1. Introduction SICURA
A registered trademark of D GROUP EUROPE BV (MARKT 19, 6071 JD SWALMEN, NETHERLANDS) and its affiliated companies distributing the SICURA brand (collectively “SICURA”), is committed to the lawful and transparent processing of personal data in accordance with applicable data protection legislation.
2. Data Protection Officer Contact Information
For any inquiries or requests regarding the collection and processing of personal data by SICURA, please direct communication to our designated Data Protection Officer at privacy@sicura-watches.com.
3. Consent and Acceptance
By Interacting with SICURA (accessing or utilizing our Websites, communicating with us, or providing personal data), you acknowledge that you have read, understood, and unequivocally consent to the terms and conditions of this Policy. You agree to be legally bound by this Policy and to adhere to all relevant laws, regulations, and legal instruments, including any terms of use applicable to the Websites.
4. Lawful Basis for Processing
SICURA will process personal data only when a lawful basis exists under applicable data protection law, including:
- Explicit consent for specific processing purposes.
- Necessity for the performance of a contract or to take steps prior to entering into a contract. Compliance with a legal obligation.
- Protection of the vital interests of the data subject or another natural person.
- Performance of a task carried out in the public interest or in the exercise of official authority.
- Legitimate interests pursued by SICURA or a third party, except where such interests are overridden by your rights and freedoms. Where legitimate interests are relied upon, these will be clearly identified in the relevant sections.
5. Withdrawal of Consent
You have the right to withdraw your consent at any time where consent is the lawful basis for processing. To do so, please notify us explicitly at privacy@sicura-watches.com. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
6. Mandatory Data Provision
Where providing certain personal data is a statutory or contractual requirement, or necessary to enter into a contract, SICURA will clearly indicate this at the point of collection. Failure to provide such mandatory data may prevent us from fulfilling your requests or providing the requested goods or services.
7. Sources of Personal Data
SICURA may collect personal data from the following sources:
- SICURA Websites and Mobile Applications
- Direct Communications (email, SMS, phone, etc.)
- SICURA Retail Locations and Service Centers
- SICURA Events and Promotions (questionnaires, surveys, forms)
- Publicly Available Sources (where legally permissible and for specific, legitimate purposes)
- Closed-Circuit Television (CCTV) Systems (in some physical locations, with clear signage)
8. Categories of Personal Data Collected and Purposes of Processing
SICURA collects personal data that is adequate, relevant, and limited to what is necessary for the purposes of processing:
- Identity and Contact Information: (Name, address, email, phone, social media IDs) for account management, order processing, communication, customer service, identity verification, personalization, and marketing (with consent). Lawful basis: Contract, legitimate interests, consent.
- Payment Information: (Payment card details, bank account information) for processing payments and fraud prevention. Lawful basis: Contract, legal obligation, legitimate interests. Security measures: Encrypted transmission to PCI DSS compliant processors; SICURA does not store full card details.
- Preferences and Interests:(Product/service preferences, watch collection, nationality, DOB, gender) for personalization, tailored offers, and service improvement. Lawful basis: Consent, legitimate interests.
- Website Usage Data and Technical Information: (IP address, browser type, device info, referring URL, browsing activity, logs, geolocation if enabled) for website functionality, security, improvement, personalization, and diagnostics. Lawful basis: Legitimate interests, consent (for certain cookies).
- Communications Data: (Content of emails and other communications) for responding to inquiries, record-keeping, and service improvement. Lawful basis: Legitimate interests.
- Social Network Data: (Publicly shared data and profile information shared with permission) for social media interaction, website personalization (if using social features), and audience analysis. Lawful basis: Consent. Review social network privacy policies.
9. Cookies and Similar Technologies
SICURA uses cookies and similar technologies (web beacons) to enhance user experience, analyze website traffic, and personalize content and advertising.
Definition of Cookies: Small text files placed on your device.
Utilization of Cookies: Strictly Necessary Cookies * Performance and Analytics Cookies (including Google Analytics - see Section 10) * Functional Cookies * Targeting and Advertising Cookies * Management of Cookie Preferences: Most browsers allow control over cookies through settings. Refer to your browser's "Help" menu or [Insert Link to a Reputable Cookie Management Resource]. Blocking cookies may impact website experience. * "Do Not Track" Signals: The Websites do not currently respond to "Do Not Track" signals.
10. Google Analytics
The Websites use Google Analytics, a web analytics service provided by Google Ireland Limited (“Google”). Google Analytics uses cookies to analyze website usage. Data (including IP address) is transmitted to and stored by Google on servers in the United States. Google uses this information to evaluate website use, compile reports, and provide other services related to website activity and internet usage. Google may transfer this data to third parties where legally required or where they process data on Google's behalf. Google will not associate your IP address with other data held by Google. You can prevent data collection by Google Analytics by adjusting your browser settings to reject cookies or by installing the Google Analytics opt-out browser add-on: [https://tools.google.com/dlpage/gaoptout](https://tools.google.com/dlpage/gaoptout). By using the Websites, you consent to the processing of your data by Google as described.
11. Data Retention
SICURA will retain personal data only as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements. Retention periods are determined based on the data's nature, sensitivity, potential risk, processing purposes, and legal obligations. Specific retention periods for different data categories are: * Account and Profile Data: [Specify precise retention period] * Order and Transaction Data: [Specify precise retention period] * Customer Service Communications: [Specify precise retention period] * Marketing Communication Preferences: [Specify precise retention period] * Website Usage Data: [Specify precise retention period] In some cases, data may be anonymized and retained for longer periods for analytical purposes without further notice.
12. Disclosure and Transfer of Personal Data
SICURA may disclose personal data to the following categories of recipients for legitimate purposes:
- SICURA Affiliates
- Third-Party Service Providers (IT, payment processors, shipping, marketing, customer service, analytics) - with contractual obligations for data protection.
- Business Transfers (in case of merger, acquisition, etc., with notice to data subjects).
- Legal and Regulatory Authorities (if legally compelled or to protect rights/safety). * With Explicit Consent.
13. Cross-Border Data Transfers
If personal data is transferred outside Switzerland and the EEA to countries without adequate data protection laws, SICURA will implement appropriate safeguards such as:
- Transferring to countries with adequacy decisions.
- Implementing Standard Contractual Clauses (SCCs).
- Ensuring Binding Corporate Rules (BCRs) are in place.
- Relying on other legally recognized transfer mechanisms.
You can request a copy of these safeguards by contacting privacy@sicura-watches.com.
14. Data Security
SICURA has implemented robust technical and organizational measures to ensure a level of security appropriate to the risk, including: * Pseudonymisation and encryption of personal data. * Ensuring ongoing confidentiality, integrity, availability, and resilience of processing systems. * Ability to restore data access in a timely manner after an incident. * Regular testing, assessment, and evaluation of security measures. Specific security measures include encryption (SSL/TLS for payments), access controls, regular security assessments, employee training, and incident response procedures. While we strive for security, no online transmission or storage is completely secure. Data breach procedures are in place as required by law.
15. Your Rights
Under applicable data protection laws, you have the following rights: * Right to Access * Right to Rectification * Right to Erasure ("Right to be Forgotten") * Right to Restriction of Processing * Right to Data Portability * Right to Object * Right to Withdraw Consent * Rights Related to Automated Decision-Making To exercise these rights, please contact privacy@sicura-watches.com or by mail at the address in Section 1. We may require identity verification. We will respond within legal timeframes. You also have the right to lodge a complaint with a competent data protection authority.
16. Marketing Communications
With your explicit consent, SICURA may send you marketing communications about our products, services, promotions, and news. You can manage your preferences: * Opt-in: Via tick boxes on registration forms or your My SICURA account. * Opt-out: Via unsubscribe links in emails, your My SICURA account, or by contacting privacy@sicura-watches.com. Even if you opt-out of marketing, you may still receive administrative communications.
17. Updates to this Policy
SICURA may revise or update this Policy periodically. Any changes will be effective upon posting the revised Policy on the Websites.
18. Jurisdiction and Applicable Law
This Policy and all matters arising from or related to it shall be governed by the substantive laws of the Netherlands, without regard to its conflict of laws principles. Any controversy, claim, or dispute shall be subject to the exclusive jurisdiction of the Courts of Amsterdam, Netherlands.
19. Contact Information
For any questions or requests regarding your personal data, please contact our Data Protection Officer at privacy@sicura-watches.com.
