Date of Policy 02/01/23

Your privacy is important to us, so we have developed a Data Protection and Privacy Policy (the “Privacy Policy”) that covers how we collect, use, disclose, process, transfer, store and delete your personal information when you are using AUBADE’s website (the “Website”)  or when you are dealing with us through any other means.

As used in this Privacy Policy, the term “AUBADE”, “we”, “us” and “our” means Aubade Jewelry and Watches Co., Aubade Jewelry and Watches LLC and any of their respective branches, parent companies, affiliates, and subsidiaries and the term “you” and “your” means a customer dealing with AUBADE either through the Website  or any other means.

This Privacy Policy covers how we collect, use, process, store, transfer, disclose, manage and protect your personal information.

You should review the entirety of this Privacy Policy, our standard Terms and Conditions accessible at [NOTE: INSERT LINK TO STANDARD TERMS AND CONDITIONS] and the Website Legal Notice accessible at [NOTE: INSERT LINK TO WEBSITE LEGAL NOTICE] before using the Website. If the processing of personal data as described in this Privacy Policy is not acceptable to you, do not use or continue using the Website and/or submit your personal information.

By continuing to use the  Website and/or submitting your personal information, you are deemed to have unequivocally consented to our Terms and Conditions, this Privacy Policy and the Website Legal Notice in their entirety including with respect to use of cookies and the collection, use, processing, transfer, disclosure, management and protection of your personal information as per the terms of this Privacy Policy.

The  Website facilitates online procurement of products and services to which AUBADE has distribution rights and, therefore, must, as is the case with providing such products and services, collect relevant personal information of customers.

Personal information is data that can be used to identify or contact a specific person. You may be asked to provide your personal information (pursuant to our Terms and Conditions or the terms regulating the  Website) when using the  Website. AUBADE entities may share this personal information with each other and the independent providers and use it consistent with this Privacy Policy in providing you with its products and services. AUBADE entities may also combine your personal information with other information to provide and improve their products, services, content, and advertising.

You are not obligated to provide the personal information that we request, but, if you chose not to do so, in many cases you may not be able to secure the products or services that you require or receive a response to any queries you may have.

Here are some examples of the types of personal information AUBADE may collect from customers and how it may use it:

·  When you create an account  through the Website, download a software update, register to receive our newsletter, connect to our services, or contact us, we may collect a variety of information, including your name, nationality, date of birth, passport and national/civil identification card number, work and home addresses, phone number, email address, residential address, contact preferences, device identifiers, Internet Protocol (IP) address, location information, credit card information and profile information

·  When you register a minor or adult under your guardianship and thereby share their personal information with us (which we will assume you have obtained permission or have the authority to do), AUBADE may collect the information you provide about those individuals such as their name, nationality, date of birth, home address, email address and phone number and use it in accordance with the Privacy Policy. AUBADE will use such information to enable you or such individual to access the relevant product or service, or for anti-fraud purposes.

·  We may ask for government issued identification when you create an account on the  Website, for the purpose of verifying your identity or as required by law.

With your consent, we may process your personal information to enable us or the third party providers of ancillary services (such as payment processing companies) provide you with products and services, for compliance with a legal obligation to which AUBADE is subject, for the performance of a contract to which you are party, in order to protect your vital interests, or when we have assessed it is necessary for the purposes of the legitimate interests pursued by AUBADE or a third party to whom it may be necessary to disclose the information.

The personal information we collect also allows us to keep you updated on our latest product announcements, software updates, and upcoming events. If you do not want to be on our mailing list, you may opt-out at any time by modifying your account settings.

We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes. We may also use your personal information for account and network security purposes, including to protect our products and services for the benefit of all our customers. Where we use your personal information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of personal information for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services such as during the conduct of an online transaction with us. For certain online transactions we may also validate the information provided by you with publicly accessible sources.

We may use your personal information, including your date of birth, to verify your identity, and determine appropriate products and services. For example, we may use date of birth to determine the age of the AUBADE account holders and customers.

We may use your personal information if we believe it is reasonably necessary to share your personal information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of the applicable terms of use of the  Website, or as otherwise required by law.

We may provide your personal information to our professional advisors and consultants for billing, auditing, business, legal and taxation purposes.

From time to time, we may use your personal information to send important notices, such as communications about orders made, purchases made and changes made to our terms, conditions, and policies.

We may also use personal information for internal purposes such as for auditing, data analysis, and research to improve AUBADE’s products, services, and customer communications.

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we may collect and how we intend to use it:

• We may collect information such as occupation, language, unique device identifier, referrer Uniform Resource Locators (URLs), and location where the services are used so that we can better understand customer behavior and improve our products, the services on offer, and advertising.

• We may collect information regarding customer activities on our  Website and from our other products and services. This information may be aggregated and used to help us provide more useful information to our customers and understand which parts of our  Website, products, and services are of most interest. Aggregated data is considered non-‑personal information for the purposes of this Privacy Policy.

•  We may collect and store details of how you use our products and services and the services on offer on the  Website including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.

• With your explicit consent, we may collect data about how you use your device and our applications in order to help our application developers improve our applications and products.

If we combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

The  Website, services, online services and email messages may use “cookies” and other technology such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our  Website people have visited, and facilitate and measure the effectiveness of web searches. We treat information collected by cookies and other technologies as non-personal information. However, to the extent that IP addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

The AUBADE domains may also use cookies and other technologies to remember personal information when you use our  Website, services, products and online services. Our goal in these cases is to make your experience with AUBADE more convenient and personal. For example, knowing your contact information, hardware identifiers, and information about your computer or device helps us personalize your operating system and provide you with better customer service.

By using the  Website, you authorize us to use cookies unless you specifically opt out.

If you want to disable cookies, you may modify your browser settings. Please note that if you disable the cookies you will alter your experience with our  Website and certain features of the  Website will not be available to you once cookies are disabled.

As is true of most internet based services, we may gather some information automatically and store it in log files. This information includes IP addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date and time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base. AUBADE may also use this information in its marketing and advertising services.

In some of our email messages, we may use a “click-through URL” linked to content on the Website. When customers click one of these URLs, they may pass through a separate web server before arriving at the destination page on our Website. We may track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format a customer can read, and tell us whether email have been opened. We may use this information to reduce or eliminate messages sent to customers.

AUBADE will, in certain circumstances, provide third parties with certain or all of your personal information in order to administer or provide the services that you are requesting, including ordering of products and services with service providers or purchasing other products and services, or to improve our services, or to have products requested or ordered delivered to you. When we do, we require those third parties to handle it in accordance with relevant data protection laws.

Personal information will never be shared with third parties for their marketing purposes. For example, when you create an AUBADE account and place an order, you authorize AUBADE and its suppliers or service providers to exchange the information you provide during the account activation process in order to provide you with the relevant products and services.

AUBADE may also share personal information with individuals and companies who supply products and related services, fulfilling of customer orders, delivering of products to you (pursuant to our Terms and Conditions), management and enhancement of customer data, processing of information processing, provision of customer service, assessment of customer interest in our products and services and conduct of customer research or satisfaction surveys or delivery or courier companies. These companies are obligated to protect your information and may be located inside or outside of your jurisdiction.

The products and services obtained via the  Website are paid services which are processed through third-party payment processors. AUBADE will store your payment card details and that information may be provided directly to our third-party payment processors, whose use of your personal information is governed by their Privacy Policy, during an online transaction.

It may be necessary by law, legal process, litigation, and/or requests from public and governmental authorities within your jurisdiction for AUBADE to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our policies and Terms and Conditions or protect you or our operations or users.  This could include providing information to public or governmental authorities.

Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party. Any such third party shall have the right to continue to use your personal information but subject to the terms of this Privacy Policy or any replacement data privacy policy they may notify you of. In this event, you will be notified if your personal information becomes subject to a different data privacy policy.

AUBADE takes the security of your personal information very seriously. AUBADE’s online services such as the  Website protect your personal information during transit using encryption and other data security measures that are internationally recognized. The personal information we collect is stored in encrypted form including when we utilize third-party storage. It should however be remembered that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security and infallibility and you agree not to initiate any claim against us as a result.

You are responsible for the personal information you choose to share or submit to others online or offline. AUBADE will not take responsibility for your decision to make any personal information public.

AUBADE makes it possible for you to keep your personal information accurate, complete, and up-to-date. We will retain your personal information for the period necessary to fulfill the purposes it is collected for and as outlined in this Privacy Policy. When assessing this period, we carefully examine the reason such personal information was collected and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

You can help ensure that your information is accurate, complete, and up-to-date at any time. For the personal information we hold, we will provide you with access, including a copy, for any purpose including to request that we correct the data if it is inaccurate or delete the data if AUBADE is not required to retain it by law or for legitimate business purposes.

We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier. Unless restricted by law or otherwise, you may request from us the deletion of your personal information. That information will be removed from our active database. However, AUBADE reserves the right to keep and use de-identified data as permitted under this Privacy Policy. A request for deletion may be sent to us at care@aubadejewelry.com.

Individuals below the age of majority under the laws of your jurisdiction are not permitted to create their own AUBADE accounts, unless their parent or guardian have provided verifiable consent, and such individuals must be placed under a parental account. In such case, the parent or guardian must review the applicable terms and conditions and this Privacy Policy before they begin the AUBADE account creation process for their child. If we learn that we have collected the personal information of an individual who is below the age of majority or otherwise has no legal capacity to contract, we will take steps to delete the information as soon as possible.

To provide location-based services on the  Website where applicable, AUBADE and our partners and licensees, may collect, use, and share precise location data, including the real-time geographic location of your computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your device’s approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by AUBADE and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with the  Website when you opt-in to their location-based services. Some location-based services offered by AUBADE require your personal information of such nature for the feature to work.

The Website  may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties from you, which may include your personal information is governed by their own privacy practices and policies for which AUBADE takes no responsibility. We encourage you to learn about the privacy practices of those third parties before engaging with them.

We operate globally and may transfer your personal information to other companies within the AUBADE Group or to approved partners in locations around the world. All the information you provide may be transferred to or accessed by other entities as described in this Privacy Policy. AUBADE will take all reasonable steps necessary to ensure that your information is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information. Your consent to this Privacy Policy followed by your submission of personal information represents your unequivocal agreement to that transfer.

To make sure your personal information is secure, we communicate our privacy and security guidelines to all AUBADE employees and strictly enforce privacy safeguards within our group.

If you have any questions or concerns about the Privacy Policy, or if you would like to make a complaint about a possible breach of the Privacy Policy, please contact us at care@aubadejewelry.com.

AUBADE may update this Privacy Policy from time to time and on an as-needed basis. When we change the Privacy Policy, a notice will be posted on  our Website along with the updated Privacy Policy. We may also contact you via your contact information on file, for example by email, notification or some other equivalent method to inform you of such change.

You are advised to check  the Website and/or your email from time to time for any updates or modifications to this Privacy Policy and to educate yourself of any such updates or modifications.

Upon your request, we may provide you with a hard copy of this Privacy Policy provided that the version of the Privacy Policy appearing on our Website  shall take precedence in the event of ambiguity or inconsistency.

In the event that this Privacy Policy is published in Arabic and another language, the Arabic version of this shall take precedence in the event of ambiguity or inconsistency.