Last modified: 08/30/2013INTRODUCTION
This policy does not apply to information we collect through any other means, or to information collected on any other Company, affiliate or any third-party site or by any third-party application that may link to or be accessible from the Website.
We comply with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. The Company has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the Company's certification, please visit http://www.export.gov/safeharbor/.
CHILDREN UNDER THE AGE OF 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, please do not register on the Website, make any purchases through the Website or send any information about yourself to us, including your name, address, telephone number or e-mail address. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at – firstname.lastname@example.org
INFORMATION WE COLLECT ABOUT YOU
We collect several types of information from and about users of our Website, including:
We may collect and use the following information that you provide to us:
USES MADE OF THE INFORMATION
We use information that we collect about you or that you provide to us, including any personal information, in the following ways:
DISCLOSURE OF YOUR INFORMATION
We may disclose personal information that you provide via this Website to the following third parties:
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You can review and update your personal information by logging into the Website and visiting your account profile page and making changes. If you have forgotten your password, once you have tried to register and failed, you can click on the "Forgot your password?" link to reach a page on which you can submit your e-mail address. Your user name and password then will be e-mailed to you.
You may also send us an e-mail at – email@example.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account.
YOUR CALIFORNIA PRIVACY RIGHTS
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted and in full compliance with all applicable laws, rules and regulations.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.
The United States Department of Commerce has agreed with the European Commission on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirements under EU law that adequate protection be given to personal information transferred from the EEA to the United States (U.S.-EU Safe Harbor Framework). The EEA also has recognized the U.S.-EU Safe Harbor Framework as providing adequate data protection. The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (U.S.-Swiss Safe Harbor Framework). Consistent with its commitment to protect personal privacy, MGI adheres to the principles set forth in the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework (Safe Harbor Principles).
This Policy applies to all personal information received by MGI in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal.
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, MGI or to which MGI discloses personal information for use on MGI's behalf.
"MGI" means Movado Group, Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States.
"Personal information" means any information or set of information that identifies or could be used by or on behalf of MGI to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, MGI will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Policy have been developed based on the Safe Harbor Principles.
NOTICE: Where MGI collects personal information directly from individuals in the EEA or Switzerland, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which MGI discloses that information, the choices and means, if any, MGI offers individuals for limiting the use and disclosure of personal information about them, and how to contact MGI. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to MGI, or as soon as practicable thereafter, and in any event before MGI uses or discloses the information for a purpose other than that for which it was originally collected.
Where MGI receives personal information from its subsidiaries, affiliates or other entities in the EEA or Switzerland, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
CHOICE: MGI will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
MGI in the U.S. particularly receives, holds and processes the following personal data from the EEA and/or Switzerland:
In connection with its retail sale activities and its after-sales service, MGI may receive, hold, and process personal information from clients within the EEA and/or Switzerland, including payment card data provided by clients for the purpose of merchandise transactions and client information relating to services agreements and watch repairs.
In addition, MGI's goal is to provide its clients with a personalized Internet experience and deliver services that are most relevant and helpful to its users. In order to achieve these goals, MGI may collect information and process personal information during user's visits to its web- sites and, in particular, during a user's visit to movado.com and/or movadogroupinc.com web-sites. As a consequence, MGI may receive, hold, and process personal information from clients within the EEA and/or Switzerland while providing web-site services such as a searching listing of authorized MGI retailers. MGI's collection and use of personal information varies based on the web-site services requested by the users and the user's choice of privacy options within the relevant web-site services.
Further MGI receives, holds, and processes personal information from employees of MGI's wholly owned European subsidiaries, which are transferred to MGI in the U.S. for purposes of human resource administration. Any such personal information is collected and processed solely for job related purposes, for other legitimate purposes reasonably related to an individual's employment, their performance of job responsibilities and MGI's ability to make employment services and benefits available to them. MGI particularly collects and uses personal information for the proper management of global operations, including for payroll management, headcount, promotions and performance reviews, vacation, tax and social security withholding, enrollment in company benefit programs, stock purchase and stock incentive programs as well as other compensation plans, relocation or immigration assistance, and the mandatory compliance with all applicable labor, employment, tax and other laws.
For sensitive personal information, MGI will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
MGI will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY: MGI will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. MGI will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: MGI will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where MGI has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, MGI will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, MGI will grant individuals reasonable access to personal information that it holds about them. In addition, MGI will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: MGI will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Accordingly, MGI has put in place appropriate physical, electronic and managerial security measures to safeguard and secure any personal data under MGI's control. However, MGI cannot guarantee the security of personal data on or transmitted via the Internet.
ENFORCEMENT: MGI will conduct annual compliance audits of its relevant privacy practices to verify adherence to this Policy and will have a program in place to oversee the daily functions of the privacy program. Any employee that MGI determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the MGI Privacy Officer at the address given below. If the question or concern relates to personal information of any employees of MGI or any of MGI subsidiaries the MGI Privacy Officer will refer the matter to MGI's Senior Vice President of Human Resources (HR Representative). MGI will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints not involving human resources data and which cannot be resolved between MGI and the complainant, MGI has agreed to participate in the dispute resolution procedures of the panel established by the American Arbitration Association (AAA). For complaints involving human resources data and which cannot be resolved between MGI and the complainant, MGI has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities (DPA) and to cooperate with the Swiss FDPIC in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by MGI to these Safe Harbor Principles may be limited (a) to the extent required to respond to or satisfy a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
Questions or comments regarding this Policy should be submitted to the MGI Privacy Officer by mail as follows:
MGI Privacy Officer – Timothy F. Michno
Movado Group, Inc.
650 From Rd. Ste 375
Paramus, NJ 07652-3556
EFFECTIVE DATE: August 30, 2013