1. Scope of application
“Adler” means Adler Joailliers SA, rue du Rhône 23, 1204 Geneva, Switzerland, and all entities of the Adler group.
2. Personal Data collected by Adler
“Personal Data” means any information relating to an identified or identifiable natural person (e.g. surname, first name, address, e-mail address).
Adler collects the following Personal Data when a customer account is created in a shop or on the Website, when using the Website, when tracking orders or when communicating with Data Subjects (e.g. when questions are asked on the Website). Some Personal Data may also be collected indirectly through external sources, in particular public sources (for example publications or databases).
Personal Data includes:
- Contact data: surname, first name, address, billing address, e-mail address, telephone number, date of birth;
- Professional information (g. employment);
- Financial data: bank details and billing information;
3. Purpose and legal basis of the processing of Personal Data
The processing of Personal Data includes the collection, recording, storage, use, modification, communication, archiving, deletion or destruction of data.
In general, Adler collects and processes Personal Data in the course of its business activities, including the fulfilment of its legal or regulatory obligations, (hereafter the “Purposes“) and according to the legal basis set out below:
- In the course of the performance and management of the contractual relationship between Adler and the Data Subject and in particular for the following Purposes:
- Creation and management of customer accounts;
- Processing and tracking of orders or repairs;
- Provision of information in relation to Adler’s products;
- Other processing related to the execution and management of the contractual relationship.
- In the context of the fulfilment of legal and regulatory obligations, which may arise under the laws of countries other than the country of residence of the Data Subject, and in particular for the following Purposes:
- Checks related to the fight against money laundering and terrorist financing;
- Providing information required by customs authorities in connection with the processing of an order;
- Responding to a request from a judicial or administrative authority;
- Transaction reporting obligations.
- In the course of pursuing Adler’s legitimate interests and in particular for the following Purposes:
- Management of the Website and the IT infrastructure;
- Maintenance and security of the premises and infrastructure;
- Sending offers and marketing materials in connection with Adler’s products or services;
- Analysis, evaluation and improvement of customer service quality;
- Analysis and anticipation of the consumption habits, behaviour, interests and personal preferences of Data Subjects (profiling), in particular for the configuration of targeted advertising;
- Personalisation of the offer of products and services;
- Establishing, exercising or defending a legal right.
- On the basis of the Data Subject’s consent for any processing of Personal Data that cannot be based on the Purposes above, in particular for the following Purposes:
- Invitation to events organised by Adler;
- Sending Adler’s newsletters; and
- For any other Purpose for which the Data Subject has given his/her consent.
The Data Subject may withdraw his/her consent at any time. However, his/her consent remains valid for any processing of Personal Data carried out prior to the withdrawal of his/her consent.
When Data Subjects authorize a social network (such as Facebook, Instagram, etc.) to share personal data with Adler, Adler may receive any personal data publicly shared by Data Subjects on the social network, such as contact information (e.g. name, electronic address, gender, friends or contact lists) or information published on Data Subjects’ profile (e.g. profile picture or preferences).
4. Sharing of Personal Data and transmission abroad
Adler may share Personal Data provided by Data Subjects with entities of the Adler group, its subcontractors or commercial partners to carry out operations related to the provision of its products and services, the management of the Website, or more generally to Adler’s activities.
In particular, Adler transfers Data Subjects’ Personal Data to the following categories of recipients:
- Website host; IT, payment and data storage service providers;
- Providers of communication services (e.g. in connection with the management of Adler’s newsletter and the social networks used by Adler), providers of events, marketing or other services in connection with Adler’s customer management;
- Service providers for the maintenance or repair of Adler’s products;
- Legal or administrative authorities, upon request and to the extent permitted by law.
Personal Data is primarily processed in Switzerland or in the European Union. If Adler transfers Personal Data to a country that has not been recognized as providing an adequate level of data protection by the competent authority, Adler implements the additional safeguards necessary to respect the rights of Data Subjects, such as the implementation of standard contractual clauses applicable to the transfer.
Data Subjects may obtain further information regarding the transfer of their Personal Data (including recipients, countries of destination and safeguards in place) by contacting Adler at the address provided in Section 7 below.
5. Data security
Internet is an open network accessible to anyone and does not offer a secure environment. Adler uses standard technologies and security measures to protect Personal Data from unauthorized access, illegal or improper use, disclosure, loss, destruction or damage. Personal Data may be stored on Adler’s technological systems or paper files or on those of Adler’s subcontractors.
6. Personal Data retention
In principle, Adler retains Personal Data as long as Adler needs it to achieve the Purposes or until the Data Subject withdraws his/her consent, or exercises his/her right to be forgotten, provided that Adler is not legally required or permitted to continue to hold such Personal Data (e.g. to establish, exercise and/or defend its rights as part of legal proceedings, investigations, or similar proceedings).
Data Subjects may obtain additional information about the retention period of their Personal Data, or the criteria used to determine that retention period, by contacting Adler at the address provided in Section 7 below.
7. Rights of Data Subjects and contact
Data Subjects have the following rights at all times, subject to the limitations provided for by applicable regulations:
- Right to access and obtain a copy of their Personal Data;
- Right to request the rectification or erasure of their Personal Data if it is inaccurate or incomplete;
- Right to request the erasure of their Personal Data when it is no longer necessary for the Purposes for which it was collected or processed or when the Data Subject withdraws the consent necessary for the processing;
- Right to object on legitimate grounds to the processing of their Personal Data and right to object at any time to the processing of Personal Data for marketing purposes, including profiling;
- Right to request the restriction of the processing of their Personal Data;
- Right to withdraw at any time the consent given for the processing of their Personal Data;
- Right to obtain the Personal Data they have provided, in a commonly used electronic format; and
- Right to file a complaint with the competent supervisory authorities concerning the processing of their Personal Data.
Even if a Data Subject objects to the processing of his/her Personal Data, Adler is entitled to continue the processing if it is (i) required by law, (ii) necessary for the performance of a contract to which the Data Subject is a party, (iii) necessary for the performance of a task carried out in the public interest, or (iv) necessary for Adler’s overriding legitimate interests, including the establishment, exercise or defense of legal claims. Adler will not use for direct marketing purposes the Personal Data of Data Subjects who object to such processing.
A version of this text is available in English. However, the French version prevails in the event of a difference in interpretation.
Date of issue: 8th of June 2021