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Privacy Policy

This privacy policy (hereinafter, the “Privacy Policy”) explains the policy and the practices of the company AMH INTERNATIONAL SARL, with the brand “HRH Joaillerie”, a limited liability company with a capital of 15000 euros, having its Registered Office at 19 Boulevard de Suisse, MC 98000 Monaco, registered with the Trade and Industry Directory of Monaco under the number RCI No. 17 S 07491 (hereinafter, “HRH Joaillerie”) to collect and ensure the processing of personal data of the users (hereinafter, the “Users”) that are visiting or using the functions and the services offered on the HRH Joaillerie website, accessible from the URL address https://www.hrh.com (hereinafter, the “Site”), in its role as processing manager.

For any questions regarding the protection of the personal data of HRH Joaillerie the User can contact the following address: customerservice@hrh.com.

Any information relating to a User - an identified individual or an individual that can be identified directly or indirectly, by reference to an identification number or to one or more elements which are specific related to him/her (in particular, the surname, name, date of birth, postal address, email address, photograph, curriculum vitae) will be considered as Personal data (hereinafter called “Personal data”).

The Privacy Policy is common to all processes implemented by HRH Joaillerie and is part of the Legal Disclaimer and Terms of Use and the General Terms and Conditions of Sale of which the User acknowledge to be informed and to have accepted.

HRH Joaillerie therefore asks the User to duly make themselves aware of the terms and conditions of the Privacy Policy before any use of the Site and before any communication of their Personal Data.

The Privacy Policy is accessible permanently, except during maintenance periods, to any User from the Site, by clicking on the link entitled “Privacy Policy” appearing at the bottom of the webpages of the Site or in the General Terms of Use.

HRH Joaillerie protects the privacy of its website users by complying with applicable regulations

Therefore, HRH Joaillerie proceed with collecting and processing Personal Data of Users, in accordance with the national and European regulations in force, and in particular the Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 relating to protecting individuals regarding the processing of personal data and to the free circulation of this data (hereinafter, “GDPR”) and the Monegasque law No. 1.165 of 23 December 1993 relating to the protection of nominative information such as modified (hereinafter, “Monegasque law regarding Personal Data”), without prejudice of any provision of the national local law of any User applicable in this regard (hereinafter together, “the applicable Regulations”).

The Privacy Policy explains the policies how HRH Joaillerie uses Personal Data and informs Users of the measures taken by HRH Joaillerie to ensure the protection of Personal Data, in compliance with the applicable Regulations.

1. Collecting Personal Data

To view and visit the Site, the User does not need normally to communicate Personal Data concerning them, except for the Cookies potentially installed in the conditions specified below.

HRH Joaillerie is only likely to collect Personal Data from Users by way of the sections “WISH LIST”, “CLIENT SERVICE”, “PAYMENT”, “REGISTRATION FORM”, “NEWSLETTER FORM”, “ORDER”, in order to ensure the correct monitoring of requests formulated by the User.

Any User wanting to order or to make a reservation from the Site must complete a detailed registration form as provided, by giving information about their identity, a valid email address and confirm their agreement to the General Terms of Use (GCU) and to the General Terms and Conditions of Sale (GTCS), as well as to this Privacy Policy.

During the collection of Personal Data, the User warrants expressly to communicate only complete, correct and updated information, and not cause any damages to the rights of third parties.

2. Purpose and legal basis of processing Personal Data

The processing of Personal Data carried out by HRH Joaillerie is to execute the contract and precontractual measures or the agreement of Users.

HRH Joaillerie processes Personal Data in order to be able to, in particular:

  • send information in line with HRH Joaillerie’s activity;
  • administer profiles and orders from Users through the accounts;
  • manage and monitor payments;
  • carry out operations relating to the promotion of HRH Joaillerie’s activity, including commercial canvassing and managing technical canvassing operations (which in particular includes technical operations like standardisation, enrichment and data deduplication) in compliance with the applicable provisions in force;
  • ensure the management of the requests from the Users and develop the necessary statistics for improving the Site;
  • ensure the management of requests for the guaranteed rights in compliance with the applicable Regulations, in particular rights of access, of correction, of opposition, of portability, of removal and rights of limiting the processing

3. Recipients of Personal Data

HRH Joaillerie is responsible for processing Personal Data of Users such as listed above, in compliance with the applicable Regulations.

Within the limits of their respective activities, the following can have access to all or some of the Personal Data:

  • services responsible for developing the Site, and for promoting HRH Joaillerie’s products and commercial services;
  • services responsible for control (auditor, services responsible for internal control procedures, etc.);
  • subcontractors responsible for ensuring technical services linked to administration, maintenance and hosting the Site, in accordance with the applicable local and European provisions regarding protecting personal data, 
  • subcontractors responsible for ensuring the secure online payment services, in accordance to the applicable Regulations, in particular the company Lyra Network, a simplified joint-stock company with a share capital of 421950 euros, with registered Office at 109 rue de l’Innovation 31670 Labège, registered with the Trade and Company Register of Toulouse under the SIRET number 434 075 719;
  • authority administrations, court officers and ministerial officers.

 

4. Conservation and Security of Personal Data

4.1 Durations of conservation of Personal Data

Generally, the Personal Data are retained for the time strictly necessary to manage the relationship between HRH Joaillerie and the Users. The duration of retaining the personal data depends on the purposes for which data is collected and processed.

Personal Data are retained by HRH Joaillerie for the whole actual duration of using the Site by the User and, if necessary, for a maximum timeframe of 3 years from the User’s last login to his account.

At the end of this 3-year timeframe, HRH Joaillerie can contact the User in order to find out if he wants to conserve his account and continue to receive information in line with HRH Joaillerie’s activity. In case of no response from the User, the Personal Data will be removed or made anonymous in accordance with the provisions of the applicable Regulations.

Personal Data to provide proof of a purchase can however be stored in accordance with the legal provisions in force.

All processing likely to be implemented by HRH Joaillerie is summarised in the table below:

 

Personal Data processing table

 

Purposes Data collected and method of collection Processing manager Legal basis of the processing Duration of conservation Recipients
Management of registration and sending the Newsletter Surname, name, email address, password, year of birth, gender, country, postcode.

Collection done via: the newsletter form available on the website hrh.com
HRH Joaillerie Agreement of concerned users given by sending the registration form and by accepting the GTU and the privacy policy Data is retained for three years from the date of its collection or from the last contact - HRH Joaillerie’s marketing department
- The subcontractor responsible for the processing of registrations and sending of newsletters
Contact – complementary information to customers / visitors of the HRH Joaillerie website Data recorded in the contact form, “CONTACT US” of the customer/visitor on the website  hrh.com, IP address of the visitor, civil status, identity, number of conversations, replies. HRH Joaillerie Agreement of concerned users - Data from the contact form is retained for three years from the date of its collection or from the last contact.
-Other data (number of pages viewed, date and time of the session, browser language, site username, browsing duration, etc.) is retained for one day by the subcontractor, or 12 months for the number of visits on the site or the unique username of the visitor.
- The Marketing department
Recruitment Surname, forename, email address, telephone number

Collection via: form on the site hrh.com 
HRH Joaillerie Agreement of the user given by sending the application and acceptance of the privacy policy and of the GTU Data is retained for the duration necessary for the processing of the application and five years from the last contact - RH Joaillerie’s human resources department
Account – creation of an account on HRH Joaillerie’s online store Surname, forename, email address, password

Collection done via: form on the site hrh.com 
HRH Joaillerie Agreement given formally by the acceptance of the GTU, GTCS and privacy policy Data is retained for three years from the date of its collection or from the last contact - The Marketing department
- The subcontractor making it possible to manage the back office of the website hrh.com 
Order – jewellery purchase via the HRH Joaillerie online store - Surname, name, email address, address, telephone number
- Data relating to the transaction, monitoring the commercial relationship, etc.

Collection done at the time of placing the order via hrh.com 
HRH Joaillerie Execution of the contract As all accounting documents and supporting documents, data is conserved for 10 years. - The Marketing department
- The subcontractor for managing orders (payment platform)
- The subcontractor making it possible to manage the back office of the website hrh.com
- Logistics specialist
Statistics for measuring audience Information stored in the terminal of web users (cookies, for example) or any other element used to identify web users and making it possible to trace web users (analytical web tool)

Collection done on HRH Joaillerie’s official sites via the cookies
HRH Joaillerie Agreement of the web user given formal by the acceptance of the cookies via a banner Data is retained by default on the analytical web tool for 13 months as of the acceptance - Marketing department
- Google
- The subcontractor making it possible to analyse web management

 

4.2 Security measures

HRH Joaillerie commits to taking all suitable measures, to preserve the confidentiality and security of Personal Data, and to protecting them against any loss, misappropriation, unauthorised disclosure, alteration or destruction.

The IT systems used to conserve Personal Data are equipped with a software protection device. Physical and electronic safeguarding procedures for data collected from the Site are implemented, in compliance with the French and European legislation relating to the protection of Personal Data.

HRH Joaillerie’s employees, who, because of their role, would have access to Personal Data, commit to the highest level of confidentiality in this regard.

The personal account of each User is only accessible by using login usernames, such that only the User has access to Personal Data appearing on his profile.

The User commits to providing the Company with correct and reliable information and the Company cannot be held responsible in the event where the information provided proves to be false or incomplete.

The User is solely and fully responsible for the use and confidentiality of his username and his password and must ensure that only people authorised by him have access to his account. In this regard, any use of the User’s account is considered to have been made by him or with his authorisation.

The User must notify, as soon as possible, of any security failure linked in particular to the unintentional communication or to the misappropriation of his username and/or his password, such that the suitable measures in view of overcoming this failure can be taken. In case of loss or misappropriation of the username and/or the password, a procedure for allocating new access codes will be implemented as soon as the notification by the User has been received by HRH Joaillerie.

HRH Joaillerie recommends the User to log out of his account and to close the browser’s window used for his session on the Site.

Moreover, the User is informed that HRH Joaillerie has entrusted the securing of its payment system to the company Lyra Network, a provider specialising in securing online payments, which guarantees a total confidentiality of Users’ banking information, secured by the SSL protocol, which systematically controls the validity of rights of access at the time of the payment by the User’s bank card and encrypts all exchanges in order to guarantee their confidentiality. For more information on the security and confidentiality measures applied, Users are asked to view the Personal Data Protection Charter of the company Lyra Network, accessible at the following address: https://lyra.com/fr/base/charte-rgpd/ or its page, “Network GDPR FAQ”, accessible at the following address: https://lyra.com/fr/base/faq-rgpd-network/.

  • Users’ Rights

In accordance with the applicable Regulations, Users have, at any time, the right to access, to correct, a to remove the Personal data and a right to limit the processing of their Personal Data.

Users have the right to request the removal as soon as possible of their Personal Data collected when the User was a minor at the time of the collection.

Users have the right to withdraw their agreement at any time to the processing parties as implemented by HRH Joaillerie following this agreement.

Users have the option to have transmitted all their Personal Data in a structured format in the case where they would wish to transfer it to another processing manager.

Users can, at any time, modify and revoke the directives relating to the stockage, the removal and the communication of their Personal Data after their death.

Users are informed that HRH Joaillerie has no recourse to an automated processing of their Personal Data, including the profiling, nor to the transfer of their Personal Data outside of the territory of the European Union without suitable guarantees being implemented in accordance with the applicable Regulations.

To exercise these rights and to obtain this information, all the User needs to do is to make their request to HRH Joaillerie. To enable HRH Joaillerie to reply to the User’s request, the User must send the necessary elements to identify him; their name, first name(s), address and email address, by email to the following address: customerservice@hrh.com or by post to the following address:

HRH Joaillerie

Customer Service

7, rue du Gabian,

MC 98000 Monaco

PLEASE NOTE: timeframes for processing User requests will be necessarily increased if said request is made by letter, due to the material and technical limitations.

Any User has also the option to forward a complaint to the ‘Commission de Contrôle des Informations Nomitaves’, the Monegasque authority regarding Personal Data (www.ccin.mc) or any competent control authority in virtue of his national law.

5. Specific information relating to the use of Cookies

5.1 HRH Joaillerie can be led to install cookies on the hard disk of the User’s computer (i.e. a file containing information on the browsing done by the User on the pages of the Site). This can be cookies which will not allow to identify the User, but that are recording a certain number of information necessary for the User’s browsing on the Site (browsing language, date and time of viewing, pages viewed, etc.) or Google Analytics cookies making it possible to identify the User (geographic information by means of the IP address). During the User’s visits afterwards on the Site, HRH Joaillerie can read the cookies installed, in particular to make it possible and/or to facilitate the User’s browsing experience on the Site. The site tracks anonymous cookies with third parties including Google Analytics, Google Ads, Hotjar, Facebook & instagram, Woopra etc, to better improve the customer experience.

You can define your cookie preferences by changing your browser settings to prevent the Site cookies from being saved on your device.

5.2 As of the first visit to the Site, the User is informed of the Privacy Policy and must agree to the installation of the different cookies.

The User’s agreement is required as of his first visit to the Site ran by HRH Joaillerie.

5.3 Functional cookies: In order to facilitate the use of the Site’s functions, HRH Joaillerie installs technical cookies, such as:

  • persistent personalisation cookies of the User’s interface;
  • “basket” cookies for the e-commerce Site https://www.hrh.com;
  • “session ID” cookies for the duration of a session;
  • authentication cookies;
  • session cookies created by a multimedia player.

HRH Joaillerie informs the User that they can, at any time, refuse the recording of technical cookies on the hard disk of his computer by correctly configuring their web browser. In that case, the use of the Site risks to be deteriorated, or even impossible.

For any information on the methods of configuring web browsers, the User should view the help menu of the browser, please find here below the links of the most used browsers:

5.4 Social media: HRH Joaillerie offers the option for the User to view its pages on social media by means of buttons (Facebook, LinkedIn and Instagram).

The social media plugins made available on the Site use cookies which allow to trace Users’ browsing, independently of the fact that they are registered with the social media or that they are logged into their personal account on the social media Site. The cookies as implemented also make it possible for the editors of different social media to target advertising offers on their respective platforms.

In this regard, HRH Joaillerie exercise no control over the processing of Personal Data possibly operated by the editors of different social media platforms, which remain solely responsible for its own processing, except for the processing of the specific configurations done by HRH Joaillerie on these social network platforms, for which HRH Joaillerie is jointly responsible for the processing.

HRH Joaillerie asks the User to view the general terms of use, as well as the respective privacy policies of the social media platforms beforehand, if the User wants to use the buttons made available to them to access the social media platforms.

5.5 Audience measurements: On the Site www.hrh.com, HRH Joaillerie uses cookies and Google Analytics proprietary identifiers made available by the company Google Inc.

The Google Analytics audience measurement tool allows a better understanding of the Users behaviour, by collecting anonymous information and by generating reports on statistics of the Sites’ use.

In particular, HRH Joaillerie has activated a Google Analytics function making it possible to obtain reports on Users’ demographic data and areas of interest, in order to propose a suitable commercial offer meeting the needs of the Customer.

The processing of data generated by Google Analytics cookies can entail the transfer and the storage (including temporary) of the data on the servers of the company Google Inc. located in the United States. In this regard, HRH Joaillerie exercises no control over the processing and recommends the User to view the general terms of use as well as the privacy policy of the company Google Inc. beforehand.

In case the User refuses that data will be collected via the Google Analytics tool, they can deactivate the Google Analytics advertising functions including, via the parameters of advertisements, the parameters of advertisements for mobile phones or any other means available (for example, via the deactivation page of the Network Advertising Initiative or NAI).

The User has also the option to download and to install the complementary module for deactivating all the Google Analytics functions made available to the public by the company Google Inc. at the following URL address: https://support.google.com/analytics/answer/181881?hl=fr.

5.6 If the User agrees to it, HRH Joaillerie is likely to install cookies of a directly commercial type from time to time, in a one-off manner during web marketing operations.

5.7 In accordance with the applicable Regulations, the duration for conserving these cookies cannot exceed 13 months after the first depositing on the User’s terminal.

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6. HRH Joaillerie accounts opened on Social Networks

In order to promote its activity and to share updates to the general public, HRH Joaillerie is the owner of a dedicated account on various social media platforms (Facebook, LinkedIn and Instagram). The User can access, follow and comment on what HRH Joaillerie is doing, under the general terms of use and under the personal data policy in force on these social networks.

Consequently, the User acknowledges that it is his responsibility to view, directly and beforehand, the conditions of access, the follow-up and the sharing of the content on these social media platforms. HRH Joaillerie cannot be held responsible for the processing of Personal Data implemented by the editors of these social media platforms, except for the processing of the specific configurations done by HRH Joaillerie on these social network platforms, for which HRH Joaillerie is jointly responsible for processing.

7. Updating the Privacy Policy

HRH Joaillerie is likely to modify the Privacy Policy according to the developments of the applicable Regulations, as well as its activity.

Any substantial modification of the Privacy Policy will be notified to the Users, by any means, prior to the entry into force of these new provisions.