Privacy Policy

Last updated: August 2024
This Data Privacy Notice describes the collection and further processing of personal data by companies of theSwarovski Group and its affiliates (together SWAROVSKI). In the event that the activities covered by this notice are governed by other data protection policies, are evident from the circumstances, or are governed by applicable laws outside of the European Union and the European Economic Area, then such applicable law and resulting policies shall control. The term personal data shall include all information relating to an identified or identifiable person.

This Data Privacy Notice describes in Section I processing of personal data by SWAROVSKI in general. Section II contains specific provisions for specific applications (e.g. online-shop, newsletter and banner advertisment).

If you provide SWAROVSKI with personal data of other persons, for example data about the receiver of a gift, please provide their personal data to SWAROVSKI only if you are allowed to do so pursuant to applicable data protection laws and only if the other person would agree to you providing its personal data to SWAROVSKI for the purposes the data are collected and the processing of its personal data according to our data privacynotice.

I. GENERAL PROVISIONSCONTROLLER, DATA PROTECTIONOFFICER
1. CONTROLLER, DATA PROTECTION OFFICER

Every website (including online-shops and mini sites for special offers), every presence on social media, multimedia portals, chatbots and every application of SWAROVSKI (each a WEBSITE) has a controller within SWAROVSKI with respect to collecting personal data according to the EUGeneral Data Protection Regulation (GDPR) (or comparable provisions according to applicable data protection laws). Unless provided otherwise on the WEBSITE(according to the imprint, the terms of use, etc.) or under Section II below, Swarovski CrystalOnline AG, Alte Landstrasse 411, 8708 Männedorf, Switzerland, is the controller for the Online-Shops www.swarovski.com andSwarovski Aktiengesellschaft, Dröschistrasse 15, 9495 Triesen, Liechtenstein, is the controller for the Swarovski Group websites.

The respective subsidiary or affiliate is the controller in the event SWAROVSKI communicates through other means of communication (such as email, letter, telephone, in person) and the communication does not fall within an activity for which SWAROVSKI has appointed a specific controller within this Data Protection Notice or otherwise.

Should a SWAROVSKI company or affiliate disclose personal data to another SWAROVSKI company or affiliate for certain purposes of the receiving company or affiliate, such company or affiliate is the controller. A list of the relevant companies and affiliates of SWAROVSKI can befound in ANNEX 1, which may be updated from time to time.

SWAROVSKI has not appointed a data protection officer according to article 37 GDPR save for SWAROVSKI companies and affiliates in Germany and Spain.

HOW TO CONTACT SWAROVSKI

If you want to exercise any of your rights regarding newsletter subscriptions, data access or data deletion, please address the same to the Group Data Privacy Team at [email protected].

Alternatively, if you reside in Germany or Spain,you can contact:

- The data protection officer for Germany at Swarovski (Deutschland) GmbH, DataProtection Officer, Hüttenstrasse 27, DE-87600 Kaufbeuren;
- The data protection officer for Spain atSwarovski Ibérica S.A., C/ Llacuna, 10-20 1ª Planta, 08005, Barcelona, Spain.i       .

The representative for all SWAROVSKI companiesand affiliates domiciled outside of the EU or EEA is D. Swarovski DistributionGmbH, Legal Department, Swarovskistrasse 30, AT-6112 Wattens (pursuant toArticle 27 of the GDPR).

2. PROCESSING OF PERSONAL DATA

SWAROVSKI collects and processes personal dataof
• users of SWAROVSKI registered WEBSITES;
• users registered with a SWAROVSKI WEBSITE(e.g. if he or she creates a user account);
• individuals purchasing andreceiving/benefitting from products and services of SWAROVSKI;
• potential or actual parties interested inproducts and services of SWAROVSKI;
• recipients of SWAROVSKI newsletters;participants in research campaigns and opinion surveys conducted by SWAROVSKI;
• participants in courses, seminars and othertrainings organized by SWAROVSKI;
• users of WIFI provided at SWAROVSKI stores andother locations;
• registered participants of customer loyaltyprograms or individuals purchasing or using customer loyalty programs ofSWAROVSKI (CUSTOMER PROGRAM)

(together CUSTOMERS).

The personal data of CUSTOMERS is generallycollected directly by SWAROVSKI during the course of using the WEBSITE, as wellas in stores or at events of SWAROVSKI as well as through direct communicationsuch as email, telephone or in any other way. Personal data can also becollected indirectly, such as through third party processors, (e.g.,SWAROVSKI’s PARTNERS (as defined further below, including wholesalers, dealers,retailers, suppliers and further business partners such as customer servicesvendors).  SWAROVSKI also collects data when the CUSTOMER making thepurchase does not correspond with the person benefitting from the purchase orif the purchase is shipped to a different person (e.g. as a gift), based on therecommendation of a third party (e.g. recommendation by family or friends ofthe CUSTOMER) or through further acquisition of supplementary information fromthird party data sources (e.g. social media).

In particular, the following categories ofpersonal data are processed by SWAROVSKI:

Personal data and contact information includingbut not limited to first and last name, maiden name, address, residence,telephone number, email address, age, date of birth, gender, marital status,relatives, contact in case of emergency, pictures;

Data pertaining to orders and purchasesincluding but not limited to payment information, credit card details and otherpayment details (in accordance with other laws and regulations), billing andshipping address, products and services ordered and purchased, information andqueries and complaints relating to products and services, or respectivecontracts entered into such as warranty claims, after sales services, repairs,customer care and services, rescissions and disputes;

Data in connection with product and servicesmarketing including but not limited to information relating to newsletter andother communication channels, opt-ins and opt-outs, invitations to andparticipations at events and special activities (as far as they are not part ofa customer loyalty program), personal preferences and interests, and customersegmentation information;

Data concerning the use of the WEBSITE includingbut not limited to the IP address and other user identification (e.g. user nameof social media, MAC address of smartphones or computers, cookies), date andtime of WEBSITE visits, visited sites and contents, and referring websites;

Data in connection with communication includingbut not limited to preferred means of communication, correspondence and communicationwith SWAROVSKI (including records of the communication);

Data which was collected in connection with acustomer program including but not limited to membership numbers, access codes(including passwords), preferred language, number of gift certificate, date andduration of the membership, payment information of the CUSTOMER or a potentialthird party, information concerning the recipient of a gift, number of visitsof the WEBSITE, purchase history, products acquired (all WEBSITE accounts,activities and events for which a CUSTOMER must register with his or herpersonal data and thus enter into a contract with SWAROVSKI shall be deemed acustomer program for the purposes of this policy, other than traditionalcustomer loyalty programs);  

together CUSTOMER DATA.

In addition, SWAROVSKI collects:

Data of users of the WEBSITE, who do notregister with SWAROVSKI (VISITOR) but may constitute personal data for examplewith social media (VISITOR DATA), the provisions of this notice regarding datacollected from a CUSTOMER in connection with the use of the WEBSITE shall applyaccordingly even though the identification of a VISITOR usually is not possiblefor SWAROVSKI;

Information pertaining to employees and otherindividuals acting on the part of wholesalers, dealers, retailers, suppliersand further business partners of SWAROVSKI (hereinafter natural persons shallbe referred to as PARTNERS, their data as PARTNER DATA) including but notlimited to contact details, information regarding their function, informationrelating to the previous contact with these individuals, data regardingmarketing activities (e.g. receipt of newsletters), information regardingbusiness transactions, requests, offers, tenders, conditions and contracts,information related to professional or other interests of the individuals.

Within the framework of their businessrelationship, CUSTOMERS will be required to provide CUSTOMER DATA necessary forthe establishment and execution of the contractual relationship and thefulfilment of the associated contractual obligations or if required by law.Without these data, SWAROVSKI will generally not be able to conclude or executethe contract with the respective CUSTOMER. This also applies analogously to thePARTNER DATA as far as business relations with the wholesalers, dealers,retailers, suppliers and business partners of SWAROVSKI are concerned;contracts in principle cannot be concluded and processed without information ontheir employees and other contacts. As any access to the WEBSITE is logged,connection data (such as the IP address) will always be logged; this is doneautomatically during the use and cannot be deactivated for individual VISITORS,CUSTOMERS or PARTNERS.

3. PURPOSE OF PROCESSING AND LEGAL GROUNDS

3.1 PURPOSE of the processing

In accordance with applicable law, SWAROVSKI mayprocess CUSTOMER DATA for all lawful PURPOSES including but not limited to thefollowing:

In connection with services offered, conclusionsof contracts (for example purchases), executions of contracts (for examplepurchase contracts and contracts regarding the participation at customerprograms and events), maintenance and development of customer relations,communication, customer service and support, promotions, advertisement andmarketing (including newsletters and mailing of promotional materials);

Management of the users of the WEBSITE and otheractivities in which CUSTOMERS participate, operation and enhancement of theWEBSITE (including the provision of functions which require identifiers or otherpersonal data) and additional IT systems and identity verifications;  

protection of CUSTOMERS, employees and otherindividuals and protection of data, secrets and assets of and entrusted toSWAROVSKI, and the protection of the safety of systems and premises ofSWAROVSKI;

compliance with legal and regulatoryrequirements, including the internal rules of SWAROVSKI, enforcement andexploitation of legal rights and claims, defense against legal claims,litigation, complaints, combating abusive conduct, engaging in legalinvestigations and proceedings and responding to inquiries of publicauthorities;

sale or acquisitions of business divisions,companies or parts of companies and other corporate transactions and thetransfer of CUSTOMER DATA associated therewith; and

for other lawful purposes where such processingwas evident from the circumstances or indicated at the time of the collection.

(together the PURPOSE OF CUSTOMER DATAPROCESSING).

3.2 LEGAL GROUNDS of processing

SWAROVSKI uses the CUSTOMER DATA for the PURPOSEOF CUSTOMER DATA PROCESSING based on the following LEGAL GROUNDS:

• performance of contracts;
• compliance with legal obligations ofSWAROVSKI;
• consent of the CUSTOMER (only insofar as theprocessing is based on a specific query and can be withdrawn at any time, forexample the receipt of newsletters for which the CUSTOMER has registered for);

• legitimate interests of SWAROVSKI, includingbut not limited to
purchase and shipment of products and services,also in connection with individuals who are not direct contractual partners(such as e.g. individuals receiving a gift); advertising and marketingactivities; efficient and effective customer support, maintenance of contactand other communication with CUSTOMERS outside of the processing of contracts;understanding CUSTOMER behavior, activities,concerns and needs, market studies;  
efficient and effective improvement of existingproducts and services and development of new products and services; efficient and effective protection of CUSTOMERS,employees and other individuals as well as protection of data, secrets andassets of or entrusted to SWAROVSKI, protection and safety of systems andpremises of SWAROVSKI; maintenance andsecure, efficient and effective organization of business operations including asecure, efficient and effective operation and successful further development ofthe WEBSITEs and other IT systems; reasonablecorporate governance and development; successfulsale and acquisition of business units, companies or parts of companies andother corporate transactions;
compliance with legal and regulatoryrequirements and internal rules of SWAROVSKI; concerns regarding the prevention of fraud, offences and crimes as wellas investigation in connection with such offences and other improper conduct,handling of claims and actions against SWAROVSKI, cooperation in legalproceedings and with public authorities as well as the prosecution, exercise ofand defense against legal actions.

In accordance with applicable data protectionlaws, SWAROVSKI may process VISITOR DATA for the purpose of maintaining anddeveloping the WEBSITE (including the provision of functions which requireidentifiers or other personal data), for statistical analysis regarding the useof the WEBSITE as well as for combating abusive conduct, for purposes of legalinvestigations or proceedings and for the response to inquiries of publicauthorities. The VISITOR DATA shall be processed in accordance with theprinciples set out for CUSTOMER DATA above.

In accordance with applicable data protectionlaws, SWAROVSKI may process PARTNER DATA  for the purpose of entering intoand performance of contracts and other business relationships with PARTNERS,promotions, advertisement and marketing, communication, invitation to eventsand participation in promotions for PARTNERS, organization of joint activities,compliance with legal and regulatory requirements and internal rules ofSWAROVSKI, enforcement and exploitation of legal rights and claims, defenseagainst legal claims, litigation, complaints, combating abusive conduct,engaging in legal investigations and proceedings and responding to inquiries ofpublic authorities, for the sale or acquisition of business units, companies orparts of companies and other corporate transaction and related transfers ofPARTNER DATA. The PARTNER DATA shall be processed in accordance with theprinciples set out for CUSTOMER DATA above.

All the purposes of processing shall beapplicable for the whole SWAROVSKI Group, i.e. not only for the company whichinitially collected the personal data. Personal data of CUSTOMERS, VISITORS andPARTNERS is collected for the purpose of all SWAROVSKI companies subject tothis data privacy notice, any other policies developed by SWAROVSKI and pursuantto applicable data protection laws.

4. TRANSFER AND DISCLOSURE OF DATA

In accordance with applicable data protectionlaws, SWAROVSKI may transfer CUSTOMER DATA, VISITOR DATA and PARTNER DATA tothe following categories of third parties who process PERSONAL DATA inaccordance with the PURPOSE OF DATA PROCESSING on behalf of SWAROVSKI or fortheir own purposes:

- service providers (within SWAROVSKI as well asexternal), including processors;
- wholesalers, dealers, retailers, suppliers andother business partners;
customers of SWAROVSKI;
- local, national and foreign authorities;
- media;
- the public including visitors of WEBSITES andsocial media of SWAROVSKI;
- industry organizations, associations,organizations and other committees;
- acquirers or parties interested in acquiringbusiness units, companies or - other parts of SWAROVSKI;
- other parties in potential or actual legalproceedings;
- other Group companies of SWAROVSKI.

(together THIRD PARTIES).

SWAROVSKI may disclose CUSTOMER DATA, VISITOR DATA and PARTNER DATA within SWAROVSKI as well as to THIRD PARTIES and in everycountry/region worldwide, including namely all countries/regions in whichSWAROVSKI is represented by Group companies, affiliates or other offices and representatives (see ANNEX 2, as updated from time to time). As far asreasonable, Swarovski will transfer CUSTOMER DATA, VISITOR DATA and PARTNER DATA to countries/regions recognized as guaranteeing an adequate level of data protection. If CUSTOMER DATA, VISITOR DATA and PARTNER DATA need to be transferred abroad in countries/regions not providing such an adequate level of protection, less stringent data protection rules may apply. If DATA is disclosed to countries/regions that do not guarantee adequate protection, SWAROVSKI will ensure that data disclosed of CUSTOMERS, VISITORS or PARTNERS is adequately protected and transferred in accordance with current legally recognized data transfer mechanisms, such as appropriate standard contractual clauses approved by the European Commission (see https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en) or required revisions thereof (e.g Switzerland)), binding corporate rules, or transferring data pursuant to consent, conclusion or performance of a contract, or in connection with the determination, exercise or enforcement of legal claims, or pursuant to overriding public interests, or  in order to protect the integrity of these individuals. The CUSTOMER, VISITOR or PARTNER can obtain a copy of the contractual guarantees from us or will be advised where to obtain such copies by the contact points named above (see para. 1 above). SWAROVSKI reserves the right to redact such copies for applicable legal or secrecy reasons.

5. RETENTION OF DATA

In general, SWAROVSKI retains personal data for no longer than it is necessary for the purposes for which the personal data are processed. Notwithstanding the general principle, SWAROVSKI may process personal data for longer periods subject to the following rules and obligations: SWAROVSKI retains personal data as long as SWAROVSKI (i) is obligated to do so (by way of contract, law or other provisions) or (ii) has an overriding interest (e.g. an interest for reasons of proof in case of claims, documentation of compliance with certain legal or other requirements, an interest in non-personalized analysis). Deviating rules are reserved with respect to anonymization or pseudonymization of personal data subject to applicable law.

As a rule for contract related CUSTOMER DATA and PARTNER DATA (including business records and communication) SWAROVSKI retains personal data as long as the contractual relation is ongoing and for ten years after the termination of the contractual relationship unless (i) a shorter or longer statutory storage obligation is applicable on a case-by-case basis, (ii)the retention is required for reasons of proof or another valid reason based on applicable law, or (iii) the deletion of the data is required earlier (because e.g. the data is no longer required or SWAROVSKI is required to delete the respective data).

As a rule for operational data containing CUSTOMER DATA, VISITOR DATA or PARTNER DATA (e.g. protocols, logs), Swarovski retains personal data for a period of 3 - 12 months.

6. COOKIES, GOOGLE ANALYTICS AND SOCIAL PLUG-INS

SWAROVSKI uses cookies on its WEBSITE. Cookies are a widespread technique that allocates an identification to the browser of the user of a WEBSITE which the user saves and shows upon request. On the one hand, SWAROVSKI uses session cookies which are automatically erased when the user closes the WEBSITE and which enable the server to establish a stable connection to the user (so that the content of a shopping basket is not lost, for example) as long as he or she browses on the WEBSITE. On the other hand, SWAROVSKI also uses permanent cookies which are only erased after a period defined per WEBSITE. Permanent cookies allow the saving of certain settings (e.g. language) for several sessions or allow for an automated log-in. The user consents to the application of permanent cookies through the use of the WEBSITE and the respective functions (e.g. language settings and automated log-in). The user may block or delete the application of cookies on his or her browser but this activity may impair the use of the WEBSITE.

In accordance with applicable law, SWAROVSKI may install coding in newsletters and other marketing email which allow it to determine if the recipient has opened an email or downloaded pictures contained in the email. However, the recipient may block this application in his/here mail application. In any case he/she consents to the application of this technology by way of receiving newsletters or other marketing related emails.

In the event that SWAROVSKI places advertisements of third parties on the WEBSITE (e.g. banners) or  places an own ad on the website of a third party, cookies from companies specializing in the use of such advertisement may be employed. SWAROVSKI will not disclose personal data to such companies, i.e. they shall only place a permanent cookie with users of the WEBSITE in order to recognize users and do so in the sole interest of SWAROVSKI. This allows SWAROVSKI to place aimed advertisements for these individuals on external third party websites (e.g. in connection with products for which these individuals showed an interest in the online-shop). SWAROVSKI will not disclose personal data to the operators of external websites. The companies owning these websites and platforms have their own privacy policies in place, and SWAROVSKI privacy policy does not extend to the processing activities carried out by these third Parties where the latter are acting on their own account. Please visit the respective privacy policies to know how they process your Personal Data. In this context, SWAROVSKI relies on The Trade Desk (hereafter also "TTD") services to display ads to users who have shown an interest in our websites or who have specific characteristics (e. g. interests in certain products or certain demographic characteristics) for the purposes of targeted advertising. TTD helps SWAROVSKI to manage digital advertising campaigns by ensuring that the advertisements you see on the internet are relevant to you (personalizing ads) and by measuring and evaluating the effectiveness of our marketing campaigns (measurement and analytics; reporting; clicks and conversion). For these purposes, the TTD´s technology (hereafter also “TTD Platform”) collects and processes pseudonymized– i.e. non-directly identifying – data about users, devices and ads, as well as where they are shown. The processed data includes: Cookie ID, Mobile Device ID, IP address, interest information, web browser and device information, information about which advertisements you have already seen, how you responded to ads, location information, timestamps and website URLs. If you are based in theEuropean Economic Area (EEA), the United Kingdom or Switzerland, the UK TradeDesk Ltd. is responsible for processing your personal data. For the provision of the services to Us, TTD may disclose information to third parties, including third parties based in the United States, as described in The Trade Desk privacy policy available at https://www.thetradedesk.com/us/privacy.

SWAROVSKI may use Google Analytics or similar services on its WEBSITE. These applications are third party services which allow SWAROVSKI to measure and analyze the use of its WEBSITE. The provider of these services may be located in any country worldwide (in the case of GoogleAnalytics which is operated by Google Inc. it is the U.S., www.google.com).The service provider uses permanent cookies for these applications. SWAROVSKI will not disclose any personal data to the service provider (who will also not save any IP addresses). The service provider may, however, monitor the use of the WEBSITE by the user and combine this data with data from other websites monitored by the same service provider which the user has visited and the service provider may use these findings for its own benefits (e.g. control of advertisement). The service provider knows the identity of the user who has registered with the service provider. In this case the processing of personal data will be the service provider's responsibility and data shall be processed pursuant to data protection and privacy laws and according to the data protection policies of the service provider (for Google see policies.google.com/privacy). The service provider will provide data on the use of the WEBSITE to SWAROVSKI.

In addition, SWAROVSKI may use plug-ins from social media networks such as Facebook, Twitter, Youtube, Google+, Pinterest orInstagram on its WEBSITE. In the default setting of the WEBSITE plug-ins are deactivated; the user can thus choose when to activate them. Should the user do so, the social media providers are able to establish a direct connection to the user during his or her visit on the WEBSITE, which allows the provider to be aware of the user's visit and may analyze the respective information. The subsequent processing of the personal data will be conducted in the responsibility of the social media provider pursuant to data protection and privacy laws and according to its data protection policies published on its website (such as www.facebook.com/; 
www.twitter.com/; www.youtube.com/; www.google.com/; 
www.pinterest.com/; www.instagram.com/).

You can find more information about Cookies used by SWAROVSKI on our WEBSITE and also manage your Cookie settings here.

7. RIGHTS OF THE CUSTOMER, VISITORS AND PARTNERS

Any affected individual, including any CUSTOMER, VISITOR and PARTNER, may request information from SWAROVSKI as to whether data concerning them is being processed. In addition, they have the right to request the correction, destruction or restriction of personal data regarding them as well as to object to the processing of personal data. Should the processing of personal data be based on consent, the affected individual may withdraw consent at any time. In countries of the EU and EEA the affected individual may, in certain cases, have the right to obtain data generated during the use of online services in a structured, common and machine-readable format which allows for further use and transfer. Request in this respect shall be submitted to the contact point (see para. 1 above). SWAROVSKI reserves the right to restrict the rights of the affected individual in accordance with applicable law and e.g. not to disclose comprehensive information or not to delete data.  

In the event that SWAROVSKI makes an automated decision with respect to a certain individual which may have a legal effect for the affected individual or seriously affect him or her in a similar way, the affected individual shall have, in accordance with applicable law, the right to communicate with a controller of SWAROVSKI and to request a reconsideration of the decision or to request the prior evaluation by the controller. In this casethe affected individual may no longer be able to use certain automated services. The individual will be informed thereof subsequently or separately in advance.

Any affected individual may also raise a complaint with the competent data protection authority, which in the case of a SWAROVSKI controller in Switzerland is the Federal Data Protection andInformation Commissioner in Switzerland (http://www.edoeb.admin.ch), the SWAROVSKI controller in the Principality in Liechtenstein is the Data Protection Office (Amtstelle Datenschutzstelle, in the Principality in Liechtenstein (https://www.llv.li/), the SWAROVSKI controller in Austria is the Austrian Data Protection Authority in Austria (https://www.dsb.gv.at/). In all other cases a list can be found here.

8. CHANGES TO THE DATA PRIVACY NOTICE

SWAROVSKI reserves the right to amend this Data Privacy Notice at any time and without prior notice or announcement. The latest version posted on the SWAROVSKI WEBSITE shall be applicable.

Should the Data Privacy Notice form part of an agreement with CUSTOMERS and PARTNERS, SWAROVSKI may inform them of an update or amendments by email or in another appropriate manner. The amendments shall be deemed to have been accepted unless an objection is raised within 30 days of notification. In case of objection SWAROVSKI shall be free to terminate the agreement exceptionally and with immediate effect.



II. Specific Provisions

The following provisions shall supplement the general provisions in Section I for certain activities of SWAROVSKI. In the event there is any inconsistency, the following provisions shall control.

1. ONLINE-SHOPS

The creditworthiness of CUSTOMERS may be evaluated automatically in online-shops in order to offer the purchase on account based on this decision. In this case the credit rating is evaluated on the basis of information from an external credit rating agency, which will provide SWAROVSKI with a credit score of the respective CUSTOMER. The agency will calculate the score based on a secret formula based on data on the payment history of the CUSTOMER, its debt and insolvency history and possible limitations of its legal capacity. Should the score be below a certain threshold no payment by invoice will be offered. In this event the CUSTOMER may contact the contact person shown on the imprint of the respective website of the online-shop if he/she is not ready to accept the decision.

Online shops of SWAROVSKI may automatically decide whether to enter into purchase agreements. However, SWAROVSKI does not deem this an automated individual decision (according to article 22 of the GDPR). In the event the CUSTOMER does not wish such an automated entering into an agreement, it has the option to purchase products and services from SWAROVSKI physical stores.

2. PARTNERS, INCLUDING WHOLESALERS, RETAILERS,DEALERS, CUSTOMER SERVICE VENDORS ETC.

As previously indicated, CUSTOMER DATA, PARTNER DATA and VISITOR DATA is generally collected directly by SWAROVSKI but also indirectly, (e.g. when SWAROVSKI requests THIRD PARTIES to act as processors, such as SWAROVSKI’s PARTNERS). In these cases, SWAROVSKI’s PARTNERS process personal data on behalf and under instruction of SWAROVSKI and are bound by specific processor agreements covering the terms and conditions of their duties in a manner to ensure the protection of the rights of our CUSTOMERS, PARTNERS and VISITORS and the processing and security of their personal data in accordance with applicable data protection laws.

3. NEWSLETTER AND BANNER ADVERTISEMENT

SWAROVSKI may send newsletters or other commercial communications in connection with its products and services to CUSTOMERS and PARTNERS. In accordance with applicable law, SWAROVSKI reserves the right to do so without prior consent of existing customers and business partners. However, the respective customers and business partners may object to a further mailing of newsletters or other commercial communications at any time through their account on the respective WEBSITE or through the link indicated in every mailing. However, the termination of one newsletter may not entail the termination of other newsletters.

SWAROVSKI reserves the right to place personalized advertisement during WEBSITE visits. Such banner advertisements displayed to the CUSTOMER contains products offered on the WEBSITE which have previously been looked at by the CUSTOMER. The advertisement is generated by SWAROVSKI by the means of cookies (see Section I para. 6 above).

4. SWEEPSTAKES and other PROMOTIONAL ACTIVITIES

The following provisions shall be applicable forthe processing of data by SWAROVSKI in connection with customer SWEEPSTAKES andother PROMOTIONAL ACTIVTIES.

The data in connection with the SWEEPSTAKE andother promotional activties is processed by (i) the controller of therespective local Swarovski company which sponsors, promotes and organizes the sweepstake and as the case may be by (ii) Swarovski Aktiengesellschaft, Dröschistrasse 15, 9495 Triesen, Liechtenstein, as a joint controller. Other companies and affiliates of SWAROVSKI may however use the collected personal data for their purposes according to Section I para. 3 above.

With respect to SWEEPSTAKE and other PROMOTIONAL ACTIVITES, SWAROVSKI processes the personal data of participants according to Section I para. 2 above.for the purposes listed under that respective provision, and in particular alsofor the following purposes in accordance with applicable laws:

- carrying out the competition;
- contacting winners;
- publication of the contact details of thewinners
- promoting winners on social media, and
- other promotional and marketing activities.

Further information regarding the SWEEPSTAKE and OTHER PROMOTIONAL ACTIVTIES can be found in the specific terms and conditions applicable to each SWEEPSTAKE and PROMOTIONAL ACTIVTIY, as published and organized from time to time.

5. Video surveillance

Some premises and offices of Swarovski are under video surveillance. The controller of personal data collected on surveillance recordings with respect to collecting personal data according to the EU General Data Protection Regulation (“GDPR”) and provisions other applicable local data protection laws (collectively as: “Data protection laws”) is the Swarovski entity indicated in the Swarovski premises. The processing of the personal data is necessary for the purposes of the legitimate interests pursued by the Swarovski, that is ensuring security in the premises and protecting the property of the Swarovski. Personal data 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. In accordance with the Data protection laws, SWAROVSKI may transfer personal data to the following categories of  the third parties who process personal data in accordance with the purpose of data processing on behalf of Swarovski or for their own purposes: service providers, including processors; local, national and foreign authorities; other parties in potential or actual legal proceedings, other group companies of Swarovski. If data is disclosed to countries that do not guarantee adequate protection, Swarovski will ensure adequate protection of data disclosed of by putting adequate contractual guarantees in place, (e.g.,on the basis of EU standard clauses), binding corporate rules or transferring data pursuant to consent, conclusion or performance of a contract, or in connection with the determination, exercise or enforcement of legal claims, or pursuant to overriding public interests, or  in order to protect the integrity of these individuals. Any affected individual may request information from Swarovski as to whether data concerning them is being processed. In addition, they have the right to request the correction, destruction or restriction of personal data regarding them as well as to object to the processing of personal data and the right to data portability. Any affected individual may also raise a complaint with the competent data protection authority. If you want to exercise any of your rights regarding or you have any queries or concerns about our privacy policy or the processing of your personal data can also be addressed to The Group Data Privacy Team at [email protected].

   
Annex 1 –  List of SWAROVSKI Legal entities

Argentina
Swarovski Argentina Sociedad Anónima, Comercial e Industrial, Av J.B.Justo 637 4to Piso, Buenos Aires, 1425, Argentina

Australia

Swarovski Australia Pty Ltd, Unit 1, 4D Huntley Street, Alexandria NSW 2015, Australia

Austria

D. Swarovski Distribution GmbH, Swarovskistrasse 30, 6112 Wattens, Tirol, Austria D. Swarovski KG, Swarovskistrasse 30, 6112 Wattens, Tirol, Austria D. Swarovski Tourism Services GmbH, Swarovskistrasse 30, 6112 Wattens, Tirol, Austria  Swareflex GmbH, Swarovskistrasse 30, 6112 Wattens, Tirol, Austria Swarovski Mobility GmbH (ehem. Swarovski Energy GmbH), Swarovskistrasse 30, 6112 Wattens, Tirol, Austria

Belgium
Swarovski Belgium N.V., Louizalaan 50b, 1050 Brussels, Belgium

Brazil
Swarovski Cristais Ltda., Edifício Spazio Centralle, Alameda Itu, Nº 852 Conjunto 132 13º Andar, 01421-002 São Paulo, Brazil

Canada
Swarovski Canada Limited, 66 Wellington Street West, Suite 5300, TD Bank Tower, Toronto ON M5K 1E6, Canada

Chile
Swarovski Chile Limitada, Marchant Pereira 150, Providencia Santiago, Región Metropolitana, Chile

Chinese Mainland
Swarovski (Guangzhou) Trading Co. Ltd, Taikoo Hui, No. 385 Tianhe Road, Tianhe District, 510620, Guangzhou, China Swarovski (Shanghai) Trading Co. Ltd., Unit 2803, 2805 and Floor 27, Building 4, No 1, Lane 838, South Huangpi Road, Huangpu district, Shanghai, 200025, China

Costa Rica
Swarovski Global Business Services Americas, SRL., Escazú Village Corporate Center, Avenida Central, 10201 San José, Costa Rica

Czech Republic
Swarovski Bohemia spol. s r.o., Kateřinská Business Center, Kateřinská 466/40, Prague 2,Nové Město, 120 00, Czech Republic

France
Swarovski France S.A.S., 13 Ter Boulevard Berthier, 75017, Paris, France

Germany
Swarovski (Deutschland) GmbH, Hüttenstr. 27, 87600, Kaufbeuren, Bayern, Germany

Greece
Swarovski Hellas Single Member Industrial & Commercial S.A., 114, Vouliagmenis av. & 5 Spetson str., Athens, Glyfada, GR 16674, Greece

Hong Kong SAR
Swarovski Greater China Limited, CITI TOWER, ONE BAY EAST NO. 83 HOI BUN ROAD, Hong Kong SAR, Hong Kong Swarovski Hong Kong Limited, 8th Floor, Citi Tower, One Bay East No. 83 Hoi Bun Road, Ngau Tau Kok, Kowloon, Hong Kong, Hong Kong Swarovski Taiwan Ltd, CITI TOWER, ONE BAY EAST NO. 83 HOI BUN ROAD, Hong Kong SAR, Hong Kong

Hungary
Swarovski Hungary Retail Limited Liability Company, Népfürdő street 22, Building B 13th Floor, Budapest, 1138, Hungary

India
Swarovski India Private Limited, One Horizon Centre, 12th Floor, DLF Phase V, Sector 43, 122002, Gurgaon, Haryana, INDIA

Ireland
Swarovski Ireland Limited, 70 Sir Rogerson's Quay, Dublin, Dublin, Ireland

Italy
Swarovski Internazionale d'Italia S.r.l., Via G.Giulini, n.3, 20123 Milano, Italy

Japan
Swarovski Japan Ltd., 1-12-1 Kojimachi, Chiyoda-ku, Tokyo, 102-0083, Japan

Liechtenstein
Swarovski Aktiengesellschaft, Dröschistrasse 15, Triesen, 9495, Liechtenstein Swarovski International Distribution AG, Dröschistrasse 15, Triesen, 9495, Liechtenstein

Luxemburg
Swarovski Luxembourg Sarl, Grand-Rue 49, Luxembourg, 1661, Luxembourg

Republic of Korea
Swarovski Korea Ltd, 10,11,12F Baekyoung Bldg. 456 Dosan-daero, Gangnam-gu/ Seoul, 06062, Korea, Republic of

Macao SAR
Swarovski Macao Ltd., Avenida da Praia Grande, no 429 Edificio Centro Commercial da Praia Grande, 23° andar B. em Macau, Macau SAR, Macao

Malaysia
Swarovski Global Business Services Asia SDN. BHD, Unit 1.01, GBS@Mayang, Jalan Mahsuri, Bandar Bayan Baru, 11900 Bayan Lepas, Penang, Malaysia Swarovski Malaysia Trading Sdn Bhd, Arcc Offices Pavilion Tower Level 16, Pavilion Tower, Jalan Raja Chulan, 50200 Kuala Lumpur, Malaysia

Mexico
Swarovski Crystal SA de CV, Av. Ejército Nacional Mexicano No. 579 Piso 11, Col. Granada, Del. Miguel Hidalgo, D.F.,Mexico City, 11520, Mexico

Netherlands
Swarovski Netherlands B.V., Dam 6, 1012, NP Amsterdam, Netherlands

New Zealand
Swarovski International (NZ) Limited, 3/45 Queen Street, Auckland, 1010 New Zealand

Poland
Swarovski Global Business Services Sp. z o. o., ul. Cypriana Kamila Norwida 5, "Yoko" Building, 80-280, Gdansk, Poland Swarovski Poland Sp. z o.o., Crown Tower, ul. Hrubieszowska 2, 01-209, Warsaw, Poland

Portugal
Swarovski Ibérica S.A - Sucursal Em Portugal, Rua Garret 28-30, 1200-204, Lisboa, Lisboa, Portugal

Serbia
Swarovski Subotica d.o.o., Subotica, Batinska 94, Subotica, 24000, Serbia, Republic of

Singapore
Swarovski Singapore Trading Pte Ltd., DELTA HOUSE, 2 ALEXANDRA ROAD, #03-01, SINGAPORE 159919, Singapore

South Africa
Swarovski South Africa (Pty) Ltd, 300 Acacia Road, Darrenwood, Randburg, Gauteng, 2194, South Africa

Spain
Swarovski Ibérica, S.A, C/ Llacuna, 10-20 1ª Planta, 08005, Barcelona, Spain

Switzerland
Crystalon Finanz AG, Alte Landstrasse 411, 8708 Männedorf, ZH, Switzerland DSW Leitungsgesellschaft AG, Alte Landstrasse 411, 8708 Männedorf, ZH, Switzerland Swarovski (Schweiz) AG, Alte Landstrasse 411, 8708 Männedorf, ZH, Switzerland Swarovski Brand License AG, Alte Landstrasse 411, 8708 Männedorf, ZH, Switzerland Swarovski Crystal Online AG, Alte Landstrasse 411, 8708 Männedorf, ZH, Switzerland Swarovski Immobilien AG, Alte Landstrasse 411, 8708 Männedorf, ZH, Switzerland Swarovski International Holding AG, Alte Landstrasse 411, 8708 Männedorf, ZH, Switzerland

Taiwan Region
Swarovski Taiwan Ltd. Taiwan Branch, FU TSU CONSTRUCTION BUILDING, 9F, No. 27, Chung Shan North Road, Sec. 1, Taipei City, Taiwan region, 10441, Taiwan

Thailand
Swarovski Gemstones (Thailand) Ltd, 333 Moo 17 Bangplee Industrial Estate, Bangna-Trad Road, Bangsaothong, Samutprakan, 10570, Thailand Swarovski Manufacturing (Thailand) Co., Ltd., 200 Moo 1, Hi-Tech Industrial Estate (FZ), Baanlane DIST, Bang Pa-In, Ayutthaya, 13160, Thailand Swarovski (Thailand) Limited, 849 Vorawat Building, 16th Floor, Room 1601-1602, Silom Road, Bangrak, Bangkok, 10500, Thailand Swarovski SCST Limited, 849 Vorawat Building, 12th Floor, Silom Road, Silom Sub-dist, Bangkok, 10500, Thailand

Turkey
Swarovski Kristal Ticaret Limited Sirketi, Nisbetiye Mahallesi, Nisbetiye Mah. Nisbetiye Cad. No:24 İç Kapı No:3, Istanbul, 34340 Turkey

United Arab Emirates
Swarovski Middle East FZE, R/A No. 6, P.O.Box 17128, Jebel Ali, Dubai, United Arab Emirates

United Kingdom
Swarovski UK Limited, 1st Floor, Building 4, Chiswick Park, 566 Chiswick High Road, London, England and Wales, W4, 5YE, United Kingdom

United States
Swarovski North America Limited, One Kenney Drive, Cranston RI 02920, United States Swarovski Retail Ventures Ltd., Swarovski North America Limited, One Kenney Drive, Cranston RI 02920, United States Touchstone Crystal, Inc., Swarovski North America Limited, One Kenney Drive, Cranston RI 02920, United States

Vietnam
Swarovski Manufacturing Vietnam Limited Liability Company, Lot 204, AMATA Industrial Park, Bien Hoa City, Dong Nai Province, 70000, Vietnam


Annex 2 – List of Countries/Regions

Argentina, Australia, Austria, Belgium, Brazil, Canada, Chile, Chinese Mainland, Costa Rica, Czech Republic, France, Germany, Greece, Hong Kong SAR, Hungary, India, Ireland, Israel, Italy, Japan, Republic of Korea, Liechtenstein, Lithuania, Luxembourg, Macao SAR, Malaysia, Mexico, Netherlands, New Zealand, Poland, Portugal, Serbia, Singapore, Spain, Sweden, South Africa, Switzerland, Taiwan region, Thailand, Turkey, United Arab Emirates, United Kingdom, United States of America, Vietnam