PRIVACY NOTICE

www.vyntage.com (the “Website”) is owned and operated by Ahmed Seddiqi & Sons LLC., a subsidiary of Seddiqi Holding LLC., a company incorporated under the laws of the United Arab Emirates with registered office at P.O. Box 2123 (“Company", "we" or “us” or “Seddiqi”). The Company is the leading retailer of luxury watches and jewelry in the United Arab Emirates. This Privacy Notice (“Privacy Notice” or “Notice”) covers the personal information that Seddiqi may collect or receive from you through the Website. This Notice outlines what our purpose and practices are for collecting and processing your personal information.

We primarily collect personal information with your permission or to process any request submitted on the Website. We only collect the minimum amount of personal information required to process your request. The personal information we collect may include your name, email address, phone number, if you create a user profile or fill the online form for enquiries on the Website.

2.2 Other information we collect

Information about your use and navigation of the Website such as, IP address and other device identifiers, browser type, and information about the web pages you visit. For more information on the personal information collected using cookies and similar technologies, please refer to the section on Cookies below.

The sources of your personal information include the following:

• User profile creation on the Website.
• The online form for enquiries on the Website.
• Cookies and similar technologies.

This Notice does not apply to information collected by any third party, including through any application or content (including advertising) that may link to any website that is not owned or operated by Seddiqi.

We use personal information for the following purposes:

• To create a user profile on the Website based on your request. We collect the following personal information – name, email address, password.
• To authenticate you for the purpose of granting access to your user profile on the Website pursuant to our legitimate interests to prevent unauthorized access to user profiles.
• To follow up on enquiries and requests submitted on the Website based on your permission. Personal information we collect, and process include – name, email address, phone number, and any personal information you choose to include in the body of your message.
• To generate internal aggregated reports and analytics based on our legitimate interests to monitor business performance.
• To create advertising campaigns using anonymized data pursuant to our legitimate interests to deliver advertising to people who may be interested in our products and services.
• To comply with applicable law and to exercise or defend legal claims. This may include sharing your personal information with relevant government authorities as may be required.

We may disclose personal information as described in this Privacy Notice:

• We may share your personal information with affiliate companies of Seddiqi, including other subsidiaries of Seddiqi Holding LLC, to conduct the activities described in this Privacy Notice. Such affiliate companies and subsidiaries are located in the United Arab Emirates and Kingdom of Saudi Arabia. For more information, please follow the instructions provided in the How to Contact Us section below.
• We may use carefully selected third parties to assist us with managing the Website (for example, website development partners). 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 share your personal information with government agencies, government officials, regulators, and law enforcement agencies to comply with any applicable law, regulation, government directive, court order, or legal process.
• To generate internal aggregated reports and analytics based on our legitimate interests to monitor business performance.
• To create advertising campaigns using anonymized data pursuant to our legitimate interests to deliver advertising to people who may be interested in our products and services.
• 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 the Website users 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.

The personal information that we collect is stored at a destination within the United Arab Emirates, Kingdom of Saudi Arabia, and through our authorized cloud service providers.

Personal information we collect may be transferred to, stored, and processed in the United Arab Emirates and Kingdom of Saudi Arabia where one or more of the members of Seddiqi Holding LLC are located or maintain facilities. We carry out such transfers for the purposes described in this Notice. Where we transfer personal data outside the United Arab Emirates or Kingdom of Saudi Arabia, we 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, including, where relevant, entering standard contractual/data protection clauses (or equivalent measures). If you would like more information on transfer mechanisms, please contact us using the details provided in Section - ‘How do you contact us?’.

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 the purposes outlined above and legal requirements under applicable law(s). For more information on where and how long your personal information is stored and your right of erasure, please contact us using the details provided in Section - ‘How do you contact us?’

We use industry standard security controls to safeguard the confidentiality of your 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.

The Website may use cookies to distinguish you from other users and customize your experience on the Website. By continuing to browse the Website, you are agreeing to our use of cookies.

A cookie is a small text file that we store on your browser or computer if you agree. There are different types of cookies, including:

• Strictly necessary cookies: these are required for the operation of the Website. 
• Analytical/performance cookies: these allow us to recognize and count the number of visitors and how visitors navigate the Website. 
• Functionality cookies: these are used to recognize you when you return to the Website.
• Targeting cookies: these cookies record your visit to the Website, the pages you visited, and the links you have followed. We use this information to make the Website and advertising displayed on it more relevant to your interests. 

You can block cookies by activating the setting on your browser that allows you to decline the setting of all or some cookies. If your browser setting is to block all cookies (including essential cookies), you may not be able to access all or parts of the Website.

Depending on the jurisdiction, certain privacy laws allow you to exercise certain rights over your personal information. If you wish to exercise any of the rights noted below, we may ask you for additional information to verify your identity for security purposes, before disclosing personal information to you. 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, please send a request to us at privacy@seddiqi.com. We 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 will promptly inform you. 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 with regards to your personal information:

11.1 The right to access

You have the right to obtain confirmation as to whether we process your personal information, 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).

11.2 The right to rectification

You have the right to request amendment or correction of your personal information where it is inaccurate (for example, if you change your name) and to have incomplete personal information completed.

11.3 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 to 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 it was 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.

11.4 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:

• Where the 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 applicable law to which we are subject.

We are not required to comply with your request to erase personal information if processing your personal information is necessary:

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

11.5 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.

11.6 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.

11.7 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 writing to us at the email provided above.

11.8 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 jurisdiction 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 at the email provided above. We will closely review and ensure a timely response to any complaints we receive.

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 personal information we have collected from children under 18, you may contact us by email at privacy@seddiqi.com.

This Notice may change from time to time. Your continued use of the Website after we make changes is deemed to be acceptance of those changes; please check this Notice periodically for updates.

In case of any queries related to this Notice, you can contact our Data Privacy Office by sending an email to privacy@seddiqi.com.