Personal Information Processing Rules

 

The "RIMOWA" brand is operated and distributed in Mainland China by RIMOWA GmbH, having its registered office at Richard-Byrd-Strasse 13, 50829 Cologne, Germany, and RIMOWA International SAS, having its registered office at 24-32 rue Jean Goujon, 75008 Paris, France (hereinafter referred to as "RIMOWA" or “We/Our/Us”). According to the relevant laws and regulations of the People’s Republic of China, we are honored and obliged to provide information about the processing of personal information in accordance with the relevant laws and regulations of the People’s Republic of China.

The Personal Information Processing Rules (hereinafter referred to as the "Processing Rules" or the "Rules") are designed to give users (or “you”) a clear understanding of how we collect and use your information, our commitment to protecting your information, and the options you have for managing your information and your privacy.

The Processing Rules apply to the products and services related to online channels such as websites, APPs and social application Mini-Programs provided by us to you, as well as all activities (for example: product review, information browsing) related to the RIMOWA products and services, etc. At the same time, we will revise and update the Processing Rules from time to time in accordance with the update requirements of applicable laws and regulations or the needs of business changes. If you use our online shopping, membership registration and other services, please carefully read the Personal Information Processing Rules disclosed then. Where there is any discrepancy between the Rules and the agreement/rules expressly you agreed to at that time, such agreement/rules shall prevail.

Last updated: [November, 1st], 2021.

If you have any questions, comments or suggestions, please contact us according to the contact information in Article 10 below.

The Processing Rules will help you to understand the following:

1. How do we collect and use your personal information

2. How do we share, transfer, and publicly disclose your personal information

3. How do we protect your personal information

4. How do you manage your personal information

5. How do we deal with the personal information of children (referring to minors under the age of 14)

6. How does your personal information transfer globally

7. How do we store your personal information

8. Cookies Policy

9. How does the Rules update

10. Contact us

Please read and understand the Processing Rules carefully before using our services. If you choose to use our services, it means that you fully understand all the contents of the Processing Rules, and agree that we collect, store, use, process, transmit, provide, publicly disclose, and delete your personal information in accordance with the Processing Rules. If you do not agree to the Processing Rules or any part of it, please stop using our services immediately.

  1. How Do We Collect and Use Your Personal Information

a. Necessary information for us to provide you services

b. In addition to the information necessary for us to provide you with services, we may, subject to your authorization and consent, process other information for the purpose disclosed to you at that time, including:

c. Information collected through third parties, including:

We may collect information about you (including personal information) provided by other parties when using our website, or obtain information from other channels, and integrate it with the information we collect through website services. We will not control, supervise, or respond to how the third party that provides your information handles your personal data. Any information request for the disclosure of your personal information sent to us should be sent directly to such third party.

The user can choose whether to provide the information for free, and the use of such information is subject to the user’s consent. Refusal to provide such information will result in our inability to continue to fulfill this purpose.

  1. How Do We Share, Transfer, and Publicly Disclose Your Personal Information
  1. Share

We will not share your personal information with any company, organization or individual, except in the following situations and other situations that you have specifically agreed to:

  1. - We may share your personal information with external parties in accordance with laws and regulations, or mandatory requirements of government authorities;
  2. - Sharing with our affiliated companies or business partners: we may share anonymous, integrated information related to our consumers with our affiliates or our business partners, for example, for trend analysis;
  3. - In addition, your personal information can also be processed by the following companies:

We will agree in written agreement with the above companies on the purpose, duration, method of processing, types of personal information, protection measures, rights and obligations of both parties and will supervise their personal information processing activities.

The collected data can also be processed by independent third-party data controllers, such as:

The complete list of third parties that process personal information as independent third-party data controllers, as well as the contact information, processing purpose, processing method and types of personal information, can be obtained by contacting us at any time through the contact information published in Article 10 of the Rules.

  1. - The situation in which we share personal information to third parties by accessing third-party codes, plug-ins, and interfaces is explained as follows:

Purposes of Processing Personal Information

Types of Personal Information Processed

To answer questions and queries sent via the “Contact us” form available on the Website, per e-mail or via service telephone

Information given in the contact form or by e-mail, IP address and date/time of the request

To compile statistics and marketing analysis following your visits to the RIMOWA Website

Your browsing behavior such as cookies, your IP address, service log information, social network ID

To perform direct marketing, to manage retargeting devices and suggest targeted advertising

Contact details, your navigation data, service log information and other information provided on the website

To send you information on our offers, products, latest news and events (newsletters, invitations to events organised by RIMOWA, including private sales and other news publications)

Your information collected upon subscription to the newsletter, event or other

Technical provision of the Website

Your navigation data, service log information and other information provided on the website

We will sign strict confidentiality agreements with the companies, organizations and individuals with whom we share personal information, requiring them to process personal information in accordance with our instructions and any other relevant confidentiality and security measures. In addition, we will also carry out personal information protection impact assessment, and only start sharing behavior after the assessment is qualified.

  1. Transfer

We will not transfer your personal information to any company, organization or individual, except in the following cases:

1Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

  1. - In the event of a merger, division, liquidation or bankruptcy involving transfer of personal information, we will require the new company or organization that holds your personal information to continue to be bound by the Processing Rules, otherwise we will require the company or the organization re-seeks authorization and consent from you.

  1. - Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

  1. - After obtaining your explicit consent;

2Disclosure based on the law: We may publicly disclose your personal information when required by law, legal procedures, litigation, or compulsory government authorities.

  1. How Do We Protect Your Personal Information
  1. - We are committed to protecting your personal information. We have adopted appropriate technical measures and organizational settings, including encryption, to protect your personal information and security, set positions and responsibilities, and conduct regular inspections and compliance audits. We combine physical and information technology security control measures to protect your personal information, including access control, to limit and manage the processing, management, and method of use of your personal information and data. We also ensure that our employees receive appropriate training in the protection of personal information.
  2. - Your account is secured by security protection function, please keep your account and password information properly. We will take security measures such as backing up to other servers and encrypting your password to prevent your information from being lost, abused and altered to the greatest extent possible. Despite the aforementioned security measures, at the same time, please understand that there is no "perfect security measures" on the information network. We cannot promise the complete security of your data and information, especially to remind you to stay away from telecommunications and network fraud, stay away from network illegal network activities, and properly keep your financial accounts and network accounts safe, and avoid any damage caused by  illegal acts.
  3. - In order to respond to personal information security incidents, we will perform reporting and notification obligations in accordance with the requirements of laws and regulations, including: the basic situation and possible impact of the security incident, the handling measures we have taken or will take, suggestions for you to prevent and reduce risks, remedial measures for you, etc. Where applicable, we will promptly inform you of the relevant circumstances of the incident by email, letter, telephone call, push notification, etc. If it is difficult to inform the subjects of personal information one by one, we will take a reasonable and effective way to release the announcement. Meanwhile, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

  1. How Do You Manage Your Personal Information

    1. - Consult, duplicate, change, and delete your personal information. You have the right to consult, duplicate, change, and delete your personal information, subject to the exceptions provided by laws and regulations. You also have the right to request the transfer of personal information, provided that it complies with the law. To exercise the aforesaid rights or require us to make an explanation, please contact us through the contact information published under Article 10 of the Rules.

    1. - Withdraw consent and change the scope of consent

We process your personal information on the basis of consent. You can revoke your consent at any time by changing your account settings, sending us unsubscribe message, or contacting us through the contact information published under Article 10 of the Rules, stating which consent you wish to revoke. Unless otherwise required by law, upon revocation of your consent, we will no longer process the corresponding personal information. This decision will not affect the previous processing of personal information based on your authorization.

With respect to the collection and use of the information you choose to submit, you may change the scope of your consent. You may do this by contacting us.

    1. Cancel your relevant account

If you have a registered account, you may contact us at any time via the contact information published under the Personal Information Processing Rules applied at that time, and we will respond to your cancellation request within 15 working days.

After the account is cancelled, we will stop providing you with products or services based on the account and delete or anonymize your personal information according to your request, unless otherwise provided by laws and regulations.

  1. How Do We Deal With the Personal Information of Children (referring to minors under the age of 14)

Our products or services, and corresponding websites, do not target children. We will not collect any personal information from children without the consent of their guardians.

If you are a child, please do not provide us with any of your personal information. If you are a child, but voluntarily and must use our products or services, please make sure your guardians read the Rules carefully, and you will use our products or services and provide us personal information with the consent of your guardians.

If we find that we have collected children’s personal information without the prior consent of a verifiable child’s guardian, we will delete the relevant data in accordance with the law.

  1. How Does Your Personal Information Transfer Globally

In order to ensure the consistency of global business strategies, service standards and network systems, we need to provide your personal information cross-border to relevant entities, including RIMOWA GmbH and RIMOWA International SAS, its parent company, subsidiaries, affiliates, companies under the same control, or companies in the same group as RIMOWA. You may contact us at any time through the contact information published under Article 10 hereof with respect to the names and contact information of these entities.

We will perform the necessary procedures in accordance with the law and take necessary measures to ensure that the recipient meets the standards of protection stipulated by applicable laws and regulations. If expressly required by applicable laws, we will perform security assessment, certification or enter into a standard contract for the cross-border transfer of personal information, and determine whether to continue cross-border transfer of your personal information and whether to apply desensitization technologies in accordance with applicable laws.

  1. How Do We Store Your Personal Information (data retention period)

Data collected for the purposes set out in Article 1 a. shall be stored by RIMOWA GmbH and RIMOWA International SAS for the period necessary for the performance of the Contract and subject to legal and traditional safeguards or mandatory legal provisions on data storage.

Data collected for the purposes set out in Article 1 b) and c) will be stored until such time as the user withdraws his/her consent to process his/her personal data or requests deletion or our purpose of processing has been achieved.

  1. Cookies Policy

For users of the "RIMOWA" official channel, please note that we can store "Cookies" on your computer to identify you. Cookies are small data text files sent from a server computer during browsing. Cookies are usually stored on the computer's hard drive, and websites use Cookies to simulate a continuous connection. We have taken relevant security measures to prevent unauthorized access to user data. However, the user confirms that we cannot control the transfer of data on electronic communication facilities (including the Internet). Therefore, we will not take any responsibility for the security breaches or unauthorized disclosure or use of such data on the Internet. You may set your browser to refuse to accept Cookies, but doing so may prevent you from taking full advantage of our services.

  1. How Does the Rules Update

The Rules are updated on the date stated at the top of the page.

When the applicable laws and policies change, or our products or service functions undergo major changes, our processing rules may change. However, without your explicit consent, we will not mitigate your rights under the Rules.

For major changes to the Rules, we will provide prominent notifications (including sending such notifications via e-mail, station mail, or pop-up windows, etc.).

  1. Contact Us

If you have any questions, comments, suggestions, concerns, complaints or reports concerning the content of the Rules or how we process your personal information, please contact us by the following manner:

1Contact information of person in charge of personal information protection: [dataprotection@rimowa.com]

2Customer service: [contact@rimowa.com]

 

The "[RIMOWA]" brand is operated and distributed in Mainland China by RIMOWA GmbH, having its registered office at Richard-Byrd-Strasse 13, 50829 Cologne, Germany, and RIMOWA International SAS, having its registered office at 24-32 rue Jean Goujon, 75008 Paris, France (hereinafter referred to as "RIMOWA" or “We/Our/Us”). According to the relevant laws and regulations of the People’s Republic of China, we are honored and obliged to provide information about the processing of personal information in accordance with the relevant laws and regulations of the People’s Republic of China.

The Personal Information Processing Rules (hereinafter referred to as the "Processing Rules" or the "Rules") are designed to give users (or “You”)  a clear understanding of how we coll  ect and use your information, our commitment to protecting your information, and the options you have for managing your information and your privacy.

The Processing Rules apply to the products and services related to online channels such as websites, APPs and social application Mini-Programs provided by us to Users, as well as the products and services provided by our offline stores, and all activities (for example: online membership registration; online purchase and after-sales; participation in brand activities; pushing product and event information; sending event invitations) related to the RIMOWA products and services, etc. At the same time, we will revise and update the Processing Rules from time to time in accordance with the update requirements of applicable laws and regulations or the needs of business changes.

Last updated: [November, 1st], 2021.

If you have any questions, comments or suggestions, please contact us according to the contact information in Article 10 below.

The Processing Rules will help you to understand the following:

1. How do we collect and use your personal information

2. How do we share, transfer, and publicly disclose your personal information

3. How do we protect your personal information

4. How do you manage your personal information

5. How do we deal with the personal information of children (referring to minors under the age of 14)

6. How does your personal information transfer globally

7. How do we store your personal information

8. Cookies Policy

9. How does the Rules update

10. Contact us

Please read and understand the Processing Rules carefully before using our services. If you choose to use our services, it means that you fully understand all the contents of the Processing Rules, and agree that we collect, store, use, process, transmit, provide, publicly disclose, and delete your personal information in accordance with the Processing Rules. If you do not agree with the Processing Rules or any part of it, please stop using our services immediately.

  1. How Do We Collect and Use Your Personal Information

  1. Necessary information for us to provide you service

You agree that in order to provide you better services, we may collect and process other information for the purposes set out in b) and c) below:

  1. Statistical analysis of data and user characteristics of e-commerce website may be conducted through third-party services. We will use the relevant personal information within the scope of your authorization and take necessary security protection measures in accordance with the law. The third-party data processing must comply with relevant provisions of the Chinese laws and regulations in response to the request for prior inspection submitted by "RIMOWA".

  1. To provide personalized sales services or automatically recommend products and send information to users, such as but not limited to the following methods: personal shopping service, online recommendation service, free assistance service and concierge service, sending information related to brand works, exclusive sales and events, or similar events organized or participated in by "RIMOWA" (including potential invitations to participate in such events) via phones, letters, emails, text messages and multimedia messages, social networks and instant messengers, and used for sending a questionnaire to assess the level of satisfaction achieved with the services provided. If you are unwilling to accept such information, you can unsubscribe according to the method provided in the message received.

Other information includes:

  1. Information collected through third parties

We may collect information about you (including personal information) provided by other parties when using our website, or obtain information from other channels, and integrate it with the information we collect through website services. We will not control or supervise the third party who provides your personal information, or respond to the inquiry how  it processes your personal information. Any information request for the disclosure of your personal information sent to us should be sent directly to such third party.

For the purposes set out in Article 1 a), if the user does not provide personal data, we cannot continue to provide the requested services including notification, reservation, appointment, after-sales, consultancy and other services.

For the purposes set out in Article 1 b) and c) above, the user can choose whether to provide the information for free. Refusal to provide such information will result in our inability to continue to fulfil such purpose.

  1. How Do We Share, Transfer, and Publicly Disclose Your Personal Information
  1. Share

We will not share your personal information with any company, organization or individual, except in the following situations and other situations that you have specifically agreed to:

  1. We may share your personal information with external parties in accordance with laws and regulations, or mandatory requirements of government authorities;
  2. Sharing with our affiliated companies or business partners: we may share anonymous, integrated information related to our consumers with our affiliates or our business partners, for example, for trend analysis;
  3. In addition, your personal information can also be processed by the following companies:

We will agree in written agreement with the above companies on the purpose, duration, method of processing, types of personal information, protection measures, rights and obligations of both parties and will supervise their personal information processing activities.

The collected data can also be processed by independent third-party data controllers, such as:

The complete list of third parties that process personal information as independent third-party data controllers, as well as the contact information, processing purpose, processing method and types of personal information, can be obtained by contacting us at any time through the contact information published in Article 10 of the Rules.

  1. The situation in which we share personal information to third parties by accessing third-party codes, plug-ins, and interfaces is explained as follows:

Purposes of Processing Personal Information

Types of Personal Information Processed

To enable you to create a “MyRIMOWA" customer account on our Website

Registration data, IP address

To answer questions and queries sent via the “Contact us” form available on the Website, per e-mail or via service telephone

Information given in the contact form or by e-mail, IP address and date/time of the request

To compile statistics and marketing analysis following your visits to the RIMOWA Website

Your browsing behavior such as cookies, your IP address, service log information, social network ID

To perform direct marketing, to manage retargeting devices and suggest targeted advertising

Contact details, your navigation data, service log information and other information provided on the website

To send you information on our offers, products, latest news and events (newsletters, invitations to events organised by RIMOWA, including private sales and other news publications)

Your information collected upon subscription to the newsletter, event or other

Technical provision of the Website

Your navigation data, service log information and other information provided on the website

We will sign strict confidentiality agreements with the companies, organizations and individuals with whom we share personal information, requiring them to process personal information in accordance with our instructions and any other relevant confidentiality and security measures. In addition, we will also carry out personal information protection impact assessment, and only start sharing behavior after the assessment is qualified.

  1. Transfer

We will not transfer your personal information to any company, organization or individual, except in the following cases:

  1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
  2. In the event of  a merger, division, liquidation or bankruptcy involving transfer of personal information, we will require the new company or organization that holds your personal information to continue to be bound by the Processing Rules, otherwise we will require the company or the organization re-seeks authorization and consent from you.

  1. Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

  1. After obtaining your explicit consent;
  2. Disclosure based on the law: We may publicly disclose your personal information when required by law, legal procedures, litigation, or compulsory government authorities.

  1. How Do We Protect Your Personal Information
  1. We are committed to protect your personal information. We have adopted appropriate technical measures and organizational settings, including encryption, to protect your personal information and security, set positions and responsibilities, and conduct regular inspections and compliance audits. We combine physical and information technology security control measures to protect your personal information, including access control, to limit and manage the processing, management, and method of use of your personal information and data. We also ensure that our employees receive appropriate training in the protection of personal information.
  2. Your account is secured by security protection function, please keep your account and password information properly. We will take security measures such as backing up to other servers and encrypting your password to prevent your information from being lost, abused and altered to the greatest extent possible. Despite the aforementioned security measures, at the same time, please understand that there is no "perfect security measures" on the information network. We cannot promise the complete security of your data and information, especially to remind you to stay away from telecommunications and network fraud, stay away from network illegal network activities, and properly keep your financial accounts and network accounts safe, and avoid any damage caused by  illegal acts.
  3. In order to respond to personal information security incidents, we will perform reporting and notification obligations in accordance with the requirements of laws and regulations, including: the basic situation and possible impact of the security incident, the handling measures we have taken or will take, suggestions for you to prevent and reduce risks, remedial measures for you, etc. Where applicable, we will promptly inform you of the relevant circumstances of the incident by email, letter, telephone call, push notification, etc. If it is difficult to inform the subjects of personal information one by one, we will take a reasonable and effective way to release the announcement. Meanwhile, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

  1. How Do You Manage Your Personal Information

    1. Consult, duplicate, change, and delete your personal information. You have the right to consult, duplicate, change, and delete your personal information, subject to the exceptions provided by laws and regulations. You also have the right to request the transfer of personal information, provided that it complies with the law. To exercise the aforesaid rights or require us to make an explanation, please contact us through the contact information published under Article 10 of the Rules.

    1. Withdraw consent and change the scope of consent

We process your personal information on the basis of consent. You can revoke your consent at any time by changing your account settings, sending us unsubscribe message, or contacting us through the contact information published under Article 10 of the Rules, stating which consent you wish to revoke. Unless otherwise required by law, upon revocation of your consent, we will no longer process the corresponding personal information. This decision will not affect the previous processing of personal information based on your authorization.

With respect to the collection and use of the information you choose to submit, you may change the scope of your consent. You may do this by contacting us.

    1. Cancel your relevant account

You may contact us at any time via the contact information published under Article 10 of the Rules, and we will respond to your cancellation request within 15 working days.

After the account is cancelled, we will stop providing you with products or services based on the account, and delete or anonymize your personal information according to your request, unless otherwise provided by laws and regulations.

  1. How Do We Deal With the Personal Information of Children (referring to minors under the age of 14)

Our products or services, and corresponding websites, do not target children. We will not collect any personal information from children without the consent of their guardians.

If you are a child, please do not provide any of your personal information to us. If you are a child but voluntarily and necessarily use our products or services, please make sure that your guardians read the Rules carefully, and you will use our products or services and provide us with personal information with your guardian's consent.

If we find that we have collected children’s personal information without the prior consent of a verifiable child’s guardian, we will delete the relevant data in accordance with the law.

  1. How Does Your Personal Information Transfer Globally

In order to ensure the consistency of global business strategies, service standards and network systems, we need to provide your personal information cross-border to relevant entities, including RIMOWA GmbH and RIMOWA International SAS, its parent company, subsidiaries, affiliates, companies under the same control, or companies in the same group as RIMOWA. You may contact us at any time through the contact information published under Article 10 hereof with respect to the names and contact information of these entities.

We will perform the necessary procedures in accordance with the law and take necessary measures to ensure that the recipient meets the standards of protection stipulated by applicable laws and regulations. If expressly required by applicable laws, we will perform security assessment, certification or enter into a standard contract for the cross-border transfer of personal information, and determine whether to continue cross-border transfer of your personal information and whether to apply desensitization technologies in accordance with applicable laws.

  1. How Do We Store Your Personal Information (data retention period)

Data collected for the purposes set out in Article 1 a) shall be stored by "RIMOWA GmbH" and "RIMOWA International SAS" for the period necessary for the performance of the Contract and subject to legal and traditional safeguards or mandatory legal provisions on data storage.

Data collected for the purposes set out in Article 1 b) and c) will be stored until such time as the user withdraws his/her consent to process his/her personal data or requests deletion or our purpose of processing has been achieved.
 

  1.  Cookies Policy

For users of the "RIMOWA" official channel, please note that we can store "Cookies" on your computer to identify you. Cookies are small data text files sent from a server computer during browsing. Cookies are usually stored on the computer's hard drive, and websites use Cookies to simulate a continuous connection. We have taken relevant security measures to prevent unauthorized access to user data. However, the user confirms that we cannot control the transfer of data on electronic communication facilities (including the Internet). Therefore, we will not take any responsibility for the security breaches or unauthorized disclosure or use of such data on the Internet. You may set your browser to refuse to accept Cookies, but doing so may prevent you from taking full advantage of our services.

  1. How Does the Rules Update

The Rules are updated on the date stated at the top of the page.

When the applicable laws and policies change, or our products or service functions undergo major changes, our processing rules may change. However, without your explicit consent, we will not mitigate your rights under the Rules.

For major changes to the Rules, we will provide prominent notifications (including sending such notifications via e-mail, station mail, or pop-up windows, etc.).

  1. Contact Us

If you have any questions, comments, suggestions, concerns, complaints or reports concerning the content of the Rules or how we process your personal information, please contact us by the following manner:

1Contact information of person in charge of personal information protection: [dataprotection@rimowa.com]

2Customer service: [contact@rimowa.com]

or

Email address of the brand: [hello@rimowa.com]