Ahmed Seddiqi & Sons

Privacy Notice

Introduction

Ahmed Seddiqi & Sons LLC, a subsidiary of Seddiqi Holding LLC, a company incorporated under

the laws of the United Arab Emirates (“UAE”) with registered office at P.O. Box 2123 (“Company",

"we" or “us” or “Seddiqi”), is the leading retailer for luxury watches and jewelry in the UAE

(together the “Services”). We take your privacy seriously and are committed to safeguarding your

personal information at Seddiqi. We value you and respect your privacy and are committed to

protecting it through our compliance with this Notice.

This Privacy Notice (“Privacy Notice” or “Notice”) covers the personal information that Seddiqi

may collect or receive from you to provide or facilitate provision of the Services. This Notice

outlines what our purpose and practices are for collecting, processing, using, maintaining,

retaining, protecting, and disclosing your personal information.

What personal information do we collect about you?

Personal information you give us

We primarily collect personal information with your permission, or to process your requests, such

as to register your enquiries, process your payments, issue invoices, or any other activities

necessary to provide the Services. We only collect the minimum amount of personal information

required to conduct operational activities, process your requests, and manage our relationship

with you. The personal information we collect may include:

Information you provide to us to process your payment and invoice for the Services such
as name, email address, credit card information.
Information you provide to us by filling our online form for enquiries as provided on our
website (www.seddiqi.com), which may include personal information such as name,
email, mobile number, and any other personal information you include in the heading or
body of your enquiries.
Records and copies of your correspondence (including e-mail addresses) when you
contact us.
Information that you provide when you contact our contact centre.
Information that you provide when you visit any of our stores or office locations.
Information that you provide when you contact us via email, SMS, social media, web
chats, web forms, WhatsApp chats, or directly call our customer experience team for
general enquiries, complaints, request for support services. This information may include
your name, email address, mobile number, and call recordings (in case you call our
customer experience team).
Personal information captured on documents you provide to us for processing your
payments, invoicing, Anti-Money Laundering (AML) compliance, Value Added Tax (VAT)
refund, or other service requests, including information captured on your passport, visa,
Emirates ID, and any other documentation you provide to us.

Sensitive personal information we collect may include:

Family information: if you provide information regarding your family, we may process

such information to effectively manage your customer account with us.

If you are a representative of any of our partner brands and joint ventures, we may collect

and process minimal personal information about you, which may include:

Information that you provide through correspondence including name, business address,
contact number, and email address.
Professional details including employment information.

Other Information We Collect:

When you visit our website, we may collect information about your use and navigation of
the website, such as IP address and other device identifiers, browser type, and
information about the website pages you visit. For more information, please refer to the
cookies notice to understand the personal information collected and how it is processed
using cookies and similar tracking technologies.
Information obtained through any system operated for the purpose of security and safety
(such as, CCTV) when you visit any of our stores, office locations, or facilities.

What are the sources of your personal information?

The sources of your personal information may include without limitation the following:

Emails, text messaging services, and other electronic messages, phone calls:
These are the electronic text-based or voice interactions between you and Seddiqi.
Seddiqi customer service: Any communication between you and our customer
experience team (e.g., phone, chatbot, email, etc.).
Data we create: Seddiqi may also create data about you, when you purchase the
Services, such as customer account creation.
Data from documents you share with us: Seddiqi may access, use, and process
personal information contained in documents you share with us for providing the Services
to you such as your Emirates ID, passport copy.
CCTV cameras: CCTV footage (image and video) from CCTV cameras placed in our
stores and office locations, or facilities.
Onsite enquiries and registration: This include enquiries, requests, and registrations
that are done physically at any of our stores or office locations. This may also include
information you share with Seddiqi staff at any of our stores or other Seddiqi managed
premises when you make product enquiries or purchase a product.
We may access personal information about you from third-party sources and platforms
(such as social networking websites, online marketing firms, and ad targeting firms) to the
extent permitted by law.
If you access third-party social networking services (such as Facebook, Twitter) and
search or inquire about us or the Services, we may collect your contact information
and/or any personal information that is part of your public profile on the third-party social
network. You can learn more about the data that we may obtain about you by visiting the
privacy notices on the website of the relevant third-party social network.

This Notice does not apply to the following –

Personal information collected by any third-party website or platform that is not directly
managed by Seddiqi, even if such website or platform advertises the Services. Please
refer to the privacy notice of such website/platform for information on the personal
information being collected and for what purposes.
Personal information collected and processed in the context of any other relationship
(beyond being a customer or partner brand of Seddiqi) you might have with other
subsidiaries or affiliates of Seddiqi Holding LLC. e.g., as an employee, contractor, or
tenant. Please refer to the privacy notice issued for such relationships for information
about how your personal information is collected and processed.

Why do we collect and how do we use your personal information?

For our customers and prospects:

We collect and use personal information for several legitimate purposes, including providing and

improving the Services, registering enquiries, for processing payments, generating invoices, AML

compliance checks, processing VAT refund, and managing our relationship with you:

To create and manage your customer account with us:

Your personal information may be collected and processed to register and create a customer

account for you when you make your first purchase or update your customer account when you

make subsequent purchases or when you show interest in our products. We do this to facilitate

provision of the Services. We collect and process your personal information based on contractual

necessity and in pursuit of our legitimate interests to improve the quality of the Services.

To provide, develop, and improve the Services:

We may use your personal information to perform essential business operations including the

following:

For generating invoices for your purchases pursuant to our legal obligation to do so. For
purchases that meet the threshold prescribed by law, to fulfill Anti-Money Laundering
(AML) compliance obligations, as required by applicable law, which may require that we
collect additional information such as source of funds.
To process Value Added Tax (VAT) refund upon your request in fulfillment of our legal
obligation to do so.
To process refund/exchange requests we may receive from you based on our contractual
obligation to do so.
To analyze trends and market insights based on our legitimate business interests to
monitor and improve the performance of the business.
To activate your product warranty (as applicable) based on our contractual obligation to
do so.
To manage delivery of products to you based on our contractual obligation to do so.

To send gifts and special invitations

We may process minimal personal information (such as name, email address) to send you

personalized gifts to celebrate your special occasions (such as birthdays and wedding

anniversaries). We process personal information based on our legitimate interests to enhance our

relationship with you.

We may also process your personal information (such as name and contact information) to invite

you to events organized by us or any of our affiliates and business partners. We process your

personal information based on our legitimate interests to improve our relationship with you.

For complaint and enquiries management

We would need to collect and use your personal information (such as name, e-mail address,

phone number, and details of your complaint/enquiry) to respond to complaints, queries, and

enquiries we receive from you. Additionally, when you call our customer experience team, we

may maintain a record of the communication, including call recordings, in pursuit of our legitimate

interests to monitor and improve the quality of our support services to you.

To provide product repair services

If you request the watch and jewelry repair services provided through our affiliate business, Swiss

Watch Services (SWS), we may collect and share certain personal information (such as name,

email address, phone number) with SWS to facilitate provision of the repair services. We collect

and process this information to fulfill our contractual obligation to provide the repair service to you.

To process any special requests made by you

If you make any special requests regarding the Services, such as purchase of special pieces, we

may process your personal information (including sharing with our partner brands) to determine

your eligibility, obtain special approvals, manage the request, and provide you with a response on

the request. We process this information based on your consent.

For Email & SMS Marketing

We may occasionally send you marketing communications regarding products you have shown

interest in, or other similar products based on our legitimate business interests. You may choose

to “Opt-out” from receiving these communications at any time by following the instructions

provided in “How to Opt-out?” section.

To provide promotions, discounts, and other benefits

We may collect and use personal information (such as name, email address, phone number) to

on our legitimate business interests to enhance customer experience.

To maintain security within our premises and keep the public safe

We may need to process your personal information obtained through any system operated for

security, safety, and access management (CCTV, access control), visitor and contractor

management when you visit any of our stores, office locations, or facilities. Security records may

include ID copies for visitor and contractor management, access logs, image, video, license

plates, etc. from any of the security systems operated in our stores, office locations, facilities. We

collect and process such information pursuant to our legal obligation to maintain security, ensure

public safety, and to ensure compliance with local laws and regulations.

To comply with legal requirements and exercise or defend legal claims:

We may need to process and retain your personal information to comply with legal or regulatory

requirements to which we are subject. This may include sharing your personal information with

relevant government authorities as may be required. We may also process your personal

information where it is necessary for the purpose of exercising and defending legal claims.

To comply with any opt-out or do not disturb requests we receive from you:

We understand that you may not want us to contact you with any offers, promotions or details of

our products and services. If you opt-out, we may be required to maintain information such as

name, email ID/contact number and the subscription(s) that you have opted out of to ensure

compliance with your requests. Also, in the future, if you wish to hear from us, you may at any

time contact us to opt-in and we would be happy to keep you posted about events, offers,

promotions, and/ or details of our products and services that we believe you may be interested in.

For our Partner Brands:

We may collect and process certain personal information (such as, name, contact information) of

representatives of our partner brands for the following purposes:

To conclude onboarding formalities:

We may collect minimal personal information (such as name and email) about brand

representatives to conclude onboarding of our partner brands. We collect and process personal

information for this purpose based on contractual necessity.

For managing our relationship with our brands:

We may process personal information of our brand representatives to effectively manage our

relationship with the brand, specifically for the following purposes:

For managing and purchasing stock pursuant to our contractual obligation.
For analyzing market trends and insights pursuant to our legitimate interests to monitor and
improve performance of the business.
For managing opening and closure of stores in fulfillment of our contractual obligations.
For sending invites for special events pursuant to our legitimate interests.
To send seasonal holiday greetings pursuant to our legitimate interests to promote our
relationship with our partner brands.

How to opt out?

Email: You can click on the unsubscribe link provided in the email you receive from us.
SMS: you can follow the instructions provided in the messages you receive from us.
Data Privacy Office Notice: you may write to privacy@seddiqi.com regarding the specific
processing activity(s) that you would like to opt out of. Our Data Privacy Office will get in
touch with you to facilitate the request accordingly.
Contact us: you may contact us using the details provided in Section - ‘How do you
contact us?’.

Who might we share this information with?

We may disclose personal information that we collect, or you provide as described in this Privacy

Notice:

We may share your personal information with members of Seddiqi, including subsidiaries,
affiliates, and holding companies as well as brand partners to enable provision of the
Services, understand your preferences, and conduct the other activities described in this
Privacy Notice. Such group companies and brand partners are in UAE Mainland, Abu
Dhabi Global Market (ADGM), Kingdom of Saudi Arabia (KSA), and the EU. If you require
more information, please feel free to write to us at privacy@seddiqi.com and our Data
Privacy Office would be happy to assist you with the same.
We may use carefully selected third parties to perform services on our behalf or to assist
us with the provision of the Services to you. For example, we may engage third party
cloud service providers, IT service providers, concierge and security service providers,
courier service providers to facilitate deliveries, marketing, advertising, and
communications service providers, website developers to maintain the Seddiqi website,
cloud service providers to store data, and other third parties to personalize and optimize
our services, to analyse and enhance data (including data about users' interactions with
our services), and to provide legal, accounting, insurance, audit and /other professional
services. While providing such services, these third parties may have access to your
personal information. Personal information shared with third parties is obligated by
contractual agreement to ensure they exercise the same care when handling personal
information as we do ourselves.
We may provide your personal information to government agencies, government officials,
regulators, and law enforcement agencies to comply with applicable law, regulation,
government directive, court order, or legal process.
We may share to a buyer or other successor in the event of a merger, divestiture,
restructuring, reorganization, dissolution, or other sale or transfer of some or all the
Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or
similar proceeding, in which personal information held by the Company about our
customers and brand representatives is among the assets transferred. We may share
with other companies and organizations for the purposes of fraud protection if we believe
disclosure is necessary or appropriate to protect the rights, property, or safety of the
Company, our customers, or others.

Data Storage

The personal information that we collect from you through our interactions with you is stored at a

destination within the UAE and through our authorized cloud service providers.

International Transfers

Personal information we collect may be transferred to, stored, and processed in UAE or KSA

where one or more members of Seddiqi are located or maintain facilities. We will continue to

protect the personal information we transfer in accordance with this Privacy Notice. We will take

all steps that are reasonably necessary to ensure that your personal information is treated

securely and in accordance with this Privacy Notice and applicable data protection laws.

we carry out such transfers to facilitate the provision of the Services and in pursuit of our legitimate

business interests to serve you better. We have implemented adequate safeguards to protect and

secure the personal information involved in such transfers. Where we transfer personal

information outside of UAE Mainland, ADGM, or KSA, we either transfer personal information to

countries/ territories that provide an adequate level of protection (as determined by the relevant

authorities) or we have appropriate safeguards in place. Appropriate safeguards to cover these

transfers are in the form of standard contractual/data protection clauses as adopted by the

relevant data protection authorities. If you would like more information on protection measures

and transfer mechanisms, please contact us using the details provided in Section - ‘How do you

Data Retention

Personal information is not kept any longer than is required for the legitimate purposes of the

processing or to comply with applicable law. As we collect personal information for different

purposes, there is not a single retention period for all personal information. We will only keep

your personal information for as long as is reasonably necessary, taking into consideration our

need to answer queries or resolve problems, any other purpose outlined above or to comply with

legal requirements under applicable law(s). This means that we may retain your personal

information for a reasonable period. In certain cases, we may retain your personal information for

a longer period where extended retention periods are required by law or regulation and to

establish, exercise or defend our legal rights. For more information on where and how long your

personal information is stored, and for more information on your rights of erasure and portability,

please contact us using the details provided in Section - ‘How do you contact us?’.

Data Security

The security of your personal information is an important concern to us. We provide the utmost

care in secure transmission of your personal information from your computer and other electronic

devices to our servers. We use industry standard security controls to safeguard the confidentiality

of your personal information and to make sure that your personal information is secure with us.

We have implemented and maintained appropriate technical and organizational security

measures, policies, and procedures to protect your personal information from accidental loss,

unauthorized access, use, alteration, and disclosure. All information you provide to us is stored

on our secure servers behind a secure network. All payment transactions are encrypted.

Examples of measures we take include:

Imposing confidentiality obligations on our staff and service providers.
Restriction of access to your personal information to employees and third parties strictly
on a need-to-know basis, such as to respond to your enquiry or request.
Using secure communication channels for transmitting personal information.
Employing adequate administrative and technical controls to secure personal information.

What are your rights?

Varying on the jurisdiction, certain privacy laws allow you to exercise rights that have been

provisioned to the residents of such jurisdiction to provide control over your personal information.

If you wish to exercise any of the rights provisioned to you (noted below), we may ask you for

additional information to confirm your identity for security purposes, before disclosing personal

information to you. We shall aim to respond to all requests within a reasonable time in line with

applicable laws. If we require additional time due to the complexity of the request, we shall

promptly inform you of the same. We reserve the right to charge a fee, where permitted by law,

for example, if your request is found to be manifestly unfounded or excessive.

If you would like to exercise the below rights, you may send a request to us at

privacy@seddiqi.com. We may not always be able to fully address your request, for example,

if it would impact the confidentiality we owe to others, or
if we are legally entitled to deal with the request in a different way, or
if your request involves deletion of information that is required to comply with legal
requirements.
The section below provides the data privacy rights you have towards your personal information:

The right to access

You have the right to obtain confirmation as to whether we process personal information about

you, receive a copy of your personal information held by us, and obtain certain other information

about how and why we process your personal information (like the information provided in this

Privacy Notice).

The right to rectification

You have the right to request amendment or update of your personal information (for example, if

you change your name) and to have incomplete personal information completed.

The right to restrict processing

You have the right to restrict our processing of your personal information in the following cases:

Temporarily for a period when you have contested the accuracy of the personal
information;
Temporarily for a period when you have objected the legitimate interest identified by us;
Where your personal information has been unlawfully processed and you request the
restriction of processing instead of deletion; and/or
Where your personal information is no longer necessary in relation to the purposes for
which they were collected and processed but the personal information is required by you
to establish, exercise, or defend legal claims;

We can continue to use your personal information following a request for restriction, where:

we have your consent; or
to establish, exercise or defend legal claims; or
to protect the rights of another natural or legal person.

The right to erasure (also known as 'the right to be forgotten')

You have the right to request the deletion of your personal information in the following cases:

Personal information is no longer necessary in relation to the purposes for which it was
collected and processed.
Our lawful basis for processing is consent. If you withdraw consent, we have no other
lawful basis for the processing.
Our lawful basis for processing is that the processing is necessary for a legitimate
interest pursued by us. If you object to our processing and we do not have overriding
legitimate grounds.
You object to our processing for direct marketing purposes.
Your personal information has been unlawfully processed.
Your personal information must be erased to comply with a legal obligation under UAE
Law to which we are subject.

We are not required to comply with your request to erase personal information if the processing of

your personal information is necessary:

For compliance with a legal obligation; or
For the establishment, exercise, or defense of legal claims.

The right to object

You have the right to object to our processing of your personal information if our lawful basis for

processing is that the processing is necessary for a legitimate interest pursued by us, and our

processing is for direct marketing purposes.

The right to data portability

You have the right to receive your personal information provided to us and have the right to send

the data to another organization (or ask us to do so if technically feasible) where our lawful basis

for processing the personal information is consent or necessity for the performance of our

contract with you and the processing is carried out by automated means.

The right to withdraw consent at any time (where processing is based on consent)

Where we process personal information based on your consent, you have a right to withdraw

consent at any time. You can withdraw your consent by following the instructions provided in

“How to Opt-out” section.

The right to lodge a complaint with a data protection authority

You have the right to lodge a complaint with the local data protection authority in your country or

residence in which an alleged infringement of data protection law has occurred.

We sincerely hope that you will never need to, but you may, at any time, discuss your concerns

with us by contacting us in one of the ways mentioned in Section 14 - ‘How do you contact us?’.

We will closely review and ensure a timely response to any complaints we receive.

Children’s Privacy

We do not knowingly solicit or collect personal information from children under the age of 18

without prior verifiable parental consent. If we learn that a child under the age of 18 has submitted

personal information without parental consent, then we will take all reasonable measures to

delete such information from our databases and to not use such information for any purpose

(except where necessary to protect the safety of the child or others as required or allowed by

law). If you become aware of any data we have collected from children under 18, you may

Updates on Notice

This Notice may change from time to time. Your continued use of the Services and our platforms

after we make changes is deemed to be acceptance of those changes; please check this notice

periodically for updates.

How do you contact us?

In case of any queries related to this Notice, you can contact our Data Privacy Office by emailing

us at privacy@seddiqi.com