Personal Data Protection

PRIVACY AND PERSONAL DATA PROTECTION POLICY

Version dated 24 September 2026

IMPORTANT NOTICE – ENGLISH TRANSLATION

This English translation of AKRONE’s Privacy and Personal Data Protection Policy is provided for the convenience of English-speaking users and to facilitate their understanding of the original French-language version.

This Policy was originally drafted in French. The French-language version is the authoritative reference version.

In the event of any discrepancy, inconsistency, ambiguity or difference of interpretation between this English translation and the French-language version, the French-language version shall prevail to the fullest extent permitted by applicable law.

Nothing in this notice, or elsewhere in this Policy, shall deprive any individual of mandatory rights or protections which cannot lawfully be waived under the laws applicable to that person, including, where applicable, the laws of their country, State, province or territory of residence.

1. DATA CONTROLLER AND CONTACT DETAILS

AKRONE SAS, whose registered office is located at 3 rue Dugommier, 44000 Nantes – France, is the controller of the personal data processing activities carried out in connection with the operation of the Website, the sale of its Products and its relationship with customers and users, except where a third party acts as a separate controller for a particular service.

For any question relating to personal data protection, AKRONE’s contact details are:

Email: ilovewatches@akrone.fr
Address: AKRONE SAS, 3 rue Dugommier, 44000 Nantes – France

Where applicable law requires the appointment or publication of the identity of a person responsible for the protection of personal information, this role is performed, unless formally delegated in accordance with applicable law, by the President of AKRONE SAS.

Person responsible: Erwan Kerneur, President of AKRONE SAS
Contact: ilovewatches@akrone.fr

This designation does not mean that AKRONE has appointed a Data Protection Officer (“DPO”) within the meaning of the GDPR where such an appointment is not legally required.

2. LEGAL FRAMEWORK AND INTERNATIONAL SCOPE

AKRONE processes personal data in accordance with Regulation (EU) 2016/679 of 27 April 2016 (the “GDPR”), the amended French Data Protection Act No. 78-17 of 6 January 1978, and any other applicable provisions relating to personal data protection and electronic communications.

Where AKRONE’s activities are also subject to applicable foreign privacy or data protection legislation, AKRONE applies the relevant mandatory provisions to the extent that they apply to it.

Depending on the country or territory in which the data subject resides and the activities actually offered by AKRONE in that country or territory, additional rights or obligations may arise in particular under UK, Swiss, Canadian or certain United States privacy laws.

AKRONE takes care to collect and process only data that is adequate, relevant and necessary for the purposes pursued and implements appropriate technical and organisational measures intended to preserve its confidentiality, integrity and security.

3. PERSONAL DATA WE MAY COLLECT

Depending on how you use the Website or interact with AKRONE, we may process in particular:

• identity and contact information, such as your first name, surname, postal address, email address and telephone number;
• information relating to your customer account;
• information relating to orders, pre-orders, invoices, payments, deliveries, returns and withdrawal requests;
• information relating to after-sales service and warranty requests;
• information resulting from your communications with AKRONE;
• information relating to subscriptions to newsletters, promotional operations, surveys or competitions;
• information strictly necessary to manage or verify eligibility for certain special projects;
• technical and connection data.

Transaction data may include, in particular, the amount, payment method used, transaction status and references communicated by the payment service provider.

Data required to authorise card payments is processed by the relevant payment service providers. AKRONE does not intend to retain the card security code or the full payment card number.

Technical data may include, in particular, the IP address, device type, browser used, certain technical identifiers, connection logs, pages viewed and information required for the operation, measurement, security or, where permitted, personalisation of the Website.

In connection with an after-sales service request, eligibility verification or fraud prevention, AKRONE may request any information reasonably necessary for the verification concerned.

An identity document or comparable supporting document is requested only where necessary and proportionate, in particular where there is reasonable doubt regarding a person’s identity or objective indications of fraud.

4. SOURCE OF DATA AND MANDATORY INFORMATION

Data is primarily collected directly from you when you create an account, place an order, contact AKRONE, subscribe to communications or use the Website.

Certain information may also be received from service providers involved in fulfilling your order or operating the Website, including payment providers, carriers, technical service providers or platforms used by AKRONE.

In connection with certain special projects, information strictly necessary to verify a beneficiary’s eligibility may, where legally permitted, be obtained from the relevant organisation or project lead.

Mandatory information is identified as such where necessary.

Failure to provide data necessary for an order, delivery, warranty request or other service may prevent AKRONE from providing the relevant service.

5. PURPOSES AND LEGAL BASES

Processing relating to the creation and management of customer accounts, the placing of orders or pre-orders, payment, delivery, withdrawal, Product returns and management of the contractual relationship is primarily based on the performance of the contract entered into with the customer or on pre-contractual measures taken at the customer’s request.

Processing relating to invoicing, accounting, retention of certain documents and compliance with regulatory obligations is based on the legal obligations to which AKRONE is subject.

Processing necessary for the management of statutory guarantees, the commercial guarantee and after-sales service is based, depending on the circumstances, on performance of the contract and AKRONE’s legal obligations.

Fraud prevention, Website security, account protection, prevention of misuse and defence of AKRONE’s rights may be based on AKRONE’s legitimate interests, provided that such interests do not disproportionately affect the rights and freedoms of data subjects.

Management of a special project, verification of the eligibility of beneficiaries, or management of a competition or specific operation is based on the legal basis appropriate to the relevant operation.

Communications strictly necessary for an order, contract or requested service are sent on the basis of the contractual relationship or pre-contractual measures.

Electronic direct marketing to individuals is based on consent where consent is required.

Where an individual is already an AKRONE customer, certain communications concerning Products or services similar to those previously purchased may be sent under the conditions permitted by applicable law, provided that the individual can object easily and free of charge.

Each commercial communication includes a means of unsubscribing or objecting to future communications where required.

6. RECIPIENTS, PROCESSORS AND THIRD-PARTY SERVICES

Data is accessible to members of AKRONE staff who need it in connection with their duties.

It may also be disclosed, to the extent necessary for their involvement, in particular to:

• technical service providers;
• payment service providers;
• carriers and logistics providers;
• IT service providers;
• e-commerce platforms;
• communication and marketing tools;
• service providers involved in the operation or security of the Website.

The Website relies in particular on the Shopify platform.

For processing carried out for the operation of AKRONE’s online store, Shopify may process certain data on behalf of AKRONE.

Depending on the features enabled and the services offered directly by Shopify to consumers, Shopify or another company within the Shopify group may also act as a separate controller. The corresponding processing activities are then also subject to Shopify’s own privacy information.

AKRONE also uses Klaviyo for certain communications, marketing operations and associated features.

Where Klaviyo processes data on behalf of AKRONE, it acts in accordance with the contractual provisions applicable to data processing.

AKRONE may also disclose certain data to administrative, judicial, tax, customs or other authorised authorities where such disclosure is required or permitted by law.

AKRONE does not sell or rent files containing its customers’ personal data to third parties.

However, certain foreign laws give specific meanings to concepts such as “sale”, “sharing” or behavioural advertising, which may include certain technical transmissions of data. Where such provisions apply to AKRONE, the required information and opt-out mechanisms are made available.

7. INTERNATIONAL DATA TRANSFERS

Certain service providers used by AKRONE may process, host or make data accessible from countries located outside the European Economic Area or outside the country in which the data subject resides.

Where such transfers are subject to the GDPR, AKRONE ensures that they rely on a mechanism recognised by applicable law, including in particular:

• an adequacy decision;
• the EU–U.S. Data Privacy Framework where applicable to the relevant recipient;
• Standard Contractual Clauses adopted by the European Commission;
• approved Binding Corporate Rules, where applicable;
• or another legally recognised mechanism.

Where necessary, such mechanisms may be supplemented by a transfer assessment and appropriate contractual, organisational or technical safeguards.

Where UK law applies, AKRONE uses, where required, mechanisms recognised under the UK GDPR, including UK adequacy regulations and applicable contractual instruments for international transfers.

Where Swiss data protection law applies, disclosures of data abroad are carried out in accordance with the conditions laid down by that legislation.

Shopify states that it uses appropriate legal mechanisms for international data transfers, including adequacy decisions and Standard Contractual Clauses, as applicable, together with other safeguards or transfer mechanisms recognised under applicable data protection laws.

Klaviyo relies, where applicable, on the EU–U.S. Data Privacy Framework, the UK Extension to the EU–U.S. Data Privacy Framework and the Swiss–U.S. Data Privacy Framework. Where the relevant Data Privacy Framework cannot be relied upon, Klaviyo provides for the use of appropriate contractual safeguards, including Standard Contractual Clauses.

Additional information concerning the applicable safeguards may be requested from AKRONE, subject to the limits provided by applicable law.

8. RETENTION PERIODS

Data is retained for no longer than necessary for the purposes for which it is processed.

It may subsequently be deleted or archived where continued retention remains necessary to comply with a legal obligation, establish evidence of a right or defend AKRONE’s interests.

Information necessary to manage a customer account is retained for the period during which the account is used.

Closing or leaving an account inactive does not result in deletion of information which AKRONE is required to retain separately due to legal obligations or for the defence of its rights.

Data required to manage orders is retained throughout the commercial relationship and, where necessary, archived for the applicable statutory retention periods.

Invoices and supporting accounting documents may in particular be retained for ten years.

Data necessary to manage a warranty or after-sales service case is retained for the period required to process the case and thereafter, where justified, for the period useful for evidentiary purposes and the defence of the parties’ rights.

Customer data used for direct marketing may be retained for the duration of the commercial relationship and then for three years from the end of that relationship, subject to any different period required or permitted by applicable law.

Prospect data used for direct marketing may be retained for three years from its collection or from the last contact initiated by the prospect, subject to the same reservation.

Where an individual objects to direct marketing, the information strictly necessary to respect that objection may be retained on a suppression list for as long as necessary for that purpose and may not be used for incompatible purposes.

9. DATA SUBJECT RIGHTS

Depending on the law applicable to your situation, you may in particular have the right to:

• access personal data concerning you;
• have inaccurate data corrected;
• request erasure where the applicable conditions are met;
• request restriction of processing;
• object to certain processing activities;
• exercise your right to data portability where applicable;
• withdraw your consent at any time where processing is based on consent;
• object to the use of your data for direct marketing purposes.

Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

Where French law applies, you may also define instructions regarding the retention, deletion and disclosure of your personal data after your death.

Depending on applicable foreign legislation, you may benefit from additional rights concerning, in particular, certain categories or sources of data, certain recipients, certain uses of sensitive data, certain forms of sale or sharing, certain automated decisions or the review of certain responses to rights requests.

Exercising a right will not result in discriminatory treatment where such treatment is prohibited by applicable law.

You may exercise your rights by contacting AKRONE:

By email: ilovewatches@akrone.fr
By post: AKRONE SAS, 3 rue Dugommier, 44000 Nantes – France

AKRONE may request additional information to verify the identity of the person making the request where there is reasonable doubt concerning their identity.

A copy of an identity document is therefore not required systematically.

Requests are handled within the time limits provided by applicable law.

Where the GDPR applies, AKRONE responds in principle within a maximum period of one month, subject to the extensions permitted by the GDPR.

You may also lodge a complaint with the competent data protection authority where applicable law provides for such a right.

For processing falling within the jurisdiction of the French authorities, the supervisory authority is the Commission Nationale de l’Informatique et des Libertés (CNIL).

10. COOKIES AND OTHER TRACKING TECHNOLOGIES

The Website uses cookies and comparable technologies necessary for its operation, including to ensure Website security, maintain sessions, remember certain preferences and enable operation of the shopping cart and checkout process.

Other tracking technologies may also be used, depending on the features enabled, for purposes including audience measurement, service improvement, personalisation or marketing.

Where a cookie or other tracking technology requires the user’s consent, it is not stored or accessed until valid consent has been obtained.

On the user’s first visit, and thereafter where necessary, the cookie management tool enables the user to accept, refuse or configure non-essential tracking technologies.

Refusing tracking technologies must be as easy as accepting them where this is required by applicable law.

Users may change or withdraw their choices at any time through the preference management tool available on the Website.

Acceptance of the Terms of Use, Terms and Conditions of Sale or any other contractual document does not constitute consent to the storage of tracking technologies requiring specific consent.

Browser settings may also allow users to delete or block certain cookies, but do not replace the choice-management mechanism where such a mechanism is legally required.

The categories of tracking technologies used, their purposes, the third parties concerned and, where applicable, their operating periods are presented in the cookie management tool or corresponding documentation.

Where applicable law requires recognition of a technical signal allowing a user to automatically express a privacy preference or opt-out request, AKRONE implements the required mechanism.

Where choices expressed may apply across multiple devices linked to the same account, users are informed accordingly and must be able to accept, refuse or withdraw their choice with comparable scope and ease.

11. GOOGLE reCAPTCHA AND ANTI-FRAUD SECURITY

AKRONE may use Google Cloud reCAPTCHA, provided by Google LLC, to protect certain forms, accounts or Website features against bots, spam, fraud and abusive automated use.

When active, this service may process technical data necessary for risk analysis and the detection of automated or fraudulent activity.

The processing pursued by AKRONE is based in particular on its legitimate interest in protecting the Website, its users and its systems against abuse, subject to the specific rules applicable to cookies, tracking technologies and similar technologies where these require consent.

Where Google acts for its own purposes as a separate controller, the relevant processing activities are also governed by Google’s own privacy information.

12. NEWSLETTERS, MARKETING AND KLAVIYO

AKRONE uses Klaviyo, in particular, for sending and managing newsletters, commercial communications and certain messages relating to its customer relationship.

Users may unsubscribe from commercial communications at any time using the unsubscribe mechanism included in the relevant messages or by contacting AKRONE.

Following an unsubscribe request, the address will no longer be used for the campaigns to which the objection applies.

However, a minimum amount of information may be retained on a suppression list in order to prevent accidental re-subscription or further unwanted communication.

Depending on the configuration used, Klaviyo and messages sent through it may enable measurement of deliverability, message opens or certain interactions.

Where such measurements use pixels or technologies requiring consent under applicable law, they are implemented in accordance with the choices expressed by the individual.

Where processing legally benefits from a regime not requiring prior consent, all other applicable information and objection requirements continue to be respected.

13. PROFILING AND AUTOMATED DECISION-MAKING

Certain technologies used in connection with the Website may enable analysis of behaviour or preferences, including for fraud prevention, security, measurement, personalisation or marketing purposes where such purposes are legally permitted.

Where applicable law classifies processing as profiling or requires specific information concerning identification, location or profiling technology, AKRONE provides the required information and choice mechanisms.

If AKRONE were to implement a decision based solely on automated processing that produces legal effects or similarly significantly affects an individual, that person would receive the information and safeguards required by applicable law, including, where applicable, rights to human intervention, challenge or review.

14. INTERNATIONAL USERS

AKRONE is a company established in France.

This Policy is primarily structured around the requirements of French and European Union law, while taking into account the international development of AKRONE’s activities.

Where AKRONE’s activities are also subject to mandatory foreign legislation, such legislation applies to the extent provided by the relevant rules.

Additional information or privacy notices may be made available for certain territories where necessary.

United Kingdom

Where AKRONE’s activities fall within the scope of the UK GDPR or the Data Protection Act 2018, data subjects benefit from the protections and rights provided by those laws.

Where applicable law requires AKRONE to appoint a representative in the United Kingdom, the representative’s identity and contact details are made available in accordance with that law.

Switzerland

Where AKRONE’s processing activities fall within the scope of the Swiss Federal Act on Data Protection, the rights and obligations provided by that legislation apply.

Where the statutory conditions requiring the appointment of a representative in Switzerland are met, the representative’s identity and contact details are made available in accordance with applicable law.

Canada and Québec

Where AKRONE’s activities are subject to Canadian or Québec privacy legislation, the corresponding obligations and rights are applied to the extent required.

Where Québec law applies, the person responsible for the protection of personal information may be contacted using the details set out in Section 1 of this Policy.

Where required, AKRONE applies applicable rules relating in particular to personal information governance, confidentiality incidents, privacy impact assessments, transfers or disclosures outside the relevant territory, profiling and individual rights.

United States

Certain US federal or State privacy laws may become applicable to AKRONE where their legal applicability criteria or thresholds are met.

Where any such legislation applies, AKRONE grants the relevant individuals the rights provided by that legislation and implements the required information and mechanisms.

Depending on the applicable regime, such rights may include rights of access, correction, deletion or portability, as well as rights to opt out of certain forms of sale, sharing, targeted advertising or use of sensitive data.

Where applicable law requires recognition of a signal such as Global Privacy Control, AKRONE respects that signal under the conditions provided by the relevant legislation.

15. DATA SECURITY AND PRIVACY INCIDENTS

AKRONE implements appropriate technical and organisational measures to protect personal data against destruction, loss, alteration, disclosure or unauthorised access.

These measures are adapted to the nature of the data processed, the purposes of the processing and the identified risks.

Access to data is restricted to individuals and service providers who need it in connection with their duties.

As no information system can provide absolute security, AKRONE adapts its measures in light of changing risks, technologies and reasonably available means.

In the event of a personal data breach or privacy incident, AKRONE applies the documentation, assessment, authority notification and, where required, data subject notification procedures provided by applicable law.

16. CHILDREN

The Website and Products marketed by AKRONE are not specifically intended for children.

AKRONE does not intend knowingly to collect personal data relating to minors beyond what may be necessary in a legally permitted situation.

Where processing of a minor’s data requires authorisation or consent from a person holding parental responsibility under applicable law, AKRONE implements the required measures.

17. CHANGES TO THIS POLICY

AKRONE may amend this Policy to reflect changes in its services, tools, service providers, processing activities, geographic markets or applicable law.

The version published on the Website states the date on which it was last updated.

Where a change materially affects the way personal data is collected, used, disclosed or protected, or affects the rights of data subjects, AKRONE provides appropriate notice where required by applicable law.

Where applicable law requires prior notice, renewed consent or any other specific formality, AKRONE follows the required procedure.

18. CONTACT

For any question concerning this Policy, the use of your personal data or the exercise of your rights:

AKRONE SAS
3 rue Dugommier
44000 Nantes – France

Email: ilovewatches@akrone.fr

Person responsible for the protection of personal information, where this function is applicable: Erwan Kerneur, President of AKRONE SAS