Privacy Policy

//Collection and Use of Personal Information for sending e-newsletter and marketing purposes, and enquiry (See more) //

L’Ecole Van Cleef & Arpels (hereinafter “we”, “us” and “our”), with its registered office at 22 Place Vendôme, 75001 Paris, France, hereby establishes and discloses the following personal information management policies for the protection of personal information of data subjects and a prompt and smooth management of any grievances thereon in accordance with the Personal Information Protection Act (the “Act”).

Article 1 (Purposes of Managing Personal Information)

1.1 We may process your personal information for the purposes listed below on the basis of the following justifications:

Consent: this is the legal basis when you have given clear consent for us to process your personal information (for example, where you consent to receiving marketing information).

Performance of a contract: the processing is necessary for a contract we are entering into with you (including compliance with our Terms of Use), or because we have asked you to take specific steps before entering into a contract (for example, processing your contact information relating to the purchase and delivery of a course or product).

Legitimate interests: the processing is necessary to pursue our legitimate interests, provided these interests clearly outweigh the rights of the data subject. In such cases, processing will only be carried out to the extent that it is substantially related to our legitimate interests and does not exceed a reasonable scope.

Legal obligation: the processing is necessary for us to comply with the law (for example, a court order).

Other grounds: the processing may on occasion be necessary for other legal reasons such as to prevent and detect crime, to protect life or the processing is otherwise in the public interest.

1.2 We shall manage personal information for the following purposes on relevant justification. The personal information being managed shall not be used for any purpose other than those described in the following, and in the event of any material change to such purposes, we shall take required actions such as separately obtaining consent to such change or posting the revised policies on the website pursuant to the Act.

1. Provision of courses, goods or services, dealing with enquiries and requests, and management of accounts and records
   
   We shall manage personal information to manage and fulfil purchase orders, sending of agreements and invoices, delivery of contents, delivery of customized services, identity and age authentication, payment or settlement of fees, and collection of debts, dealing with customers’ requests and enquiries, and management of our accounts and records etc.  We shall manage personal information to send service-related communications, including announcements and administrative messages such as order confirmation and to manage and fulfil purchase, gift and returns, to facilitate delivery and to provide after-service care.
    
2. Management of grievances and legal compliance
   
   We shall manage personal information for the verification of the identity of a person who filed a complaint; identification of the matter being complained of; contact and notification for inquiry of facts; and notification of the result of the grievance management, etc.
    
3. Customer management, market research, personalized services and marketing
   
   We shall manage personal information:

• to deal with your enquiries and requests;
• for the purposes of sending you e-newsletters, catalogue, newsletter subscription, and marketing communications, direct marketing and advertisements in the business areas in which it operates and of providing information related to courses, products, services or events relating to us and other third party partners that we think may be of interest to you through online display ads or using communication channels you have provided, including by telephone, email, post and electronic or text messages (including Kakao Talk, WhatsApp, Line or other one-t-one communications), and delivering personalized messages or advertising on social media or other digital platforms ;  
• to share your personal information (such as your email address, usually in an encrypted or “hashed” form, or specific cookie data) with social media and other platforms or other service providers for the purpose of custom audience or lookalike matching, or intra-group client/prospect matching for marketing purposes;
• to conduct customer satisfaction survey and market research based on your purchases via your account or guest checkout so that we can continuously improve the service we provide to our customers; and
• to understand how our website and platforms are used so that we can continuously improve our platforms, services and other offerings.
   

4. Provision of integrated services
   
   We provide the services, as integrated services of 1 to 3 above, from all channels, including websites, mobile applications, campuses.
    
5. Events, appointments and communities
   
   We process your personal information for the purposes of organising and running events, campus appointments, including registering you as a member, attendee or speaker, or reporting or logging a health and safety incident that you may have suffered or assisted with. We may also take photographs or make video or voice recordings of you at one of our events for promotional purposes.
    
6. Regulatory compliance, credit checking and prevention of prohibited activities
   
   We process your personal information for the purposes of undertaking anti-money laundering or international sanctions compliance, credit checking, prevention of fraud and other prohibited or illegal activities as part of our efforts to keep our Platforms and services secure or as otherwise required to respond to a legitimate request from a third party (for example, a regulatory or police authority or financial institution). We reserve our rights not to provide courses, products and/or services to you where we have a legitimate reason not to do so in accordance with applicable law.
    
7. CCTV, video surveillance & Wifi processing
   
   We process your personal information using CCTV and video surveillance data for the prevention and detection of crime, assisting law enforcement agencies in the apprehension, investigation and prosecution of offenders, ensuring the safety of our staff, visitors and property and, occasionally, to monitor activity on our sites and campuses or WiFi browsing. For CCTV and video surveillance, please see Article 10 (Installation and Operation of CCTV) below.
    
8. Platform support, maintenance and security
   
   We process your personal information in connection with administering and protecting our business and the platforms (including troubleshooting, dealing with error messages, data analysis, testing, system maintenance, support, reporting and hosting of data).
    
9. Receipt of courses, products and services from suppliers
   
   We process your personal information for the purposes of benefiting from any courses, products or services provided by you or your organisation, where you are, or your organisation is, a supplier.
    
10. Business administration and legal compliance
    
    We process your personal information for the purposes of the administration of our business or to comply with our legal obligations.
     
11. Enable a corporate transaction such as a merger & acquisition
    
    We process your personal information for the purposes of any merger or acquisition activity and we will disclose your personal information to any third party that purchases, or to which we transfer, all or substantially all of our assets and business.

※ In commercial activities, we assume that a customer have the appropriate capacity for civil conduct. We understand the importance of safeguarding the personal information of minors. The platforms are not directed at any minor who we know to be under the age of 14, nor do we collect any personal information from any minor who we know to be under the age of 14. We may collect your birthday information to verify your age. If you are under the age of 14, you should not use the platform and should not submit any personal information to us. In case we find that you are under the age of 14 but you submit your personal information to us, we will terminate services to you (including account cancelation) and delete such personal information as soon as possible.

Article 2 (Personal Information Items Under Management)

2.1 We manage the following items of personal information with the consent of customers in accordance with Article 15(1)(1), 22(1)(7) of the Act.

1. Information that may be collected from the website
   Purpose of collection: subscription to newsletter, deal with customers’ enquiries and requests
   1.    Enquiry (Contact us)
   -    title, first name, last name, email address, phone number, enquiry details, purchase details
   
   2.    Newsletter subscription
   -    title, first name, last name, email address
    
2. Information that may be collected when doing customer survey during offline events/sites/campuses

• Purpose of collection: measure customer satisfaction and experience to improve our services to customers
• Personal information: title, first name, last name and email address if wishing to be contacted for enquiries and any information voluntarily provided by customers
   

3. Information collected through our mobile applications or when you interact with us over social media or other digital platforms

• Purpose of collection: answering customers’ queries on courses, goods and services, making campus appointments and providing information, customer management and marketing, analyzing preferences or interests of customers and update the contents, and location services.
• Personal information: name, mobile number, email address, social media ID, and any information that customers voluntarily provide
   

4. Information about your behaviour, interests, preferences (such as courses, products, topics and channel and frequency of communication), wish lists, hobbies, client interactions and marketing campaign activities, opinions, customer reviews, demographic data, habits, celebration events, purchasing reviews and feedback as well as your general purchasing tendencies

• Purpose of collection: to have a full understanding of our clients.
• Personal information: name, phone number, email address, transaction records, preferences and communication, and any information voluntarily provided by customers
   

5. Photos and video recordings

• Purpose of collection: to take measurements from you required for our courses, products and/or services (using some of our technology products, including connected mirrors, augmented reality technologies or photo booths, collect) and to take photos or video in our events attendance
• Personal information: photos and video or voice recordings
   

6. Information you provide about third parties (for example, friends and family members upon their consent to providing their information to us)

• Purpose of collection: to provide requested courses, products or services to customers
• Personal information: name, address, date of birth, email address, telephone number, marital status, wish list, hobbies and preferences
   

2.2 We manage the following items of personal information without the consent of customers or relevant individuals.

1. Services that require processing of customers’ personal information, including courses or product reservations and sales, service communications, programme updates, announcements and administrative messages, such as acknowledgement and confirmation of, or changes to, orders and shipment, confirmation of, or changes to, event or appointment bookings, to notify you about changes to our terms or privacy policy as well as send you service-related messages when you abandon your shopping cart or browsing session unexpectedly

• Legal Grounds: Article 15(1)(4) of the Act (Performance of Contracts)
• Personal information to be collected and used: Order and delivery details and payment information
   

2. Legal obligations to comply with the laws and regulations or with the authorities’ requests in accordance with the law

• Legal Grounds: Articles 15(1)(2) of the Act
• Personal information to be collected and used: as required by the relevant law or requested by relevant authorities, which may include passport information, national ID card data and the information described in Article 2.1 above.
   

3. Our legitimate interests (such as operating our business, protecting against fraud, or ensuring the security of our Platform), provided these interests clearly outweigh the rights of the data subject. In such cases, processing will only be carried out to the extent that it is substantially related to our legitimate interests and does not exceed a reasonable scope.

• Legal Grounds: Article 15(1)(6) of the Act
• Personal information to be collected and used: information described in Article 2.1 above.
   

4. Prevention and detection of crime, protecting life or in the public interest (provided this is limited to cases where it is clearly necessary for the imminent protection of the life, body, or property of the data subject or third party, or where it is urgently required for public safety and well-being, such as in matters of public health):

• Legal Grounds: Articles 15(1)(5) and 15(1)(7) of the Act
• Personal information to be collected and used: information described in Article 2.1 above.

2.3 “Information we collect from third parties about you”: Information collected about you from third parties and from publicly available sources, including our social media platforms, advertising and marketing partners, analytics providers, and third parties that provide technical or strategic data services to us and we may collate such information with other information that we have.

• Legal Grounds: Articles 15(1)(1), 17(1)(1) and 18(2)(1) of the Act
• Purpose of collection: providing customer services (including customer care, after-sale services), customer profiling, market research and personalized advertising.
• Personal information: name, phone number, email address, transaction records, preferences and communication; and any information voluntarily provided by customers

2.4 Information that may be collected through customers’ access to and use of the website: we operate a computer system whereby we collect IP address (where available), MAC address, service usage records, visit records, improper usage records and other information collected by automatic tracking technologies, such as Cookies.

Cookies are text files, containing small amounts of information, which are downloaded to your computer or mobile device when you visit a website or mobile application. They are used to recognize your computer as you move between pages on a website, or when you return to a website or mobile application you have visited previously.  Cookies are widely used in order to make platforms work, or to work more efficiently, as well as to provide information to the owners of the Platform.

We use this information to enhance the online experience of our visitors (for example, by remembering your language and/or product preferences) and to better understand how our Platforms are used. Cookies will tell us, for example whether you have visited our Platforms before or whether you are a new visitor.  They can also help to ensure that adverts you see online are more relevant to you and your interests. 
 

Cookies and other information that we automatically collect

1. There are two broad categories of cookies:

• First party cookies, served directly by us to your computer or mobile device. They are used only by us to recognise your computer or mobile device when it revisits our Platform.
• Third party cookies, which are served by a third-party service provider on our Platform and can be used by the service provider to recognise your computer or mobile device when it visits other platforms. Third party cookies are most commonly used for platform analytics or advertising purposes.

Cookies can remain on your computer or mobile device for different periods of time. We use both 'session cookies' and ‘permanent cookies’. Session cookies exist only while your browser is open and are deleted automatically once you close your browser. Permanent cookies survive after your browser is closed and can be used to recognise your computer or mobile device when you open your browser and browse the internet again.

2. What cookies do we use?

The Platform serves only the following types of cookies to your computer or mobile device:

3. Purpose of collection: analysis of the frequency of customers’ visit and use of the website; implementation of targeted marketing (for example, to ensure that the adverts you see online are more relevant to you and your interests); provision of customized or personalized service (for example, to remember your language and/or product preferences); analysis of preference or interests of customers; and upgrade and improvement of the website and its contents; and provision of membership services; internal reporting

4. Control and deletion of cookies: The use of cookies does not always require your express consent. In particular, technical cookies do not require such consent as far as they are necessary to provide a service expressly requested by the user.  You have the right to refuse the use of cookies at any time and we have explained how you can exercise this right below.
   
   However, please note that if you choose to refuse cookies you may not be able to use the full functionality of our Platforms.
   
   You can set your cookie preferences by changing your browser settings so that cookies from this Platform cannot be placed on your computer or mobile device.  In order to do this, follow the instructions provided by your browser.

• Allow/block cookies in web browsers
  • Chrome: Select ⁝ on the top right of the web browser > New secret window (shortcut: Ctrl+Shift+N)
  • Edge: Select ... on the top right of the web browser > New InPrivate window (shortcut: Ctrl+Shift+N)

• Allow/block cookies in mobile browsers

  • Chrome: Select ⁝ on the top right of the mobile browser > New secret window
  • Safari: Mobile device settings > Safari > Advanced > Block all cookies
  • Samsung Internet: Select “Tab” icon at the bottom of the mobile browser > Turn on the secret mode > Start
     

  If you would like to learn more, please visit http://www.aboutads.info/choices/ and https://globalprivacycontrol.org/ .  More detail on how businesses use cookies is available at www.allaboutcookies.org.  We are not responsible for effectiveness of or compliance with any third parties’ op-out options.
   

5. About advertising: The Platforms use third parties such as network advertisers and ad exchanges to serve you ads on third party platforms after you leave our Platforms, and we use third party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Platforms and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which are based on your visits to the Platforms and other apps and sites you have visited. Third party ad serving enables us to target advertisements to you for products and services that you might be interested in. 
   
   Third party tracking technologies are not controlled by us, even if they are associated with our Platforms or our ads. Statements regarding our practices do not apply to the methods for collecting information used by these third parties and others or the use of the information that such third parties collect. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties, such as Meta. 
   
   You have choices in respect of the delivery of ads. You can opt-out of receiving certain types of behavioral ads by visiting the third party websites described in the section headed “How to control or delete cookies” described in this Article paragraph 4 above. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.
    

Article 3 (Management and Retention Period of Personal Information)

1. We shall manage and retain personal information within the legal retention and use period of personal information or within the retention and use period of personal information consented to by the data subject at the time of collecting personal information.
 

2. The period of managing and retaining personal information for the purposes set out in Article 1 is as follows:

1. For the provision of courses, goods or services, we shall manage and retain personal information until the completion of the supply of such courses, goods or services, and the completion of the payment or settlement of fees; provided, however, that the personal information necessary for our accounting treatment or reflected in the books and records material to our business shall be maintained for 10 years pursuant to the Commercial Code of Korea.
2. For management of grievances and legal compliance, we shall manage and retain personal information until the service or follow-up service of customers’ grievances and complaints is completed.
3. For customer management, market research, personalized services and marketing, the personal information will be managed and retained until the time it is withdrawn by the customer.
4. For the provision of integrated services, we shall manage and retain personal information until 2 months following the withdrawal of your consent.
5. Notwithstanding the foregoing, we may retain customers’ personal information for a longer time period as required by applicable laws or government orders.

• Records on the contract or subscription withdrawal, etc.: Stored for 5 years pursuant to the Act on the Consumer Protection in the Electronic Commerce Transactions, etc.
• Records on the payment and supply of goods, etc.: Stored for 5 years pursuant to the Act on the Consumer Protection in the Electronic Commerce Transactions, etc.
• Records on the consumer complaints or dispute settlement: Stored for 3 years pursuant to the Act on the Consumer Protection in the Electronic Commerce Transactions, etc.

Article 4 (Consignment/Delegation of Management of Personal Information to Overseas Affiliates for Processing)

1. We shall manage the personal information of data subjects within the extent set forth in Article 1 (Purposes of Managing Personal Information). In order to better service customers and properly gather, process and manage customer data, we may delegate the management and processing of such personal information to its overseas affiliates listed in paragraph 6 below, in accordance with Article 28-8(1)(3)(a) of the Act, as necessary for execution and performance of contracts. We have entered into an agreement for delegation of personal information processing services with such entities.
    
2. The date/time and method of transfer: transfer of personal information is carried out from time to time during the provision period of the services via electronic transfer.
    
3. The purposes of delegating the management and processing of the personal information include providing technical and IT system, storage and support for client data, conduct analysis and research based on transactions (including analysis of purchase preferences), arranging logistics and product delivery, providing customer services and all other sale, customer card and after-sale services, handling customer’s requests and complaints, and providing customer communication services (including sending e-newsletter and marketing communications on our behalf).
    
4. Items of personal information to be transferred are specified in Article 2 above.
    
5. Retention period of personal information performed for consignment work will be in accordance with Article 3.
    

6. We shall ensure that all persons and affiliates receiving such personal information shall make best efforts to make sure that the information of data subjects is safely retained according to the Act and relevant laws. We will delegate the personal information processing and management services to the following overseas affiliates:
    

   Name of affiliate	Location and country	Email address
   Richemont International SA	Route des Biches 10, 1752,  Villars-sur-Glâne,  Switzerland	Client Data Representative: helena.gobin@vancleefarpels.com
   Richemont Asia Pacific Limited	6/F Jardine House,  1 Connaught Place,  Central Hong Kong	Client Data Representative: helena.gobin@vancleefarpels.com

• Sub-consignees of Richemont International SA:
  • Registration services
    • Company name: EVENTTIA OÜ
    • Details of the duties consigned: On-site registration, survey and data capture of the visitors
  • Cloud services
    • Company name: AWS
    • Details of the duties consigned: cloud solutions and data storage
  • Client satisfaction survey
    • Consignee : EVENTTIA OÜ and Microsoft Form
    • Details of the duties consigned: Conducting post-event surveys about client satisfaction levels on our behalf
  • Client relation management & marketing automation service
    • Consignee: Brevoand Selligent
    • Details of the duties consigned: CRM and marketing service solution

7. At the time of entering into consignment/delegation agreements, we specify in the agreements etc. the matters relating to prohibition of processing personal information beyond the purpose of performing the consigned duties, technical and administrative protection measures, restriction on re-consignment, management and supervision of the consignee, compensation for damages and etc., and supervises a safe management of personal information by the consignee in accordance with the Act.
    
8. In the event of any change to the contents or nature of the consigned duties or any change of the consignee, we shall disclose without delay such change through this privacy policy.
    
9. You have the right to refuse consent to the overseas transfer of your personal information in the manner described above. If you wish to refuse the overseas transfer of your personal information, please contact us using the contact details in section 2 of Article 5 (Rights and Obligations of Data Subject and Method of Exercise) below . If you refuse the overseas transfer of your personal information, you may not be provided with the services requested, including placing orders and making transactions online.
    

Article 5 (Rights and Obligations of Data Subject and Method of Exercise)

1. You may exercise any of the following rights related to personal information protection against us at any time.

1. Right to demand a view of his/her personal information;
2. Right to demand correction in case of an error
3. Right to demand deletion;
4. Right to demand cessation of management of his/her personal information; and
5. Right to opt out from, or demand explanation regarding, automated decision.
   
   However, we may refuse the request for cessation of management if special provisions in the statute are provided.
    

2. Any of the rights set forth in paragraph 1 may be exercised against us through the following contact details. Any request pertaining to personal information or cessation of services provided by us is to be sent via e-mail at hk.lecole@vancleefarpels.com or by mail to the following address:

L’ÉCOLE, School of Jewelry Arts in Hong Kong
510A, 5F, K11 MUSEA, 
Victoria Dockside, 18 Salisbury Road, 
Tsim Sha Tsui, Hong Kong
hk.lecole@vancleefarpels.com
+852 26530030

When you exercise the rights set forth in paragraph 1, we shall verify whether the person is himself/herself or his/her legitimate legal representative.

You are requested to notify us of any change to your personal information in order to keep your information up-to-date, and if you do not wish to receive e-mail services provided by us, you may choose to stop receiving such services at any time following the instructions specified at the bottom of the e-mail.
 

3. In the case that we are demanded by you to correct or delete any error etc. in personal information, we shall not use or provide the relevant personal information until such correction or deletion is complete.
 

4. Any of the rights set forth in paragraph 1 may be exercised through agents such as a legal representative or a delegated person of the data subject, in which case the power of attorney should be submitted in accordance with the Appendix Form No. 11 of the Notice on Personal Information Processing Methods.

Article 6 (Destruction of Personal Information)

1. If personal information becomes no longer needed such as by the elapse of the retention period, achievement of the purpose of managing personal information and etc., we shall destroy the relevant personal information immediately.
    
2. If we are required by law to keep preserving personal information even though the retention period consented to by the data subject expired or the purpose of managing personal information is achieved, the relevant personal information shall be migrated to a separate database or be kept at a different place.
    
3. Personal information is destructed based on the following procedure and method:

• Destruction procedure
  • We select the personal information which is required to be destroyed and destroys it under the approval by the personal information protection officer.
• Method of destruction
  • We destroy personal information recorded and stored in the form of electronic files in a way that it cannot be re-generated, and personal information recorded and stored in the form of paper by shredding using shredding machines or by incineration.

Article 7 (Measures to Secure Safety of Personal Information)

We have put in place the following measures in order to secure the safety of personal information.

1. Administrative measures: Establishment and execution of internal plan for management, regular staff training, and etc.
    
2. Technical measures: Management of access authority to the personal information management system, installation of the access control system, encryption of authentic identification numbers, and installation of security programs
    
3. Physical measures: Restriction of access to the computer room, the data storage room, and etc.

Article 8 (Department and Contact Information for Personal Information Protection)

For the purpose of the General Data Protection Regulation in the European Union, we have appointed the following entity as our legal representative:

Data Protection & Privacy Team
RLG EUROPE B.V.
Herengracht 436
1017BZ Amsterdam
The Netherlands

A data subject may contact us at the address provided below for any inquiry on personal information protection, complaints, remedies and etc.  We are committed to answering and acting upon any inquiry from you immediately.

L’ÉCOLE, School of Jewelry Arts in Hong Kong
510A, 5F, K11 MUSEA, 
Victoria Dockside, 18 Salisbury Road, 
Tsim Sha Tsui, Hong Kong
hk.lecole@vancleefarpels.com 
+852 26530030 
 

Article 9 (Installation and Operation of CCTV)

L’Ecole Van Cleef & Arpels has installed and is operating CCTV as follows.

1. Basis and purpose of the installation of CCTV: Safety of facilities, prevention of fire and theft and at the campuses (Article 25(1) of the Act)
    
2. Number of CCTV, location, and scope of recording: [number of CCTV] devices are installed in major facilities including the campuses covering the entire space of major facilities
    
3. Manager in charge: Security Team / Responsible department; and persons with access to the image data: managers and vice managers of each campus
    
4. Duration of recording, period of storage, place of storage and method of management

• Duration: 24 hours a day
• Period of Storage: 35 days from recording
• Place of storage and method of management: Stored and managed in the control rooms for CCTV at each campus
   

5. Method and place of viewing image data: To be requested to the manager in charge (Security Team)
    
6. Request for a view of image data by a data subject: Application for the confirmation of the existence of image data of an individual and the view of such image data should be filed. The view will be allowed only if the data subject him/herself is recorded in the image or it is necessary without doubt for the protection of the life, body, and properties of the data subject.
    
7. Technical, administrative, and physical measures for the protection of image data: Establishment of internal management plan, access control and access authority restriction, application of technologies enabling safe storage and transmission of image data, retention of management records, preventative actions against alteration and counterfeit, preparation for facility for retention, and installation of locking mechanism, etc.

Article 10 (Remediation of infringement of rights and interests)

1. We are working to ensure self-determination of personal information and provide consultation and remedy for damage caused by personal information infringement. If you need to report or consult, please contact us using the contact details in Article 8 (Department and Contact Information for Personal Information Protection) above.
    
2. In case you wish to report or need advice on a personal information infringement, please contact the institution below.

• Personal Information Dispute Mediation Committee : 1833-6972 (www.kopico.go.kr)
• Personal Information Infringement Report Center : 118 (privacy.kisa.or.kr)
• Supreme Prosecutors' Office : 1301 (www.spo.go.kr)
• Korean National Police Agency : 182 (ecrm.cyber.go.kr)

Article 11 (Amendment to Personal Information Management Policies)

1. This privacy policy shall take effect as of April 1, 2026.