Privacy Policy

Foreword

We, Royalty Fashion (hereinafter jointly: "the company", "we" or "us") take the protection of your personal data seriously and would like to inform you here about data protection in our company.

Within the scope of our responsibility under data protection law, additional obligations have been imposed on us by the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: "GDPR") in order to ensure the protection of personal data of the data subject (we also refer to you as data subject hereinafter as "customer", "user", "you", "you" or "data subject").

Insofar as we decide either alone or jointly with others on the purposes and means of data processing, this includes above all the obligation to inform you transparently about the nature, scope, purpose, duration and legal basis of the processing (cf. Art. 13 and 14 DS-GVO). With this declaration (hereinafter: "data protection notice"), we inform you about the manner in which your personal data is processed by us.

Our data protection information has a modular structure. It consists of a general part for all processing of personal data and processing situations that come into play each time a website is called up (A. General) and a special part, the content of which only relates to the processing situation specified there with the designation of the respective offer or product, in particular the visit to websites as detailed here (B. Visit to websites).

In order to be able to find the parts that are relevant to you, please refer to the following overview for the breakdown of the data protection notices:

Part	Designation	This part is for you	Page
Part A	General	always relevant.	[2]
Part B	Website and social media presence	relevant if you use our German website including our social media presence.	[6]

General

(1) Definitions

Following the example of Art. 4 of the GDPR, this data protection notice is based on the following definitions:

-Personal data" (Art. 4 No. 1 GDPR) means any information relating to an identified or identifiable natural person ("data subject"). A person is identifiable if he or she can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or by means of information relating to his or her physical, physiological, genetic, mental, economic, cultural or social identity characteristics. The identifiability can also be given by means of a linkage of such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photographs, video or audio recordings may also contain personal data).

-Processing" (Art. 4 No. 2 GDPR) means any operation which involves the handling of personal data, whether or not by automated (i.e. technology-based) means. This includes, in particular, the collection (i.e. acquisition), recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data, as well as the change of a purpose or intended use on which a data processing was originally based.

- "Controller" (Art. 4 No. 7 DS-GVO) means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

-Third party" (Art. 4 No. 10 GDPR) means any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who are authorised to process the personal data under the direct responsibility of the controller or processor; this also includes other group-affiliated legal entities.

-A "processor" (Art. 4 No. 8 DS-GVO) is a natural or legal person, authority, institution or other body that processes personal data on behalf of the controller, in particular in accordance with the controller's instructions (e.g. IT service provider). In the sense of data protection law, a processor is in particular not a third party.

-Consent" (Art. 4 No. 11 GDPR) of the data subject means any freely given specific, informed and unambiguous indication of his or her wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

(2) the name and address of the controller

We are the controller for the processing of your personal data within the meaning of Art. 4 No. 7 DS-GVO:

Royalty Watches Nevena Zezelj

Zuckschwerdtstr. 49, 65929 Frankfurt am Main, Hessen, Germany

+491751162438

nevena.zezelj@royalty-watches.com

For further information on our company, please refer to the imprint details on our website [link to imprint].

(3) Legal basis for data processing

In principle, any processing of personal data is prohibited by law and only permitted if the data processing falls under one of the following justifications:

-Art. 6 (1) p. 1 lit. a DS-GVO ("consent"): Where the data subject has voluntarily, in an informed manner and unambiguously indicated by a statement or other unambiguous affirmative act that he or she consents to the processing of personal data relating to him or her for one or more specified purposes;

-Art. 6 (1) p. 1 lit. b DS-GVO: If the processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject;

-Art. 6 para. 1 p. 1 lit. c DS-GVO: If processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a legal obligation to keep records);

-Art. 6 (1) p. 1 lit. d DS-GVO: If the processing is necessary to protect the vital interests of the data subject or another natural person;

-Art. 6 (1) p. 1 lit. e DS-GVO: Where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or

-Art. 6 (1) p. 1 lit. f DS-GVO ("Legitimate Interests"): Where processing is necessary for the purposes of legitimate (in particular legal or economic) interests of the controller or a third party, unless such interests are overridden by the conflicting interests or rights of the data subject (in particular where the data subject is a minor).

For the processing operations carried out by us, we indicate below the applicable legal basis in each case. A processing operation may also be based on several legal bases.

(4) Data deletion and storage period

For the processing operations carried out by us, we indicate below in each case how long the data will be stored by us and when it will be deleted or blocked. Unless an explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for the storage no longer applies. Your data will only be stored on our servers in Germany, subject to any transfer in accordance with the provisions in A.(7) and A.(8).

However, storage may take place beyond the specified time in the event of a (threatened) legal dispute with you or other legal proceedings or if storage is provided for by statutory regulations to which we are subject as the responsible party (e.g. § 257 HGB, § 147 AO). If the storage period prescribed by the legal regulations expires, the personal data will be blocked or deleted unless further storage by us is necessary and there is a legal basis for this.

(5) Data security

We use appropriate technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorised access by third parties (e.g. TSL encryption for our website), taking into account the state of the art, the implementation costs and the nature, scope, context and purpose of the processing as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments.

We will be happy to provide you with more detailed information on request. Please contact our data protection officer (see A.(3)).

(6) Cooperation with processors

As with any larger company, we also use external domestic and foreign service providers (e.g. for IT, logistics, telecommunications, sales and marketing) to process our business transactions. These service providers only act on our instructions and are contractually obliged to comply with data protection regulations in accordance with Art. 28 DS-GVO.

If personal data from you is passed on by us to our subsidiaries or is passed on to us by our subsidiaries (e.g. for advertising purposes), this is done on the basis of existing order processing relationships.

(7) Conditions for the transfer of personal data to third countries

In the course of our business relationships, your personal data may be passed on or disclosed to third party companies. These may also be located outside the European Economic Area (EEA), i.e. in third countries. Such processing takes place exclusively for the fulfilment of contractual and business obligations and to maintain your business relationship with us. We will inform you about the respective details of the transfer in the following at the relevant points.

Some third countries are certified by the European Commission as having a level of data protection comparable to the EEA standard through so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be found here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.html). However, in other third countries to which personal data may be transferred, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is sufficiently guaranteed. This is possible through binding company regulations, standard contractual clauses of the European Commission for the protection of personal data, certificates or recognised codes of conduct. Please contact our data protection officer (see under A.(3)) if you would like more information on this.

(8) No automated decision making (including profiling)

We do not intend to use any personal data collected from you for any automated decision making process (including profiling).

(9) No obligation to provide personal data

We do not make the conclusion of contracts with us dependent on you providing us with personal data in advance. As a customer, you are under no legal or contractual obligation to provide us with your personal data; however, we may only be able to provide certain services to a limited extent or not at all if you do not provide the necessary data. If this should exceptionally be the case in the context of the products we offer presented below, you will be informed of this separately.

(10) Legal obligation to transmit certain data

We may, under certain circumstances, be subject to a specific legal or statutory obligation to make the lawfully processed personal data available to third parties, in particular public bodies (Art. 6 para. 1 p. 1 lit. c DS-GVO).

(11) Your rights

You can assert your rights as a data subject regarding your processed personal data at any time by contacting us using the contact details provided at the beginning of A.(2). As a data subject, you have the right

-In accordance with Art. 15 DS-GVO, you may request information about your data processed by us. In particular, you can request information about the processing purposes, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information about its details;

-In accordance with Art. 16 DS-GVO, you have the right to demand the correction of incorrect data or the completion of your data stored by us without delay;

-In accordance with Art. 17 DS-GVO, you may request the deletion of your data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims;

-In accordance with Art. 18 DS-GVO, you may request the restriction of the processing of your data if the accuracy of the data is disputed by you or the processing is unlawful;

Pursuant to Art. 20 DS-GVO, you have the right to receive your data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another controller ("data portability");

-You have the right to object to processing in accordance with Article 21 of the German Data Protection Regulation (DS-GVO) if the processing is based on Article 6 (1) sentence 1 lit. e or lit. f of the DS-GVO. This is particularly the case if the processing is not necessary for the performance of a contract with you. Unless it is an objection to direct marketing, when exercising such an objection, we ask you to explain the reasons why we should not process your data as we have done. In the event of your justified objection, we will review the merits of the case and either cease or adapt the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing;

-In accordance with Art. 7 (3) of the GDPR, you may revoke your consent - i.e. your voluntary, informed and unambiguous intention to consent to the processing of the personal data in question for one or more specific purposes by means of a declaration or other unambiguous affirmative action - given once (also before the GDPR came into force, i.e. before 25.5.2018) at any time. This has the consequence that we may no longer continue the data processing based on this consent in the future, and

-In accordance with Art. 77 of the Data Protection Regulation, you have the right to lodge a complaint with a data protection supervisory authority about the processing of your personal data in our company, for example with the data protection supervisory authority responsible for us: [competent data protection supervisory authority], [address], e-mail: [email address].

(12) Changes to the data protection notice

In the context of the further development of data protection law as well as technological or organisational changes, our data protection information is regularly reviewed for the need to adapt or supplement it. You will be informed of any changes in particular on our German website at [address of the company's website]. This data protection notice is valid as of [month and year of publication of the data protection notice].

Visiting websites

(1) Explanation of the function

You can obtain information about our company and the services we offer in particular at [address of the company's website] together with the associated sub-pages (hereinafter collectively: "websites"). When you visit our websites, your personal data may be processed.

(2) Personal data processed

During the informative use of the websites, the following categories of personal data are collected, stored and processed by us:

"Log data": When you visit our websites, a so-called log data record (so-called server log files) is stored temporarily and anonymously on our web server. This consists of:

-the page from which the page was requested (so-called referrer URL).

- the name and URL of the requested page

-the date and time of the call

-the description of the type, language and version of the web browser used.

-The IP address of the requesting computer, which is shortened in such a way that a personal reference can no longer be established.

-the amount of data transferred

-the operating system

-the message whether the call was successful (access status/http status code).

-the GMT time zone difference

"Contact form data": When contact forms are used, the data transmitted through them are processed (e.g. gender, surname and first name, address, company, e-mail address and the time of transmission).

In addition to the purely informational use of our website, we offer the subscription to our newsletter, with which we inform you about current developments in business law and events. If you subscribe to our newsletter, the following "newsletter data" will be collected, stored and processed by us:

-the page from which the page was requested (so-called referrer URL)

-the date and time of the call

-the description of the type of web browser used

-The IP address of the requesting computer, which is shortened in such a way that a personal reference can no longer be established.

-the email address

-the date and time of registration and confirmation

We would like to point out that we evaluate your user behaviour when sending the newsletter. For this evaluation, the emails sent contain so-called web beacons or tracking pixels, which are single-pixel image files that are stored on our website. For the evaluations, we link the aforementioned data and the web beacons with your e-mail address and an individual ID. Links contained in the newsletter also contain this ID. The data is only collected pseudonymously, i.e. the IDs are not linked to your other personal data, a direct personal reference is excluded.

(3) Purpose and legal basis of the data processing

We process the personal data described in more detail above in accordance with the provisions of the GDPR, the other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Art. 6 (1) sentence 1 lit. f DS-GVO, the aforementioned purposes also represent our legitimate interests.

The processing of the log data serves statistical purposes and the improvement of the quality of our website, in particular the stability and security of the connection (legal basis is Art. 6 para. 1 p. 1 lit. f DS-GVO).

Contact form data is processed for the purpose of handling customer enquiries (legal basis is Art. 6 para. 1 p. 1 lit. b or lit. f DS-GVO).

The newsletter data is processed for the purpose of sending the newsletter. When registering for our newsletter, you consent to the processing of your personal data (legal basis is Art. 6 para. 1 lit. a DS-GVO). We use the so-called double opt-in procedure to register for our newsletter. This means that after your registration, we will send you an e-mail to the e-mail address you provided in which we ask you to confirm that you wish to receive the newsletter. The purpose of this procedure is to verify your registration and, if necessary, to be able to clarify any possible misuse of your personal data. You can revoke your consent to receive the newsletter at any time and unsubscribe from the newsletter. You can declare the revocation by clicking on the link provided in every newsletter e-mail, by e-mail to [e-mail address of the company] or by sending a message to the contact details given in the imprint.

(4) Duration of the data processing

Your data will only be processed for as long as is necessary to achieve the above-mentioned processing purposes; the legal bases stated in the context of the processing purposes apply accordingly. With regard to the use and storage duration of cookies, please note point A.(5) as well as the Cookie Policy [link to Cookie Policy].

Third parties engaged by us will store your data on their system for as long as is necessary in connection with the provision of the services for us in accordance with the respective order.

You can find more details on the storage period under A.(5) and the Cookie Policy [link to Cookie Policy].

(5) Transfer of personal data to third parties; justification basis

The following categories of recipients, which are usually processors (see A.(7)), may have access to your personal data:

-The legal basis for the transfer of data is Art. 6 (1) sentence 1 lit. b or lit. f of the German Data Protection Act (DS-GVO). The legal basis for the transfer is then Art. 6 para. 1 sentence 1 lit. b or lit. f DS-GVO, insofar as it does not involve order processors;

-Government agencies/authorities, insofar as this is necessary for the fulfilment of a legal obligation. The legal basis for the disclosure is then Art. 6 para. 1 p. 1 lit. c DS-GVO;

-Persons appointed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the disclosure is then Art. 6 para. 1 sentence 1 lit. b or lit. f DS-GVO.

For the guarantees of an adequate level of data protection in the event of a transfer of the data to third countries, see A.(8).

In addition, we will only pass on your personal data to third parties if you have given your express consent to do so in accordance with Art. 6 (1) p. 1 lit. a DS-GVO.

(6) Use of cookies, plugins and other services on our website

a) Cookie

We use cookies on our websites. Cookies are small text files that are assigned to the browser you are using and stored on your hard drive by means of a characteristic string of characters and through which certain information flows to the body that sets the cookie. Cookies cannot execute programmes or transfer viruses to your computer and therefore cannot cause any damage. They serve to make the internet offer as a whole more user-friendly and effective, i.e. more pleasant for you.

Cookies can contain data that make it possible to recognise the device used. In some cases, however, cookies only contain information on certain settings that are not personally identifiable. However, cookies cannot directly identify a user.

A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. With regard to their function, a distinction is made between cookies:

-Technical cookies: these are mandatory to move around the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes nor do they store which web pages you have visited;

-Performance cookies: these collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect information that could identify you - all information collected is anonymous and is only used to improve our website and find out what interests our users;

-Advertising cookies , targeting cookies: These are used to offer the website user tailored advertising on the website or offers from third parties and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;

-Sharing cookies: These are used to improve the interactivity of our website with other services (e.g. social networks); sharing cookies are stored for a maximum of 13 months.

Any use of cookies that is not absolutely technically necessary constitutes data processing that is only permitted with your explicit and active consent pursuant to Art. 6 (1) sentence 1 lit. a DS-GVO. This applies in particular to the use of advertising, targeting or sharing cookies.Furthermore, we will only pass on your personal data processed by cookies to third parties if you have given your express consent to do so in accordance with Art. 6 (1) sentence 1 lit. a DS-GVO.

b) Social media plugins

Use of Facebook plugins

This website uses plug-ins of the social network www.facebook.com, which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook").

If you call up a website of our internet presence that is provided with such a plug-in, the plug-in only becomes active after you have clicked on the "Activate Facebook" button. Only now will a connection to the Facebook servers be established. The plug-in now appears on the website after informing your browser (by clicking on the activated "f" button). This tells the Facebook server which of our websites you have visited. If you are already logged in as a Facebook member, Facebook assigns this information to your personal Facebook user account. When using the plug-in functions (e.g. clicking the "Like" button, submitting a comment), this information is also assigned to your Facebook account, which you can only prevent by logging out before using the plug-in. You can deactivate the function at any time by clicking on the "Deactivate Facebook" button.

For more information on the collection and use of data by Facebook, as well as your rights in this regard and options for protecting your privacy, please refer to Facebook's privacy policy at https://www.facebook.com/policy.php.

Use of Pinterest plug-ins

This website uses plug-ins of the social network Pinterest, which is operated by Pinterest Inc., 635 High Street, Palo Alto, CA 94301, USA ("Pinterest"). We use the "P" button on our website. If you call up a web page of our internet presence that contains such a plug-in, a link between your computer and the servers of Pinterest is only established when you have activated this plug-in by clicking on the "Activate Pinterest" button. In doing so, the plug-in is displayed on the website by informing your browser. Both your IP address and the information about which of our websites you have visited are transmitted to the Pinterest server in the USA. If you are also a Pinterest member and logged into Pinterest at the time you use the plug-in, the information collected about your website visit will be linked to your Pinterest account and made known to other users. Also in the case of interactions that are possible with the various Pinterest plug-ins, the corresponding information about you is collected and transmitted to Pinterest and stored. You can deactivate the function at any time by clicking on the "Deactivate Pinterest" button.

For more information on the collection and use of data by Pinterest, please visit https://policy.pinterest.com/de/privacy-policy.

Use of Instagram plug-ins

On our website, we use so-called social plug-ins ("plug-ins") from Instagram, which is operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA ("Instagram"). The plug-ins are marked with an Instagram logo, for example in the form of an "Instagram camera". When you call up a page of our website that contains such a plug-in, your browser establishes a direct connection to the Instagram servers. The content of the plug-in is transmitted by Instagram directly to your browser and integrated into the page. Through this integration, Instagram receives the information that your browser has called up the corresponding page of our website, even if you do not have an Instagram profile or are not currently logged in to Instagram. This information (including your IP address) is transmitted by your browser directly to an Instagram server in the USA and stored there.

If you are logged in to Instagram, Instagram can directly assign your visit to our website to your Instagram account. If you interact with the plug-ins, for example by clicking the "Instagram" button, this information is also transmitted directly to an Instagram server and stored there. The information is also published on your Instagram account and displayed there to your contacts. For the purpose and scope of the data collection and the further processing and use of the data by Instagram, as well as your rights in this regard and setting options for protecting your privacy, please refer to Instagram's privacy policy: https://help.instagram.com/155833707900388/ If you do not want Instagram to directly assign the data collected via our website to your Instagram account, you must log out of Instagram before visiting our website. You can also completely prevent the loading of Instagram plug-ins with add-ons for your browser, e.g. with the script blocker "NoScript" (https://noscript.net/).

Use of YouTube plug-ins

We use the YouTube.com platform to post our own videos and make them publicly available.

YouTube is the service of a third party not affiliated with us, namely YouTube LLC., 901 Cherry Ave, San Bruno, CA 94066, USA; YouTube is a subsidiary of Google Inc.

As a general rule, we are not responsible for the content of websites to which links are provided. However, in the event that you follow a link to YouTube, we would like to point out that YouTube stores the data of its users (e.g. personal information, IP address) in accordance with its own data usage guidelines and uses it for business purposes. For more information on this and YouTube's privacy policy, please see their privacy policy at:

- https://policies.google.com/privacy?hl=de&gl=de

- https://www.datenschutz.org/youtube/

- https://support.google.com/youtube/answer/171780?hl=de

We integrate YouTube on our website exclusively in the extended data protection mode. YouTube provides this mode and thus ensures that initially no cookies are set and used. As soon as you start the playback of an embedded video by clicking on it, YouTube only saves cookies on your device through the extended data protection mode, which do not contain any personally identifiable data, unless you are currently logged into a Google service. This may also lead to a connection with the Google "DoubleClick network" (formerly Internet Advertising Network), under which online marketing solutions are offered. These cookies can be prevented by appropriate browser settings and extensions. YouTube uses cookies to collect information about visitors to their website, to gather statistics, to prevent fraud, and to improve the user experience. When you start the video, this could trigger further data processing operations. We have no influence on this. The data processing is carried out under YouTube's own responsibility."

Use of Twitter plug-ins

Royalty uses the technical platform and services of Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103 U.S.A. for the short message service.

The data controller for individuals living outside the U.S. is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland.

Royalty has no control over the nature and extent of the data processed by Twitter, the manner in which it is processed and used, or the disclosure of such data to third parties. Nor does it have any effective means of control in this respect.

Information on what data is processed by Twitter and for what purposes can be found in Twitter's privacy policy:

- https://twitter.com/de/privacy (external link).

Twitter Inc. has committed itself to the principles of the EU-US Privacy Shield. More details can be found at:

- https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active (external link).

By using Twitter, your personal information is collected, transferred, stored, disclosed and used by Twitter Inc. and transferred to and stored and used in the United States, Ireland and any other country in which Twitter Inc. does business, regardless of your country of residence.

Twitter processes on the one hand your voluntarily entered data such as name and user name, e-mail address, telephone number or the contacts of your address book when you upload or synchronize it.

On the other hand, Twitter also evaluates the content you share to determine what topics you are interested in, stores and processes confidential messages that you send directly to other users, and can determine your location using GPS data, wireless network information or your IP address in order to send you advertising or other content.

For analysis, Twitter Inc. may use analytics tools such as Twitter Analytics or Google Analytics.

Finally, Twitter also receives information when you view content, for example, even if you have not created an account. This so-called "log data" may be the IP address, browser type, operating system, information about the website you visited previously and the pages you viewed, your location, your mobile provider, the terminal device you use (including device ID and application ID), the search terms you used and cookie information.

Via Twitter buttons or widgets embedded in websites and the use of cookies, it is possible for Twitter to record your visits to these websites and assign them to your Twitter profile. Based on this data, content or advertising can be offered tailored to you. Since Twitter Inc. is a non-European provider with a European branch only in Ireland, it is not bound by German data protection regulations according to its own interpretation. However, due to the principle of establishment in Article 3 (1) of the GDPR, Twitter Inc. is bound by the provisions of the GDPR.