Swiss Watch Services Privacy Policy 2

1.  Introduction

Swiss Watch Services LLC, a subsidiary of Seddiqi Holding LLC, a company incorporated under the laws of the United Arab Emirates (UAE) with registered office at P.O. Box 2123 (“Company", "we" or “us” or “SWS”), is the largest independent Aftersales Service workshop in the region (the “Services”). We take your privacy seriously and are committed to safeguarding your personal information at SWS. We value you and respect your privacy and are committed to protecting it through our compliance with this Notice.

This Privacy Notice (“Privacy Notice” or “Notice”) covers the personal information that SWS may collect or receive from you to provide or facilitate provision of the Services.

2. What personal information do we collect about you?

2.1        Personal information you give us

We primarily collect personal information with your permission, or to process your request for the Services. We only collect the minimum amount of personal information required to conduct operational activities and provide you with the Services. The personal information we collect may include:

• Personal information that you provide us with when you request the Services such as, your name, email address, phone number, address.
• Records and copies of your correspondence (including e-mail address) when you contact us.
• Information that you provide when you contact our helpdesk for support services.
• Information that you provide when you visit our office, stores or office locations managed by any of our affiliate companies.
• Information that you provide when you contact us via email, SMS, social media, web chats, WhatsApp chats, or directly call our customer service team (as available) for general enquiries, complaints, and request for support services. This information may include your name, email address, mobile number, and call recordings (in case you call our customer service team).
• Information captured on documents you provide to us to facilitate providing the Services, including information captured on your passport, Emirates ID, product certificate, and any other documentation you provide to us.

If you are a representative of any of our partner brands and suppliers, we may collect and process minimal personal information about you, which may include:

• Information that you provide through correspondence including name, business address, contact number, and email address.
• Professional details including employment information.

2.2  Other personal information we collect

Information obtained through any system operated for the security, safety, access management (CCTV, access control), and visitor management when you visit our office.

3. What are the sources of your personal information?

The sources of your personal information may include without limitation the following:

• Emails, text messaging services, and other electronic messages, phone calls: These are the electronic text-based or voice interactions between you and SWS.
• SWS customer service: Any communication between you and our customer service team (e.g., phone, chatbot, email, etc.).
• Data we create: SWS may also create data about you when you request the Services, such as job card creation.
• Data from documents you share with us: SWS may access, use, and process personal information contained in documents you share with us for providing the Services to you such as your Emirates ID, passport copy, or product certificate.
• CCTV cameras: CCTV footage (image and video) from CCTV cameras placed in our office.

This Notice does not apply to the following –

• Personal information collected by any third-party website or platform that is not directly managed by SWS, even if such website or platform advertises the Services. Please refer to the privacy notice of such website/platform for information on the personal information being collected and for what purposes.
• Personal information collected and processed in the context of any other relationship (beyond being a customer or partner brand of SWS) you might have with other subsidiaries of Seddiqi Holding LLC. e.g., as a customer, employee, contractor, or tenant. Please refer to the privacy notice issued for such relationships for information about how your personal information is collected and processed.

4.Why do we collect and how do we use your personal information?

We use personal information for several legitimate purposes, including providing and improving the Services and managing our relationship with you:

4.1 To provide, develop, and improve the Services

We collect your personal information (such as name, email address, delivery address) to avail you of the Services. We use the personal information we collect to perform essential business operations to support provision of the Services, including the following:

• To issue invoices for the Services based on our legal obligation to do so.
• To process your payment for the Services pursuant to our legitimate business interests to receive payment for services rendered.
• To create a job card when you request the Services, which is essential to fulfil our contractual obligation to provide you with the Services.
• To generate internal reports on the performance of the business based on our legitimate business interests to improve the quality of our service to you.

4.2   To send you updates regarding the Services

We use your personal information such as name, email address, phone number to provide you with updates regarding the Services and schedule pick up/delivery upon conclusion of the Services. We do this to fulfil our contractual obligation to you.

4.3        To comply with legal requirements and exercise or defend legal claims

We may need to process and retain your personal information to comply with legal or regulatory requirements to which we are subject. This may include sharing your personal information with relevant government authorities as may be required. We may also process your personal information where it is necessary for the purpose of exercising and defending legal claims.

4.4    To maintain security within our premises and keep the public safe 

We may process your personal information obtained through any system operated for security, safety, access management (CCTV, access control), or visitor management when you visit any of our stores, office locations, or facilities. Security records may include government-issued identification for visitor management, access logs, image, video, license plates, etc. from any of the security systems operated in our stores, office locations, or facilities. We collect and process such personal information pursuant to our legitimate interests to ensure the physical security of our employees, contractors, customers, vendors, other visitors, and assets located within the Seddiqi premises that the visitor is accessing to prevent loss, fraud, theft, injury, and other similar events. We also have a legal obligation to maintain security, ensure public safety, and to ensure compliance with local laws and regulations.

4.5 To respond to queries made by you

We would need to collect and use your personal information (such as name, e-mail address, phone number, and details of your enquiry/complaint) to process your queries, complaints, and requests. Additionally, when you call our customer service team, we may maintain a record of the communication, including call recordings, in pursuit of our legitimate interest to monitor and improve the quality of our support services to you.

For our Partner Brands and Suppliers:

We may collect and process certain personal information (e.g., name, contact information) of representatives of our partner brands and suppliers for the following purposes:

4.6 For managing our relationship with our brands and suppliers.

We may process personal information of our brand and supplier representatives to effectively manage our relationship with the brand/supplier, specifically for the following purposes:

• To facilitate provision of the Services including managing the products that are sent overseas for repairs, we may process your personal information (such as name and email ID). We process personal information for this purpose based on contractual necessity.

5. How to opt out?

• Email: you can click on the unsubscribe link provided in the email you receive from us.
• SMS: you can follow the instructions provided in the messages you receive from us.
• Privacy Office Notice: you may write to [email protected] regarding the specific processing activity(s) that you would like to opt out. Our Privacy Office will get in touch with you to facilitate the request accordingly.

6. ​​Who might we share this information with?

We may disclose personal information as described in this Privacy Notice:

• We may share your personal information with affiliate companies of SWS, including other subsidiaries of Seddiqi Holding LLC, to enable provision of the Services and conduct the other activities described in this Privacy Notice. Such affiliate companies and subsidiaries are located in the United Arab Emirates (UAE) and Kingdom of Saudi Arabia (KSA). If you require more information, please feel free to write to us at [email protected] and our Privacy Office would be happy to assist you with the same.
• We may use carefully selected third parties to perform the Services on our behalf or to assist us with the provision of the Services to you. For example, we may engage third party concierge and delivery service providers to support and facilitate delivery upon conclusion of the Services (in case you request for delivery).  While providing such services, these third parties may have access to your personal information. Personal information shared with third parties is obligated by contractual agreement to ensure they exercise the same care when handling personal information as we do ourselves.
• We may share your personal information with government agencies, government officials, regulators, and law enforcement agencies to comply with any applicable law, regulation, government directive, court order, or legal process.
• We may share to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our customers is among the assets transferred. We may share with other companies and organizations for the purposes of fraud protection if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

7.  Data Storage

The personal information that we collect is stored at a destination within the United Arab Emirates, Kingdom of Saudi Arabia, and through our authorized cloud service providers.

 

8. International Transfers

Personal information we collect may be transferred to, stored, and processed in the UAE or KSA where one or more of the members of Seddiqi Holding LLC are located or maintain facilities. We carry out such transfers to facilitate the provision of the Services and in pursuit of our legitimate business interests to serve you better. We will continue to protect the personal information we transfer in accordance with this Privacy Notice. We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice and applicable data protection laws, including, where relevant, entering standard contractual clauses (or equivalent measures). Where we transfer personal information outside of UAE Mainland, Abu Dhabi Global Market (ADGM), or KSA, we either transfer personal information to countries/territories that provide an adequate level of protection (as determined by the relevant authorities) or we have appropriate safeguards in place. Appropriate safeguards to cover these transfers are in the form of standard contractual/data protection clauses as adopted by the relevant data protection authorities. If you would like more information on protection measures and transfer mechanisms, please contact us using the details provided in Section - ‘How do you contact us?’.

 

9. Data Retention

Personal information is not kept any longer than is required for the legitimate purposes of the processing or to comply with applicable law. As we collect personal information for different purposes, there is not a single retention period for all personal information. We will only keep your personal information for as long as is reasonably necessary, taking into consideration the purposes outlined above and legal requirements under applicable law(s). For more information on where and how long your personal information is stored, and your rights of erasure, please contact us using the details provided in Section - ‘How do you contact us?’.

 

10. Data Security

The security of your personal information is an important concern to us. We use industry standard security controls to safeguard the confidentiality of your personal information and to make sure that your personal information is secure with us.

We have implemented and maintained appropriate technical and organizational security measures, policies, and procedures to protect your personal information from accidental loss, unauthorized access, use, alteration, and disclosure. All personal information you provide to us is stored on our secure servers behind a secure network. Examples of measures we take include:

• Imposing confidentiality obligations on our staff and service providers.
• Restriction of access to your personal information to employees and third parties strictly on a need-to-know basis, such as to respond to your enquiry or request.
• Using secure communication channels for transmitting personal information.
• Employing adequate administrative and technical controls to secure personal information.

11.  What are your rights?

Varying on the jurisdiction, certain privacy laws allow you to exercise rights that have been provisioned to the residents of such jurisdiction to provide control over your personal information. If you wish to exercise any of the rights provisioned to you (noted below), we may ask you for additional information to confirm your identity for security purposes, before disclosing personal information to you. We aim to respond to all requests within a reasonable time in line with applicable law(s). We reserve the right to charge a fee, where permitted by law, for example, if your request is found to be manifestly unfounded or excessive.

If you would like to exercise the below rights, please send us a request at [email protected]. We may not always be able to fully address your request, for example,

• if it would impact the confidentiality we owe to others, or
• if we are legally entitled to deal with the request in a different way, or
• if your request involves deletion of personal information that is required to comply with legal requirements.

The section below provides the data privacy rights you have with regards to your personal information:

11.1 The right to access

You have the right to obtain confirmation whether we process personal information about you, receive a copy of your personal information held by us, and obtain certain other information about how and why we process your personal information (like the information provided in this Privacy Notice).

11.2 The right to rectification

You have the right to request amendment or update of your personal information (for example, if you change your name) and to have incomplete personal information completed.

11.3  The right to restrict processing

You have the right to restrict our processing of your personal information in the following cases:

• Temporarily for a period when you have contested the accuracy of the personal information.
• Temporarily for a period when you have objected to the legitimate interest identified by us.
• Your personal information has been unlawfully processed and you request the restriction of processing instead of deletion.
• Your personal information is no longer necessary in relation to the purposes for which it was collected and processed but the personal information is required by you to establish, exercise, or defend legal claims.

We may continue to use your personal information following a request for restriction, where:

• we have your consent; or
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.

11.4    The right to erasure (also known as 'the right to be forgotten')

You have the right to request the deletion of your personal information in the following cases:

• Where the personal information is no longer necessary in relation to the purposes for which it was collected and processed.
• Our lawful basis for processing is consent. If you withdraw consent, we have no other lawful basis for the processing.
• Our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us. If you object to our processing and we do not have overriding legitimate grounds.
• You object to our processing for direct marketing purposes.
• Your personal information has been unlawfully processed.
• Your personal information must be erased to comply with a legal obligation under UAE or KSA Law to which we are subject.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

• For compliance with a legal obligation; or
• For the establishment, exercise, or defence of legal claims.

11.5    The right to object

You have the right to object to our processing of your personal information if our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us.

11.6    The right to data portability

You have the right to receive your personal information provided to us and have the right to send the data to another organization (or ask us to do so if technically feasible) where our lawful basis for processing the personal information is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

11.7    The right to withdraw consent at any time (where processing is based on consent)

Where we process personal information based on your consent, you have a right to withdraw consent at any time. You can withdraw your consent by following the instructions provided in “How do you contact us” section of this Notice.

11.8    The right to lodge a complaint with a data protection authority

You have the right to lodge a complaint with the local data protection authority in your country or residence in which an alleged infringement of data protection law has occurred.

We sincerely hope that you will never need to, but you may, at any time, discuss your concerns with us by contacting us in one of the ways mentioned in Section 14 - ‘How do you contact us?’. We will closely review and ensure a timely response to any complaints we receive.

12. Children’s Privacy

We do not knowingly solicit or collect personal information from children under the age of 18 without prior verifiable parental consent. If we learn that a child under the age of 18 has submitted personal information without parental consent, then we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under 18, you may contact us by emailing us at [email protected].

13. Updates on Notice

This Notice may change from time to time. Your continued use of the Services and our platforms after we make changes is deemed to be acceptance of those changes; please check this notice periodically for updates.

14. How do you contact us?

In case of any queries related to this Notice, you can contact our Data Privacy Office, email us at [email protected]. ​​​​​​​