Data protection information

As the operator of the THOMAS SABO online shop, we – THOMAS SABO Pte Ltd– regard data protection as a fundamental concern and we would like to ensure that your privacy is, and remains, protected at all times when using our online shop.

GENERAL

Your personal data are only collated, processed and used by us if you issue your consent, or legislation allows us to collate, to process and/or use your personal data. Needless to say, we adhere to the valid legal stipulations on data protection.

WHAT ARE PERSONAL DATA?

According to the Singapore Personal Data Protection Act personal data refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organization has or is likely to have access. Personal data in Singapore is protected under the Personal Data Protection Act 2012 (PDPA).

WHY DO WE COLLATE, PROCESS AND UTILISE PERSONAL DATA?

• For processing your orders, including delivery and services associated with the order
• For processing payments
• For responding to your questions and queries
• For sending out our newsletter insofar as you have given us your consent to do so

WHAT INFORMATION DO WE COLLECT IN THE PROCESS?

Only information that you enter while visiting our online shop or transmit to us in any other way is collated, saved and processed. You have the option to withhold certain information – which can however mean that you will be unable to utilize some of our offerings, services and features.

NEWSLETTER

When subscribing to the newsletter, your first name, your last name and your e-mail address are processed and used for sending the newsletter. Here, you can revoke your consent for the purpose of sending the newsletter for the future at any time without any formal procedure or notice. Furthermore, you can – when subscribing to the newsletter – voluntarily furnish us with additional data, particularly data relating to your postal address. Insofar as we process and utilize the data provided by you for advertising purposes within the context of the legally permissibly framework, for instance for postal marketing measures, you can object to this utilization at any time. In all cases of revocation or appeal, send us an informal message, i.e. by post, to the following address: THOMAS SABO GmbH & Co. KG Dataprivacy Silberstraße 1 D-91207 Lauf Germany Telephone: +49 (0) 91 23-97 15 0 FAX: +49 (0) 91 23-97 15 20 E-mail: dataprivacy@thomassabo.com Furthermore, each newsletter contains a link with which you can revoke your consent to receive the newsletter with effect for the future.

TO WHAT EXTEND DO WE PASS PERSONAL DATA ON TO THIRD PARTIES?

When passing on your personal data, we always ensure the highest level of security possible. For this reason, we exclusively pass on your data as follows: For the purpose of checking your credit history and identity, credit checking and for collecting outstanding debts, we transfer your data, if necessary, to the Schimmelpfeng Creditmanagement GmbH business information service or the Intrum Justitia GmbH debt collection agency. This is designed to avoid difficulties regarding payments and prevent any resulting financial damages in a timely manner. Furthermore, we transfer your data insofar as this is essential and permitted by legislation; for instance, to our logistics partner for sending your order within the context of dispatch handling. If we otherwise pass on your personal data, we do so exclusively to service providers or partner companies supporting us with order processing, providing the customer information and/or providing services in accordance with instructions (order data processing in accordance with § 11 BDSG). From their side, these companies are obliged to adhere to the data protection stipulations. Particularly stringent data protection stipulations apply to processing order data; in particular, companies may use the data exclusively for fulfilling the tasks on our behalf. We will otherwise not forward your personal data to third parties unless we are fundamentally obliged to do so as a result of legal stipulations or legal processes are mandatory (for example, inquiries from investigative authorities) or you have explicitly given us your consent to forward your personal data to third parties. The separate applicant data protection stipulations apply when using the applicant tools.

FOR HOW LONG WILL THE DATA BE STORED?

Only for as long as they are required for the processing of our services or for the period the legal stipulations require them to be saved for.

HOW DO WE PROTECT YOUR DATA?

We deploy technical and organizational measures that protect your personal data against loss, manipulation and unauthorized access by third parties. We regularly adapt our security measures to the current state of the art. We encrypt your personal data using the SSL process (Secure Socket Layer process) for our online shop and for transmitting your personal data stored there, which includes the payment information. The SSL process is currently the most common and most secure Internet data transmission process.

DATA COLLATION USING COOKIES

We use cookies (small text files that are saved on your computer’s hard drive) to simplify navigation for you. You can only use the site-wide basket display with the help of these session cookies – and comfortably read how many articles are currently in your basket and the current total value of your shopping. When you visit our Website, we also automatically collect technical and statistical data on the utilization of the THOMAS SABO online shop by setting cookies. This involves the following data: • IP address • Browser type and version • The Website from which you are visiting us • The operating system used by you • Date and time of your visits to the individual Websites • Information regarding the allocation of your visit and/or an order with a marketing channel These data are used to consistently improve our Website and are exclusively statistically and anonymously assessed. If you do not wish cookies to be used, ensure that you browser blocks the use of cookies. However, we would like to point out that in such cases you may not be able to use all the functions offered by our online shop.

COOKIE CONSENT

We use these cookies to anonymously track your activities to provide you with an optimal experience on our site and to provide personalised advertising. THOMAS SABO may share this information with third parties such as advertising partners like Google, Facebook or Instagram. Please note that based on your settings, you may no longer be able to use all the functions of the site. 

COLLECTION OF DATA BY USING ETRACKER

Furthermore, our online shop’s Website collects and saves anonymized data for marketing and optimization purposes using etracker GmbH (www.etracker.com) technologies. This data can be used to create user profiles by means of a pseudonym. Cookies can be used here. The cookies enable the recognition of the Internet browser. Without the separately issued consent of the affected persons, the data cannot be used to personally identify visitors to our online shop and are not merged with personal data on the bearer of the pseudonym. The collection and saving of data can be revoked with effect for the future at any time here: etracker.de/privacy

COLLECTION OF DATA BY USING Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. In case of activation of the IP anonymization, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of the website provider Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB . You can refuse the use of Google Analytics by clicking on the following link. An opt-out cookie will be set on the computer, which prevents the future collection of your data when visiting this website: Disable Google Analytics Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms/gb.html or athttps://www.google.de/intl/en_uk/policies/. Please note that on this website, Google Analytics code is supplemented by “anonymizeIp” to ensure an anonymized collection of IP addresses (so called IP-masking). We also use Google Analytics for analysing AdWords and double click cookie data for statistical purposes. If you don't agree with this, you can disable it in the Ads Preferences manager (http://www.google.com/settings/ads/onweb/?hl=en). Cookies & Preference Management adlicious uses DoubleClick by Google and other services for online advertising. Any information that these providers collect via so called 3rd party cookies is anonymous and non-personally identifiable. See Google's privacy policy for more information: Google Privacy Policy . The technology that we use is called "Online Behavioural Advertising" (OBA). Find more information about it and how to disable it via the Preference Management here: Online Behavioural Advertising.

GOOGLE REMARKETING

We use a Google Inc., USA (hereinafter referred to as ‘Google’) Web analysis service for “Google Remarketing”. For this, Google collates information on your visit to our Website. Google deploys cookies for this. Within the context of remarketing, these cookies are used to alert you – on the basis of visiting our Website – to other Websites by displaying online advertising for our products and services. The Google data protection stipulations can be found here. If you do not wish cookies to be used, ensure that your browser blocks the use of cookies. However, we would like to point out that in such cases you may not be able to use all the functions offered by our online shop. Furthermore, you can also deactivate display advertising using the Google Ads Preferences Manager by clicking on the following link and adjust ads within the Google display network: www.google.com/settings/ads/onweb/

CRITEO

Furthermore, we are working with Criteo SA (http://www.criteo.com/de/datenschutzrichtlinie). Criteo cookies are used for targeting/retargeting users of our Website, so as to display personalised ads in their future browsing. On request, you can configure your browser by changing the browser settings so that cookies are restricted or completely blocked. Comprehensive information on how to do this with numerous browsers can be found by visiting the following Websites: youronlinechoices, Network Advertising Initiative and/or Digital Advertising Alliance. These contain information on how you can delete cookies from your computer along with general information on cookies. Refer to your smart phone user instructions for information on how these settings can be carried out for your smart phone browser. Users can also select their settings by visiting the following platforms: IAB Opt-Out platform, Network Advertising Initiative Opt-Out platform, Digital Advertising Alliance platform, which offer options for making a decision for all companies registered on this platform. Please note that – even following deactivation of personalised ads from Criteo and other advertising partners – you will continue to receive ads that are, however, less accurately tailored to your interests/browsing behaviour.

OPTIMIZELY

This Website uses Optimizely, a Web analysis service owned by Optimizely, Inc., (‘Optimizely’). Optimizely uses so-called ‘cookies’, text files stored on your computer that permit the analysis of your use of the Website. Information on your use of this Website generated by the cookie is generally transmitted to an Optimizely server in the USA and saved there. In the event of activating the IP anonymisation on this Website, your IP address is however shortened by Optimizely in advance within European member states or in other contractual states covered by the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to an Optimizely server in the USA and shortened there. On behalf of the operator of this Website, Optimizely will use this information to evaluate your use of the Website and to compile reports on the Website activities. The IP address transmitted to Optimizely by your browser is not merged with other Optimizely data. You can prevent the saving of the cookies by correspondingly setting your browser software; however, we would like to point out that this may result in you being unable to fully use all functions of this Website . Furthermore, you can also deactivate Optimizely tracking at any time (and hence prevent the collation and transmission of the data generated by the cookie relating to your use of the Website - including your IP address - to Optimizely and the processing of this data by Optimizely) by following the instructions at http://www.optimizely.com/opt_out.

FACEBOOK

Furthermore, THOMAS SABO uses  a so-called Facebook Pixel, whose cookie consent is deployed within our Web presence. It is a product owned by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (‘Facebook’). It allows the tracking of user behaviour once the user has been forwarded to the advertiser’s Website by clicking on a Facebook advert. This procedure is used to evaluate the effectiveness of Facebook adverts for statistical and market research purposes and can help optimise future advertising measures. The collated data are anonymous for us, therefore offer no conclusions regarding the identity of the users. However, the data are saved and processed by Facebook to enable a connection to the respective user profile and so that Facebook can utilise the data for its own advertising purposes in accordance with the Facebook data utilisation guidelines (https://www.facebook.com/about/privacy/). You can enable Facebook and its partners to display adverts both on Facebook and outside. Furthermore, it can save a cookie on your computer for this purpose. Consent for the utilisation of Facebook Pixel audience tracking can only be given by users who are over the age of 13. If users are younger, we request that they ask for the permission of a parent or guardian. Please click here if you would like to revoke your consent: https://www.facebook.com/settings?tab=ads

USE OF SOCIAL PLUGINS

We use Facebook, Twitter, Google+ and Pinterest social plugins on this Website. When you visit a Website that includes such a plug-in, your browser can connect directly to the Facebook, Twitter, Google + or Pinterest servers and transfer data on your visitor behaviour to the Facebook, Twitter, Google + or Pinterest servers. Using Twitter plugins and the ‘Twitter’ button Twitter – a social network operated by Twitter Inc., 795 Folsom Street, Suite 600, San Francisco, CA 94107, USA – plugins are used on these Web pages. If you use Twitter and in particular the ‘Share’ function, Twitter will link your Twitter account to that of the Web pages you visit. This will be shared with other Twitter users, particularly your followers. This also means that data is transmitted to Twitter. As the host of our Website, we are not informed of the content of the transmitted data or the data utilisation by Twitter. You can access further information using the following link: http://twitter.com/privacy However, please note that you have the possibility to change your data protection settings in Twitter in the account settings under http://twitter.com/account/settings Using Google plugins and the ‘g+’ button: These Web pages use the ‘+1’ button from Google Plus, a social network operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA, (hereinafter referred to as ‘Google’). Using the ‘g+’ button on our Website creates a connection to the Google servers in the USA. Here, both your IP address and the information regarding which of our Web pages you have visited is transmitted to the Google servers. If you are also a Google Plus member and are logged on to Google Plus while using the plugin, the collated information on your Website visit will be linked to your Google Plus account and shared with other users. In the case of interactions that are possible with various Google plugins, the corresponding information on you is also collated and transmitted to, and saved by, Google. An overview of the various types of Google plugins can be viewed here: https://developers.google.com/+/plugins If you have made your profile publicly accessible in the Google Plus settings, Google can insert your ‘g+’ as references – together with your profile name and your photo – into Google services, such as search results, your Google profile or in other places on Websites and in Internet adverts. More detailed information on how Google collates and uses the data, on your relevant rights and on the privacy options can be found in Google’s data protection policy: www.google.com/intl/de/+/policy/+1button.html. By installing corresponding add-ons in your browser, you also have the possibility to block Google plugins. Using Pinterest plugins: These Web pages use plugins from Pinterest, a social network operated by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA (‘Pinterest’). The various logos contained within the plugin (i.e. the ‘Pin-it’ button or the ‘P’ button), can be viewed using the following link: http://business.pinterest.com/pin-it-button/; the ‘P’ button is used on our Website. Here, both your IP address and information on which of our Web pages you have visited is transmitted to the Pinterest servers in the USA. If you are also a Pinterest member and are logged on to Pinterest while using the plugin, the collated information on your Website visit will be linked to your Pinterest account and shared with other users. Even in the case of interactions that are possible with the various Pinterest plugins, the corresponding information on you is collated and transmitted to, and saved by, Pinterest. Further information on the collation and utilisation of data by Pinterest can be viewed under http://de.about.pinterest.com/privacy/. LINKS TO

EXTERNAL WEBSITES The THOMAS SABO

Website and this data protection declaration include links to external Websites, over whose contents THOMAS SABO has no influence. For this reason, THOMAS SABO assumes no liability for the contents, the nature or the reliability of these external Websites. The placement of links does not include any support for, or approval of, the information or services offered on the respective Websites. The respective provider or host of the Websites is solely responsible for the contents of the linked Websites.

WHERE CAN YOU GET INFORMATION ABOUT YOUR DATA STORED WITH US?

You have the right to demand free-of-charge information relating to your personal data stored with us at any time. If your personal data is incorrect or has been saved for incorrect reasons, we will gladly correct, block or delete said data. Here, we kindly request that you inform us of any changes to your personal data. In the event you wish to receive information on your personal data or you have questions relating to data protection, please write to: THOMAS SABO GmbH & Co. KG Dataprivacy Silberstraße 1 D-91207 Lauf Germany Telephone: +49 (0) 91 23-97 15 0 FAX: +49 (0) 91 23-97 15 20 E-mail: dataprivacy@thomassabo.com

CHANGES TO THIS DATA PROTECTION DECLARATION

We reserve the right to change or supplement the data protection declaration as required. We will publish all changes/supplements on this Website. For this reason, we kindly request that you regularly visit the Website to inform yourself of the latest status of the data protection declaration. Status: August 2016