Privacy Policy
Privacy Policy
A P M MIDDLE EAST JEWELRY TRADING L.L.C (BRANCH) takes the protection of personal data very seriously. Pursuant to UAE Federal Decree-Law No. 45/2021 on the Protection of Personal Data (UAE PDPL) and the Abu Dhabi Global Markets (ADGM) Data Protection Regulations 2021 (ADGM DPR), on the protection of personal data, please find below a description of how your data is processed, a statement of your rights with respect to your personal data, as well as our cookie policy. Please read the following Privacy Policy carefully to understand our practices regarding your personal data. By using the Services, you agree to the collection and handling of your personal data in accordance with this Privacy Policy. For the purposes of this Privacy Policy, the “Personal Data” shall mean and include the categories of data set out in Session A of this Privacy Policy.
A. Processing of personal data
1. Data Controller
The Data Controller is the A P M MIDDLE EAST JEWELRY TRADING L.L.C (BRANCH) (hereinafter referred to as: “APM”), registered in the government of Dubai under register No. 1382619.
2. Purposes of the processing (purpose and legal basis)
As part of its online store, APM processes personal data for the following purposes:
- To carry out customer management operations in relation to the creation of a customer account; contracts; orders; deliveries; invoices; accounting and in particular the management of customer accounts; the loyalty program within one or more legal entities, excluding programmes that are common to several companies; customer relationship monitoring such as conducting satisfaction surveys and managing after-sales service complaints;
- To carry out prospecting operations;
- To develop audience measurement statistics;
- To manage requests for the right of access, rectification and objection;
- To manage customer reviews of products, services or contents.
The legal justifications for the processing are as follows:
|
Features |
Reasons
|
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Manage orders: Prepare and send out customer orders / Receive and process customer returns |
Contract performance
Legitimate interest |
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Exercise of customer rights (access, correction, objection, etc.) |
Legal obligation |
|
Manage customer relationship: - Manage customer requests - Manage disputes and litigation - Process customer reviews - Process customer after-sales requests - Manage exchanges with customers |
Contract performance Legitimate interest
|
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Accounting processing: customer invoicing
|
Legal obligation Contract performance |
|
Cookies - Audience measurement (Google Analytics), advertising and functional - Necessary |
Consent
Legitimate interest |
|
Newsletters |
Consent |
3. Data categories and retention periods
APM processes the following personal data:
• Identity, address and contact details: title, surname, name, address, delivery and billing address, e-mail address, telephone number.
The above data is kept until the account is deactivated or after three years of inactivity;
We are not intended for anyone who has not attained age of majority as per the relevant applicable laws that govern such individual. However, it is not possible for us to prevent certain users, including children, from fraudulently representing their age in order to gain access to the website. If you are a parent or guardian and believe we have collected information about your child, please contact us immediately as described in Session B of this Privacy Policy.
• Order-related data: transaction number, purchase details, purchase amount, purchase history, invoice payment data, product return.
The above data is kept until the account is deactivated or after three years of inactivity. However, the invoice is kept for 10 years in accordance with the applicable legal requirements;
• Data on means of payment: credit card number, date of expiry of the credit card, visual cryptogram (which is immediately deleted).
The above data is not retained by APM;
• Cookies: 13 months.
4. Data recipients
The following are the exclusive recipients of the data within the limits of their respective responsibilities:
§ public bodies, exclusively to meet legal obligations;
§ court officers and public officers within the framework of their debt collection duties;
§ financial institutions and professional account-keepers;
§ the payment service provider, the delivery service provider
5. Data Transfers
We hereby transfer the personal information we collect about you to the parent company in Hong Kong, China and countries/areas outside of the country in which the information originally was collected, including the jurisdictions in which our affiliates and service providers operate. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will implement appropriate safeguards to help ensure that we protect that information as described in this Privacy Notice.
To obtain a copy of these security measures or to know how to access them, please send a written request in accordance with Section B hereof.
a) Transfer of personal data from customer files to the parent company in Hong Kong, whose servers are located in Singapore, for customer relationship management purposes
This includes the following information:
Identity, address and contact details: title, surname, name, address, delivery and billing address, e-mail address, telephone number;
Order-related data: transaction number, purchase details, purchase amount, purchase history, invoice payment data, product return.
b) Transfer of personal data to Shopify Inc. servers in the United States from the APM website for hosting purposes
The website apm.mc is hosted by Shopify Inc., whose servers are located in the United States, thus implying the transfer of your personal data to the United States.
This includes the following information:
Identity, address and contact details: title, surname, name, address, delivery and billing address, e-mail address, telephone number;
Order-related data: transaction number, purchase details, purchase amount, purchase history, invoice payment data, product return.
c) Transfer of data for statistical purposes from Google Analytics to Google Inc. in the United States
The transfer concerns “Google Analytics” cookies to the company operating this module, namely Google Inc., located in Mountain View (USA). For a more detailed description of this transfer, please refer to Part C “Cookie Policy” below.
If you are located in UAE onshore, there are three possibilities relating to such transfers. Transfers may occur:
to countries which the UAE Data Office has approved for the purposes of transfers of personal data outside of the UAE pursuant to the terms of the UAE PDPL;
to countries which the UAE has acceded to bilateral or multilateral agreements related to personal data protection to which the personal data is to be transferred;
to operations based in countries where there is no data protection law or approval from the UAE Data Office, and we have entered into a contract or agreement with that other operation that obliges the recipient operation in those countries to implement the provisions, measures, controls and requirements set out in the UAE PDPL, including provisions related to imposing appropriate measures on us, as either controller or processor, through a competent supervisory or judicial authority in that recipient country, which shall be specified in the contract;
In cases where the UAE Data Office has not approved such transfers of personal data outside of the UAE, we will transfer the personal data in any of the following cases:
with your express consent to transfer your personal data outside the UAE in a manner that does not conflict with the security and public interest of the UAE;
if the transfer is necessary to fulfill obligations and establish, exercise or defend rights before judicial authorities;
if the transfer is necessary to enter into or execute a contract between us as a controller, and you as a data subject;
between us as a controller and a third party to achieve your interests as a data subject;
if the transfer is necessary to perform a procedure relating to international judicial cooperation; or
if the transfer is necessary to protect the public interest.
We may also transfer for other reasons that are allowed under executive regulations issued by the UAE Cabinet from time to time.
If you are located in the ADGM, we will comply with applicable legal requirements under the ADGM DPR to place adequate protection for the transfer of personal information to recipients in countries outside of the ADGM that have not been recognized as providing an adequate level of data protection. In this event, we will implement appropriate safeguards, such as Standard Contractual Clauses approved by the ADGM Commissioner of Data Protection, a copy of which can be found here.
6. SECURITY MEASURES
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
7. Links to non-APM Monaco sites and services
For your convenience and information, our Online Channels may provide links to non- APM Monaco sites, apps and services that may be operated by companies not affiliated with APM Monaco. These companies may have their own privacy notices or policies, which we strongly suggest you review. Our products and services also may be made available to you through third-party platforms (such as providers of app stores) or through other third-party channels. We are not responsible for the privacy practices of any non- APM Monaco sites, apps or services.
B. Existence of the right to object, to access and to rectify with respect to your personal data
Pursuant to Subject to applicable law, you have the right to object, access and rectify data concerning you.
To exercise these rights, please send a letter to:A P M MIDDLE EAST JEWELRY TRADING L.L.C (BRANCH).You can also send an email to the following address: DPO@apm.mc
Your letter or email must specify your request and be accompanied by a copy of one of your valid identification documents to enable us to verify that you are the sender of the request.
C. Cookie policy
A cookie is a very small text file that websites, visited by the user, send to the user’s computer or mobile device.
APM MONACO processes different types of cookies:
• Necessary cookies: these are cookies necessary for the operation of our website and for the core services that form an integral part of it. They allow you to use the main features of our website.
• Advertising cookies: these are cookies used to present advertisements or to send you information tailored to your interests on our website or outside.
• Functional cookies: these are cookies that provide you with certain features that are not essential for accessing the service but that significantly improve your visitor experience.
• Analytical cookies: these are cookies that allow us to understand the use, traffic and usage volumes as well as the performance of our website.
Regarding necessary cookies, in accordance with the applicable regulations, your consent is not required.
Regarding advertising, functional and analytical cookies your consent is necessary and can be withdrawn at any time.
Regarding analytical cookies, please note that:
• We use the “Google Analytics” module that implies the transfer of data to the company operating this module, namely Google Inc., located in Mountain View (USA);
• The data processed are the IP address, the user’s Internet domain name, the pages visited and their number, the number of displays per page, the length of time spent on each page, the number of clicks, the name and version of the Internet user’s web browser, the user’s operating system, the timestamp of access to the website and the pages visited on the website.
Analytical cookies will only be activated and used on the website if you give your consent to their use via the banner that is displayed when you visit the website’s home page.
You can choose to accept only technical cookies, to accept all cookies, or to change your choices and consents, at any time, in the cookie preference settings, by clicking on the corresponding buttons in the banner that is displayed at the bottom of the home page when you first visit the website.
In any case, you can also change your cookie preferences on your Internet browser, according to the instructions for each of them, whose links are available below:
Internet explorer: http://windows.microsoft.com/en-us/windows7/block-enable-or-allow-cookies
Safari: http://support.apple.com/kb/PH19255?viewlocale=en_UK
Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=fr&hlrm=en
Opera https://help.opera.com/en/latest/web-preferences/#cookies
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
In this regard, you may refuse the use of Cookies by changing the settings of your web browser as follows:
– On Internet Explorer:
1. Go to Tools & Internet Options
2. Click on the “Privacy” tab.
3. Click on the Advanced button, tick the “Ignore automatic cookie handling” box
– On Firefox:
1. At the top of the Firefox window, click on the Firefox button (Tools menu in Windows XP), then select Options
2. Select the Privacy panel
3. Set the Retention Rules to: use custom settings for history
4. Untick Accept cookies
– On Google Chrome:
1. Click on the Chrome menu icon
2. Select Settings
3. Click on Show Advanced Settings
4. In the “Privacy” section, click on Content Settings
5. Select "Block sites from setting any data"
Lastly, we remind you that you can exercise your rights under the terms and conditions provided for in Article B “Existence of the right to object, to access and to rectify with respect to your personal data” hereof.
