Privacy Policy

PRIVACY NOTICE 

SWAROVSKI ALUMNI NETWORK

Last modified on October 2023

This Privacy Notice describes the collection and further processing of personal data by companies of the Swarovski Group and its affiliates (together SWAROVSKI) with regard to the SWAROVSKI ALUMNI NETWORK.

For the collection and further processing of personal data by SWAROVSKI in general, or with regard to specific applications (e.g. online-shop, newsletter and banner advertisement on www.swarovski.com ) as well as provisions related to customer programs, please visit www.swarovski.com and read the “Privacy Policy”.

1. RESPONSIBLE FOR THE PERSONAL DATA (CONTROLLER)

Every website (including online-shops and mini sites for special offers), every presence on social media, multimedia portals, chatbots and every application of SWAROVSKI (each a WEBSITE) has a controller within SWAROVSKI with respect to collecting personal data according to the EU General Data Protection Regulation (GDPR), the Swiss Data Protection Act or comparable provisions according to applicable data protection laws.

The Controller of the PERSONAL DATA collected and processed in connection with the SWAROVSKI ALUMNI NETWORK is Swarovski International Holding AG, Alte Landstrasse 411, CH-8708 Männedorf, Switzerland.

Other companies and affiliates of SWAROVSKI may however use the collected personal data for their purposes. For more information, please visit www.swarovski.com and consult SWAROVSKI Privacy Policy. If you have any questions about data protection in connection with our website or the services offered on it beyond the data protection information published here, please contact the Group Data Privacy Team at dataprivacy@swarovski.com or the other contact points mentioned in Section 2 below.

2. HOW TO CONTACT SWAROVSKI

Any queries or concerns about our privacy policy or the processing of your personal data can be addressed to the Group Data Privacy Team at dataprivacy@swarovski.com .

If you reside in the United States, please visit the Privacy Policy here (https://swa-public-us-east-1.s3.amazonaws.com/20230301_Swarovski_Employee_Privacy_Notice_Final+United+States.pdf) for any queries you might have in relation to the processing of your personal data.”.

If you reside in Canada, please visit the Privacy Policy here (https://www.swarovski.com/en_GB-CA/s-dataprotection/Privacy-Policy/ ) for any queries you might have in relation to the processing of your personal data.

The representative for all SWAROVSKI companies and affiliates domiciled outside of the EU or EEA is D. Swarovski Distribution GmbH, Legal Department, Swarovskistrasse 30, AT-6112 Wattens (pursuant to Article 27 of the GDPR).

3. LEGAL GROUNDS AND PURPOSES OF THE PROCESSING OF PERSONAL DATA 

SWAROVSKI collects and retains required and voluntary provided Personal Data of SWAROVSKI Alumni registering and using the SWAROVSKI ALUMNI PLATFORM (hereinafter also “WEBSITE”).

A. Legal grounds of the processing

By registering on the SWAROVKI ALUMNI PLATFORM users give their consent to the processing of their Personal Data by SWAROVSKI. SWAROVSKI Alumni can revoke their consent at any time. To do so, SWAROVSKI Alumni simply need to delete their account or contact alumni@swarovski.com in case of any problems with the deletion. Please note that the consent revoked only has effect for the future and has no influence on the lawfulness of the processing in the past.

In some cases, despite the revocation, SWAROVSKI is entitled to continue processing SWAROVSKI Alumni Personal Data on the following legal basis:

• performance of contracts;
• compliance with legal obligations of SWAROVSKI;
• legitimate interests of SWAROVSKI, including but not limited to
  • advertising and marketing activities;
  • efficient and effective support, maintenance of contact and other communication with SWAROVSKI Alumni outside of the processing of contracts;
  • understanding SWAROVSKI Alumni behavior, activities, concerns and needs, market studies;
• efficient and effective improvement of existing products and services and development of new products and services;
• efficient and effective protection of SWAROVSKI Alumni, employees and other individuals as well as protection of data, secrets and assets of or entrusted to SWAROVSKI, protection and safety of systems and premises of SWAROVSKI;
• maintenance and secure, efficient and operation and successful further development of the SWAROVSKI ALUMNI PLATFORM;
• compliance with legal and regulatory requirements and internal rules of SWAROVSKI;
• concerns regarding the prevention of fraud, offences and crimes as well as investigation in connection with such offences and other improper conduct, handling of claims and actions against SWAROVSKI, cooperation in legal proceedings and with public authorities as well as the prosecution, exercise of and defense against legal actions.

All the purposes of processing shall be applicable for the whole SWAROVSKI Group, i.e. not only for the company which initially collected the Personal Data. Personal Data of SWAROVSKI Alumni is collected for the purpose of all SWAROVSKI companies subject to this data privacy notice, any other policies developed by SWAROVSKI and pursuant to applicable data protection laws.

B. Purpose of processing

SWAROVSKI collects and processes the personal data of members of the SWAROVSKI ALUMNI NETWORK in particular for the following purposes:

• Registration and administration of the SWAROVSKI ALUMNI membership
• Operation of the SWAROVSKI ALUMNI PLATFORM
• Provision of relevant information and personalized contents and services
• Non-marketing communication including but not limited to: changes related to our Privacy Policy, General Terms and Conditions and/or Terms of Use; general changes to product and service offering; account verification; password reset; or an information related to incidents that could affect our services 
• Promotion of job opportunities within SWAROVSKI 
• Provision of information about SWAROVSKI as well as special SWAROVSKI Alumni offers on the WEBSITE (e.g. invitation to events, use of alumni benefits, networking with other alumni), whereby the information is exclusively related to the SWAROVSKI ALUMNI NETWORK and may also take the form of a newsletter dispatch by e-mail. 
• Participation in surveys, requiring SWAROVSKI Alumni feedback

4. CATEGORIES OF PERSONAL DATA

In order to provide the above-mentioned services, SWAROVSKI collects the following categories of Personal Data:

• Name data and contact details: First name/last name and email address required for the creation of a personal account
• Last position in SWAROVSKI, location and period of employment: Last position in SWAROVSKI, country/region and period of employment required for verification purposes
• Information on the SWAROVSKI Alumni, the work experience and current location: Voluntary provided by the Swarovski Alumni with the purpose of tailoring SWAROVSKI´s Alumni offers to individual needs and for regional groups/events, or for the promotion of particular job openings
• Information on language and other knowledge and skills: Voluntary provided by the Swarovski Alumni, with the purpose of creating a user profile in order to be able to tailor the Swarovski Alumni offers to individual needs
• Activities on the platform: Voluntary visible engagement of users on the platform, e.g. publishing articles, comments on articles, registration for events
• Data in connection with communication: Voluntary provided by the Swarovski Alumni, including but not limited to preferred means of communication, correspondence and communication with SWAROVSKI and other Swarovski Alumni (including records of the communication)
• Data pertaining to the use of the SWAROVSKI ALUMNI PLATFORM: Data concerning the use of the SWAROVSKI ALUMNI PLATFORM including but not limited to Information about the browser type and version used, the operating system of the user, the user's Internet service provider, the IP address and other user identification (e.g. user name of social media, cookies), date and time of SWAROVSKI ALUMNI PLATFORM visits, visited sites and contents, and referring websites. The processing is done to ensure the functionality and security of the platform as well to better understand the needs of our users, to continuously improve the platform and to enable the respective users to optimally deliver the website to their end device.

5. COOKIES AND SOCIAL PLUG-INS

SWAROVSKI uses cookies on its SWAROVSKI ALUMNI PLATFORM. Cookies are a widespread technique that allocates an identification to the browser of the user of a website which the user saves and shows upon request. On the one hand, SWAROVSKI uses session cookies which are automatically erased when the user closes the SWAROVSKI ALUMNI PLATFORM, and which enable the server to establish a stable connection to the user as long as he or she browses on the SWAROVSKI ALUMNI PLATFORM. On the other hand, SWAROVSKI also uses permanent cookies which are only erased after a defined period. Permanent cookies allow the saving of certain settings (e.g. language) for several sessions or allow for an automated log-in. The user consents to the application of permanent cookies through the use of the WEBSITE and the respective functions (e.g. language settings and automated log-in). The user may block or delete the application of cookies on his or her browser but this activity may impair the use of the WEBSITE.

SWAROVSKI may use Matomo on its WEBSITE. Matomo is an open-source web analytics platform used in order to measure, collect, analyse and report visitors data for purposes of understanding and optimizing their website. Matomo is used to analyse the behaviour of the website visitors to identify potential pitfalls; not found pages, search engine indexing issues, which contents are the most appreciated etc. Once the data is processed (number of visitors reaching a not found pages, viewing only one page…), Matomo is generating reports for website owners to take action, for example changing the layout of the pages, publishing some fresh content etc. The processing of personal data with Matomo is based on explicit consent. The personal data received through Matomo is sent to SWAROVSKI and Matomo data is hosted in Germany. 

In accordance with applicable law, SWAROVSKI may install coding in newsletters and other marketing email which allow it to determine if the recipient has opened an email or downloaded pictures contained in the email. However, the recipient may block this application in his/her email application. In any case he/she consents to the application of this technology by way of receiving newsletters or other marketing related emails.

In addition, SWAROVSKI may use plug-ins from social media networks such as Facebook, Twitter, Xing, LinkedIn or TikTok on the SWAROVSKI ALUMNI PLATFORM. In the default setting of the WEBSITE plug-ins are deactivated; the user can thus choose when to activate them. Should the user do so, the social media providers are able to establish a direct connection to the user during his or her visit on the WEBSITE, which allows the provider to be aware of the user's visit and may analyze the respective information. The subsequent processing of the personal data will be conducted in the responsibility of the social media provider pursuant to data protection and privacy laws and according to its data protection policies published on its website (such as www.facebook.com/; www.twitter.com; www.xing.com; www.linkedin.com; www.tiktok.com; www.youtube.com; www.instagram.com).

These third-party services are outside of the control of SWAROVSKI. Providers may, at any time, change their terms of service, purpose and use of cookies, etc.

6. DISCLOSURE OF PERSONAL DATA

In order to provide SWAROVSKI Alumni with our services, SWAROVSKI may need to share SWAROVSKI Alumni´ Personal Data with third parties within or outside SWAROVSKI. These recipients can be categorized as follows:

• to PARTNERS, including business, marketing and promotion partners (including social media partners) irrespective of whether the company is run by SWAROVSKI or another sales or cooperation partner;
• to a SWAROVSKI company to whom the processing of data (operation of the database) regarding SWAROVSKI has been outsourced in technical respect (processors)
• to PROCESSORS to whom the processing of data regarding the operation and functioning of the SWAROVSKI ALUMNI NETWORK has been outsourced for technical reasons.

7. TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES

The SWAROVSKI ALUMNI NETWORK is hosted in the European Union. However, because of the global nature of the service, personal data may be transferred or remotely accessed from outside of the EU/EEA and from countries, including the United States, that do not have an adequate level of protection of personal data (see ANNEX 2, as updated from time to time). Please be aware that if the data is transferred to a third country, there is a risk that your data can be processed by authorities, for control and surveillance measures, possibly without legal remedies. By opening and using a SWAROVSKI Alumni account, SWAROVSKI Alumni consent that the provided personal data may be transferred and/or processed in these countries. If personal data is disclosed to countries that do not guarantee adequate protection, SWAROVSKI will ensure that data disclosed is adequately protected and transferred in accordance with current legally recognized data transfer mechanisms, such as appropriate standard contractual clauses approved by the European Commission (see https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en ) or required revisions thereof (e.g Switzerland), binding corporate rules, or transferring data pursuant to consent, conclusion or performance of a contract, or in connection with the determination, exercise or enforcement of legal claims, or pursuant to overriding public interests, or  in order to protect the integrity of these individuals. SWAROVSKI Alumni can obtain a copy of the contractual guarantees from or will be advised where to obtain such copies by the contact points named above (see Section 2 above). SWAROVSKI reserves the right to redact such copies for applicable legal or secrecy reasons.

7.1 Transferees

By using the site, please be aware that you give your consent to transfers and /or processing of your personal data in countries different to your country of residence.

Swarovski International Holding AG (Switzerland, dataprivacy@swarovski.com ) is the Controller of the personal data collected and processed in connection with the SWAROVSKI ALUMNI NETWORK.

SWAROVSKI may disclose Personal Data within SWAROVSKI as well as to THIRD PARTIES and in every country worldwide, including namely all countries in which SWAROVSKI is represented by Group companies, affiliates or other offices and representatives as well as to countries in which service providers of SWAROVSKI process their data. A list of the relevant companies and affiliates of SWAROVSKI can be found in ANNEX 1. This list may be updated from time to time.

For more information, please visit www.swarovski.com and consult the SWAROVSKI Privacy Policy.

THE SWAROVSKI ALUMNI NETWORK is powered by EnterpriseAlumni Inc. (United States,  admin@enterprisealumni.com ). To learn more about Enterprise Alumni privacy policy, please visit: https://app.termly.io/document/privacy-notice/b58f0709-5bf9-4759-8fe6-d51373352e71 

8. RIGHTS OF DATA SUBJECTS

SWAROVSKI Alumni may request information from SWAROVSKI as to whether data concerning them is being processed. In addition, they have the right to request the correction, destruction or restriction of personal data regarding them as well as to object to the processing of personal data. Should the processing of personal data be based on consent, the affected individual may withdraw consent at any time. In countries of the EU and EEA the affected individual may, in certain cases, have the right to obtain data generated during the use of online services in a structured, common and machine-readable format which allows for further use and transfer. Request in this respect shall be submitted to the contact point (see para. 2 above). SWAROVSKI reserves the right to restrict the rights of the affected individual in accordance with applicable law and e.g. not to disclose comprehensive information or not to delete data.

In the event that SWAROVSKI makes an automated decision with respect to a certain individual which may have a legal effect for the affected individual or seriously affect him or her in a similar way, the affected individual shall have, in accordance with applicable law, the right to communicate with a controller of SWAROVSKI and to request a reconsideration of the decision or to request the prior evaluation by the controller. In this case the affected individual may no longer be able to use certain automated services. The individual will be informed thereof subsequently or separately in advance.

In Europe, any affected individual may also raise a complaint with the competent data protection authority, which in the case of a SWAROVSKI controller in Switzerland is the Federal Data Protection and Information Commissioner in Switzerland (http://www.edoeb.admin.ch ), the SWAROVSKI controller in the Principality in Liechtenstein is the Data Protection Office (Amtstelle Datenschutzstelle, in the Principality in Liechtenstein (https://www.llv.li/ ), the SWAROVSKI controller in Austria is the Austrian Data Protection Authority in Austria (https://www.dsb.gv.at/ ). In all other cases a list can be found here.

If you reside in the US, to know your rights, please visit the Privacy Policy here (https://www.swarovski.com/en-US/s-dataprotection/Privacy-Policy/ ).

If you reside in Canada, to know your rights, please visit the Privacy Policy here (https://www.swarovski.com/en_GB-CA/s-dataprotection/Privacy-Policy/).

9. Data Retention

In general, SWAROVSKI retains personal data for no longer than it is necessary for the purposes for which the personal data is processed.

The SWAROVSKI Alumni´ personal data will be stored as long as the user is a member of the SWAROVSKI ALUMNI NETWORK. If the registration process is not completed, the data entered during the registration will be deleted after two weeks. A new registration is possible at any time thereafter. In case of inactivity, the SWAROVSKI Alumni account will be deleted after two years. 

Users have the possibility to delete their SWAROVSKI Alumni account at any time. With the confirmation of the deletion by SWAROVSKI, the personal data of the alumni will be deleted in our systems. Personal data entered by SWAROVSKI Alumni will be deleted and visible engagement activities on the platform as well as data in connection with communication by the SWAROVSKI Alumni will be anonymized.

Notwithstanding the general principle, SWAROVSKI may process personal data for longer periods subject to the following rules and obligations: SWAROVSKI retains personal data as long as SWAROVSKI (i) is obligated to do so (by way of contract, law or other provisions) or (ii) has an overriding interest (e.g. an interest for reasons of proof in case of claims, documentation of compliance with certain legal or other requirements, an interest in non-personalized analysis). Deviating rules are reserved with respect to anonymization or pseudonymization of personal data subject to applicable law.

Annex 1 –  List of SWAROVSKI Legal entities

Annex 2 –  List of Countries