1. Introduction

At Mouawad MENA DMCC (including House of Mouawad Ltd in the UK) ("Mouawad", "we", "us", "our") we take our obligations in respect of data privacy seriously and we recognise that it is important for you to understand how we make use of personal data.

Please read this privacy policy carefully as it contains important information about how we use personal data that you provide to us or we collect from you/third parties when operating our business, for example, when you visit the Mouawad website and mobile application (together this/our "Site") and the Mouawad boutique (this/our "Boutique") and when we visit you in your home or other desired location to sell our products and services ("Personal Shopping"). This privacy policy explains how we use personal data about visitors to our Site and our Boutique, including customers and potential customers, about Personal Shopping customers and potential customers and about individuals that get in contact with us, our suppliers, social media users, third-party stockists, agency partners, affiliates (e.g. influencers), press contacts and those individuals whose personal data we otherwise process in the course of our business. This privacy policy also covers data processing related to job applications and our recruitment activities.

It also explains the ways in which we (and our authorised service providers) will protect your personal data and sets out your rights in respect of personal data that we process about you. We will only use personal data in ways that are described in this policy and only ways that are consistent with our obligations and your rights under applicable data protection laws.

2. Who we are

For the purpose of applicable data protection laws, the "data controller" (in other words, the organisation that determines how and for what purposes your personal data is used) will be Mouawad.

Mouawad is a company registered in England and Wales with company number 14386468 and registered address C/O Foot Anstey Llp Salt Quay House, 4 North East Quay, Sutton Harbour, Plymouth, England, England, PL4 0BN.

This privacy policy details how we process personal data that we are a data controller of.

3. Personal data we may collect from you and how we collect it

Personal data you provide to us directly.

- Ways in which you might provide the data to us

This is personal data about you that you give us, which can happen in a wide variety of ways, including by:
- visiting and browsing our Site and other websites operated by us;
- telephoning or emailing us;
- using our Live Chat feature (where available);
- making a purchase from our Boutique or our Site;
- making a Personal Shopping visit;
- asking us to provide you with products and services and your use of those products or services;
- signing up to our newsletter;
- completing our "contact us" forms on our Site;
- registering as a user of our Site;
- registering products you have purchased from us;
- scheduling an appointment at our Boutique via the "schedule an appointment" form on our Site;
- corresponding with us by e-mail, telephone or SMS; or any other means of communication.
- mentioning or interacting with us on social media (for example by following/mentioning/tagging us or by contacting us directly).
It also includes personal data you provide when you search for a product on our Site, report a problem with our Site or products, enter into a contract with us or otherwise provide us with any personal data. We and our authorised service providers may collect some of this personal data even if you are not a registered user or do not place an order with us.

- What type of data might be included?

The personal data you give us may include but is not limited to:
- your title
- your name;
- your date of birth;
- your delivery address;
- e-mail address;
- phone number (including mobile number);
- gender (and preferred salutation);
- nationality;
- jewellery size and product interest;
- social media handle and personal data on your social media account;
- financial and credit card personal data;
- purchase history;
- gift recipient details; and
- thoughts about our products (including complaints and reviews (and any photos you provide as part of those reviews)).
If you are one of our [third-party stockists or] suppliers, we will process your business contact details and your job role.

We will only ever ask you to give us personal data which we need in order to provide you with the products or services that you have requested from us.

- Job applicants

If you apply for a role with us, we will collect a range of information directly from you either by email, over the phone or via an online job application process/system which may include but is not limited to:
- your name;
- postal address;
- e-mail address;
- phone number (including mobile number);
- gender (and preferred salutation);
- date of birth;
- National Insurance number;
- your health information (if relevant to your application);
- the contents of your CV (including details of previous roles, any relevant qualifications you have obtained);
- evidence that you are legally permitted to work in the United Kingdom;
- your current and desired annual salary;
- your current notice period;
- whether you have previously been employed by us;
- how you heard about the role you are applying for; and
- any other information that we reasonably require as part of the recruitment process.
If you are a job applicant and want more detail about how we process your personal data as part of our recruitment process, you can contact our HR department by email at HR@Mouawad.com.

- Visiting our Boutique

If you visit our Boutique, we will process your personal data. This personal data may include: your name, postal address, and e-mail address and phone number (including mobile number).

We may also process your personal data in the form of video or audio recordings via CCTV. CCTV is used in our Boutique, for the safety of and prevention of any crimes committed against our staff, our equipment and our properties, not for other monitoring purposes. In the event of any criminal investigations, we may be required by law, to share the data captured with the relevant authorities.
Personal data we collect or generate about you.

When you visit our Site or get in touch with us, we may collect, generate, store and use certain personal data about you. In some cases we will use cookies to do this, for further information about the cookies we use and how to opt out of such cookies please see our cookie policy.

This personal data may include:
- technical information, including: the Internet protocol (IP) address used to connect your computer to the Internet and domain type; browser type and version; time zone setting; browser plug-in types and versions; device types; operating system; time and date of consent and platform; and any phone number used to call our customer service number.
- information about your visit to our Site, including: your location, the full Uniform Resource Locators (URL); clickstream to, through and from our Site (including date and time); products you viewed, searched for or purchased; date and time of order as well as orders you decided not to complete or items you placed in your basket and discarded; preferences you have indicated to us; requested personalisation of items; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse our Site.
Personal data we receive from other sources.

We may occasionally receive personal data about you from other sources, for example from couriers, payment providers or through the internal loyalty program (they will provide us with your email address when they think that you would be interested in hearing about our products).

4. Why and how do we use your personal data and what is our "lawful basis" for doing so?

We will only use your personal information when the law allows us to. Whenever we process your personal data, we are required to identify and maintain a valid "lawful basis" (i.e. a legally compliant justification) for the processing. To help you to understand what we do with data and why, we have described the various relevant lawful bases that we rely on in the table below. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

How and why we use your personal data	What is our legal justification for processing your personal data
To carry out our obligations arising from any contractual agreement with you and to provide you with the information and products or services you request. These may include fulfilling your order with us, [managing your account with us], and the provision of services related to these purposes to us by our agreed third-party providers.	We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data in relation to an order for products and services. Alternatively, in some scenarios, we rely on our legitimate interests as a business (for example, it is in our interests to measure customer satisfaction and troubleshoot customer issues).
To measure how satisfied our Site visitors and our customers are and provide customer service (including troubleshooting in connection with visiting our Site or when you ask us questions by email, on the phone or on social media).
To process payments and maintain accounts and records of such payments.
To prevent or detect crime, fraud or abuses of our products and services or our Site and to enable third parties to carry out related technical, logistical, research or other functions on our behalf related to these purposes.	In some circumstances we will use your personal data because it's necessary for us to comply with a legal obligation (for example, if we receive a legitimate request from a law enforcement agency). In other cases (such as the detection of theft, fraud or ensuring security of our Site) we will rely on our legitimate interests in keeping our employees and our Site secure and to prevent theft and fraud.
To send you newsletters, updates, information about new products or services that we think might interest you, to send you other promotional and marketing information, to conduct other competitions or promotions via email, telephone, SMS, or post.	Unless we are contacting you in a business to business capacity, we will only use your personal data to send you electronic marketing messages if we have consent from you to do so (or if you are an existing customer and have not opted out of receiving marketing materials). In some cases, we will rely on our legitimate interests to send these types of communication (our legitimate interest in marketing and advertising our products). You can amend your preferences or opt out from marketing communications by using the unsubscribe links within our email marketing messages, by changing your marketing preferences in the communications section of your online account (if applicable) or by contacting us at any time at the contact details set out at part 17 of this privacy policy below.
To measure or understand the effectiveness of advertising we serve to you.
To carry out market research or similar surveys.
To use the reviews, comments and feedback that you provide to us for our own advertising purposes. We may use a review, comment or piece of feedback that you submit in our advertising campaigns, such as in press and digital advertising, on our social media pages, in our email marketing or on our Site.	We have a legitimate interest to promote our own products and services and to use the reviews, comments and feedback that you provide to us to do so.
To find out more about the visitors to our Site, our Boutique and our customer base as a whole (and not to find out more about you as an individual) to ensure that the products and services that we offer are most likely to interest our Site and Boutique visitors and customers. We may use cookies to do this.	We have a legitimate interest to make sure that we are providing you with the information that we think is most relevant to you. We will not place cookies other than "strictly necessary" cookies on your device unless you have told us that you are happy for us to do so. For information on how we use cookies, please see our cookie policy.
To notify you about changes to our services and terms and conditions.	We rely on our contractual arrangements with you as the lawful basis for this processing. In some cases, we rely on our legitimate interests as a business to send you these updates.
For administrative or business purposes, where you contact us for a particular reason other than those set out above, such as to report problems with our Site.	We have a legitimate interest to respond to your contact for the purposes of administering our business.
If you are a job applicant, we will use your personal data to assess your suitability for the role and to make recruitment decisions.	We have a legitimate interest in recruiting talent into our business and assessing candidates to ensure that we are making fair and appropriate recruitment decisions. We may process some of your data on the basis of a legal obligation that applies to us as an employer (e.g. in some territories, this may require us to process data relating to race, religion, gender or disability/health).
We use CCTV in our Boutique, for the safety of and prevention of any crimes committed against our staff, our equipment and our properties, not for other monitoring purposes.	We have a legitimate interest to ensure the safety of and prevention of any crimes committed against our staff, our equipment and our properties. In some circumstances we will use your personal data because it's necessary for us to comply with a legal obligation (for example, in the event of any criminal investigations, we may be required by law, to share the data captured with the relevant authorities.).

6. What if you fail to provide personal data?

Please make sure you provide us with certain information when requested as if you don't we may not be able to perform the contract we have entered into with you (such as, to provide you with products or services). In this case, we may have to cancel a product or service you have with us, including but not limited to our warranty service, but we will notify you if this is the case at the time.

7. Change of purpose

We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain our legal justification for doing so and we will provide you with any relevant further information. We may also issue a new privacy policy to you.

8. How we share your personal data

Third party suppliers and service providers involved in our contractual relationship with you

Like most businesses, we work with third party suppliers and service providers as part of the day to day operations of our business. Some of these trusted suppliers will process your personal data on our behalf and provide services to us such as the provision of CRM services (and associated applications) which enable us to manage web hosting, marketing, order fulfilment, and so on.

We may also share your personal data with digital marketing agencies, print media agencies and events and PR agencies (including customer/influencer personal contact details and addresses) to send gifts, promotions and invites to events and for other marketing purposes.

All card transactions are managed by trusted, certified and legally authorised partners who are responsible for ensuring that your payment details remain secure during the payment process

We will always make sure that these trusted suppliers meet agreed standards for the protection of your personal data and they will only ever be allowed to use your personal data in order to provide us with services and not for their own commercial purposes. We require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with applicable data protection law.
Other scenarios in which we might share your personal data

We may also share your personal information:
- with our group companies;
- with government authorities or professional bodies, such as HM Revenue & Customs in the United Kingdom (for tax purposes);
- with our professional advisors including tax, legal or other corporate advisors who provide professional services to us;
- with regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised law enforcement bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc.;
- in the event that we consider selling or buying any business or assets we will disclose your personal information to any prospective sellers or buyers of such business or assets;
- in the event of any insolvency situation (e.g. administration or liquidation);
- if we, or substantially all of our assets, are acquired by a third party, in which case your personal information will be one of the transferred assets;
- to protect the rights, property or safety of our employees, workers, contractors, clients, or others. This includes exchanging your personal information with other companies and organisations (including without limitation the local police or other local law enforcement agencies) for the purposes of our employee, worker, contractor and client safety, crime prevention, fraud protection and credit risk reduction; or
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

9. How do we protect your personal data?

We take the security of your personal data very seriously and have put in place physical, technical, operational and administrative strategies, controls and measures to help protect your personal data from unauthorised access, use or disclosure as required by law and in accordance with accepted good industry practice. We will always keep these under review to make sure that the measures we have implemented remain appropriate. You can obtain further information about these measures using the contact details set out at part 17 of this privacy policy below.

In addition, we limit access to your personal data to those employees and other third parties who have a business need to know in order to perform their job duties and responsibilities. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

10. How long does we keep your personal data?

We will retain your personal data for as long as we need it in connection with our relationship with you. This retention period may depend on whether you are visiting our Site, our Boutique or make a purchase and on whether we need to retain your personal data in order to comply with applicable laws.

Personal data which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal data where applicable. Your full payment card details are captured only for the purposes of processing your transaction and are not stored, sold or rented by us. Your full payment card details are not available to our staff.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you. In this case, we may retain such information for a longer period without further notice to you.

11. Your rights in relation to your personal data

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes so that our records can be updated. We cannot be held responsible for any errors in your personal information in this regard unless you have notified us of the relevant change.

Data protection law grants you a number of specific rights in respect of your data in addition to the broad and general right to have your data protected. We have set out some information in respect of each of those specific rights, below:

Right to be informed about how your personal information will be processed. This enables you to receive information about how we use your personal information. We have set this information out in this policy.
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information (commonly known as the "right to be forgotten"). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
Not to be subject to a decision solely based on automated processing. We do not anticipate making decisions about you based solely on automated decision making where that decision would have a significant impact on you. If we ever make a decision about you automatically by a computer or an algorithm without human intervention you can ask us to have that decision reviewed by a human.

If you want to exercise any of the rights set out above, please contact us (using the contact details set out at part 17 of this privacy policy below).

12. Where your personal data may be processed

Given the international location of our business and of some of our suppliers, your personal information may be transferred in and out of the UK and the European Economic Area ("EEA") including in and out of the United Arab Emirates where local laws may not provide legal protection for personal data in the same way as is applicable in the UK or the EEA. Where your personal information is processed outside of the UK and EEA, we will ensure that we take the necessary steps to protect your personal information as required by data protection laws.

13. Cookies

Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and allows us to improve our Site and our services.

We also place tracking cookies in our marketing emails as this helps us to improve our marketing activities - for example, these cookies allow us to see how many people open our emails, what time of day they open our emails and whether they click through on any of the information contained in the emails.

For information on how we use cookies, please see our cookie policy

14. Third-party websites

Our Site may, from time to time, contain links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

15. Changes to this privacy policy

We reserve the right to update or amend this privacy policy at any time, including where we intend to further process your personal data for a purpose other than that for which the personal data was collected or where we intend to process new types of personal data. We will place any updates here on this page. This privacy policy was last updated on 9^th March 2023.

16. Complaints

We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your data (our details are in the section immediately below). We will try to put things right.

However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint to the Information Commissioner's Office ("ICO"). You can contact the ICO at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF; 0303 123 1113; or https://ico.org.uk/;

If you are not based in the UK and are based in Europe, you can contact your local data protection authority - more details can be found here.

17. Contact

If you have any questions about this privacy policy or how we handle your personal data, please contact us as follows: Privacy@mouawad.com.

Hana Soukupova

Julia Stegner