Privacy policy

To help us provide the best possible service, we capture personal information about you but we respect and protect your privacy and do all we can to honour the trust you place in us by being transparent about what personal information we collect and how we use it, vowing to handle your data fairly and lawfully at all times.

We are Watches of Switzerland Group PLC of Aurum House, 2, Elland Road, Braunstone, Leicester LE3 1TT, United Kingdom and our subsidiary Watches of Switzerland Company Limited is registered as a Data Controller with the UK Information Commissioner's Office with registration number ZA531335.

Our Data Protection Officer is contactable via dpo@thewosgroup.com.

If you are also a customer of the Watches of Switzerland Group, you should refer to the separate customer privacy notice which governs our use of the personal information that we hold about you as a customer or prospective customer of ours.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

This notice is to inform you about how we collect and protect any personal information you provide to us and how you can control what personal information we collect from you and what we do with it. It sets out how we intend to use your information, who we will share it with and what rights you have about use of your information.

This notice applies to all our activities under the above brands and however you provide personal information to us, whether you visit us online at any of our websites or visit our stores or contact us via social media or whether you telephone, email, write to or text us.

Please note that we may amend this notice from time to time and any updated policy will be posted on our website and, where appropriate, notified to you by email. Please continue to review this notice whenever accessing our site.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Here we provide you with details about:

what personal information we collect;
how we use your personal information;
information about cookies;
who we share your personal information with;
the legal basis for using personal information provided to us;
how we aim to protect your privacy;
how long we will keep your personal information;
international transfers of your information; and
your legal rights relating to your personal information.

What personal data do we collect?

We may collect the following information about you:

your name, age/date of birth and gender;
your contact details, including addresses, telephone numbers (including mobile numbers) and e-mail address;
your social media handles;
details of arrangements between you and us;
your online browsing activities on any of our websites;
your password(s);
information about the device you use to browse our websites including the IP address and the device type;
your communication and marketing preferences;
your interests, preferences, feedback and survey responses;
your location;
your correspondence and communications with us; and
other publicly available personal data, including any which you have shared via a public platform (such as Instagram, YouTube, Twitter or public Facebook page)

This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Notice. Some personal data are collected directly, for example when you set up an online account on our website, or send an email to our Customer Relations team. Other personal data are collected indirectly, for example, when you browse our websites. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.

We may anonymise and aggregate personal data for insight and research but this will not identify anyone.

Our websites are not intended for children and we do not knowingly collect data relating to children.

How we use your data

General

We (and trusted partners acting on our behalf) use your personal data:

to provide information to you;
to manage any account(s) you hold with us;
to verify your identity;
for crime and fraud prevention, detection and related purposes;
to contact you electronically about promotional offers, events, products and services which we think may interest you;
for analysis, insight and market research purposes to better understand your needs and ensure we are giving you what you like;
to enable us to manage interactions with you; and
where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).

Marketing

We use your personal data for marketing purposes and may send you postal mail, texts and/or emails to update you on our latest offers and events.

We aim to update you about products and services of interest and relevance to you as an individual.

You have the right to opt out of receiving promotional communications at any time, by:

contacting our Customer Relations team via email customer.relations@thewosgroup.com or by telephone on 0800 085 8250 or post to Customer Relations, Watches of Switzerland Group PLC, Aurum House, 2, Elland Road, Braunstone, Leicester LE3 1TT United Kingdom; or
making use of the simple "unsubscribe" link in our emails or the "STOP" number for texts; and/or
contacting our Data Protection Committee to indicate that you wish to change your marketing preferences by emailing dpo@thewosgroup.com or by post to The Data Protection Officer, Watches of Switzerland Group PLC, Aurum House, 2, Elland Road, Braunstone, Leicester LE3 1TT, United Kingdom;

Cookies

For full information on the use of cookies on our website, please read our Cookie Policy.

Sharing data with third parties

We will never sell or rent your personal information to other organisations for marketing purposes.

We will not disclose your personal information to any third party, except for those referred to below.

We may share your data with:

other companies within our group;
purchasers, investors, funders and advisers if we sell our business or assets or restructure whether by merger, re-organisation or otherwise;
our legal and other professional advisers, including our auditors;
credit reference agencies where necessary for card payments;
governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:- to comply with our legal obligations and/or the administration of justice;
to exercise our legal rights (for example in court cases);
for the prevention, detection, investigation of crime or prosecution of offenders; and
for the protection of our employees and website users; and
our service providers and suppliers.

In order to make certain services available to you, we have partnered with certain trusted third parties including IT, mailing, payment services, delivery and marketing service providers. We may need to share your personal information with some of our service partners. We only allow our service providers to handle your personal information when they have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your information to provide services to us and to you, and for no other purposes.

Please see here for the types of service providers with whom we share personal data.

Type of External Service Provider	Reason For Sharing Your Information
Database Administrators	Administration of our databases
Mailing Houses	Delivery of Postal Mailings
Electronic Mail Administrators	Delivery of email campaigns including electronic newsletters
Software Providers	Administration
Marketing Consultancies and Advertising Services Providers	Analysis of data and website user insight for the development and administration of marketing campaigns
Insurers	Provision of insurance cover
Call recording providers	Call recording to facilitate administration of enquiries and complaints
Electronic platform providers	To create on-line accounts and electronic newsletter distribution
Email Administrators	Provision of email system
Website Hosting Service providers	Administration of our websites and electronic marketing campaigns
Document Disposal Managers	Document disposal

Legal basis for using data

We are required to set out the legal basis for our 'processing' of your personal data.

We collect and use website users’ personal data:

1. as necessary to perform our contract with you:

for the purposes of complying with our duties and exercising our rights under arrangements agreed with you; or

2. as necessary for the pursuit of our legitimate interests including:

providing information to website users;
promoting, marketing and advertising our products and services;
understanding our website users’ behaviour, activities, preferences, and needs;
protecting website users, employees and other individuals and maintaining their safety, health and welfare;
good governance, accounting, managing our operations and complying with our legal obligations;
preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
handling website users’ contacts, queries, complaints or disputes;
managing insurance claims;
protecting our company, its employees and website users, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us;
handling any legal claims or regulatory enforcement actions taken against us; and
fulfilling our duties to our website users, colleagues, shareholders and other stakeholders; or

3. as necessary for complying with our legal obligations including:

where you exercise your rights under data protection laws;
for compliance with legal and regulatory requirements; or
to establish or defend our legal rights; or

4. based on your consent.

You have the right to withdraw consent at any time. Where consent is the only legal basis for processing your personal data, we will cease to process your personal data for that purpose after consent is withdrawn.

How we protect your data

Our controls

We are committed to keeping your personal data safe and secure.

Our security measures include:

encryption of data;
regular cyber security assessments of all service providers who may handle your personal data;
regular planning to ensure we are ready to respond to cyber security attacks and data security incidents;
daily penetration testing of systems;
security controls which protect our IT systems, infrastructure and our premises from external attack and unauthorised access;
internal policies setting out our data security rules for our personnel; and
regular training for our employees.

What you can do to help protect your data

You should always be cautious when sharing your personal data. No one from our company will ever ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from Watches of Switzerland Group PLC asking you to do so, please ignore it and do not respond.

If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.

In addition, we recommend that you take the following security measures to enhance your online safety:

keep your account passwords private because anyone who knows your password may access your account or be compromised if your account is accessed without authority.
when creating a password, use a difficult word/number combination of at least 8 characters and something that is not easily guessed by hackers such as dictionary words, your name, email address, or other personal data that can be easily obtained. Also, frequently change your password. You can do this accessing your account, clicking 'your account', clicking 'your data' and selecting 'change password'.
avoid using the same password for different online accounts.

How long we keep your data

We will not retain your data for longer than necessary for the purposes set out in this Notice. Different retention periods apply for different types of information, and our Data Retention Policy sets out the length of time we will usually retain personal data and where these default periods might be changed.

In summary, various laws, accounting and regulatory requirements applicable to us require us to retain certain records for specific amounts of time. In relation to your personal data, we will hold this only for so long as we require that personal data for legal or regulatory reasons or for legitimate organisational purposes and we will not keep your data for longer than is necessary for the purposes for which we collect them.

For more detail on typical retention periods, please see below.

Record retention periods

Record	Type of Personal Data	Retention Period
Cookies	Web-tracking information including IP addresses	5 years
Website users	Email addresses	Website emails 7 years Customer care emails 7 years
Complaints	Names, addresses, telephone numbers, email addresses	7 years
Marketing Databases	Names and Addresses, email addresses	15 years
Call recordings	Telephone numbers, call recordings	28 days
CCTV	Images of Attendees at our premises	As long as required for security purposes
Visitor Records	Names and Images of Attendees at our premises	As long as required for security purposes
Automatic Number Plate Recognition System	Vehicle Registration Plates of Visitors, suppliers and other attendees at our HQ	As long as required for security purposes

International transfers

To deliver products and services to you, it is sometimes necessary to share your personal information outside of the European Economic Area (the EEA). This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.

If we transfer your personal information outside the EEA, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to assess the laws and practises of the destination country and relevant service provider and the security measures that are to be taken as regards the data in the overseas location. Alternatively, we use standard data protection clauses.

Your rights

You have the following rights:

the right to be informed about our processing of your personal data which is the aim of this Notice;
the right to request access to personal data that we hold about you at any time;
the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you;
the right to object to processing of your personal data and/or to withdraw any consent you have given us and to opt out of any marketing communications that we may send you;
the right to prevent processing that is likely to cause damage or distress to you or anyone else;
the certain rights in relation to automated decision-making processes including the right to object to profiling;
the right to request that we erase or destroy your personal data in certain circumstances (the right to be forgotten) for example when the data are no longer necessary for the purpose for which we collected them; and
the right to have your personal data provided to you by us in a structured, commonly used and machine-readable format and the right to have that data transmitted to another data controller. This is known as the right to data portability.

If you wish to exercise any of the above rights, you can always:

call our Customer Relations Team on telephone 0800 085 8250 but we will ask you to put your request in writing;
email us at either customer.relations@thewosgroup.com or dpo@thewosgroup.com; or
contact us by post to either Customer Relations or the Data Protection Committee, Watches of Switzerland Group PLC, Aurum House, 2, Elland Road, Braunstone, Leicester LE3 1TT, United Kingdom.

You have the right to lodge a complaint with the Information Commissioner's Office at Wycliffe House, Water Lane, Wilmslow SK9 5AF, United Kingdom if you believe we have not handled your personal data in accordance with the law. Further information, including contact details, is available at https://ico.org.uk.

Changes to our Privacy Policy

This privacy policy was last updated in July 2021 version 4.

PRIVACY NOTICE FOR CAREER APPLICANTS

When you choose to apply for any role with Watches of Switzerland Group Plc or any of our group companies, we capture personal information about you and we need to process that personal data but we respect and protect your privacy and do all we can to honour the trust you place in us by being transparent about what personal information we collect and how we use it.

We are Watches of Switzerland Company Limited part of Watches of Switzerland Group Plc of Aurum House, 2 Elland Road, Braunstone, Leicester LE3 1TT and we are a Data Controller registered with the UK Information Commissioner’s Office with registration number Z5617669.

We hold and process information about you on behalf of ourselves and also on behalf of the other contractual employers within the Watches of Switzerland Group, namely Watches of Switzerland Operations Limited who is a Data Controller registered with the UK Information Commissioner’s Office with registration number Z5617729 and Watches of Switzerland Group PLC who is a Data Controller registered with the Information Commissioner’s Office with registration number ZA531335.

Our Data Protection Officer is contactable via dpo@thewosgroup.com

THE KIND OF INFORMATION WE COLLECT ABOUT YOU

1.1 The sort of information we hold includes your personal contact details such as:

Recruitment information (including information about your entitlement to work in the UK such as your nationality copies of right to work documentation, including your National Insurance number, copies of your Driving Licence, Passport, Birth Certificate, and proof of current address, such as Bank Statements and Council Tax bills, references and other information included in a CV or cover letter or as part of the application process);
Personal contact details such as name, date of birth, gender, title, addresses, telephone numbers and personal email addresses;
Application form and references, details of your qualifications, skills, experience and employment history, including start and end dates with previous employers;
For some roles we will ask for details of dismissals in the past 5 years and details of Unspent Criminal Convictions to enable us to establish whether or not you have committed an unlawful act or been involved in dishonesty or other improper conduct;
We may also obtain details of your financial situation and history from a credit reference agency (or similar organisation). This is to enable us to ascertain whether there are any issues of a financial nature that could affect your suitability for employment;
Where you browse our careers webpages we will collect usage data such as your IP address, the length of your visit to our webpages, and communications and metadata associated with those communications generated by use of our website forms;
If you attend an interview at our premises we may process CCTV footage, Automatic Number Plate recordings and other information obtained through electronic means such as a record of entry to and exit from the building, information about your use of information and communication systems;
During the interview and selection process we may also ask you to complete online competency tests and our interviewers may take personal notes for their own benefit.

If you are an internal candidate we may ask your current manager for information about you.

If you are an external candidate we may contact the individuals that you have told us will provide a reference;

We may also ask you to provide some more sensitive information called Special Category data. We Ask for: Details of medical or health conditions, including whether or not you have a disability for which we need to make reasonable adjustments in the recruitment process or if you are successful in your application, information about your ethnic origin, sexual orientation and religion or beliefs, political opinions, trade union membership and information about criminal convictions and offences.

HOW WE WILL USE INFORMATION ABOUT YOU

2.1 The information we hold and process will be used for our management and administrative use. We will keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately, during the recruitment process and, if you are successful, whilst you are working for us, at the time when your employment ends and after you have left.

This includes using information to enable us to comply with the employment contract, to comply with any legal requirements, pursue the legitimate interests of the Company and protect our legal position in the event of legal proceedings. If you do not provide this data, we may be unable in some circumstances to comply with our obligations and we will tell you about the implications of that decision.

Specifically the situations in which we will process your personal information include:

Administering and managing our Applicant’s Tracking system and our careers webpages
Considering your application for job opportunities and making a decision about your recruitment such as assessing of qualifications for a particular job or task or appointment to include promotions and determining the terms on which you work for us
Checking that you are legally entitled to work in the UK
determining performance requirements
Adding to our talent pool

Due to the nature of our business activities, we may sometimes need to process your data to pursue our legitimate business interests, for example to prevent fraud, administrative purposes or reporting potential crimes.

The nature of our ‘legitimate interests’ are in relation to the interest of the business or those of third parties, or where it is required in the public interest or for an official purpose. We will never process your data where we believe that these interests are overridden by your own interests.

In limited and necessary circumstances, your information may be transferred outside of the UK or to an international organisation to comply with our legal or contractual requirements.

2.2 Sensitive Personal Information

We may process special categories of personal information in any of the following circumstances:

In limited circumstances, with your explicit written consent;
Where we need to carry out our legal obligations and in line with our policies;
Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards;
In relation to legal claims;
Where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public

We will use your sensitive personal information in the following ways:

In order to comply with our health and safety and occupational health obligations to consider how your health affects your ability to do your job and whether any adjustments to your job might be appropriate;
Information relating to your racial or ethnic origin, religion, philosophical beliefs, sexual orientation will be used to ensure meaningful equal opportunity monitoring and reporting. We will always obtain your explicit consent to those activities unless this is not required by law or where the information is required to protect your health or wellbeing in an emergency;
We may use information relating to criminal convictions where the law allows us to do so, for example where it is necessary to carry out our obligations, provided that we do so in a lawful manner.

Where we are processing data based on your consent, you have the right to withdraw that consent at any time.

2.3 LEGAL BASIS FOR USING DATA

We are required to set out the lawful basis for our processing of your personal data and the lawful bases we rely on are:

as necessary to perform our contract with you such as any contract of employment with you
as necessary for the pursuit of our legitimate interests - This is where we rely on our interests as a reason for processing, generally this is so we can continually improve our solutions, to monitor our assets and keep our information secure or in limited circumstances to monitor employees to ensure that they are complying with policy and standards. Other legitimate interests include

- good governance, accounting and managing of our operations and complying with our legal obligations;

- preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;

- protecting our company, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us;

- handling any legal claims or regulatory enforcement actions taken against us; and

- fulfilling our duties to our customers, colleagues, shareholders and other stakeholders

as necessary for complying with our legal obligations - This is where we have a statutory or other legal obligation to process the information such as for equality monitoring or in reporting to HMRC including

- where you exercise your rights under data protection laws;

- for compliance with legal and regulatory requirements; or

- to establish or defend our legal rights;

based on your consent - This is where we have asked you to provide explicit permission to process your data for a particular purpose such as the provision of certain employee benefits and occupational health if your application is successful.

Data Shared with Third Parties

We will never sell or rent your personal information to other organisations for marketing purposes.

We will not disclose your personal information to any third party, except for those referred to below.

We may share your data with:

other companies within our group;
our legal and other professional advisers, including our auditors;
credit reference agencies where necessary for carrying out credit checks;
our service providers and suppliers such as applicant tracker system providers who help us manage the application process, document copying and scanning system providers in order to allow records to be copied or scanned and talent acquisition software providers for recruitment purpose;
CCTV and ANPR system providers and monitors for security purposes ; and
governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:-
to comply with our legal obligations and/or the administration of justice;
to exercise our legal rights (for example in court cases);
for the prevention, detection, investigation of crime or prosecution of offenders; and
for the protection of our employees and customers.

We only allow our service providers to handle your personal information when they have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your information to provide services to us and to you, and for no other purposes.

Please see here for a non-exhaustive list of the types of service providers with whom we share personal data:

Talent Acquisition software provider
Application Tracker system provider
HR/Payroll System provider (currently SD Worx) for storing and processing of employee information for HR and Payroll functions;
Pension providers and pensions consultants for administering your pension contributions and entitlement;
Electronic Platform Providers to create online application
Email Administrators for the provision of the email system; and
Document Disposal Managers to dispose of documents

DATA SECURITY AND RETENTION

We have put in place appropriate security measures to prevent your personal information from being accidently lost, used or accessed in an unauthorised way, altered or disclosed.

In relation to unsuccessful job applications from external candidates your data is stored for 12 months from capture. For unsuccessful internal applicants, and for successful applicants, your data is retained in accordance with our Privacy Notice for Employees, Workers and Contractors which can be found here [link]

AUTOMATED DECISION- MAKING

Currently, we do not make decisions about you using automated means. If this changes in the future, then the privacy notice will be updated accordingly.

YOUR RIGHTS

The law gives you certain rights relating to the use of your data.

The right to be informed about our processing of your personal data which is the aim of this Notice;

The right to access – You have the right to request Our Company for copies of your personal data. We may charge you a small fee for this service;

The right to rectification – You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete;

The right to erasure – You have the right to request that Our Company erase your personal data, under certain conditions;

The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, under certain conditions;

The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions;

The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions;

If you wish to exercise any of the above rights, you can always:

call our Customer Relations Team on telephone 0800 085 8250 but we will ask you to put your request in writing; or
email us at either customer.relations@thewosgroup.com or dpo@thewosgroup.com; or
contact us by post to either Customer Relations or the Data Protection Officer, Watches of Switzerland Company Limited, Aurum House, 2, Elland Road, Braunstone, Leicester LE3 1TT, United Kingdom.

CHANGES TO THIS PRIVACY NOTICE

This privacy notice does not form part of any contract of employment and we reserve the right to update it at any time.

Our Company keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated in October 2021 Version 1