Privacy Statement 1 November, 2019

TW STEEL WEBSITES PRIVACY STATEMENT

When you use this website, we may process your personal data, in accordance with this privacy statement. TW Steel Europe B.V. or TW Steel Store B.V. (also "TW Steel" or we/us/our) is the data controller in respect of this processing of your personal data within the meaning of the General Data Protection Regulation. This Privacy Statement is designed to help you understand how we use your personal information. We may change this privacy statement from time to time.

PERSONAL DATA; WHICH DATA AND WHY?

When using our website, you share with us certain information or leave certain information behind. For example, this might be the case when placing an order, when you subscribe to a newsletter or when you indicate that you wish to receive information regarding TW Steel watches.

The personal data we might collect and process from our website are:
- your name, date of birth, gender, email and (billing and shipping) address of individuals;
- company name, chamber of commerce file number and VAT number, if relevant;
- payment information;
- your (mobile) telephone number;
- which product(s) you ordered;
- your correspondence with TW Steel, if any;
- behavior data (online movement, use of the internet and the length of your session); and
- IP addresses and time stamps.

We may use this personal date for the following purposes:
- to properly process and fulfil any orders placed assessment and acceptance of our business partners;
- to analyse and/or improve the quality and quantity of information our products, (customer) services and websites;
- to fine tune our correspondence with regards to deliveries and refunds;
- to send information, offers and promotions based on your interest and click and surf behavior;
- to answer questions asked through, for example, the website;
- to provide news and information regarding TW Steel, new products and services;
- to be able to provide the customer with a personal account on our website;
- to allow you to connect with our social media accounts;
- research on the level of satisfaction of the customers, business partners or others; and
- internal analysis for (consumer) research purposes.

We may analyse your personal information to create a profile of your interests and preferences so that we can tailor and target our communications in a way that is timely and relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. This allows us to be more focused, efficient and cost effective with our resources and also reduces the risk of someone receiving information they may find inappropriate or irrelevant.

We may also use data about how you use our website to prevent or detect fraud, abuse, and illegal uses and to comply with court orders, governmental requests or applicable law.

The personal data we might collect and process if you apply for a job at TW Steel are:
- your name, date of birth and gender;
- resume details;
- contact details: telephone number, email and address.

The personal data you provide in your application for a job vacancy at TW Steel and as part of the recruitment process will only be held and processed to facilitate the selection process and in connection with any subsequent employment. We process your personal data for this purpose as a preparatory step to possibly entering into an employment contract with you. If you are not selected, we will keep your personal data to contact you for any new job applications, if we think it could be a match. For this purpose, we process your personal data based on your consent.

HOW LONG WILL INFORMATION BE KEPT?

We shall store and process your personal data for as long as we believe would be necessary to fulfil the purposes for which we collected such personal data. Nevertheless, we shall not retain your personal data for a period exceeding five years, unless applicable law requires otherwise, This does not consider (anonymous) information in relation to statistic purposes.

In case we receive your personal data when you apply for a job opening at TW Steel, we will hold your data for no longer than 12 months. In the event of your application resulting in the offer and your acceptance of a position at TW Steel, the data collected will become part of your employment record and will be used for employment purposes.

THIRD PARTIES

Your personal data may be transferred within the TW Steel group and shared with companies working under the brand TW Steel. Such information may be exchanged for us to have a complete overview of your information. We might share your personal data with the following third party service providers processing personal data on behalf of TW Steel Europe B.V.:
1. media agencies and technical suppliers for distribution of physical and digital direct marketing and TW Steel product promotions,
2. companies to validate your address, communication agencies to send you order confirmation, warehouse and distribution suppliers in connection with the delivery of your order, payment service providers for your payment,
3. debt collection agencies,
4. research and analysis agencies for our internal data analysis purposes.

BROWSER SESSIONS AND IP ADDRESS

We use the IP address of your computer. This IP address is a number that is automatically assigned to your computer during a browsing session. The IP address of your computer can be used to see how websites are used and for the preparation of analyses.

COOKIES

As indicated in the cookie banner on our website, TW Steel makes use of various types of cookies on our website. In this section we explain what kinds of cookies these are, what they are used for and how you can adjust your browser settings to accept or refuse cookies.

Permission

According to European law, you have to give permission for the use of cookies. This cookie policy explains which cookies these are. You can accept our cookies in two ways: by closing the cookie notification you see on your first visit, or simply by continuing on our website.

You continue on our website (and thus agree to the placement of all cookies) by clicking on any part of the TW Steel web pages or by browsing other pages on the TW Steel website.

What are cookies?

A cookie is a small text file that is placed on your computer during a visit to a website. Information is saved in this text file. This information can be read by the website or by third parties on a later visit. Some of the cookies are necessary for the website to function properly. Other cookies are used to increase the user-friendliness of the site for visitors or to show targeted advertisements on, for example, our social media channels. A JavaScript is a program that is placed on the user’s peripheral devices and executed by them. The execution of this program allows TW Steel to establish the location of the visitor and which actions they perform. This gives TW Steel greater insight into the behavior of its visitors.

Deleting or disabling cookies

Browsers may accept or reject cookies automatically but allow you to change these settings. The help menu on most browsers will tell you how to change your browser setting as to cookies, how to have browser notify you when you receive a new cookie and how to disable cookies al together. You can also disable or delete cookies you have previously accepted if you wish to. To find out how to manage cookies on the following browsers, follow the provided link: - Google Chrome
- Microsoft Internet Explorer
- Apple Safari
- Mozilla Firefox

Which types of cookies does TW Steel use, and what for?

The cookies used by TW Steel can be divided into different categories:

Functional cookies

This category of cookies is necessary to ensure the proper functioning of the website. They ensure, for example, that information from one page is carried over to the next. This means you don’t have to repeatedly fill in the same information. These cookies also ensure that certain preferences that you’ve indicated for the use of the website (such as language settings) are retained. Your prior consent is not required for the use of these cookies.

Analytical cookie

These cookies are necessary to align our website as well as possible with the wishes of our users, by determining how our visitors use our website. We use Hodjar, Google Analytics, GA Audiences, Pinterest Conversion Tracker and AB Tasty. Hodjar keeps track of where you click on our sites. This means we can optimise these pages to display the most relevant information in the best places. With Google Analytics, we measure the way you use our website and how you found us. We use this information to improve our site. We test any changes to our sites first by using AB Tasty. For more details about the cookies that these parties place and the data that can be collected with them, we refer below to the statements by these parties. Your consent is not required for the use of these cookies.

Marketing cookies

With Google Analytics, Adwords, YouTube and Adroll cookies, we measure how you use the TW Steel website. We use this information to help you choose the product that suits you the best and to show you offers for products you may be interested in during remarketing campaigns. We use Facebook & Instagram cookies to see which products you view. This enables us to show you relevant advertisements on Facebook and Instagram.

For more details about the cookies that these parties place and the data that can be collected with them, we refer below to the statements by these parties. Your consent is required for the use of these cookies: Google, Facebook & Instagram and Adroll.

Social Media (plugin) cookies

You can share the content on our website with social media parties by using buttons (go-to links). For more details about the cookies that these social media parties place when you click on the buttons, we refer to the statements of these parties. Your consent is required for the use of these cookies: Facebook, Instagram and Pinterest.

Changes to the cookie policy

From time to time, we may make changes to this cookie policy without notifying you, for example because the website or the cookie regulations have changed. Changes will take effect immediately after these have been published on the website. We therefore advise you to consult our cookie policy regularly in order to remain informed about any changes and, if desired, to change the settings. By continuing to use this website, you agree to any changes to the cookie policy.

Do you want to stop cookies?

If you do not want us to use cookies then you can easily stop them. Also, you are able to turn on your notifications to become aware of when cookies are used. For this, you will have to adopt the appropriate settings on your browser.

YOUR RIGHTS; WITHDRAWAL, ACCESS, CORRECTION AND REMOVAL

You are entitled to be obtain free-of-charge information concerning data stored about your person and, as the case may be, to correct, restrict the processing, enable the portability of, or delete those data. If you have any questions about how we collect, process or use your personal data, want to enquire about, correct, block or delete your data, or withdraw any consents you have given, or opt-out of any particular data use, please send an email to us by using the email address stated under Customer Service.

You may also submit a complaint to the responsible data protection supervisory authority, if you believe that we have not respected your rights.

EMAIL ADVERTISING: UNSUBSCRIBE AND RIGHT TO OPT-OUT

E-mail advertising if you do not subscribe to the newsletter and your right to opt out.

If we receive your e-mail address in connection with the sale of a product or service and you have not opted out, we reserve the right to regularly email you offers for products from our product range that are similar to those you have already purchased.

You can opt out of this use of your email address at any time by sending a message to the contact option specified below or by using the opt-out link in the advertising email, without incurring any costs beyond the cost of transfer calculated at the base rates.

E-mail advertising if you subscribe to the newsletter.

If you subscribe to our newsletter, we will regularly send you our e-mail newsletter based on your consent, using the data required or disclosed by you separately for this purpose.

You may unsubscribe from the newsletter service at any time. For this purpose you can either send a message to the contact option specified below or use the opt-out link in the newsletter. Upon unsubscription, we will delete your email address unless you have expressly consented to the further use of your data or we reserve the right to further use your personal data in the scope and manner permitted by the law, of which we inform you in this notice.

PROTECTION AND MANAGEMENT OF YOUR PERSONAL DATA

We use a variety of security measures, including encryption for account passwords and authentication tools, to maintain the safety of your personal data. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems. The personal data of customers we collect or generate and process in the context of our website will be stored.

UNSUBSCRIBE (TO NEWSLETTERS)

We will send you information about TW Steel, our products that are the same or similar to those that you have ordered from us and/or other information of which we believe that you will find useful. If you no longer wish to receive any information about TW Steel, you can at any time follow the unsubscribe instructions included in each marketing email that you receive from TW Steel.

DATA PROTECTION AUTHORITY

We will be happy to assist you with any complaints which you may have about the processing of your personal data. However, please note that you also have the right to file a complaint with the Data Protection Authority if you believe that we do not comply with applicable privacy law.

ADJUSTMENTS TO THIS PRIVACY STATEMENT

The type of personal data that we need and the purposes we need such personal data for may change over time. Therefore, we reserve the right to amend our privacy statement at any time. The most up-to-date version of this privacy statement is published on our website and will apply upon publication on our website.

If you have any further questions about our privacy statement, please contact us by using the information stated above under Customer Service

SECURITY DISCLAIMER

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information whilst it is in transit over the internet and any such submission is at your own risk. All we can do is use all our reasonable efforts to safeguard your personal data and ensure that we maintain a reliable and safe environment to use your personal data. It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal data if you use a shared computer or a computer in a public place.

Our website may use cookies stored on your computer by your browser. A cookie is a small and simple text file stored on your computer. You can adjust your browser settings so that you do not receive cookies when you visit our website, however please note that if you do this you may not be able to use the full functionality of this website. For example, our 'Storelocator' which allows you to search for retailers, detects and uses you browser settings to direct you to the relevant local retailers.

GOOGLE ANALYTICS

This website also uses cookies by means of Google analytics, a web analytics service provided by Google, Inc. ("Google"). These cookies generate information about your use of this website (including your IP address), which Google uses for the provision of services in the field of user statistics and analysing website use. The information referred to will be transmitted to and stored by Google on servers in the United States. Google may transfer the collected information to third parties where required to do so by law, or where such third parties process the information on Google's behalf (as sub-data processors). Google will not associate your IP address with any other data held by Google.

OTHER WEBSITES AND SOCIAL MEDIA

Our website may contain hyperlinks to third-party websites, including social media platforms. We are not responsible for the data processing and privacy policies on such websites. We may also display content originating from social media platforms on our own website. Please note that such social media content is automatically collected and not reviewed by us.

INTERNATIONAL USERS

This website is operated, in whole or in part, from the Netherlands. You understand that, regardless of where you live in the world, when you use this website your personal data may be processed in the Netherlands.

QUESTIONS OR REQUESTS

Any questions or requests relating to your personal data as well as any request to cancel your registration for services offered by TW Steel can be sent by e-mail: info@twsteel.com. To modify or delete the information you have provided during registration or to unsubscribe from mailings, please follow the instructions included in any e-mail you receive.

Please also find our other (contact) details below.