Data Protection Policy

INTRODUCTION
Rolex and/or “we”, “us” or “our” wishes to offer its customers, as well as interested people who so request, a personalised experience with the Rolex Boutique Genève, Rue de la Fontaine 3, 1204 Geneva, Switzerland, the “Boutique”. In this context, if you have chosen to share certain personal data with us, you may, depending on your preferences, receive marketing communications from the Boutique.

Rolex respects your right to privacy and undertakes to protect your personal data. This Data Protection Policy informs you of how we process your personal data when you visit the Boutique or when you visit the Boutique’s website, the “Site”, whether to make an appointment online or while browsing our Site, irrespective of the location from which you connect. This policy applies exclusively to these two channels and does not cover the rolex.com website, which is governed by its own privacy policy.

We invite you to read this policy, which informs you of your privacy rights and of the protection afforded to you by applicable law.

DATA CONTROLLER
ROLEX SA
3-5-7 rue François-Dussaud
1211 Geneva 26
Switzerland

ROLEX SA identification number: CHE-105.962.823

We act as controller of the personal data collected during your direct interactions with the Boutique or when you use our Site.

We have appointed a Data Protection Officer, hereinafter the “DPO”, responsible for handling matters relating to this Data Protection Policy. If you have any questions concerning the Data Protection Policy, and in particular if you wish to exercise your rights, please contact the DPO using the contact details below:

ROLEX SA, 3-5-7 rue François-Dussaud, 1211 Geneva 26, Switzerland
Telephone: +41 22 302 22 00
Email: privacy@rolex.com

ROLEX SA will respond only to requests relating to data protection. For any other question, requests may be made by contacting the Boutique directly.

SUPERVISORY AUTHORITY
You also have the right to lodge a complaint at any time with the Federal Data Protection and Information Commissioner (FDPIC).

THE DATA WE COLLECT ABOUT YOU
Personal data means any information relating to an individual that enables that individual to be identified. It does not include anonymised data. We collect different categories of data depending on the channel through which you interact with us.

Data collected during your visit to the Boutique
This data is collected directly during your visit to the Boutique, in the event of a purchase or where you express an interest.

Identification data, which may include:

• - Form of address (Mr, Ms, Not specified)
• - Title
• - Surname and first name
• - Date of birth
• - Email address
• - Mobile phone
• - Country of residence
• - Postal address
   

Preference data

• - Communication language
• - Consent to marketing communications
   

Product-related data (for customers who have made a purchase)

• - Reference number and serial number of the watch purchased
• - Date of purchase
   

Consent data

• - Date and time of the collection of your personal data and of your consent in the Boutique
   

Data collected via the Site

Identification and contact data (online appointment booking)

• - Form of address (Mr / Ms)
• - Surname and first name
• - Email address
• - Mobile phone
• - Country of residence
• - City of residence
• - Purpose and preferred date of the appointment
   

Technical data

• - Internet Protocol address (IP)
• - Type and version of browser used
• - Operating system and platform
• - Time zone and approximate location
• - Browser plug-in types and versions
• - Connection data and access logs
   

Usage data

• - Information on how you browse the Site, including pages viewed, duration of visit and browsing path
   

We do not collect sensitive categories of personal data concerning you, such as health data, political opinions, religious or philosophical beliefs, biometric data, data relating to administrative or penal proceedings or sanctions, etc.

HOW IS YOUR PERSONAL DATA COLLECTED?
We collect your personal data through several means, including:

- Direct collection at the Boutique: your personal data is collected directly during your visit to the Boutique. A member of staff enters your data into our internal system after obtaining your explicit consent.

- Other direct interactions: you provide us with your data when you complete the online appointment booking form, or when you contact us by any other means, including by post, telephone, email or otherwise.

- Automated technologies or interactions: when you use our website, we automatically collect technical data about your equipment, activity and browsing patterns. We collect data using cookies, server log files and similar technologies. Please consult our cookie policy for further information.

- Third parties: we collect data about you through third-party service providers, such as providers offering the following services:

• - Hosting and cloud infrastructure providers
• - Analytics tool solutions
• - Appointment booking services
• - Mapping services
   

CIRCUMSTANCES IN WHICH WE WILL USE YOUR PERSONAL DATA AND RETENTION PERIOD
We will retain your personal data only for as long as is reasonably necessary to pursue the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting obligations. We may retain your personal data for a longer period in the event of a complaint or if we reasonably consider that there is a possibility of litigation in connection with our relationship with you.

To determine the appropriate retention period for your personal data, we take into account the quality, nature and sensitivity of the data, the potential risk of harm caused by unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, whether those purposes can be pursued by other means, and any legal, regulatory, tax, accounting or other obligations.

We set out below, in table form, a description of the ways in which we intend to use your data, the legal bases on which we rely in doing so and the retention period. We have also identified our legitimate interests where applicable.

Please note that we may process your personal data on more than one legal basis depending on the specific purpose for which we use your data. Please contact us if you require further information about the specific legal basis on which we rely to process your personal data where more than one basis has been indicated in the table below.

Data collected during your visit to the Boutique

Processing related to the Site and other interactions

CHANGE OF PURPOSE
We will use your data only for the purposes for which we collected it, unless another compatible purpose can reasonably be identified. If we need to use your personal data for different purposes, we will inform you in advance and explain the legal basis that authorises us to do so.

Please note that we may process your personal data without your explicit consent in the cases provided for and authorised by law.

MARKETING
You may consent, during your visit to the Boutique, to receive marketing communications from us.

You may withdraw your consent at any time and request that you no longer receive marketing messages by contacting us. The withdrawal of your consent to marketing communications shall not affect the lawfulness of processing carried out prior to such withdrawal.

If you choose no longer to receive these marketing messages, this choice will not apply to personal data processed for other legitimate purposes, including customer relationship management, legal obligations, etc.

DISCLOSURE OF YOUR PERSONAL DATA

Within ROLEX SA and the ROLEX Affiliates
Your personal data is accessible, to the extent necessary to achieve the purpose of the processing, to our internal teams, including in particular:

- Sales, marketing and communications teams
- IT and security teams
- Compliance and data protection teams
 

Third-party service providers
In order to ensure the best possible experience for you, we may also share your personal data with third-party service providers bound by data processing agreements:

- Hosting and infrastructure providers: to store and manage the data
- Analytics solution providers: to analyse and improve the use of the Site and ensure the effectiveness of our marketing communications
- Logistics service providers: a local logistics service provider may receive your personal data for the dispatch of postal mailings
- Customer support providers: for the handling and resolution of technical requirements that may be linked to the infrastructure and environment of the customer experience
- Auditors and legal advisers: in the context of compliance audits

We require all third parties, in all circumstances, to ensure the security of your personal data and to process it in accordance with applicable law. We do not authorise our third-party service providers to use your personal data for their own purposes and authorise them to process your personal data only for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS
We may share your personal data within the Rolex group of companies. This may involve transferring your data outside Switzerland.

Some of our external third parties are established outside Switzerland, meaning that the processing of your personal data will involve the transfer of such data outside Switzerland.

Whenever we transfer your personal data outside Switzerland, we ensure a similar level of protection by implementing at least one of the following safeguards:

- We will transfer your personal data only to countries that have been considered by the Federal Data Protection and Information Commissioner (FDPIC), as providing an adequate level of protection. You can consult the adequacy lists at www.edoeb.admin.ch or www.pfpdt.admin.ch.

- Where we use certain service providers, we may use specific contracts approved by the Federal Data Protection and Information Commissioner (FDPIC). For further details, please consult www.edoeb.admin.ch or www.pfpdt.admin.ch.

- Where we use providers established in the United States, we may transfer personal data to them if they have adhered to the Swiss-US Data Privacy Framework, recognised as adequate by the Federal Data Protection and Information Commissioner (FDPIC). For further details, please consult the Data Privacy Framework information available at www.edoeb.admin.ch or www.pfpdt.admin.ch.

Please contact us if you would like further information on the specific mechanism we use to transfer your personal data outside Switzerland.

DATA SECURITY
We have implemented appropriate security measures to prevent the accidental loss, unauthorised use or access, and any alteration or disclosure, of your personal data. In addition, we limit access to your personal data to employees, agents, subcontractors and other third parties who have a need to know it for business purposes. These third parties will process your personal data only on our instructions and are subject to a duty of confidentiality.

We have implemented procedures to deal with any suspected personal data breach and will notify you and any competent authority of a breach where we are legally required to do so.

COOKIES AND THIRD-PARTY LINKS
You can configure your browser to refuse all cookies or only certain cookies, or to alert you when websites use or access cookies. If you disable or refuse cookies, please note that certain parts of this website may become inaccessible or may not function properly. For further information about the cookies we use, please click here.

This website may contain links to third-party websites, plug-ins and applications. By clicking on these links or enabling these connections, you may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we recommend that you read the privacy policy of every website you visit.

YOUR LEGAL RIGHTS
In certain circumstances, under applicable data protection law, you have the following rights in relation to your personal data:

- Request access to your personal data — a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to verify that our processing of your data is lawful.

- Request rectification of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.

- Request erasure of your personal data. This enables you to ask us to erase or delete personal data where we no longer have a valid reason to continue processing it. You also have the right to ask us to erase or delete your personal data where you have exercised your right to object to processing, see below, where we have processed your information unlawfully, or where we are required to erase your personal data in accordance with local law. Please note, however, that we may not be able to comply with your request for erasure for specific legal reasons, which will be notified to you, where applicable, in response to your request.

- Object to the processing of your personal data where we rely on a legitimate interest, or on the legitimate interest of a third party, and there is something about your particular situation which makes you wish to object to processing on this basis because you consider that it affects your fundamental rights and freedoms. You also have the right to object to our processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds for processing your information which override your rights and freedoms.

- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following cases:- If you want us to establish the accuracy of the data.

- Where our use of the data is unlawful, but you do not want us to erase it.

- Where you need us to retain the data even if we no longer need it, because you need it for the establishment, exercise or defence of legal claims.

- If you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds.

- Request the transfer of your personal data to you or to a third party. We will provide your personal data to you, or to a third party of your choice, in a structured, commonly used and machine-readable format. Please note that this right applies only to automated information for the use of which you initially provided your consent to us, or where we use the information for the performance of a contract with you.

- Withdraw your consent at any time where we rely on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before the withdrawal of your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will inform you where applicable at the time you withdraw your consent.

- Right not to be subject to automated decision-making. You have the right not to be subject to a decision based exclusively on automated processing of your data if it produces legal effects concerning you or significantly affects you. We do not use this type of process in connection with the Boutique and its website.

If you wish to exercise any of the rights set out above, please contact the DPO at the following email address: privacy@rolex.com

NO FEE IN PRINCIPLE
You will not have to pay any fee to access your personal data, or to exercise any of your other rights. However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. In such circumstances, we may simply refuse to comply with your request.

WHAT WE MAY REQUIRE FROM YOU
We may request specific information from you in order to help us confirm your identity and enable you to exercise your right of access to your personal data, or any of your other rights. This is a security measure designed to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to obtain further information about your request in order to speed up our response.

TIME LIMIT FOR RESPONSE
We try to respond to all legitimate requests within one month. The time required may, however, exceed one month if your request is particularly complex or if you have submitted several requests. In such case, we will inform you of the progress of your request.

YOUR OBLIGATION TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and up to date. Please inform us of any changes to your personal data during your relationship with us.

AMENDMENT OF THIS POLICY
We reserve the right to amend this privacy policy at any time, in particular to reflect changes in our practices, technological developments or amendments to applicable legislation.

Material changes will be notified to you:

• - By email, if we have your email address;
• - By updating this policy with an indication of the revision date.

Minor changes, including drafting corrections and clarifications, shall take effect immediately and shall not be subject to specific notification.

CONTACT
For any question or concern regarding the Data Protection Policy or your communication with Rolex, please contact Rolex in writing or by telephone at:

ROLEX SA
Rue François-Dussaud, 3-5-7
1211 Geneva 26 – Switzerland
+41 22 302 22 00

Email: privacy@rolex.com

For any other question, you may contact the Rolex Boutique Geneva directly.

Rolex Boutique Genève
Rue de la Fontaine, 3
1204 Geneva
+41 22 302 44 44

Date on which this policy was updated: 16 June 2026