Privacy policy

1. Introduction

This Privacy Notice is provided by Ahmed Seddiqi & Sons LLC, a company incorporated under the laws of the United Arab Emirates with registered office at P.O. Box 2123 (together “Seddiqi”, “we”, “us”), in its role as the operator of gcc.danielwellington.com (the “Website”).

Daniel Wellington offers sleek and minimalist watches, jewellery, and accessories available for sale via the Website (the “Services”).  We operate the Website on behalf of Daniel Wellington so Daniel Wellington may access and process the personal information collected in connection with the Services as further described in this Privacy Notice.

We take your privacy seriously and are committed to safeguarding your personal information at Seddiqi through our compliance with this Notice.

This Privacy Notice (“Privacy Notice” or “Notice”) covers the personal information that Seddiqi may collect or receive from you to provide or facilitate provision of the Services to you. This Notice outlines what our purpose and practices are for collecting, processing, using, maintaining, retaining, protecting, and disclosing your personal information.

2. What 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 requests, such as registering your enquiries, processing your payments, issuing invoices, or any other activities necessary to supply you with the Services. We only collect the minimum amount of information required to conduct operational activities, process your requests, and manage our relationship with you. The personal information we collect may include:

• Information you provide to us to process your payment and invoice for the Services such as name, email address, credit card information, delivery address.
• Information you provide to us by filling our online form for enquiries as provided on the Website, which may include personal information such as name, email, and any other personal information you include in the heading or body of your enquiries.
• Information you provide when you create a user account on the Website such as name, email, mobile number, username, and password.
• Information you provide when you subscribe to our newsletter such as name, email, mobile number.
• Information you provide to signify your interest in certain products through a wish list or notify me request such as name and email.  
• Records and copies of your correspondence (including e-mail addresses) when you contact us.
• Information that you provide when you contact our contact center such as name, mobile number, details of complaint or enquiry.
• Information that you provide when you attend our events and/ activations.
• Information that you provide when you contact us via email, SMS, social media, web chats, web form, WhatsApp chats, or directly call our customer experience team for general enquiries, complaints, request for support services. This information may include your name, email address, mobile number, and call recordings (in case you call our customer experience team).
• Information captured on documents you provide to us for processing your payments, invoicing, Value Added Tax (VAT) refund, or other service requests, including information captured on your passport and any other documentation you provide to us.

Sensitive personal data we collect may include:

Family information: if you provide information regarding your family, we may process such information to effectively manage your customer account with us and to facilitate provision of the Services.

2.2 Other Information We Collect

• When you visit the Website, we may collect information about your use and navigation of the Website, such as IP address and other device identifiers, browser type, and information about the Website pages you visit. Please refer to the ‘Cookies’ section of this Notice for more information on our use of cookies.
  
  

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 interaction between you and Seddiqi.
• Seddiqi customer service: Any communication between you and our customer experience team (e.g., via phone, email, etc.).
• Data we create: Seddiqi may also create data about you, when you purchase the Services, such as customer account creation.
• Data from documents you share with us: Seddiqi may access, use, and process data contained in documents you share with us for providing the Services to you such as your passport copy (if you request VAT refund).
• We may access information about you from third-party sources and platforms (such as social networking websites, online marketing firms, and ad targeting firms) to the extent permitted by law.
• If you attend any of our events and/activations, we may collect and process your personal information (such as, your name, email address, and phone number).
• If you access third-party social networking services (such as Facebook, Twitter) and search about us or the Services, we may collect your contact information and/or any personal information that is part of your profile on the third-party social network). You can learn more about the data that we may obtain about you by visiting the privacy notices on the website of the relevant third-party social network.

This Notice does not apply to the following:

• Personal information collected by any third-party website or platform that is not directly managed by Seddiqi, even if such website or platform advertises the Services. Please refer to the privacy notice of such third-party 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 the scope of the Services captured in this Notice) you might have with Seddiqi or any of its affiliates g., as a customer, tenant, employee, or contractor.  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 collect and process personal information for several legitimate purposes, including providing and improving the Services, registering enquiries, processing payments, generating invoices, processing VAT refund, and managing our relationship with you:

4.1 To create and manage your customer account with us

Your personal information may be collected and processed to register and create a customer account for you when you make your first purchase or make enquiries about the Services. We will collect and process your personal information based on contractual necessity.

4.2 To provide, develop, and improve the Services

We may use your personal information to perform essential business operations including the following:

• For generating invoices for your purchases pursuant to our legal obligation to do so.
• To process Value Added Tax (VAT) refund upon your request in fulfillment of our legal obligation to do so.
• To process refund/exchange requests we may receive from you based on our contractual obligation to do so.
• To notify you when we have products on your wish list in stock based on your permission. If you have requested to be notified when we restock certain products, we may process your personal information to register and perform this request.
• To analyze trends and market insights based on our legitimate business interests to monitor and improve the performance of the business.
• To activate your product warranty (as applicable) based on our contractual obligation to do so.
• To manage delivery of the Services to you based on our contractual obligation to do so.

4.3 To send gifts and special invitations

We may process minimal personal information (such as name, email address) to send you personalized gifts to celebrate your special occasions (such as birthdays and wedding anniversaries). We process your personal information based on our legitimate interests to improve our relationship with you.

We may also process your personal information (such as name and contact information) to invite you to events organized by us or any of our affiliates and business partners. We process your personal information based on our legitimate interests to improve our relationship with you.

4.4 For complaint and enquiries management

We would need to collect and use your personal information (such as name, e-mail address, phone number, and details of your complaint/enquiry) to respond to complaints, queries, and enquiries we receive from you. When you call our customer experience team, we may maintain a record of the communication, including call recordings, based on our legitimate interests to monitor and improve the quality of our support services to you.

4.5 To provide promotions, discounts, and other benefits:

We may collect and use personal information (such as name, email address, phone number) to register you for raffle draws or provide special discounts/promotions (as applicable) to you based on our legitimate business interests to enhance customer experience.

4.6 To provide product repair services

If you request watch and jewelry repair services provided through our affiliate business, Swiss Watch Services LLC. (SWS), we may collect and share certain personal information (such as name, email address, phone number) with SWS to facilitate provision of the repair services. We collect and process this information to fulfill our contractual obligation to provide the repair service to you.

4.7 To process any special requests made by you

If you make any special requests regarding the Services, we may process your personal information to determine your eligibility, obtain special approvals, manage the request, and provide you with a response on the request. We process this information based on your consent.

4.8 For Email & SMS Marketing

We may occasionally send you marketing communications regarding products you have shown interest in, or other similar products based on your consent. You may choose to opt-out from receiving these communications at any time by following the instructions provided in “How to Opt-out?” section.

4.9 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.

4.10 To comply with any opt-out or do not disturb requests we receive from you:

We understand that you may not want us to contact you with any offers, promotions or details of our products and services. In the event you opt-out, we may be required to maintain information such as name, email ID/contact number and the subscription(s) that you have opted out of to ensure compliance with your requests. If you wish to resume receiving marketing or promotional communication from us, you may contact us at any time to opt-in and we would be happy to keep you posted about events, offers, promotions, and/ or details of our products and services that we believe you may be interested in.

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.
• Data Privacy Office Notice: you may write to privacy@byedit.com regarding the specific processing activity(s) that you would like to opt out. Our Data Privacy Office will get in touch with you to facilitate the request accordingly.
• Contact us: You may contact us using the details provided in Section - ‘How do you contact us?’.

6. Who might we share this information with?

We may disclose personal information that we collect, or you provide as described in this Privacy Notice:

• We may share your personal information with affiliate companies of Seddiqi, including other subsidiaries of Seddiqi Holding LLC, to support provision of the Services, understand your preferences, and conduct the other activities described in this Privacy Notice. Such affiliate and subsidiary companies are in the United Arab Emirates (UAE) and the Kingdom of Saudi Arabia (KSA). If you require more information, please feel free to write to us at privacy@byedit.com and our Data Privacy Office would be happy to assist you with the same.
• As we operate the Website on behalf of Daniel Wellington, we may share your personal information with Daniel Wellington in connection with the Services, to ensure proper functioning of the Website, and conduct the other activities described in this Privacy Notice.
• We may use carefully selected third parties to perform services on our behalf or to assist us with the provision of the Services to you. For example, we may engage third party payment gateways to process your payments, cloud service providers, e-commerce platforms (such as, Shopify), IT service providers, and other third parties to support and facilitate concierge and security services, courier/delivery services, marketing, advertising, communications, to maintain the Website, to store data, to personalize and optimize the Services, to analyse and enhance data (including data about users' interactions with the Services), and to provide legal, accounting, banking, insurance, audit and /other professional services.  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 provide your personal information to government agencies, government officials, regulators, and law enforcement agencies to comply with 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 from you through our interactions with you and to provide the Services is stored at a destination within the UAE, KSA, and through 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 affiliates of Seddiqi 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 the UAE 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 in this Privacy Notice and legal requirements under applicable law(s). This means that we may retain your personal information for a reasonable period. In certain cases, we may retain your personal information for a longer period where extended retention periods are required by law or regulation and to establish, exercise or defend our legal rights.  For more information on where and how long your personal information is stored, and for more information on your rights of erasure and portability, please contact us using the details provided in Section - ‘How do you contact us?’.

10. Cookies

If your web browser is set up to accept cookies, a cookie will be stored on your hard drive when you visit the Website. Cookies allow us to collect information about your computer or device, which may include your IP address (a number assigned to your computer/device when you register with an Internet Service Provider), type of browser, operating system, domain name, and the details of any website which has linked you to the Website. The Website uses cookies to track and collect information about which parts of the Website (including links to other websites) you visited.

Cookies also allow us recognize your computer/device while you are on the Website. This information is used to maintain the quality of our service and to provide tracking and statistics regarding use of the Website.

The types of cookies we use include:

• Strictly necessary cookies: these are required for the operation of the Website, such as cookies that enable you to log into your account or make purchases, or cookies that enable us comply with applicable law (for example, to keep your information safe). We would not be able to operate the Website without using strictly necessary cookies.
• Performance cookies recognize and count the number of users on the Website and help us see how users move around the Website. These cookies do not collect information that identifies a user. Any information collected by these cookies is anonymous. We only use such information to improve the Website. This information helps us find out how well the Website works and highlights where it can be improved.
• Functionality cookies are used to recognize you when you return to the Website and assist us to personalize your content and website experience by remembering your preferences. These cookies are also used to provide services you have asked for (such as watching a video). You can block these cookies using your browser settings.
• Targeting cookies are used to record your visit to the Website, the pages you have visited, and the links you have followed. These cookies are used to advertise relevant products to you on other websites, based on the products and categories you looked at on the Website. You can block these cookies using your browser settings.

If you would rather not have any of this information stored on your computer/device, you can configure your browser, so it does not accept cookies. However, if you disable cookies, you may not be able to access all parts of the Website, including the purchase section. For more information and to learn how to disable cookies, please visit www.allaboutcookies.org or www.youronlinechoices.com.

11. Data Security

The security of your personal information is an important concern to us. We provide the utmost care in secure transmission of your personal information from your computer and other electronic devices to our servers. We use industry security standards to safeguard the confidentiality of your 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 information you provide to us is stored on our secure servers behind a secure network. All payment transactions are encrypted. 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; and
• Employing adequate administrative and technical controls to secure personal information.

12. 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 privacy@byedit.com. 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 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:

12.1  The right to access

You have the right to obtain confirmation as to whether we process your personal information, 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).

12.2 The right to rectification

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

12.3 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; and/or
• 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 can 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.

12.4 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:

• 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 applicable 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 defense of legal claims.

12.5 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, and our processing for direct marketing purposes.

12.6 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.

12.7 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 to Opt-out” section.

12.8 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 15 - ‘How do you contact us?’. We will closely review and ensure a timely response to any complaints we receive.

13. 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 privacy@byedit.com.

14. 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.

15. How do you contact us?

In case of any queries related to this Notice, you can contact our Data Privacy Office, e-mail us at privacy@byedit.com