Talent Privacy Notice

This Talent Privacy Notice (the “Talent Privacy Notice”) explains how Richemont, including each of its Maisons and operating entities (all of which we refer to as “Richemont”, “we”, “our” and “us”), uses personal information about its job applicants, potential candidates for employment, those who have participated in recruiting events and individuals who have expressed an interest in working at Richemont (referred to as “you” or “your”). The definition of personal information can vary from country to country, but it generally means any information that relates to an identified or identifiable individual. Personal information excludes anonymous or de-identified data that is not associated with a particular individual.

This Talent Privacy Notice is provided by the local entity in which you apply for a job, attend a recruitment event or express an interest in Richemont (“recruitment process”) which is considered to be the “data controller” for the purposes of certain data protection laws and regulations. In addition, Richemont International SA will also be considered an independent “data controller” in respect of certain processing activities when it is not the main recruiting or hiring entity.

This Talent Privacy Notice documents what personal information we collect about you, for what purposes we process such personal information, how we secure your personal information, when we may disclose your personal information to third parties, and when we may transfer your personal information outside of your home jurisdiction. This Talent Privacy Notice also describes your rights regarding the personal information that we hold about you, including how you can access, correct, and request erasure of your personal information.

This Talent Privacy Notice applies to you whether you are or used to be a job applicant, potential candidate for employment, or participated in recruiting events.

We will only process your personal information in accordance with this Talent Privacy Notice, including Richemont’s Privacy Commitments, unless otherwise required by applicable law.

Please note that this Talent Privacy Notice may be supplemented by any local requirements relevant to your place of application or participation as will be further set out in the Appendix to this Talent Privacy Notice (if any).

Privacy is built into all of our products and services by design and by default. We respect the trust you place in us with your personal information. We will be fully transparent with you regarding the purposes for which we use your personal information and will only use it for those specified purposes when we have a right to do so. This will include, where necessary, obtaining your explicit consent. Any material changes to how we process your personal information will be notified to you.

We commit to implementing leading data protection, privacy and security standards so that you feel comfortable that your personal information is protected – if there is an incident impacting your personal information, we commit to notifying you and/or relevant regulators in accordance with data breach notification requirements. Your personal information will be handled with the same protection when it is shared with third parties or when it is transferred internationally. We will only retain your personal information for as long as is necessary or for as long as required by law.

We will respect the choices you make in relation to your personal information. We will respect the legal rights you have in relation to accessing, erasing and updating the personal information that we hold about you. We will also respect the choices you make in relation to objecting to how we process your personal information and will provide channels for you to contact us with questions or complaints.

Data protection and privacy compliance is central to how we process personal information.

What this means for you

‘Privacy by Design’ is an approach that helps us ensure that data privacy is not an afterthought. Before we start to process personal information, we assess a number of privacy-related factors, including the state of technology, the cost of implementation, the scope, context and purposes of the processing, as well as the risks to individuals, including our job applicants.

We must provide you with clear, transparent and comprehensive information about what personal information we collect from you.

What this means for you

We collect various types of personal information about you in connection with the recruitment process at Richemont. This may include the following categories:

• Contact details: including name, title, address, telephone number, personal e-mail address, emergency contact details, etc.
• Financial information: including information relating to your existing compensation and benefits, such as salary, bank account information, tax codes, tax identification number, social security number and/or any other government identifier or other benefits, etc.
• Recruitment information: including information obtained through your recruitment process, such as your Curriculum Vitae (CV) or résumé, cover letter, photograph, application form, notes of job interviews and evaluations, preferences relating to location and salary, third party references and past records, academic and professional transcripts and qualifications, psychometric test results, drug and alcohol test results (where relevant), information obtained from background checks such as criminal convictions and financial history (where relevant and permitted by law), publicly available information such as details obtained via social media and other personal information such as conflicts of interests (including family networks), personal or business contact information, etc.
• Onboarding administration information: including date of birth, marital status, gender, new joiner information such as proof of identification (passport, ID card etc.) and immigration records (visa, work permit etc.) and associated documentation, terms and conditions of employment, photographs, driver’s licence details and associated documents, start date and, if different, the date of your continuous employment, talent management records, training records, employment and career history (including details of specific project and work assignments) and termination details.
• Location/access data: including details of your whereabouts in Richemont locations and buildings to the extent recorded by Richemont’s electronic card access systems, IT systems, CCTV and other such electronic systems.
• Benefits data: including details relating to the administration of employee benefits, such as health insurance programmes, pension or retirement schemes, including information about any dependents or beneficiaries (e.g. spouse, domestic partner, or children).

Where lawful to do so (for example, with your consent or where required to do so by law), we may also collect the following types of data for equal opportunities monitoring purposes as required by applicable equal opportunities legislation:

• Special categories of personal information: including personal information that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (as relevant), sexual orientation, and data related to your physical or mental health, including any health information, including medical; health conditions, disabilities or required accommodations.
• Criminal convictions and offences data: including personal information that reveals details of actual or suspected crimes such as fraud, arrests, convictions, unspent convictions, driving offences and proceedings relating to the same (where relevant and permitted by law).

The Richemont entity who is the main recruiting or hiring entity will usually collect the personal information from you directly. In some instances, it may be collected from third party sources such as employment/recruitment agencies or from other Richemont entities (such as where you undertake a secondment). In addition, your personal information may be obtained from publicly available sources, such as professional networking websites. You may provide personal information about a third party (such as your partner or dependent), and we will process that personal information under the terms of this Talent Privacy Notice. In this context, you shall inform the third party of the processing of their personal information by Richemont and provide them with this Talent Privacy Notice.

We must have a lawful basis for collecting and processing personal information.

What this means for you

Any personal information that is collected under this Talent Privacy Notice will have a specific purpose for which it is collected and a lawful basis for its processing, which include:

• The processing is necessary for the performance of a contract to which you are party (including an employment contract) or in order to take steps at your request prior to entering into a contract.
• The processing is necessary for compliance with a legal obligation (other than a contractual obligation) to which Richemont is subject. This could include, for example, if we need to check that you have a visa, work permit or other proof of your legal entitlement to work in your country.
• The processing is necessary to protect your vital interests or the vital interests of another person (for example, where we need to give someone’s name to the police in the case of an emergency).
• The processing is strictly necessary for the purposes of legitimate interests pursued by Richemont or a third party, and those interests are not overridden by your own interests, fundamental rights and freedoms.
• We have obtained your consent to process your personal information for a specific purpose or for specific purposes. You can withdraw your consent at any time and it will become effective once we have received a valid request from you. Please note we do not need your consent if we use special categories of your personal information to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your explicit consent to allow us to process certain special categories of personal information. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Please be aware that if we are no longer able to rely on one lawful basis (e.g. you withdraw your consent), alternative lawful grounds may sometimes apply to justify continued processing of your personal information by Richemont for a particular purpose.

We need to ensure that personal information is only used for the purposes for which it is collected and that it is not processed further in a way that is incompatible with those purposes.

What this means for you

The table below sets out the specific purposes, categories of data and lawful basis. More information about how we use special categories of your personal information is set out underneath the table. The lawful basis relied upon may also vary from country to country depending upon the applicable law, including where additional lawful bases are available.

Special categories of personal information

Where we process special categories of your personal information, certain applicable laws require us to demonstrate an additional lawful basis. For example, such processing is often necessary for us to perform obligations and exercise specific rights in the field of employment law. This may include: (i) information about health concerns or disabilities, for which Richemont may be required to make reasonable adjustments during the recruitment process; (ii) pre-screening checks (where relevant) if you are selected for a specific position; or (iii) information related to gender, religious affiliation, sexual orientation, disabilities, race, ethnicity or other defining characteristics for equal monitoring purposes.

We only process personal information that is adequate, relevant and limited to what is necessary in relation to the purposes for which the personal information is processed.

What this means for you

We limit the personal information that we collect and further process to only the personal information that we need in connection with the purpose(s) for which it was originally collected. Where we want to collect extra personal information which we do not actually need, we will make clear which personal information we need and which personal information is voluntary.

We may also convert your personal information into statistical or aggregated form so that you are not identified or identifiable from it, for the purposes of conducting research and analysis, including producing statistical research and reports.

We will ensure that personal information is accurate and kept up-to-date, and we will take every reasonable step to ensure that inaccurate data is corrected or erased without delay.

What this means for you

Our data needs to remain accurate. We can help achieve this, for example, by actively encouraging you to tell us promptly if your personal information changes, by conducting regular checks for inaccuracies, and by taking appropriate steps when our relationship comes to an end.

We may occasionally update this Privacy Notice. When we do, we will publish it on the Richemont website.

What this means for you

If there are material changes to this Talent Privacy Notice or in how Richemont uses your personal information, we will use reasonable efforts to notify you by prominently posting a notice of such changes before they take effect on our website. We encourage you to periodically review this Talent Privacy Notice to learn how Richemont protects your personal information.

We ensure that personal information is protected against unauthorised or unlawful use and against accidental loss, destruction or damage.

What this means for you

We are committed to protecting the personal information we collect from you by implementing leading data protection, privacy and security standards. We limit access to personal information to our employees, staff and contractors who reasonably need access to it. We have appropriate technical and organisational physical, electronic, and procedural safeguards to protect personal information against unauthorised or unlawful processing and against accidental loss, damage or destruction. In order to achieve this, we have put in place all necessary security and operational policies.

We only share personal information with others when we are permitted by law to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information shared and to comply with our data protection, confidentiality and security standards and obligations.

What this means for you

We will share your personal information only with people within Richemont (including our Maisons, Richemont entities, and affiliates of Richemont) who “need to know” that information. 

In addition, we share your personal information with our authorised third party service providers who will process that information on our behalf and with our other authorised partners who may act as independent data controllers and process such information under their own responsibility. Examples of third parties with whom we share personal information include: 

Our affiliated group companies; 

Service providers (including data processors, recruitment management platforms, background screening providers (for the purposes of conducing background, criminal records or credit reference checks) and external recruitment agencies); 

Professional advisors (including law firms, auditors or consultants); 

Regulatory and law enforcement authorities (including the police and the courts);

Entities involved in our mergers and acquisitions; and

Hotels, airlines and other business travel-related third parties (if recruitment process involves travel arrangements).

Where we engage a service provider that may be handling your personal information, we will only use service providers who we can trust to protect that information.

We process personal information within our Group both locally and internationally, mainly using centralised servers. We may also transfer personal information to third parties abroad, such as our service providers.

What this means for you

As a global Group doing business across national borders, there are situations where your personal information will be transferred to a Richemont entity or a service provider outside of Richemont based in a country not related to any recruitment process, including countries that may afford less legal protection to your personal information. We take steps to protect your personal information when it is transferred in this way (including by implementing appropriate safeguards). If you are in Europe, safeguards may include the Standard Data Protection Clauses (also known as Standard Contractual Clauses). Please do not hesitate to contact us should you wish additional information in this respect.

We will undertake data protection impact assessments for any type of processing that is likely to result in a high risk to the rights and freedoms of individuals.

What this means for you

We will periodically conduct risk assessments related to the processing of personal information, especially when introducing new or innovative technologies or functionalities. In certain circumstances, these new technologies or functionalities may require us to provide enhanced privacy notices and/or consent forms to ensure that we continue to meet our privacy commitments.

We will ensure that personal information is not kept in a form that enables someone to be identified for any longer than is necessary for the purposes for which the personal information is processed.

What this means for you

We keep personal information for as long as is necessary for the purpose(s) for which we originally collected it, and in particular to protect ourselves in the event of a legal claim (for example, information relating to your application with Richemont may be kept for the lifetime of the contract and for several years after). Any deletion or retention of your personal information will be consistent with applicable Richemont retention policies.

Examples of the criteria that we use to determine retention periods for personal information include one or more of the following:

1. Retention in case of queries.
   For instance, if you apply for a position and are unsuccessful, Richemont will retain personal information relating to your application and interview notes for a reasonable period in case you have queries.
2. Retention in case of claims.
   Richemont will retain certain personal information for the period in which you might legally bring claims.
3. Retention for Richemont’s compliance with law and regulation.
   Richemont will retain certain personal information for the periods that are necessary in view of its compliance obligations.

You may, depending upon where you are based and which Richemont entity is processing your personal information, have certain rights under data protection and privacy laws in relation to your personal information.

What this means for you

You are under no statutory or contractual obligation to provide data to Richemont during the recruitment process. However, if you do not provide the information, Richemont may not be able to process your application properly or at all. If your application is successful, it will be a condition of any offer of employment that you provide evidence of your right to work in the country within which the position is based and provide satisfactory references.

In certain jurisdictions, such as the European Union, Switzerland and the United Kingdom, as well as countries in the Americas, Asia Pacific, Japan and the Middle East, India and Africa, you are able to exercise specific rights in relation to your personal information. The exercise of these rights is at all times subject to compliance with the applicable legal and regulatory framework:

Right of access: You have the right to ask for access to any personal information that is being processed by us.

Right to erasure/restriction of processing: In some circumstances, you have the right to request the erasure of your personal information or to restrict how we use it.

Right to update or correct: You have the right to ask us to correct any inaccurate personal information and to update any out-of-date personal information.

Right to object: You have, in certain circumstances, the right to object, on grounds relating to your particular situation, at any time to the processing of personal information concerning you which is carried out on the basis of legitimate interests.

Right to data portability: In some circumstances, you have the right to request from us the personal information concerning you in a structured, commonly used, machine-readable format.

Right to withdraw consent: If you have given us consent to process your personal information, you can withdraw this consent at any time with effect for the future. The withdrawal does not affect the lawfulness of the processing carried out on the basis of this consent until the withdrawal.

Right to complain: If you think we have processed your personal information in a manner that is unlawful or breaches your rights, you have the right to complain to a relevant data protection authority.