PRI VACY POLI CY

Last modified on July 25, 2018.

This Data Privacy Notice describes the collection and further processing of personal data by
companies of the Swarovski Group and its affiliates (together SWAROVSKI). In the event that
the activities covered by this notice are governed by other data protection policies, are evident
from the circumstances, or are governed by applicable laws outside of the European Union and
the European Economic Area, then such applicable law and resulting policies shall control. The
term personal data shall include all information relating to an identified or identifiable person.

This Data Privacy Notice describes in Section I processing of personal data by SWAROVSKI
in general. Section II contains specific provisions for specific applications (e.g. online-shop,
newsletter and banner advertisement) and Section III contains specific provisions for customer
programs.

If you provide SWAROVSKI with personal data of other persons, for example data about the
receiver of a gift, please provide their personal data to SWAROVSKI only if you are allowed
to do so pursuant to applicable data protection laws and only if the other person would agree to
you providing its personal data to SWAROVSKI for the purposes the data are collected and the
processing of its personal data according to our data privacy notice.

I. GENERAL PROVISIONS

1. CONTROLLER, DATA PROTECTION OFFICER

Every website (including online-shops and mini sites for special offers), every presence on
social media, multimedia portals, chatbots and every application of SWAROVSKI (each a
WEBSITE) has a controller within SWAROVSKI with respect to collecting personal data
according to the EU General Data Protection Regulation (GDPR) (or comparable provisio ns
according to applicable data protection laws). Unless provided otherwise on the WEBSITE
(according to the imprint, the terms of use, etc.) or under Section II and III below, Swarovski
Crystal Online AG, Alte Landstrasse 411, 8708 Männedorf, Switzerland, is the controller for
the Online-Shops www.swarovski.com and www.swarovskioptik.com and Swarovski
Aktiengesellschaft, Dröschistrasse 15, 9495 Triesen, Liechtenstein, is the controller for the
Swarovski Group website www.swarovskigroup.com.

The respective subsidiary or affiliate is the controller in the event SWAROVSKI communica tes
through other means of communication (such as email, letter, telephone, in person) and the
communication does not fall within an activity for which SWAROVSKI has appointed a
specific controller within this Data Protection Notice or otherwise.

Should a SWAROVSKI company or affiliate disclose personal data to another SWAROVSKI

company or affiliate for certain purposes of the receiving company or affiliate, such company
or affiliate is the controller. A list of the relevant companies and affiliates of SWAROVSKI can
be found in ANNEX 1, which may be updated from time to time.

SWAROVSKI has not appointed a data protection officer according to article 37 GDPR save
for SWA-ROVSKI companies and affiliates in Germany and Principality of Liechtenstein.

HOW TO CONTACT SWAROVSKI

If you want to exercise any of your rights regarding newsletter subscriptions, data access or
data deletion, please do not hesitate to contact our Customer Care team, who will be happy to
answer any questions you may have.

Any queries or concerns about our privacy policy or the processing of your personal data can
also be addressed to The Group Data Privacy Team at [email protected].

Alternatively, if you reside in Germany or Liechtenstein, you can contact:

• The data protection officer for Germany at Swarovski (Deutschland) GmbH, Data Protection
Officer, Hüttenstrasse 27, DE-87600 Kaufbeuren;
• The data protection officer for Liechtenstein at Swarovski Aktiengesellsc haft, Data Protection
Officer, Dröschistrasse 15, FL-9495 Triesen.

The representative for all SWAROVSKI companies and affiliates domiciled outside of the EU
or EEA is D. Swarovski KG, Legal Department, Swarovskistrasse 30, AT-6112 Wattens
(pursuant to Article 27 of the GDPR).

2. PROCESSING OF PERSONAL DATA

SWAROVSKI collects and processes personal data of

• users of SWAROVSKI registered WEBSITES;
• users registered with a SWAROVSKI WEBSITE (e.g. if he or she creates a user account);
• individuals purchasing and receiving/benefitting from products and services of
SWAROVSKI;

• potential or actual parties interested in products and services of SWAROVSKI;

• recipients of SWAROVSKI newsletters;
• participants in research campaigns and opinion surveys conducted by SWAROVSKI;
• participants in courses, seminars and other trainings organized by SWAROVSKI;
• users of WIFI provided at SWAROVSKI stores and other locations;
• registered participants of customer loyalty programs or individuals purchasing or using
customer loyalty programs of SWAROVSKI (CUSTOMER PROGRAM)
(together CUSTOMERS).

The personal data of CUSTOMERS is generally collected directly by SWAROVSKI during the
course of using the WEBSITE, as well as in stores or at events of SWAROVSKI as well as
through direct commu-nication such as email, telephone or in any other way. Personal data can
also be collected indirectly, such as through third party processors, (e.g., SWAROVSKI’s
PARTNERS (as defined further below, including wholesalers, dealers, retailers, suppliers and
further business partners such as customer ser-vices vendors). SWAROVSKI also collects data
when the CUSTOMER making the purchase does not correspond with the person benefitting
from the purchase or if the purchase is shipped to a different person (e.g. as a gift), based on
the recommendation of a third party (e.g. recommendation by family or friends of the
CUSTOMER) or through further acquisition of supplementary information from third party
data sources (e.g. social media).

In particular, the following categories of personal data are processed by SWAROVSKI:

• Personal data and contact information including but not limited to first and last name,
maiden name, address, residence, telephone number, email address, age, date of birth, gender,
marital status, relatives, contact in case of emergency, pictures;
• Data pertaining to orders and purchases including but not limited to payment informatio n,
credit card details and other payment details (in accordance with other laws and regulatio ns),
billing and shipping address, products and services ordered and purchased, information and
queries and complaints relating to products and services, or respective contracts entered into
such as warranty claims, after sales services, repairs, customer care and services, rescissions
and disputes;

• Data in connection with product and services marketing including but not limited to
information relating to newsletter and other communication channels, opt-ins and opt-outs,
invitations to and participations at events and special activities (as far as they are not part of a
customer loyalty program), personal preferences and interests, and customer segmentatio n
information;

• Data concerning the use of the WEBSITE including but not limited to the IP address and
other user identification (e.g. user name of social media, MAC address of smartphones or
computers, cookies), date and time of WEBSITE visits, visited sites and contents, and referring
websites;

• Data in connection with communication including but not limited to preferred means of
communication, correspondence and communication with SWAROVSKI (including records of
the communication);

• Data which was collected in connection with a customer program including but not limited
to membership numbers, access codes (including passwords), preferred language, number of
gift certificate, date and duration of the membership, payment information of the CUSTOMER
or a potential third party, information concerning the recipient of a gift, number of visits of the
WEBSITE, purchase history, products acquired (all WEBSITE accounts, activities and events
for which a CUSTOMER must register with his or her personal data and thus enter into a
contract with SWAROVSKI shall be deemed a customer program for the purposes of this
policy, other than traditional customer loyalty programs);

together CUSTOMER DATA

In addition, SWAROVSKI collects:

• Data of users of the WEBSITE, who do not register with SWAROVSKI (VISITOR) but
may constitute personal data for example with social media (VISITOR DATA), the provisio ns
of this notice regarding data collected from a CUSTOMER in connection with the use of the
WEBSITE shall apply accordingly even though the identification of a VISITOR usually is not
possible for SWAROVSKI;

• Information pertaining to employees and other individuals acting on the part of whole -
salers, dealers, retailers, suppliers and further business partners of SWAROVSKI (herein-
after natural persons shall be referred to as PARTNERS, their data as PARTNER DATA)
including but not limited to contact details, information regarding their function, informa tio n
relating to the previous contact with these individuals, data regarding marketing activities (e.g.
receipt of newsletters), information regarding business transactions, requests, offers, tenders,
conditions and contracts, information related to professional or other interests of the individua ls.

Within the framework of their business relationship, CUSTOMERS will be required to provide
CUSTOMER DATA necessary for the establishment and execution of the contractual
relationship and the fulfilment of the associated contractual obligations or if required by law.
Without these data, SWAROVSKI will generally not be able to conclude or execute the contract
with the respective CUSTOMER. This also applies analogously to the PARTNER DATA as
far as business relations with the wholesalers, dealers, retailers, suppliers and business partners
of SWAROVSKI are concerned; contracts in principle cannot be concluded and processed
without information on their employees and other contacts. As any access to the WEBSITE is
logged, connection data (such as the IP address) will always be logged; this is done
automatically during the use and cannot be deactivated for individual VISITORS,
CUSTOMERS or PARTNERS.

3. PURPOSE OF PROCESSING AND LEGAL GROUNDS

3.1. PURPOSE of the processing

In accordance with applicable law, SWAROVSKI may process CUSTOMER DATA for all
lawful PURPOSES including but not limited to the following:
• In connection with services offered, conclusions of contracts (for example purchases),
executions of contracts (for example purchase contracts and contracts regarding the
participation at customer programs and events), maintenance and development of customer
relations, communication, customer service and support, promotions, advertisement and
marketing (including newsletters and mailing of promotional materials);

• Management of the users of the WEBSITE and other activities in which CUSTOMERS
participate, operation and enhancement of the WEBSITE (including the provision of functio ns
which require identifiers or other personal data) and additional IT systems and identity
verifications;

• protection of CUSTOMERS, employees and other individuals and protection of data, secrets
and assets of and entrusted to SWAROVSKI, and the protection of the safety of systems and
premises of SWAROVSKI;

• compliance with legal and regulatory requirements, including the internal rules of
SWAROVSKI, enforcement and exploitation of legal rights and claims, defense against legal
claims, litigation, complaints, combating abusive conduct, engaging in legal investigations and
proceedings and responding to inquiries of public authorities;

• sale or acquisitions of business divisions, companies or parts of companies and other corporate
transactions and the transfer of CUSTOMER DATA associated therewith; and

• for other lawful purposes where such processing was evident from the circumstances or
indicated at the time of the collection.

(together the PURPOSE OF CUSTOMER DATA PROCESSING).

3.2. LEGAL GROUNDS of processing

SWAROVSKI uses the CUSTOMER DATA for the PURPOSE OF CUSTOMER DATA
PROCESSING based on the following LEGAL GROUNDS:

• performance of contracts;
• compliance with legal obligations of SWAROVSKI;
• consent of the CUSTOMER (only insofar as the processing is based on a specific query and
can be withdrawn at any time, for example the receipt of newsletters for which the CUSTOMER
has registered for);
• legitimate interests of SWAROVSKI, including but not limited to

o purchase and shipment of products and services, also in connection with individuals who are
not direct contractual partners (such as e.g. individuals receiving a gift);
o advertising and marketing activities;
o efficient and effective customer support, maintenance of contact and other communica tio n
with CUSTOMERS outside of the processing of contracts;
o understanding CUSTOMER behavior, activities, concerns and needs, market studies;
o efficient and effective improvement of existing products and services and development of
new products and services;
o efficient and effective protection of CUSTOMERS, employees and other individuals as well
as protection of data, secrets and assets of or entrusted to SWAROVSKI, protection and safety
of systems and premises of SWAROVSKI;
o maintenance and secure, efficient and effective organization of business operations includ ing
a secure, efficient and effective operation and successful further development of the
WEBSITES and other IT systems;

o reasonable corporate governance and development;

o successful sale and acquisition of business units, companies or parts of companies and other
corporate transactions;
o compliance with legal and regulatory requirements and internal rules of SWAROVSKI;
o concerns regarding the prevention of fraud, offences and crimes as well as investigation in
connection with such offences and other improper conduct, handling of claims and actions
against SWAROVSKI, cooperation in legal proceedings and with public authorities as well as
the prosecution, exercise of and defense against legal actions.

In accordance with applicable data protection laws, SWAROVSKI may process VISITOR
DATA for the purpose of maintaining and developing the WEBSITE (including the provision
of functions which require identifiers or other personal data), for statistical analysis regarding
the use of the WEBSITE as well as for combating abusive conduct, for purposes of legal
investigations or proceedings and for the response to inquiries of public authorities. The
VISITOR DATA shall be processed in accordance with the principles set out for CUSTOMER
DATA above.

In accordance with applicable data protection laws, SWAROVSKI may process PARTNER
DATA for the purpose of entering into and performance of contracts and other business
relationships with PARTNERS, promotions, advertisement and marketing, communicatio n,
invitation to events and participation in promotions for PARTNERS, organization of joint
activities, compliance with legal and regulatory requirements and internal rules of
SWAROVSKI, enforcement and exploitation of legal rights and claims, defense against legal
claims, litigation, complaints, combating abusive conduct, engaging in legal investigations and
proceedings and responding to inquiries of public authorities, for the sale or acquisition of
business units, companies or parts of companies and other corporate transaction and related
transfers of PARTNER DATA. The PARTNER DATA shall be processed in accordance with
the principles set out for CUSTOMER DATA above.

All the purposes of processing shall be applicable for the whole SWAROVSKI Group, i.e. not
only for the company which initially collected the personal data. Personal data of
CUSTOMERS, VISITORS and PARTNERS is collected for the purpose of all SWAROVSKI
companies subject to this data privacy notice, any other policies developed by SWAROVSKI
and pursuant to applicable data protection laws.

4. TRANSFER AND DISCLOSURE OF DATA

In accordance with applicable data protection laws, SWAROVSKI may transfer CUSTOMER
DATA, VISITOR DATA and PARTNER DATA to the following categories of THIRD
PARTIES who process PERSONAL DATA in accordance with the PURPOSE OF DATA
PROCESSING on behalf of SWAROVSKI or for their own purposes:

• service providers (within SWAROVSKI as well as external), including processors;

• wholesalers, dealers, retailers, suppliers and other business partners;
• customers of SWAROVSKI;
• local, national and foreign authorities;
• media;
• the public including visitors of WEBSITES and social media of SWAROVSKI;
• industry organizations, associations, organizations and other committees;
• acquirers or parties interested in acquiring business units, companies or other parts of
SWAROVSKI;
• other parties in potential or actual legal proceedings;
• other Group companies of SWAROVSKI.

(together THIRD PARTIES).

SWAROVSKI may disclose CUSTOMER DATA, VISITOR DATA and PARTNER DATA
within SWAROVSKI as well as to THIRD PARTIES and in every country worldwide,
including namely all countries in which SWAROVSKI is represented by Group companies,
affiliates or other offices and representatives (see ANNEX 2, as updated from time to time) as
well as to countries in which service providers of SWAROVSKI process their data (see
ANNEX 2, as updated from time to time). If data is disclosed to countries that do not guarantee
adequate protection, SWAROVSKI will ensure adequate protection of data disclosed of
CUSTOMERS, VISITORS or PARTNERS by putting adequate contractual guarantees in
place, (e.g., on the basis of EU standard clauses), binding corporate rules, on the basis of the
EU-U.S. and the Swiss-U.S. Privacy Shield Framework for transfers to THIRD PARTIES
based in the U.S., or transferring data pursuant to consent, conclusion or performance of a
contract, or in connection with the determination, exercise or enforcement of legal claims, or
pursuant to overriding public interests, or in order to protect the integrity of these individua ls.
The CUSTOMER, VISITOR or PARTNER can obtain a copy of the contractual guarantees
from or will be advised where to obtain such copies by the contact points named above (see
para. 1 above). SWAROVSKI reserves the right to redact such copies for applicable legal or
secrecy reasons.
5. RETENTION OF DATA

In general, SWAROVSKI retains personal data for no longer than it is necessary for the
purposes for which the personal data are processed. Notwithstanding the general princip le,
SWAROVSKI may process personal data for longer periods subject to the following rules and
obligations: SWAROVSKI retains personal data as long as SWAROVSKI (i) is obligated to do
so (by way of contract, law or other provisions) or (ii) has an overriding interest (e.g. an interest
for reasons of proof in case of claims, documentation of compliance with certain legal or other
requirements, an interest in non-personalized analysis). Deviating rules are reserved with
respect to anonymization or pseudonymization of personal data subject to applicable law.

As a rule for contract related CUSTOMER DATA and PARTNER DATA (including business
records and communication) SWAROVSKI retains personal data as long as the contractual
relation is ongoing and for ten years after the termination of the contractual relationship unless
(i) a shorter or longer statutory storage obligation is applicable on a case-by-case basis, (ii) the
retention is required for reasons of proof or another valid reason based on applicable law, or
(iii) the deletion of the data is required earlier (because e.g. the data is no longer required or
SWAROVSKI is required to delete the respective data).

As a rule for operational data containing CUSTOMER DATA, VISITOR DATA or PARTNER
DATA (e.g. protocols, logs), SWAROVSKI retains personal data for a period of 3 - 12 months.

6. COOKIES, GOOGLE ANALYTICS AND SOCIAL PLUG-INS

SWAROVSKI uses cookies on its WEBSITE. Cookies are a widespread technique that
allocates an identification to the browser of the user of a WEBSITE which the user saves and
shows upon request. On the one hand, SWAROVSKI uses session cookies which are
automatically erased when the user closes the WEBSITE and which enable the server to
establish a stable connection to the user (so that the content of a shopping basket is not lost, for
example) as long as he or she browses on the WEBSITE. On the other hand, SWAROVSKI
also uses permanent cookies which are only erased after a period defined per WEBSITE.
Permanent cookies allow the saving of certain settings (e.g. language) for several sessions or
allow for an automated log-in. The user consents to the application of permanent cookies
through the use of the WEBSITE and the respective functions (e.g. language settings and
automated log-in). The user may block or delete the application of cookies on his or her browser
but this activity may impair the use of the WEBSITE.

In accordance with applicable law, SWAROVSKI may install coding in newsletters and other
marketing email which allow it to determine if the recipient has opened an email or downloaded
pictures contained in the email. However, the recipient may block this application in his/her
email application. In any case he/she consents to the application of this technology by way of
receiving newsletters or other marketing related emails.

In the event that SWAROVSKI places advertisements of third parties on the WEBSITE (e.g.
banners) or places an own ad on the website of a third party, cookies from companies
specializing in the use of such advertisement may be employed. SWAROVSKI will not disclose
personal data to such companies, i.e. they shall only place a permanent cookie with users of the
WEBSITE in order to recognize users and do so in the sole interest of SWAROVSKI. This
allows SWAROVSKI to place aimed advertisements for these individuals on external third
party websites (e.g. in connection with products for which these individuals showed an interest
in the online-shop). SWAROVSKI will not disclose personal data to the operators of external
websites.

SWAROVSKI may use Google Analytics or similar services on its WEBSITE. These
applications are third party services which allow SWAROVSKI to measure and analyze the use
of its WEBSITE. The provider of these services may be located in any country worldwide (in
the case of Google Analytics which is operated by Google Inc. it is the U.S., www.google.co m).
The service provider uses permanent cookies for these applications. SWAROVSKI will not
disclose any personal data to the service provider (who will also not save any IP addresses).
The service provider may, however, monitor the use of the WEBSITE by the user and combine
this data with data from other websites monitored by the same service provider which the user
has visited and the service provider may use these findings for its own benefits (e.g. control of
advertisement). The service provider knows the identity of the user who has registered with the
service provider. In this case the processing of personal data will be the service provider's
responsibility and data shall be processed pursuant to data protection and privacy laws and
according to the data protection policies of the service provider (for Google see
policies.google.com/privacy). The service provider will provide data on the use of the
WEBSITE to SWAROVSKI.

In addition, SWAROVSKI may use plug-ins from social media networks such as Facebook,
Twitter, Youtube, Google+, Pinterest or Instagram on its WEBSITE. In the default setting of
the WEBSITE plug-ins are deactivated; the user can thus choose when to activate them. Should
the user do so, the social media providers are able to establish a direct connection to the user
during his or her visit on the WEBSITE, which allows the provider to be aware of the user's
visit and may analyze the respective information. The subsequent processing of the personal
data will be conducted in the responsibility of the social media provider pursuant to data
protection and privacy laws and according to its data protection policies published on its website
(such as www.facebook.com/; www.twitter.com/; www.youtube.com/; www.google.co m/;
www.pinterest.com/; www.instagram.com/).

You can find more information about Cookies used by SWAROVSKI and how to manage your
Cookie settings on our WEBSITE.

7. RIGHTS OF THE CUSTOMER, VISITORS AND PARTNERS

Any affected individual, including any CUSTOMER, VISITOR and PARTNER, may request
information from SWAROVSKI as to whether data concerning them is being processed. In
addition, they have the right to request the correction, destruction or restriction of personal data
regarding them as well as to object to the processing of personal data. Should the processing of
personal data be based on consent, the affected individual may withdraw consent at any time.
In countries of the EU and EEA the affected individual may, in certain cases, have the right to
obtain data generated during the use of online services in a structured, common and machine -
readable format which allows for further use and transfer. Request in this respect shall be
submitted to the contact point (see para. 1 above). SWAROVSKI reserves the right to restrict
the rights of the affected individual in accordance with applicable law and e.g. not to disclose
comprehensive information or not to delete data.

In the event that SWAROVSKI makes an automated decision with respect to a certain
individual which may have a legal effect for the affected individual or seriously affect him or
her in a similar way, the affected individual shall have, in accordance with applicable law, the
right to communicate with a controller of SWAROVSKI and to request a reconsideration of the
decision or to request the prior evaluation by the controller. In this case the affected individ ua l
may no longer be able to use certain automated services. The individual will be informed thereof
subsequently or separately in advance.

Any affected individual may also raise a complaint with the competent data protection
authority, which in the case of a SWAROVSKI controller in Switzerland is the Federal Data
Protection and Information Commissioner in Switzerland (http://www.edoeb.admin.ch), the
SWAROVSKI controller in the Principality in Liechtenstein is the Data Protection O ffice
(Amtstelle Datenschutzstelle, in the Principality in Liechtenstein (https://www.llv.li/), the
SWAROVSKI controller in Austria is the Austrian Data Protection Authority in Austria
(https://www.dsb.gv.at/). In all other cases a list can be found here.

8. CHANGES TO THE DATA PRIVACY NOTICE

SWAROVSKI reserves the right to amend this Data Privacy Notice at any time and without
prior notice or announcement. The latest version posted on the SWAROVSKI WEBSITE shall
be applicable.

Should the Data Privacy Notice form part of an agreement with CUSTOMERS and
PARTNERS, SWAROVSKI may inform them of an update or amendments by email or in
another appropriate manner. The amendments shall be deemed to have been accepted unless an
objection is raised within 30 days of notification. In case of objection SWAROVSKI shall be
free to terminate the agreement exceptionally and with immediate effect.

II. Specific Provisions

The following provisions shall supplement the general provisions in Section I for certain
activities of SWAROVSKI. In the event there is any inconsistency, the following provisio ns
shall control.

1. ONLINE-SHOPS
The creditworthiness of CUSTOMERS may be evaluated automatically in online-shops in order
to offer the purchase on account based on this decision. In this case the credit rating is evaluated
on the basis of information from an external credit rating agency, which will provide
SWAROVSKI with a credit score of the respective CUSTOMER. The agency will calculate
the score based on a secret formula based on data on the payment history of the CUSTOMER,
its debt and insolvency history and possible limitations of its legal capacity. Should the score
be below a certain threshold no payment by invoice will be offered. In this event the
CUSTOMER may contact the contact person shown on the imprint of the respective website of
the online-shop if he/she is not ready to accept the decision.

Online shops of SWAROVSKI may automatically decide whether to enter into purchase
agreements. However, SWAROVSKI does not deem this an automated individual decision
(according to article 22 of the GDPR). In the event the CUSTOMER does not wish such an
automated entering into an agreement, it has the option to purchase products and services from
SWAROVSKI physical stores.
2. PARTNERS, INCLUDING WHOLESALERS, RETAILERS, DEALERS,
CUSTOMER SERVICE VENDORS ETC.

As previously indicated, CUSTOMER DATA, PARTNER DATA and VISITOR DATA is

generally collected directly by SWAROVSKI but also indirectly, (e.g. when SWAROVSKI
requests THIRD PARTIES to act as processors, such as SWAROVSKI’s PARTNERS). In
these cases, SWAROVSKI’s PARTNERS process personal data on behalf and under
instruction of SWAROVSKI and are bound by specific processor agreements covering the
terms and conditions of their duties in a manner to ensure the protection of the rights of our
CUSTOMERS, PARTNERS and VISITORS and the processing and security of their personal
data in accordance with applicable data protection laws.

3. NEWSLETTER AND BANNER ADVERTISEMENT

SWAROVSKI may send newsletters or other commercial communications in connection with

its products and services to CUSTOMERS and PARTNERS. In accordance with applicable
law, SWAROVSKI reserves the right to do so without prior consent of existing customers and
business partners. However, the respective CUSTOMERS and BUSINESS PARTNERS may
object to a further mailing of newsletters or other commercial communications at any time
through their account on the respective WEBSITE or through the link indicated in every
mailing. SWAROVSKI reserves the right to place personalized advertisement during
WEBSITE visits. Such banner advertisements displayed to the CUSTOMER contains products
offered on the WEBSITE which have previously been looked at by the CUSTOMER. The
advertisement is generated by SWAROVSKI by the means of cookies (see Section I para. 6
above).

4. SWEEPSTAKES and other PROMOTIONAL ACTIVITIES

The following provisions shall be applicable for the processing of data by SWAROVSKI in
connection with customer SWEEPSTAKES and other PROMOTIONAL ACTIVTIES.

The data in connection with the SWEEPSTAKE and other PROMOTIONAL ACTIVTIES is
processed by (i) the controller of the respective local Swarovski company which sponsors,
promotes and organizes the sweepstake and as the case may be by (ii) Swarovski
Aktiengesellschaft, Dröschistrasse 15, 9495 Triesen, Liechtenstein, as a joint controller. Other
companies and affiliates of SWAROVSKI may however use the collected personal data for
their purposes according to Section I para. 3 above.

With respect to SWEEPSTAKE and other PROMOTIONAL ACTIVITES, SWAROVSKI

processes the personal data of participants according to Section I para. 2 above. for the purposes
listed under that respective provision, and in particular also for the following purposes in
accordance with applicable laws:

• carrying out the competition;

• contacting winners;
• publication of the contact details of the winners
• promoting winners on social media, and
• other promotional and marketing activities.

Further information regarding the SWEEPSTAKE and OTHER PROMOTIONAL

ACTIVTIES can be found in the specific terms and conditions applicable to each
SWEEPSTAKE and PROMOTIONAL ACTIVTIY, as published and organized from time to
time.

III. SPECIFIC PRIVACY NOTICE FOR CUSTOMER PROGRAMS

The provisions in this Section III shall specify the general provisions in Section I regarding
customer programs of SWAROVSKI.

1. SWAROVSKI CRYSTAL SOCIETY (SCS)

The following provisions shall be applicable for the processing of data by SWAROVSKI in
connection with the customer loyalty program Swarovski Crystal Society (SCS).

a. RESPONSIBLE for the Personal Data (Controller)

The PERSONAL DATA in connection with the membership at SCS is processed by two joint
controllers, in particular (i) the controller of the respective local Swarovski company which
issues the membership according to the application form and which receives the membership
fees, and (ii) the controller of Swarovski Aktiengesellschaft, Dröschistrasse 15, 9495 Triesen,
Liechtenstein. Other companies and affiliates of SWAROVSKI may however use the collected
PERSONAL DATA for their purposes according to Section I para. 3 above.

b. Processing of PERSONAL DATA and SOURCE

SWAROVSKI collects and retains the personal obligatory data provided on the SCS applicatio n
form (including but not necessarily limited to the title, name, contact details, birth date, pre-
existing SCS membership number, language preference, order information, as well as the name,
contact details and SCS membership number of the gift giver, where applicable) by the SCS
Member him or herself or by the person that buys the SCS Membership as a gift and provides
SWAROVSKI with the PERSONAL DATA of the SCS Member (“Form Data”).

SWAROVSKI receives such PERONAL DATA from the points of sale where the membership
is ordered and paid. It assigns to each new SCS Member, a unique membership number, tracks
the membership start and renewal dates, service and mailing options chosen by the SCS
Member, services provided (including gifts sent), and, as the case may be, further data about
the SCS Member's use of the Swarovski Group's online offerings and mailings (e.g., newsletter
open rate, click rate, visited online web pages). SWAROVSKI may also process payment
information, directly or through a third party, where necessary for the payment of SCS
Membership fees. Additionally, SWAROVSKI records the purchase history of each SCS
Member, in the form of items purchased (product designation, price) and place and time of
purchase.

The purchase history is recorded only if the SCS Membership number is communicated at the
checkout for purchases in stores offering the SCS program. Where SWAROVSKI believes that
two different SCS Memberships belong to the same individual, or where a valid request is
received, SWAROVSKI may merge them.

c. PURPOSE of processing
SWAROVSKI collects and processes the PERSONAL DATA of members of the customer
loyalty program according to Section I para. 2 above and as specified below for the PURPOSES
listed under that respective provision, and in particular also for the following PURPOSES:

• administration of SCS memberships;

• operation of SCS, namely personalized offers and communications regarding products and
services of SWAROVSKI, providing of advantages and awarding special conditio ns,
participating in surveys, requiring feedback and act in social media.

The PERSONAL DATA collected is used by SWAROVSKI to administer and manage the
Membership (including also for accounting and payment purposes), to provide the Member
with the benefits and other services that come with the Membership (the legal basis for this is
the Membership) and to provide the SCS Member with commercial communications (such as
newsletters, product information, services and exclusive offers of the Swarovski Group) by e-
mail, mail, mobile messaging or a phone call based on the contact information provided by the
Member (for which SWAROVSKI relies on the SCS Member's consent). In all these cases,
SWAROVSKI may personalize the information sent to the Member so that the Member
particularly receives, where possible, information which SWAROVSKI considers interesting
for the Member. For this purpose, SWAROVSKI analyses the Form Data (and in particular,
information as to age, sex, interests and preferences) and other information that can be gleaned
from the purchase history or has been given to SWAROVSKI by the SCS Member voluntar ily
at any later time. Furthermore, SWAROVSKI may use the PERSONAL DATA for complia nce
with its legal obligations and, where it has a legitimate interest, for statistical and research
purposes, including for better understanding of SCS Members, consumer and market analysis,
improvements to the SCS Program and the development of new products and services.

d. DISCLOSURE of Personal Data

In the course of processing PERSONAL DATA in connection with SCS, SWAROVSKI may
namely disclose data to the following categories of recipients:

• PARTNERS, including business, marketing and promotion partners and all participating retail
shops or other authorized specialists dealers, irrespective of whether the company is run by
SWAROVSKI or another sales or cooperation partner; whereas these stores may be located
within any country worldwide and they may use data received from SWAROVSKI only for the
purpose of operating SCS, including personalized offers to and communication with Members
on behalf of SWAROVSKI;

• to a SWAROVSKI company to whom the processing of data (operation of the database)

regarding SCS has been outsourced in technical respect (processors).
Each recipient may be located in a country without an adequate level of data protection. If that
is the case, SWAROVSKI will ensure an adequate level of protection according to Section I
para. 4 above.

e. RIGHTS of Data Subjects

SCS Members and membership gift givers are entitled at any time to ask SWAROVSKI for
information relating to their saved personal data, and other information as provided for by
applicable data protection law. Further information about the RIGHTS of SCS Members is
provided in Section I para. 7 above.
f. DATA RETENTION

PERSONAL DATA will be held and used for the duration of the Membership; thereafter, it
will be retained as long as necessary for the aforementioned purposes, but not for more than
five years, unless required for legal reasons. The purchase history is recorded for five years.
Further information regarding SCS can be found in the General Terms and Conditions of the
customer loyalty program on www.swarovski.com.

2. BE SWAROVSKI
The following provisions shall be applicable for the processing of data by SWAROVSKI in
connection with the customer loyalty program Be Swarovski.

a. RESPONSIBLE for the Personal Data (Controller)

The PERSONAL DATA in connection with the membership of Be Swarovski is processed by

two joint controllers, in particular (i) the controller of the respective local SWAROVSKI
company which issues the membership according to the application form, and (ii) the controller
of SWAROVSKI Aktiengesellschaft, Dröschistrasse 15, 9495 Triesen, Liechtenstein. Other
companies and affiliates of SWAROVSKI may however use the collected PERSONAL DATA
for their purposes according to Section I para. 3 above.

b. Processing of PERSONAL DATA and SOURCE

SWAROVSKI collects and retains the personal obligatory data provided on the Be
SWAROVSKI application form (including but not limited to: title, name and address, and e-
mail address) plus any PERSONAL DATA provided voluntarily by Be SWAROVSKI
Members on the application form: date of birth as well as interests (e.g. in Jewellery and
Accessories, Home and Style, Wedding, Figures and Collectables and/or Watches) (“Fo rm
Data”). In Be Swarovski, SWAROVSKI also saves data on Members’ purchase history in the
form of items purchased (product designation, price, discount), place and time of purchase and
membership number. The purchase history is recorded if the Be Swarovski membership number
is communicated at the checkout for purchases in stores participating in Be Swarovski. In the
online store Members’ purchase history is recorded if the membership number is quoted when
making a purchase or the Member makes a purchase when logged into an online account
associated with a Be Swarovski membership. SWAROVSKI also collects and saves all
vouchers sent to the Be Swarovski Member. Where SWAROVSKI believes that two differe nt
Be Swarovski Memberships belong to the same individual, or where a valid request is received,
SWAROVSKI may merge them.
At the start of their membership, Members receive an email containing a link to an overview of
all currently participating stores in Be Swarovski. This overview of participating stores is also
available to view online at swarovski.com/beswarovski.

c. PURPOSE of Processing

As far as Be Swarovski is concerned, SWAROVSKI namely collects and processes the

PERSONAL DATA of Members of the customer loyalty program according to Section I para.
3 above and as specified below for the PURPOSES listed under that respective provision, and
in particular also for the following PURPOSES:
• administration of Be Swarovski memberships;
• operation of Be Swarovski, namely personalized offers and communications regarding
products and services of SWAROVSKI, providing of advantages and awarding special
conditions (e.g. vouchers), invitations to special events and promotions reserved for members,
participating in surveys, requiring feedback and act in social media.

The PERSONAL DATA collected is used by SWAROVSKI to administer and manage the
membership (including also for accounting purposes), to provide the Member with the benefits
and other services that come with the Membership (the legal basis for this is the Membership).

In participating stores, Be Swarovski allows Members to take advantage of an extended

customer advice in which, upon presentation of the membership number, the store employee
can call up the Member’s purchase history data and provide the Member with additional sales
advice based on his or her past purchases.

On presentation of the Be Swarovski membership number or of an official ID document

together with the Member’s name and date of birth (or another unique authentication attribute),
the relevant store employee has access to the relevant Member’s saved purchase history data.

SWAROVSKI may also use the PERSONAL DATA to invite selected Members to special
events and promotions, such as the presentation of new products or discount promotions. In
addition, SWAROVSKI also uses the PERSONAL DATA to send Members birthday
congratulations.

SWAROVSKI also uses the data collected in the purchase history to grant Members
membership benefits in the form of Discount or Loyalty Gift vouchers. Based on the data saved
in the purchase history, SWAROVSKI evaluates what type of voucher the Member is granted.

If a Member has given SWAROVSKI his or her consent (e. g. by clicking tick box “I agree to
receive commercial communications as per Privacy & Cookies Policy” during be Swarovski
registration), SWAROVSKI may send the Member further information about SWAROVSKI,
product information, services and exclusive offers by e-mail or in any other way chosen by
SWAROVSKI. Should sending of them fall under regulation of Act No. 480/2004 Coll., on
certain Information Society Services and on Amendments to some Acts, as amended, or any
other legislation substituting such law in the future, by granting of Member´s consent (e. g. by
clicking tick box “I agree to receive commercial communications as per Privacy & Cookies
Policy” during be Swarovski registration) the concerned Member voluntarily grants
SWAROVSKI with his or her consent to send to him or her further information about
SWAROVSKI, product information, services and exclusive offers, being the commercia l
communications pursuant to said law, (i) for the term of two years following such a consent is
granted and (ii) via the electronic mail to their email address and/or cell phone number
announced for the purposes of his or her communication with SWAROVSKI. However, the
respective Member may revoke its consent and thus may prevent to a further sending of
commercial communications at any time and free of charge through their account on the
respective WEBSITE or through the link indicated in every mailing or message.

Based on the Form Data and the purchase history reported by participating stores as well as
other information voluntarily disclosed to SWAROVSKI by the Be Swarovski Member,
SWAROVSKI may personalize the information sent to the Member so that the Member
particularly receives, where possible, information which SWAROVSKI seems interesting for
the Member. For this purpose, SWAROVSKI analyses the Form Data collected at the start of
Membership and, in particular, takes account of the saved information relating to age, sex,
interests and preferences, as well as the vouchers received, and other information that can be
gleaned from the purchase history or has been given to SWAROVSKI by the Member
voluntarily at any later time.

d. DISCLOSURE of Personal Data

In the course of processing PERSONAL DATA in connection with Be Swarovski,

SWAROVSKI may namely disclose PERSONAL DATA to the following categories of
recipients:

• PARTNERS, including business, marketing and promotion partners and all participating retail
shops or other authorized specialists dealers, irrespective of whether the company is run by
SWAROVSKI or another sales or cooperation partner; whereas these stores may be located
within any country worldwide and they may use data received from SWAROVSKI only for the
purpose of operating Be Swarovski, including personalized offers to and communication with
Members on behalf of SWAROVSKI;

• to a SWAROVSKI company to whom the processing of data (operation of the database)

regarding Be SWAROVSKI has been outsourced in technical respect (processors).
Each recipient may be located in a country without an adequate level of data protection. If that
is the case, SWAROVSKI will ensure an adequate level of protection according to Section I
para. 4 above.

e. RIGHTS of Data Subjects

Be Swarovski Members are entitled at any time to ask SWAROVSKI for information relating
to their saved personal data, and other information as provided for by applicable data protection
law. Further information about the RIGHTS of Be Swarovski Members is provided in Section
I para. 7 above.

f. DATA RETENTION

PERSONAL DATA will be held and used for the duration of the Membership; thereafter, it
will be retained as long as necessary for the aforementioned purposes, but not for more than
five years, unless required for legal reasons. The purchase history is recorded for five years.

Further information regarding Be Swarovski can be found in the General Terms and Conditions
of the customer loyalty program on www.swarovski.com.
Annex 1 – List of SWAROVSKI Legal entities
Name Address
SWAROVSKI Argentina Sociedad Anónima, Av. Juan B. Justo 637, 4to Piso, CP 1425
Comercial e Industrial Ciudad de Buenos Aire, Argentina
Unit 1, 4D Huntley Street, AU-2015
SWAROVSKI Australia Pty Ltd
Alexandria, NSW
D. SWAROVSKI Distribution GmbH SWAROVSKIstrasse 30, AT-6112 Wattens
D. SWAROVSKI KG SWAROVSKIstrasse 30, AT-6112 Wattens
D. SWAROVSKI Tourism Services GmbH SWAROVSKIstrasse 30, AT-6112 Wattens

Swareflex GmbH Josef-Heiss-Strasse 1, AT-6134 Vomp

SWAROVSKI Austria Vertriebsgesellscha ft
Feldkreuzstrasse 3, AT-6063 Rum
m.b.H.
SWAROVSKI Austria Vertriebsgesellscha ft
Feldkreuzstrasse 3, AT-6063 Rum
m.b.H. & Co. KG
SWAROVSKI Mobility GmbH SWAROVSKIstrasse 30, AT-6112 Wattens

SWAROVSKI Multibrand Distribution GmbH SWAROVSKIstrasse 30, AT-6112 Wattens

S.A. SWAROVSKI Belgium N.V. Nieuwstraat 47, BE-1000 Brussel
Alameda Itú, 852, 8th Floor, BR-01421-001
SWAROVSKI Cristais Ltda.
São Paulo
Alameda Itú, 852, 13th Floor, BR-01421-001
SWAROVSKI Crystal Components Ltda.
São Paulo
80 Gough Road, Unit # 2, CA-L3R 6E8
SWAROVSKI Canada Limited
Markham, ON
Marchant Pereira 150, Region Metropolitana,
SWAROVSKI Chile Limitada
CL-Providencia, Santiago
1063 King's Road, 20th Floor, Quarry Bay,
Signity Hong Kong Ltd
CN-Hong Kong
02-07 Room,17 Floor,Central
SWAROVSKI (Guangzhou) Trading Co. Ltd Tower,No.5,Xiancun
Road,Guangzhou,510623,China
Avendia da Amizade, n 555, Edific io
SWAROVSKI (Macao) Ltd.
Landmark, CN-Macau
168 XiZang Road (M), Room 1601, The
SWAROVSKI (Shanghai) Trading Co. Ltd. Headquarters Building, Huang Pu District,
CN-200001 Shanghai
1063 King's Road, 9th Floor, Quarry Bay,
SWAROVSKI Greater China Limited
CN-Hong Kong
 1063 King's Road, 9th Floor, Quarry Bay,
SWAROVSKI Hong Kong Limited
CN-Hong Kong
3F, No. 27, Chung Shan North Road, Sec. 1,
SWAROVSKI Taiwan Ltd
TW-10441 Taipei
SWAROVSKI Bohemia spol. s r.o. Štětkova 1638/18, CZ-14000 Prague
15 Boulevard de Poissonnière, FR-75002
SWAROVSKI France S.A.S.
Paris
SWAROVSKI (Deutschland) GmbH Hüttenstrasse 27, DE-87600 Kaufbeuren
114, Vouliagmenis av. & 5 Spetson str.,
SWAROVSKI Hellas S.A.
Glyfada, GR-16674 Athen
SWAROVSKI Hungary Retail Limited Liability
Hermina ut. 17, HU-1146 Budapest
Company
Cyber 2 Tower, 31st Floor Unit B, JL HR.
PT Crystallized Elements Rasuna Said, Blok X5 No. 13 Ku - ID 12950
Jakarta
1A-D, Vandhna , 11, Tolstoy Marg, IN-110
SWAROVSKI India Private Limited
001 New Delhi
SWAROVSKI Ireland Limited 70 Sir Rogerson's Quay, IE-Dublin
SWAROVSKI Internazionale d'Italia S.p.A. Via G. Giulini 3, IT-20123 Milano
Daisan Watanabe Building 6F, 2-1-33 Shiba,
Signity Japan Ltd
Minato-ku, Tokyo 105-0014
Name Address
Ichibancho Tokyu Building 12F, 21
SWAROVSKI Japan Ltd.
Ichibancho Chiyoda-ku, Tokyo 102-0082
10,11,12,13F Baekyoung Bldg. 456 Dosan-
SWAROVSKI Korea Ltd
daero, Gangnam-gu, KR-135-949 Seoul
SWAROVSKI Aktiengesellschaft Dröschistrasse 15, FL-9495 Triesen
SWAROVSKI International Distribution AG Dröschistrasse 15, FL-9495 Triesen
Centro Corporativo Plaza Roble, Edific io
SWAROVSKI Global Business Services
Terrazas A, Oficina Regus, 5to piso, San José,
Americas, SRL
Costa Rica
Unit 1.01, GBS@Mayang, Jalan Mahsuri,
SWAROVSKI Global Business Services Asia
Bandar Bayan Baru, 11900 Bayan Lepas,
SDN BHD
Pulau Pinang
SWAROVSKI Global Business Services Sp. Ul. Cypriana Kamila Norwida 5, “Yoko”
z.o.o Building, 80-820 Gdansk, Poland
Suite 19-03, 19th Floor, Menara Keck Seng,
SWAROVSKI Malaysia Trading Sdn Bhd 203, Jalan Bukit Bintang, MY-55100 Kuala
Lumpur
 Av. Ejército Nacional Mexicano No. 579 Piso
SWAROVSKI Crystal SA de CV 11, Col. Granada, Del. Miguel Hidalgo, MX-
11520 Mexico City
SWAROVSKI (Europe) Holding B.V. Dam 6, NL-1012 NP Amsterdam
SWAROVSKI Handelsonderneming Benelux Oosterdoksstraat 80,
B.V. NL-1011 DK Amsterdam
3/45 Queen Street, Auckland 1010 New
SWAROVSKI International (NZ) Limited
Zealand
Crown Tower, ul. Hrubieszowska 2, PL-01-
SWAROVSKI Poland Sp. z o.o.
209 Warsaw
SWAROVSKI Ibérica, S.A - Sucursal EM
Portugal, Lisbon
Dolgorukovskaya street 7,
OOO SWAROVSKI Russia
RU-127006 Moscow
SWAROVSKI Brand License AG Alte Landstrasse 411, CH-8708 Männedorf
SWAROVSKI Immobilien AG Alte Landstrasse 411, CH-8708 Männedorf
Batinska 94, 24000 Subotica
SWAROVSKI Subotica DOO
Republic of Serbia
2 Alexandra Road, # 03-01 Delta House, SG-
SWAROVSKI Management Pte Ltd
159919 Singapore
2 Alexandra Road, # 03-01 Delta House, SG-
SWAROVSKI Singapore Trading Pte Ltd.
159919 Singapore
C/ Llacuna, 10-20, 1a planta,
SWAROVSKI Ibérica, S.A
ES-08005 Barcelona
c/o Matrisen (Redovisning&Rådgivning),
SWAROVSKI Sweden AB
Box 22059, SE-10422 Stockholm
Daniel SWAROVSKI Corporation AG Alte Landstrasse 411, CH-8708 Männedorf
SWAROVSKI (Schweiz) AG Alte Landstrasse 411, CH-8708 Männedorf
SWAROVSKI Crystal Online AG Alte Landstrasse 411, CH-8708 Männedorf
849 Vorawat Building, 16th Floor, Room
SWAROVSKI (Thailand) Limited 1601-1602, Silom Road, Silom Sub-district,
Bangrak District, TH-10500 Bangkok
Abdi İpekçi Cad. No:57 Reasürans Han E
SWAROVSKI Kristal Ticaret Limited Sirketi
Blok Kat:5, TR-34367 Istanbul
Unit 48 Hoults Yard, Walker Road, Newcastle
Chamilia Europe Limited
Upon Tyne, NE6 1AB, England - UK
21 Sackville Street, London, England,
SWAROVSKI International Limited
W1S 3DN
 Roundabout No. 6, P.O. Box 17128, AE-Jebel
SWAROVSKI Middle East FZE
Ali Free Zone, Dubai
1st Floor, Building 4, Chiswick Park, 566
SWAROVSKI UK Limited
Chiswick High Road, GB-W4 5YE London
SWAROVSKI Digital Business USA Inc. 1, Kenney Drive, US-02920 Cranston, R.I.
SWAROVSKI Financial Services Corp. 1, Kenney Drive, US-02920 Cranston, R.I.

Name Address
SWAROVSKI North America Limited 1 Kenney Drive, US-02920 Cranston, R.I.
SWAROVSKI Retail Ventures Ltd. 1 Kenney Drive, US-02920 Cranston, R.I.
Amazar Americas, Inc 1 Kenney Drive, US-02920 Cranston, R.I.
Chamilia, LLC 1 Kenney Drive, US-02920 Cranston, R.I.
Signity Americas Ltd 1 Kenney Drive, US-02920 Cranston, R.I.
61 Industrial Blvd., US-Plattsburgh,
SWAROVSKI Lighting, Ltd
NY 12901
Touchstone Crystal Inc 1 Kenney Drive, US-02920 Cranston, R.I.
Lot 204, Amata IP, Bien Hoa City, Dong Nai
Marigot Vietnam LLC
Province, Vietnam

Countries - Argentina, Australia, Austria, Belgium. Brazil, Canada, Chile, China, Costa Rica,
Czech Republic, France, Germany, Greece, Hungary, India, Ireland, Italy, Japan, Korea
Republic Of, Lichtenstein, Malaysia, Mexico, Netherlands, New Zealand, Poland, Portugal,
Russian Federation, Serbia, Singapore, Spain, Sweden, Switzerland, Thailand, Turkey, United
Arab Emirates, United Kingdom, United States of America, Vietnam.