGI’s Senior Vice President of Human Resources (HR Representative). MGI will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints not involving human resources data and which cannot be resolved between MGI and the complainant, MGI has agreed to participate in the dispute resolution procedures of the panel established by the American Arbitration Association (AAA). For complaints involving human resources data and which cannot be resolved between MGI and the complainant, MGI has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities (DPA) and to cooperate with the Swiss FDPIC in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by MGI to these Safe Harbor Principles may be limited (a) to the extent required to respond to or satisfy a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
Questions or comments regarding this Policy should be submitted to the MGI Privacy Officer by mail as follows:
Chief Privacy Officer
c/o Legal Department
Movado Group, Inc.
650 From Road
Paramus, NJ 07652