UAE PRIVACY POLICY

 

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 PRIVACY POLICY

April 2021

 

Thank you for visiting this website. Ensuring personal data protection and security for our customers and users is a top priority for us. We thus comply with applicable data protection law provisions. This privacy policy explains what personal data are collected when you visit stores selling RIMOWA products and use this website and how this information is processed. If you would like to visualise and/or print the whole notice, please click here. Note, that this privacy policy should be read in conjunction with our cookie policy, available here.

 

By [ticking the consent box on our website], to the extent required under the laws of the United Arab Emirates, you agree and provide your explicit consent to RIMOWA's and its affiliates, employees’, contractors’ and relevant third parties' handling, processing, transferring and disclosing of your personal data in accordance with this Privacy Policy.

 

 

A. GENERAL INFORMATION

 

1. Details of the data controller

This policy outlines the way in which the companies RIMOWA Orient Trading L.L.C, having its registered office at The Dubai Mall, Unit TDM-GF-038 Financial Center Road, Dubai, United Arab Emirates, RIMOWA GmbH, having its registered office at Richard-Byrd-Strasse 13, 50829 Cologne, Germany, and RIMOWA International SAS, having its registered office at 24-32 rue Jean Goujon, 75008 Paris, France (“RIMOWA” or “we” or “us”), process the personal data which concerns you in its capacity as data controller for the purposes of applicable data protection laws and regulations.

 

2. Contact details of the data protection officer

If you have any questions relating to the collection and processing of your data by RIMOWA, please contact the Data Protection Officer at the following email address: dataprotection@rimowa.com.

 

B. PERSONAL INFORMATION PROTECTION POLICY

1. Definitions

In stores or on the www.rimowa.com website (the “Website”), we can collect information (your data) that does not, in itself, allow us to draw any direct conclusions as to your identity, but can constitute “Personal Data” if it is combined with other data. In this policy, “Personal Data” refers to any information relating to an identified or identifiable individual. 

 

Terms used for the purposes of this policy have the meanings given to them by the EU General Data Protection Regulation. You can find the legal text of the EU General Data Protection Regulation here.

 

2.  Data processing conditions

The Website allows us to process your Personal Data.

 

When visiting one of our stores, we can also collect and process your Personal Data, in case you set up a client profile trough entering your Personal Data into the digital data capture tool (which is provided to you via an iPad in the stores) or when one of our client advisors is setting up a client profile in our internal system on your behalf. Your Personal Data can also be processed in case you send your RIMOWA product to our repair service centers or bring it into one of our stores for repairment services. In order to be able to inform you about the repairing processes, your Personal Data will be entered into our repair management system.

Children Data

Protecting the safety and privacy of children is very important to us. We do not knowingly collect or use the Personal Data of minors under the age of majority in accordance with local legislations in force.

 

If you are under the minimum age requirement, please do not submit any Personal Data without the express consent and participation of your parent or legal guardian.

 

If you believe that we have collected Personal Data about a minor without such consent, please contact us at dataprotection@rimowa.com. and we will delete this information.

 

3. Processed Data, Legal Basis And Purposes of Processing

Depending on the services provided on our Website, in our stores and repair service centres, your Personal Data processed by RIMOWA mainly include:

 

  • - marital status;
  • - first and family name;
  • - date of birth;
  • - e-mail address;
  • - postal address and telephone number;
  • - billing and delivery address;
  • - information pertaining to the form of payment;
  • - past purchases;
  • - preferences and interests;
  • - cookies and trackers;
  • - IP address;
  • - connection logs.

Your Personal Data can therefore be processed for the following purposes:

Purposes

Processed data

Legal basis

Retention period

… to enable you to create a “MyRIMOWA" customer account on our Website. If you create a “MyRIMOWA” customer account, you will automatically be allocated a personal RIMOWA number ("MyRIMOWA ID") linked to the e-mail address you have provided. You can use your “MyRIMOWA” customer account for various processes e.g. to to buy our products online, to view your order history and manage warranties

The registration data you have given in the registration process

Your IP address

Your order and repair history

Performance of a contract

This data is deleted when your “MyRIMOWA” customer account is deleted.

Your Personal Data will be also deleted if you remain inactive (for example, if you are not purchasing any RIMOWA’s product or subscribing to our Newsletters) for a period:

  • of three (3) years if you are a prospect
  • or ten (10) years if you are a client

RIMOWA will contact you to determine whether you wish to maintain your account or not. If you choose not to maintain it, your account will be closed, and your Personal Data deleted

… to answer your questions and queries sent via the “Contact us” form available on our Website, per e-mail or via service telephone; to collect your feedback or if you participate to our surveys. This data will be added to the information we keep on your customer account. If you do not have a “MyRIMOWA” customer account, a new contact will be created in our databases

The information given in the contact form or by e-mail, IP address and date/time of the request Consent This Personal Data follows the retention period described above and will be deleted by us following your objection or when you are inactive for three (3) years if you are a prospect or ten (10) years, if you are a customer
… to send you information on our offers, products, latest news and events (newsletters, invitations to events organised by RIMOWA, including private sales and other news publications) Your data collected upon subscription to the newsletter, event or other

Your consent, where required

This data will be deleted by us following your objection or otherwise when you remain inactive for

  • three (3) years if you are a prospect but haven´t bought any RIMOWA product online
  • ten (10) years if you are a client / purchased a RIMOWA product online

… to manage and process your purchases and orders, if any (online on our Website or in the RIMOWA stores), including delivery and return of RIMOWA products Your order data (such as name, address, e-mail address, delivery specifications and other order information)  Performance of a contract

This Personal Data follows the retention period described above and will be deleted by us following your objection or when you are inactive for three (3) years if you are a prospect or ten (10) years if you are a customer

to ensure the security of online transactions, prevent fraud and payment incidents Your name, address, payment data

Necessity to protect your interests.

Legal obligation

The Personal Data is kept between 18 months and 36 months in an active database for fraud management services and 7 years in archives

… to manage, optimise and customize customer relations (notably within the framework of the management of complaints and the RIMOWA after-sales service)

The information given in the contact form or e-mail, or your order data

Necessity to protect your interests.

Consent
The Personal Data necessary to handle complaints and to enhance your customer experience will be deleted by us following your objection or when you are inactive for ten (10) years
… to save your details and usage preferences for our Website in order to optimize your navigation Please see our cookie policy

Your consent, where required

Please see our cookie policy

… to manage retargeting devices and suggest targeted advertising

Please see our cookie policy

Your consent, where required

Please see our cookie policy

… to compile statistics, and marketing analysis following your visits to the RIMOWA boutiques, your visits to the RIMOWA Website, in order to send you personalized messages and to implement an adapted relational marketing program Your browsing behavior such as cookies, your IP address, your order and repair history, location of the purchase, consent to marketing communications

Your consent, where required

This data will be deleted by us following your consent withdrawal or when you are inactive for:

  • three (3) years if you are a prospect but haven´t bought any RIMOWA product online
  • ten (10) years if you are a client or if you have purchased a RIMOWA product online.

If you do not have a customer account, please consult our cookie policy

… to perform direct marketing and to manage our “lookalike” audience based on the Personal Data collected by us.

Your Personal Data will also be shared with RIMOWA’s business partners, including companies such as social media companies, online publishers, and marketing companies

The registration data you have given in the registration process to “MyRIMOWA” customer account, your order and repair history, your browsing behavior such as cookies, your IP address, location of the purchase, consent to marketing communications, your data collected upon subscription to the newsletter, event or other

Your consent, where required

This data will be deleted by us following your consent withdrawal or when you are inactive for:

  • three (3) years if you are a prospect but haven´t bought any RIMOWA product online
  • ten (10) years if you are a client or if you have purchased a RIMOWA product online.
If you do not have a customer account, please consult our cookie policy

… to manage the invoicing and payment of your transactions

Your data collected upon registration to “MyRIMOWA” customer account

Your order data

Your payment details
Performance of a contract

Your order Personal Data will be kept as long as your MyRimowa account is active. If you do not have a “MyRIMOWA” customer account or in case of purchase in store, your data will be kept on our internal systems such the retail point-of-sale system for the duration of the transaction.

Your Personal Data will then be archived to be used: in the event of a litigation or dispute for the statute of limitation term applicable to the related purpose.

Your banking Personal Data will be kept secure for the time necessary for validation of your order and payment and will then be immediately destroyed

… to allow customers to enjoy duty-free services

Your ID and order data

Your consent

Your Personal Data will be kept for as long as it is necessary for our data processors or any other third parties to fulfill its contractual obligations to you and / or to comply with their legal obligations. Your Personal Data may also be kept to maintain business records for analysis and/or audit purposes.

... to benefit from repair services from our repair management team

Your contact data

Performance of a contract

This data will be deleted by us following your objection or when you are inactive for ten (10) years.

... to comply with legal requirements in accordance with applicable legislation.

Different legislations may require us to store your Personal Data such as identity information, your fiscal residence, payment invoices etc.

Compliance with a legal obligation

Depending on the applicable legislation, your Personal Data will be deleted in accordance with legal requirements.

The Personal Data that is indispensable for us to fulfil the purposes that are described above is marked with an asterisk on the various pages of the Website. Should you not fill in these mandatory fields, we may not be able to process your requests and/or to provide you the requested products and services. Additional Personal Data is purely optional and allow us to know you better and to improve our communications and services accordingly.

Your Personal Data will be processed by RIMOWA. Depending on where you make your purchase, your Personal Data may be accessed and processed by the following additional RIMOWA entities: RIMOWA GmbH & Co. Distribution KG, RIMOWA International SAS, RIMOWA Group Services SAS, RIMOWA France Sarl., RIMOWA Spain S.L.U., RIMOWA Netherlands B.V., RIMOWA Electronic Tag GmbH, RIMOWA NORTH AMERICA INC., RIMOWA AMERICA DO SUL MALAS DE VIAGEM LTDA., RIMOWA Japan Co., Ltd., RIMOWA Great Britain Limited, RIMOWA Austria GmbH, RIMOWA Italy Srl, RIMOWA Schweiz AG, RIMOWA CZ spol. sr.o., RIMOWA Middle East FZ-LLC, RIMOWA Korea Ltd., RIMOWA Singapore Pte. Ltd., RIMOWA Australia Pty. Ltd., RIMOWA Distribution Inc., RIMOWA MACAU LTD, RIMOWA FAR EAST LIMITED and “里莫瓦” - Limòwă (Shanghai) Commercial Limited. In certain circumstances, this processing will involve the transfer of your Personal Data out of the UAE (as further described in Section 5 below).

 

Your Personal Data can be also processed by RIMOWA’s business partners, but only if you have consented to it.

  4.1. Transfer of Personal Data to data processors

We partially use service providers, in observance of the statutory requirements, by means of data processor relationships, i.e. processing is performed on the basis of a respective contract, for our account, according to our directions and subject to our control.

 

Data processors are, in particular:

 

  • - the service provider in charge of circulating news (newsletter, invitations and other publications);
  • - providers of statistical analysis solution for cookies and trackers;
  • - media agencies in charge of monitoring the social media performance of RIMOWA;

and

  • - technical service providers whose services we retain for the provision of the Website, e.g. service providers for software maintenance, data-processing operations and hosting.

 

In such cases we remain responsible for the Personal Data processing; the transfer and processing of Personal Data to or by our data processors is made on the legal basis of your consent. In certain circumstances this processing will involve the transfer of your Personal Data out of the UAE (as further described in Section 5 below).

4.2. Transfer of Personal Data to third parties

We partially also transmit your Personal Data to third parties, i.e. partners with whom we collaborate outside of a contracted processing. The processing of your Personal Data is subject to the Personal Data protection policies of these providers, which RIMOWA will be able to provide you with on request or which you can obtain by contacting them directly. Such third parties are considered to be controllers of your personal data. As a consequence, the rights you have under the applicable regulations on the protection of Personal Data may be directly exercised with these service providers. The transmission of your Personal Data to third parties may involve the transfer of your Personal Data out of the UAE (as further described in Section 5 below).

Such third parties might be:

 

4.2.1. Payment service providers

In order to execute your orders, we transmit payment information to payment service providers who process the payment processes connected with the orders. This includes Cybersource,  and your credit institute. The legal basis for the transfer is your consent.

 

In addition, you can also use payment options provided by Apple Pay on the Website. In this case, your Personal Information is processed in accordance with the information in Apple Pay privacy statement.

 

4.2.2. Direct marketing and advertising companies

In certain cases, we can send you tailored communication on different platforms based on your express consent given to us on the RIMOWA Website or in stores. This may include, inter alia, the ability to build other audiences who are likely to be interested in our products because they are similar to you (commonly known as “lookalike” audiences).

 

 

In order to be able to offer this tailored communication, RIMOWA shares with its partners, such as Google and Facebook, some Personal Data, including contact and order details.

 

You hereby provide your consent to our collection of your personal data to be used for direct marketing of our products and services, such services to be provided by email, SMS or otherwise.  Please note that you have the right to withdraw your consent to direct marketing at any time, as further described in Section 7.

 

4.2.3. Logistic enterprises

In order to transport the goods purchased by you, we provide your address and contact details, to the extent necessary, to parcel transportation enterprises.

RIMOWA may also pass on your Personal Data to third parties if this is required by law, a statutory provision or legal decision.

Except for these cases, your Personal Data will not be passed on or made accessible to any third parties, excepted in the event of the restructuring of RIMOWA, including a total or partial asset transfer, merger, absorption, acquisition, demerger and in general any reorganisation operation, subject to appropriate legal, security and confidentiality measures.

 

5. Transfers of personal data abroad

Since RIMOWA has subsidiaries, branches and affiliates located abroad and works with data processors located abroad, the recipients of your Personal Data may also be located abroad,  in countries/regions where RIMOWA runs its activities.

To get more information on these guarantees, you may contact the data protection officer at the following email address: dataprotection@rimowa.com.

 

6. Personal data security and confidentiality

RIMOWA applies technical and organisational security measures in line with accepted practice particularly regarding the security of its information system.

 

RIMOWA strives to take all the necessary steps in order to protect the confidentiality and security of your Personal Data and prevent it from being amended, damaged, destroyed or accessed by unauthorised third parties. RIMOWA will ensure in this respect that its data processors present similar, appropriate security, technical and organisational guarantees.

 

7. Your rights

In accordance with applicable regulations, you have the following rights:

Withdrawal of consent: you can withdraw at any time your consent in respect of any processing of Personal Data based on your consent, without affecting the lawfulness of processing carried-out before the withdrawal of said consent.

Access: you can ask us to confirm whether we process your Personal Data and, as the case may be, inform you of the characteristics of such processing. You can also ask us to allow you to access such data and give you a copy of it.

Rectification: you can ask us to rectify or complete inaccurate or incomplete Personal Data.

Erasure: you can ask us to erase your Personal Data in the following cases: where it is no longer necessary for the purposes for which it was collected; where you have  withdrawn your consent; where you have objected to the processing of your Personal Data; where your Personal Data has been processed unlawfully; or to comply with a legal obligation. We are not required to comply with your request in certain cases, notably if the processing of your Personal Data is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

Restriction: you can ask us to restrict the processing of your Personal Data (i.e., keep but not use your Personal Data) where: the accuracy of your Personal Data is contested; the processing is unlawful, but you do not want it erased; it is still necessary to establish, exercise or defend legal claims or to verify the existence of overriding grounds following the exercise of your right of objection. We can continue to use your Personal Data following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.

Portability: you can ask us to provide your Personal Data to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another data controller, but only where the processing is based on your consent or on the performance of a contract with you, and the processing is carried out by automated means.

You also have the right to object:

• for reasons relating to your particular situation, to processing operations based on RIMOWA’s legitimate interest. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims.

• to processing for the purpose of sales prospecting. As such, you may at any time request to no longer receive communications regarding our offers, products, news and events by using the unsubscribe link provided for this purpose in each email we send you.

These rights may be exercised at any time by contacting RIMOWA’s Data Protection Officer at the following email address: dataprotection@rimowa.com.

 

8. Changes to this policy

In the event of a change to this policy, RIMOWA will inform you of the update of this document, by mentioning it on the privacy policy page of its Website. When you revisit us, you may therefore reread the privacy policy.