RETENTION OF PERSONAL INFORMATION

We retain personal information for as long as we believe it is needed to fulfill the purpose(s) we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In general, we will retain consumer personal information for as long as we engage with the consumer and, following that period, we will retain the personal information for as long as is reasonably necessary under the circumstances.

To determine the appropriate retention period for consumer personal information, we may consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the administrative burden to delete the personal information, the purposes for which we process the personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize personal information for analytical, statistical, or other purposes, in which case we may use or share this information indefinitely without further notice. Similarly, we may use or share aggregated data indefinitely without further notice.

PERSONAL INFORMATION WE HAVE COLLECTED

Within the last twelve (12) months, Movado Group has collected from direct interactions, automated technologies or interactions, community features, third parties, publicly available sources, and other persons the following categories of personal information about California residents: Identifiers; personal information categories listed in the California Customer Records statute, Cal. Civ. Code § 1798.80(e); protected classification characteristics under California or federal law; commercial information; biometric information; internet or other similar network activity; geolocation data; sensory data; inferences drawn from other personal information; and professional or employment-related data.

PERSONAL INFORMATION WE HAVE SHARED

We disclose personal information to service providers, data aggregators, parent or subsidiary organizations and affiliates, social media companies, internet cookie information recipients, and other third parties as described in this Notice and our Privacy Policy. 

We do not sell your personal information in exchange for monetary compensation. Moreover, few of the third parties with whom we share personal information are permitted to use that personal information for any purpose other than to provide services for us.

In those instances where a third party is permitted to use information for their own commercial purpose, we may be relying on a consumer’s intentional direction to share their personal information with that third party. We do not believe this is a “sale” under applicable U.S. law. For example, a consumer may wish to finance a purchase through a service like Affirm or Klarna. To do so, the consumer must select that offering, choose to engage with the third party, and share their Identity, Contact, Payment, Transaction or other information to enable the financing. To the extent Movado Group facilitates such information sharing, we rely on the consumer’s choice to engage with that third party. Consumers should always keep in mind that the third party’s terms and conditions and privacy policies and practices will apply to that third party’s services and offerings, and we urge you to make sure you understand them before you proceed.

In the preceding twelve (12) months, Movado Group has sold or shared the following categories of consumer personal information for business or commercial purposes, which may include cross-context behavioral advertising: Identifiers; personal information categories listed in the California Customer Records statute, Cal. Civ. Code § 1798.80(e); protected classification characteristics under California or federal law; commercial information; biometric information; internet or other similar network activity; geolocation data; inferences drawn from other personal information.

INTEREST-BASED ADVERTISING; THIRD PARY ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING

When you go to our websites, open our emails, use our apps or “smart” wearable devices, interact with Movado Group-related social media sites or tools, widgets, or plug-ins, or when you visit one of our physical stores (all digital and physical sources, our “Sites”), we may collect and store information about you, your online activities, or your geolocation information for use in providing you with advertising about products and services that is tailored to your individual interests. When using our Sites, you also may be presented with an opportunity to receive information and/or marketing offers from our curated third parties or in connection with referral programs. If you agree to such uses, including to receive such communications, your personal information will be disclosed to that third party or those third parties.

Movado Group also works with certain third parties (including network advertisers, ad agencies, and data analytics companies) to provide us with information regarding traffic on our Sites, to serve advertisements both on our Sites and elsewhere online, and to provide us with information regarding the use of the Sites and the effectiveness of our advertisements. Through these sources, we can target our messaging to users through demographic, interest-based, and contextual means. We can also track your online activities over time and use this information to show you advertisements that may be tailored to your individual interests. In addition, we can collect data about your visits to other websites that serve Movado Group advertisements, such as the pages or advertisements you view, where you viewed them, and whether you clicked through. This process helps us track the effectiveness of our marketing efforts.

When performing services for us, these third parties may set and access their own tracking technologies and may otherwise collect or have access to information about you. These technologies may be used, among other things, to more effectively target advertisements, to prevent you from seeing the same advertisements too many times, to conduct research regarding the usefulness of certain advertisements to you, and to assist in providing analytics. These third parties may transfer information that they have collected to other third parties. The ability of these third parties to use and share information among their networks is restricted by their respective terms of use and privacy policies, and we encourage you to read those privacy policies.  

THE RIGHT TO OPT-OUT

As prescribed in the applicable state law, residents and consumers in California and certain other covered states have the right to opt-out of the sale or sharing of their personal information for cross-context behavioral (targeted) advertising or for other purposes. You have the right to opt-out of our sale of your personal information. To inform us of your desire to exercise this right, you may click here;. This link will take you to the same webform that is available through the “Do Not Sell or Share My Personal Information” link enabled on our websites. Requests to opt-out of the sale or sharing of personal information also may be made by mail or by calling our Customer Service team at 1-800-810-2311. We aim to process all opt-out requests promptly and within the time permitted under applicable law and will notify you when the process has been completed.

Please understand that, even if you exercise this right to opt-out, we will still share your information in other ways, such as with our service providers for our own business purposes, including for our own online advertising. Accordingly, opting-out of the sale or sharing of your information for cross-context behavioral advertising does not necessarily mean that you will stop seeing ads for our own products and services, including interest-based ads.

Moreover, as explained in the Do Not Sell or Share My Personal Information tool, submitting the webform will not block the sale of personal information that may occur through cookies or other automated means placed on our Sites. If you wish to prevent such sales or sharing, please click Do Not Sell or Share My Personal Information. This link will take you to the Manage My Cookies tool, where you may choose to block certain types of cookies, including cookies that enable targeted advertising. Please remember that you may need to repeat this step on each separate device you use to access our Sites and for each individual Site you visit. Blocking these cookies may not prevent our own ads, including ads served to you based upon your prior browsing history, from appearing.

In addition to these means of blocking the sale or sharing of personal information for cross-context behavioral advertising, our Sites will also detect and apply the signal from GlobalPrivacyControl.org (“Global Privacy Control”).

If you submit an opt-out request via webform, mail, or call to our customer service team, but choose not to change your cookies settings or enable the Global Privacy Control, then we will treat this as your direction to stop the sharing of personal information with third parties for marketing purposes that is not conducted through cookies while allowing us to continue to sell or share for cross-context behavioral advertising any information (including personal information) collected through Site cookies.

Anyone who has opted-out may request to opt back in at any time by using the Manage My Cookies tool, by calling our Customer Service team at 1-800-810-2311, or by re-joining our marketing list.

OTHER RIGHTS AND CHOICES

The CPRA and other state laws provide certain rights regarding personal information. This section describes those rights and explains how people protected by those laws may exercise them.

The Right to Know and Portability

Residents of California and certain other covered states have the right to ask us to disclose to them information about our collection and use of their personal information, which may include asking us to provide the information to them in a portable format. Our response may be limited to a certain time period (for example, the past 12 months) or for other legally acceptable reasons. California requests may seek information about:

• The categories of personal information we collected about the data subject;
• The categories or sources for the personal information we collected about the data subject;
• Our business or commercial purpose for collecting that personal information;
• The categories of third parties with whom we shared that personal information;
• The specific pieces of personal information we collected about the data subject;
• If we sold the data subject’s personal information, a list of the personal information categories that were purchased;
• If we shared the data subject’s personal information for cross-context behavioral (targeted) advertising, a list of the personal information categories that were shared.

We will provide the applicable information after receiving and confirming a verifiable consumer request.

The Right to Delete

Subject to certain exceptions, residents of California and consumers in certain other covered states have the right to request that Movado Group delete personal information that we collected and have retained about them. Once we receive and confirm a verifiable request, we will delete (and direct our service providers to delete) such personal information from our records, unless an exception applies.

We may deny a deletion request if retaining the information is necessary for us to

• Complete the transaction for which we collected the personal information, provide a good or service that the consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with the consumer, or otherwise perform our contract with the consumer;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.) or similar law;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer’s relationship with us;
• Comply with a legal obligation;
• Make other internal and lawful uses of that information that are compatible with the context in which the consumer provided it;
• and/or as otherwise permitted under applicable law.

The Right to Correct

Residents of California and consumers in certain other covered states have the right to ask us to correct any personal information we have in our files. We encourage everyone who interacts with us, regardless of location, to keep their information up-to-date.

The Right to Limit Use

Residents of California have the right to ask us to limit the use of any sensitive information, as defined under the CPRA, about them.

How to Exercise These Rights

Covered people and their authorized agents may submit a request to know or request to delete by:

• Webform;
• Mail; or
• Calling us at 1-800-810-2311.

In California, only the data subject, or a person registered with the California Secretary of State authorized to act on a data subject’s behalf, may make a verifiable consumer request. In other covered states, we will honor a request by the data subject or by a verified agent of the data subject. Covered people also may make a verifiable consumer request on behalf of their minor child. Frequency of requests may be restricted. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

The webform includes the minimum information we believe is necessary to understand, evaluate, and respond to a request. If you choose to submit a request by mail or telephone call, we will ask you to provide the same information. In order to properly verify, track, and process requests, we ask you to please use one of these three methods. We do not accept emails.

We cannot respond to a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.

Response Timing and Format

We endeavor to respond to requests within forty-five (45) days[DK1]  of verification or such shorter time as required by applicable law. If we require more time and more time is permitted under applicable law, we will inform you of the reason and extension period in writing.

We will deliver our written response electronically, unless you instruct us to deliver it by mail.

Any disclosures we provide will cover the 12-month period preceding our receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know particular information and that necessitate a voluminous response, we will select a format to provide your personal information that is readily useable.

We generally do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

How to Appeal

If we refuse to take action in response to a permissible data subject request, you may appeal our decision by writing to us at the address stated below. Your appeal must be received within 30 days of our decision and must be accompanied by a reasonably detailed explanation of the reason(s) you believe our decision to be unsupported by applicable law. We will respond to the appeal within 60 days of its receipt, and our response will include a written explanation of the reason(s) for our decision. If your appeal is denied, you may contact your state’s attorney general or, in California, the California Privacy Protection Agency.

STATISTICS ON CONSUMER PRIVACY REQUESTS

Movado Group receives requests to exercise data privacy rights from people around the globe. The following data* is provided about requests Movado Group received during calendar year 2022.