PERSONAL DATA

PREFACE

The personal data policy put in place by BELL & ROSS can be accessed from every page of the BELL & ROSS website www.bellross.com, including the versions optimised for browsing on tablets and smartphones. You expressly recognise and accept that personal data relating to you is gathered on the Website.

1.GENERAL INFORMATION

This document details the way in which BELL & ROSS uses and gathers your personal data and informs you of the measures taken by BELL & ROSS to ensure the protection of your personal data.The new General Data Protection Regulation (GDPR) will come into effect on 25th May. BELL & ROSS has updated its confidentiality policies to provide you with more information on how we use your personal data and on your new rights.

To ensure these rules are being correctly implemented, BELL & ROSS has appointed a data protection officer who will be the point of contact with the French national data protection authority, CNIL. BELL & ROSS is also putting the corresponding internal procedures in place to ensure its employees are well-informed and to ensure these rules are respected within its organisation.

2. GATHERING, USE AND RETENTION OF DATA

2.1 GATHERING OF DATA

BELL & ROSS may gather your personal data, specifically via the "contact" section, when signing up for the electronic Newsletter offered by BELL & ROSS, when subscribing to the BELL & ROSS News (RSS feed), when making an application for a job at BELL & ROSS, or when creating your customer account in the BELL & ROSS Online Boutique.

"Personal data" refers to the information relating to you as an individual that you communicate of your own free will when completing a form found on the Website, or which BELL & ROSS gathers when you browse the Website and which, regardless of its nature, enables you to be directly or indirectly identified.

Personal data refers to nominative data (such as your name, address or photographs that you have provided) and electronic identification data available on or from your computer (such as cookies or IP addresses). Your electronic identification data enables the terminal used for Internet access to be identified or geolocated (in no more detail than the town or city) or the pages consulted on the Website during your browsing history to be identified, and is not generally sufficient by itself to identify you personally.

Furthermore, to combat counterfeiting, BELL & ROSS has put automated processing systems in place which gather information relating to companies or people who have committed or are likely to commit acts in violation of its rights. This information is available to any company legally using the BELL & ROSS trademarks, in France or abroad, which has been victim of these violations, to enable them to act or take any measures necessary to safeguard their rights.

BELL & ROSS undertakes to respect the regulation applicable to all personal data processing for which it is responsible. More specifically, BELL & ROSS undertakes to respect the following principles:

• Your personal data is processed in a fair, transparent and lawful way (fair, transparent, lawful).
• Your personal data is gathered for specified, explicit and legitimate purposes, and is not subsequently used in a way which is not compatible with these purposes (limitation of purposes).
• Your personal data is retained in an adequate, relevant manner and is limited to what is strictly necessary for the purposes for which it is being processed (minimisation of data).
• Your personal data is accurate and up to date, and all reasonable measures are taken to ensure that inaccurate data, as regards the purposes for which it is being processed, is deleted or corrected without delay (accuracy).

Adobe Flash Player™ Flash© cookies

Adobe Flash Player™ is a computer application which enables dynamic content to be developed very quickly using the Flash computer language. Flash and applications of the same type store the parameters, preferences and use of this content, using similar technology to cookies. However, Adobe Flash Player™ manages this information and your choices via a different interface to that provided by your browser software.

Provided that your terminal is able to display content developed with Flash, we invite you to access your Flash cookie management tools directly from the website http://www.adobe.com/fr/.

Social networks

BELL & ROSS is responsible for publishing a BELL & ROSS introductory and information page on various social networks such as facebook™, twitter™ and instagram™.

You can follow the BELL & ROSS pages on these social networks. Any personal information that you have designated as public and accessible from your profile can be accessed by BELL & ROSS. BELL & ROSS has not created, nor does it use, any database independent of these social networks based on personal information that you may post there.

If you wish to prevent BELL & ROSS from accessing the personal information that you have published on your profile (and which is visible publicly), we would remind you that the social networks have settings which give you the option to check and/or restrict access to your data. We recommend that you regularly check the personal data policy for these social networks.

BELL & ROSS recruitment

BELL & ROSS will collect your personal data specifically via the "recruitment space" on the Website so that it can assess and respond to your application.

You expressly recognise and accept that BELL & ROSS and its subsidiaries located within the European Economic Area are the recipients of your personal data and that this data may be transmitted, depending on the positions to be filled, to recruitment agencies.

BELL & ROSS Online Boutique

BELL & ROSS may also gather your personal data when you make a purchase from the BELL & ROSS Online Boutique, to enable you to place an order online.

Click to chat direct contact

The Online Boutique offers a service known as "click to chat" (a request for contact with the customer service department of the BELL & ROSS Online Boutique) thanks to a behavioural analysis system that uses cookies and JavaScript, which are files placed on your computer and executed by it to help BELL & ROSS to analyse your use of the Website in real time, and to provide you with a help service for browsing the Online Boutique on the Website (hereinafter "Click to chat").

The data generated by the cookies relating to your use of the Website (including your IP address) will be transmitted to servers where they will be stored by one of BELL & ROSS's service providers located within the European Union. This service provider will only use this information for the purpose of evaluating your use of the Website, compiling reports on the Website's activity, and on the history of your Click to Chat exchanges.

BELL & ROSS may communicate this data to third parties if there is a legal obligation to do so or when these third parties are processing your data on behalf of BELL & ROSS. You can deactivate the use of cookies for Click to Chat by opening the link in section 3 below. If you choose to deactivate cookies, BELL & ROSS will no longer be able to provide you with this Click to Chat service. When using the Website, you expressly consent to having your nominative data processed by BELL & ROSS under the conditions and for the purposes set out above.

The data gathered by BELL & ROSS as part of the Click to Chat service will never be used by BELL & ROSS or its service providers for purposes other than providing you with the service described above.

2.2 USE OF DATA

The information that you communicate on the Website enables BELL & ROSS to:

• Deal with your questions or requests for information,
• Analyse the frequency of visits to the Website,
• Send you targeted publicity or marketing messages, provided that you have given permission for us to do so,
• Send you the Newsletter, if you have signed up to receive this,
• Send you any catalogues,
• Give you information on BELL & ROSS products,
• Offer you a tool to make appointments at points of sale,
• Offer you an online communication tool,
• Inform you of events organised by BELL & ROSS,
• Allow you to take part in surveys,
• Enable you to follow the Website and its updates (in the "BELL & ROSS News" section),
• Recruit you to a vacant position (in the "recruitment" section).

Where applicable, information that is essential in enabling BELL &ROSS to fulfil the tasks set out above is denoted by an asterisk in the various pages of the Website. The other information is optional in nature, and enables us to find out more about you and improve the communications and services that we provide to you.

The information gathered by BELL & ROSS is specifically your surname, first name(s), postal address, e-mail address, date of birth and telephone number. This information enables BELL & ROSS to send you personalised communications based on your profile and your browsing history on the Website (using cookies) to continue to be able to offer you a high-quality, tailored service.

2.3 RETENTION OF DATA

BELL & ROSS may be required to retain your personal data for a period which shall not exceed ten years from the date of last contact. The data gathered in the recruitment space on www.bellross.com is retained for 24 months from the date of your last visit to the applicant space. The Cookies used by BELL & ROSS are retained for six months.

3. COOKIES

A cookie does not enable you to be identified; it simply records information relating to (i) your computer's browsing history on the Website (the pages that you have consulted, the date and time these were consulted, etc.) that BELL & ROSS will be able to read during your subsequent visits or (ii) the number of times our advertising content or that of third-party sites or applications has been displayed or (iii) the opening and reading of electronic communications that BELL & ROSS may have sent to you, with your agreement.

BELL & ROSS may gather information by placing a cookie or a web tag on your computer via the Website or count the clicks on elements that BELL & ROSS sends to you. BELL & ROSS uses these to store choices and login or identification information during the visit to an online service. Depending on the configuration options made on your terminal, which you may edit at any time, the Cookies that BELL & ROSS sends from the Website enable the company to:

• determine statistics and the frequency of visits and use of the various elements forming the Website (sections and content visits, browsing), thereby enabling the interest and ergonomics of the services provided to you to be improved;
• provide you with tailored, targeted services and navigation;
• provide you with tailored, targeted services and navigation;
• count clicks on an element of an online service.

Certain services, such as the online wish list that BELL & ROSS offers you, can only be used if cookies have been activated. You can review your choice relating to these services at any time when using one of these services.

BELL & ROSS may also purchase advertising space to promote its products, via advertising content published on third-party sites, online platforms or applications, which may contain one or more cookies. Subject to the configuration options made on your terminal, which you may edit at any time, this cookie may be saved in your terminal in order to:

• count the number of times our advertising content has been displayed or activated on third-party sites or applications, identify this content and these sites or applications or social networks, determine the number of users who have clicked on each content;
• send you advertising whilst you are browsing third-party sites or social networks on the internet;
• create statistics.

BELL & ROSS would also like to inform you that you can prevent "cookies" being saved by configuring your browser as follows:

For Mozilla Firefox:

Select the "Tools" menu, then "Options", and select your preferred options in the "History" section.

For Microsoft Internet Explorer 6.0 and later

Select the "Tools " menu, then "Internet Options", click the "Privacy" tab, and select the required level using the cursor.

For Opera 6.0 and later:

Select the "File" menu, "Preferences ", "Privacy" and select your preferred

For Safari:

In the Safari menu, select "Preferences ", "Security" and select your preferred options.

For Google Chrome:

Select the Chrome menu from the browser tool bar, select Settings then click "Show advanced settings"; in the "Privacy" section, click the "Content settings" button, then you can select your preferred options in the "Cookies" section.