2021 Privacy Policy

ARCHIVE - 2021 VERSION

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Personal Information Management Policies of Richemont Korea Ltd trading as Vacheron Constantin

Richemont Korea Ltd trading as Vacheron Constantin (hereinafter “Vacheron Constantin”) hereby establishes and discloses the following personal information management policies for the protection of personal information of data subjects and a prompt and smooth management of any grievances thereon in accordance with the Personal Information Protection Act (the “Act”).

Article 1 (Purposes of Managing Personal Information)

Vacheron Constantin shall manage personal information for the following purposes. The personal information being managed shall not be used for any purpose other than those described in the following, and in the event of any change to such purposes, Vacheron Constantin shall take required actions such as separately obtaining the consent to such change or posting the revised policies on the website pursuant to the Acts:

1. Management of membership to the website

Vacheron Constantin shall manage personal information for the verification of the intent of an applicant to become a member, identification and authentication of an individual for the provision of membership services, retention and management of membership eligibility, verification of individual identity according to the execution of the limited verification of identities system, prevention of improper usage of services, verification of the consent of the legal representative when managing the personal information of a minor under the age of 14, various types of notifications, management of grievances, improving contents of the website and provision of customized web-based service to members, etc.

2. Provision of goods or services, dealing with enquiries and requests, and management of accounts and records

Vacheron Constantin shall manage personal information to manage and fulfil purchase orders, sending of agreements and invoices, delivery of contents, delivery of customized services, identity and age authentication, payment or settlement of fees, and collection of debts, dealing with customers’ requests and enquiries, and management of our accounts and records etc. Vacheron Constantin shall manage personal information to send service-related communications, including announcements and administrative messages such as order confirmation and to manage and fulfil repair orders and to provide after service care.

3. Management of grievances and legal compliance

Vacheron Constantin shall manage personal information for the verification of the identity of a person who filed a complaint; identification of the matter being complained of; contact and notification for inquiry of facts; and notification of the result of the grievance management, etc.

Vacheron Constantin shall manage personal information for prevention of fraud and other prohibited or illegal activities and as part of our efforts to keep our website and platforms secure.

4. Customer management, market research and marketing

Vacheron Constantin shall manage personal information:

to deal with your enquiries and requests;
for the purposes of sending you marketing communications, direct marketing and advertisements in the business areas in which it operates and of providing information related to products, services or events, etc. through online display ads or using communication channels you have provided, including email addresses, mobile numbers, telephone numbers, social media platform ID and postal addresses;
to conduct customer satisfaction survey and market research so that we can continuously improve the service we provide to our customers; and
to understand how our website and platforms are used so that we can continuously improve our platforms, services and other offerings.

Article 2 (Personal Information Items Under Management)

Vacheron Constantin manages the following items of personal information.

1. Information that may be collected from the website

Purpose of collection: Management of membership to the website, access to call agents, reservation of visit and subscription to newsletter, deal with customers’ enquiries and requests
Items: title, salutation, name, membership ID, password, e-mail address, country of residence, phone number, date of birth, wedding anniversary, other digital platform ID, postal addresses and post codes and other personal information provided by customers

2. Information that may be received through customer cards at offline boutiques

Purpose of collection: management of membership, provision of goods or services, dealing with enquiries and requests, management of claims and legal compliance, customer management and marketing
Items: Title, name, phone number, email address, other digital platform ID, country of residence, postal addresses and post codes, date of birth, wedding anniversary and preferred language, and consent to or refusal of the provision of personal information

3. Information that may be collected from the Client Relations Center

Purpose of collection: Customer registration, receiving calls from customers, quotation of price for repairs, and answering inquiries on products and boutiques, telephone sale, and for security, training or development purposes.

Items: Name, e-mail address, phone number, other digital platform ID, country of residence, postal addresses and post code, date of birth, wedding anniversary, voice recording and other personal information provided by the customers

4. Information that may be collected when you purchase products in boutiques, online or by phone

Purpose of collection: completion of transactions, delivery of goods or services, dealing with enquiries and requests, and providing customer services (including customer care, after-sale and repair services)
Items: purchase details, payment information and other personal information provided by the customers.

5. Information that may be collected through customers’ access to and use of the website: Vacheron Constantin operates a computer system whereby Vacheron Constantin collects IP address, cookies, MAC address, service usage records, visit records, improper usage records and other information collected by automatic tracking technologies.

Purpose of collection: analysis of the frequency of customers’ visit and use of the website; implementation of targeted marketing; provision of customized or personalized service; analysis of preference or interests of customers; and upgrade and improvement of the website and its contents
Customers may choose not to store cookies by selecting the relevant option under the web browser. Customer may require Vacheron Constantin to obtain a prior consent before Vacheron Constantin collects cookies from the customer’s browser and may also refuse to provide any cookies to Vacheron Constantin. We use this information to better understand how visitors use our website and for internal reporting purposes.  We will anonymise and not identify individuals through such information without your consent.

6. Information collected through our mobile applications or when you interact with us over social media or other digital platforms

Purpose of collection: answering customers’ queries on goods and services, making boutique appointments and providing information, customer management and marketing, analyzing preferences or interests of customers and update the contents, and location services etc.
Items: Social media handles; Customers’ queries and other personal information provided by the customers

Article 3 (Management and Retention Period of Personal Information)

Vacheron Constantin shall manage and retain personal information within the legal retention and use period of personal information or within the retention and use period of personal information consented to by the data subject at the time of collecting personal information.

The period of managing and retaining personal information for the purposes set out in Article 1 is as follows.

1. For the management of membership, Vacheron Constantin shall manage and retain personal information until the earlier of (i) the achievement of the purpose of retention of personal information and (ii) 2 months following the withdrawal of membership from the website of business operator or organization; provided, however, in the case of an occurrence of any of the following events, until the end or resolution of such event:

a) Any pending investigation or probe following any violation of relevant laws, and

b) Any remaining debts or claims which arose from using the website.

2. For the provision of goods or services, dealing with enquiries and requests, and management of our accounts and records, Vacheron Constantin shall manage and retain personal information until the completion of the supply of such goods or services, and the completion of the payment or settlement of fees, or until the objective of personal information management is achieved; provided, however, that the personal information necessary for accounting treatment of Vacheron Constantin or reflected in the books and records material to the business of Vacheron Constantin shall be maintained for 10 years pursuant to the Commercial Code of Korea.

a) For management of grievances and legal compliance, Vacheron Constantin shall manage and retain personal information until the service or follow-up service of customers’ grievances and complaints is completed.

b) For customer management and marketing, the personal information will be managed and retained until the earlier of (i) the time it is withdrawn by the customer and (ii) the time the purpose of collecting the personal information has been achieved.

c) Notwithstanding the foregoing, Vacheron Constantin may retain customers’ personal information for a longer time period as required by applicable laws or government orders.

3. In the interest of protecting the personal information of customers who have been inactive for one (1) year or longer (the “Inactive Customers”), Vacheron Constantin shall separately store and manage the personal information of Inactive Customers from the personal information of other users.

a) Inactive Customers shall be determined based on factors such as login dates and customer service representative contact dates and shall mean customers who have not used our services for a period of time as designated by the relevant laws and regulations.

b) Vacheron Constantin shall provide users with prior notice one (1) month before they are classified as Inactive Customers and their information is separately stored and managed.

c) The separately stored and managed personal information of Inactive Customers shall be maintained for a certain period of time pursuant to the relevant laws and regulations and shall be destroyed once such period of time expires. Any personal information not destroyed shall be provided upon the user’s request to resume use of the services.

Article 4 (Transfer of Personal Information to Overseas Affiliates for Processing)

1. Vacheron Constantin shall manage the personal information of data subjects within the extent set forth in Article 1 (Purposes of Managing Personal Information). In order to better service customers and properly gather, process and manage customer data, Vacheron Constantin may delegate the management and processing of such personal information to its overseas affiliates listed in paragraph ⑤ below in accordance with the Act, including under the consent of the data subject, or when required by special provisions of other laws. Vacheron Constantin has entered into an agreement for delegation of personal information processing services with such entities.

2. The date/time and method of transfer: transfer of personal information is carried out from time to time during the provision period of the services via electronic transfer using [VPN].

3. The purposes of delegating the management and processing of the personal information include providing technical and IT system, storage and support for client data, conduct analysis and research based on transactions (including analysis of purchase preferences), arranging logistics and product delivery, providing customer services and all other sale, customer card and after-sale services, handling customer’s requests and complaints, and providing customer communication services (including sending e-newsletter and marketing communications on behalf of Vacheron Constantin).

4. Items of personal information to be transferred are specified in Article 2 above.

5. Vacheron Constantin shall ensure that all persons and affiliates receiving such personal information shall make best efforts to make sure that the information of data subjects is safely retained according to the Acts and relevant laws. Vacheron Constantin will delegate the personal information processing and management services to the following overseas affiliates:

Name of affiliate

Location and country

Person in charge of information management and services to be entrusted

Vacheron Constantin, branch of Richemont International SA

Chemin du Tourbillon 10, 1228 Plan-les-Ouates, Switzerland