Oriental Watch Company (China) Trading Co., Ltd.

Website Privacy Policy

Effective Date: 7 January 2026

Basis and Scope of Application

This Policy is formulated in accordance with the Personal Information Protection Law of the People’s Republic of China, the Cybersecurity Law of the People’s Republic of China, the Data Security Law of the People’s Republic of China, the E-commerce Law of the People’s Republic of China, the Consumer Rights Protection Law of the People’s Republic of China, and other applicable laws and regulations.

This Policy applies to all activities of Oriental Watch Company (China) Trading Co., Ltd. (hereinafter referred to as the “Company” or “Oriental Watch Company”) in collecting, using, storing, transmitting, and disclosing users’ personal information through its official website (hereinafter referred to as the “Website”) operated within the territory of the People’s Republic of China (excluding Hong Kong, Macau, and Taiwan).

Article 1 Definitions

1.1 Personal Information

Personal information refers to all kinds of information recorded electronically or otherwise that can identify a specific natural person, either alone or in combination with other information, or reflect the activities of a specific natural person, including but not limited to name, identification number, mobile phone number, email address, IP address, browsing records, etc.

1.2 Sensitive Personal Information

Sensitive personal information refers to personal information that, once leaked or illegally used, may easily lead to infringement of personal dignity or harm to personal or property safety, including biometric data, religious beliefs, specific identities, medical and health information, financial accounts, location tracking, and personal information of minors under the age of fourteen.

The Website does not collect users’ sensitive personal information.

1.3 Cookies

When users visit the Website, in order to facilitate browsing, the Website will send cookies used for data identification to the user’s computer and store records on the hard disk. The Company treats the cookies obtained as personal information and manages them accordingly.

Cookies are small text files. When users visit the Website, the Website stores cookies through the user’s browser on the user’s device (such as computers, mobile phones, and tablets). Cookies contain certain data information and are used to optimize user identification, record user preferences, improve user experience, and analyze website traffic.

Users may manage or delete cookies through browser settings; however, this may affect certain functional preferences of the Website.

Article 2 Scope of Collection of Personal Information

2.1 Collection Principles

The Company only collects necessary personal information of users within the scope of purposes stipulated in this Policy and does not collect irrelevant information. The specific scope is as follows:

2.2 VIP Membership Information

When users apply for VIP membership, they are required to provide their name (username), mobile phone number, and date of birth. The Company will verify identity through SMS verification codes. Users may optionally provide an email address and delivery address (for benefits distribution).

2.3 Usage Behavior Information

When users access and use the Website, the Company will automatically collect information such as IP address, browser type, browsing records, access time, and page dwell time, for the purpose of optimizing website services and analyzing user preferences.

2.4 Inquiry/Complaint Information

When users make inquiries or complaints through the Website, they may provide problem descriptions and supporting materials (images, text). The Company will collect such information to handle the inquiries and complaints.

2.5 Cookie Information

The Website uses cookies to collect user preferences (such as frequently browsed product categories). The specific types and purposes of cookies are set out in Article 7 of this Policy.

Article 3 Methods of Collection of Personal Information

3.1 User-Provided Information

Personal information voluntarily provided by users through functions such as registration, login, VIP membership application, inquiries, and complaints on the Website.

3.2 Automatic Collection

When users access and use the Website, usage behavior information, cookie information, IP address, and other data automatically collected through the Website system.

3.3 Lawful Entrusted Collection

The Company will not entrust third parties to collect users’ personal information, except as otherwise provided by laws and regulations.

Article 4 Purposes of Use of Personal Information

4.1 Principles of Use

The Company collects users’ personal information solely for the following purposes and shall not use it for other purposes without the user’s explicit consent:

4.2 Provision of Basic Services

To provide users with basic services such as registration, login, and VIP membership on the Website, verify user identity, and ensure account security.

4.3 Handling User Requests

To process users’ inquiries, complaints, and suggestions, provide solutions, and give feedback on the handling results.

4.4 Optimization of Service Experience

To optimize the Website’s service experience and provide personalized product information and membership benefits based on users’ browsing records and preferences.

4.5 Maintenance of Operational Security

To maintain the operational security of the Website, identify, prevent, and handle illegal, non-compliant, or infringing activities, and protect the legitimate rights and interests of users and the Company.

4.6 Fulfillment of Legal Obligations

To comply with mandatory legal requirements, such as cooperating with investigations by public security authorities and market regulatory authorities.

Article 5 Storage and Protection of Personal Information

5.1 Storage Period

The personal information collected by the Company will be stored during the period in which the user uses the Website services, plus three (3) years after termination of the services. This period is determined in accordance with the “principle of minimum storage period” under Article 19 of the Personal Information Protection Law, combined with the Company’s business needs (such as handling potential disputes, complaints, refunds, membership management, financial audits, etc.) and industry practices.

Upon expiration of the storage period, the Company will promptly delete or anonymize the information, unless otherwise provided by laws and regulations (e.g., where extended retention is required for investigations).

5.2 Storage Location

All personal information collected by the Company is stored on servers within the territory of the People’s Republic of China and will not be transferred abroad, except as otherwise required by laws and regulations and after fulfilling relevant filing procedures.

5.3 Protection Measures

The Company adopts technical and organizational measures in compliance with the Cybersecurity Law and the Personal Information Protection Law to ensure the security of users’ personal information:

(1) Technical Measures: encryption transmission, access control, intrusion detection and prevention, security auditing, data backup and recovery, etc., to prevent unauthorized access, theft, tampering, leakage, or loss of personal information.

(2) Management Measures: establishment of a graded personal information management system, restricting access to authorized personnel only, providing confidentiality training, and signing confidentiality agreements.

5.4 Data Breach Handling

In the event of personal information leakage, loss, or other security incidents, the Company will immediately take remedial measures and, within 24 hours, notify users by publishing announcements in a prominent position on the Website homepage or through a fixed banner at the top of the Website, and report to the local cyberspace administration and market regulatory authorities.

Article 6 Sharing, Transfer, and Disclosure of Personal Information

6.1 Principles of Sharing

The Company will not illegally share or transfer users’ personal information. Without the user’s explicit consent, the Company shall not provide personal information to any third party.

6.2 Transfer Due to Mergers, Division, Dissolution, or Bankruptcy

Where transfer of personal information is required due to mergers, division, dissolution, bankruptcy, or similar reasons, the Company will make a public announcement on the Website 30 days in advance, informing users of the transferee’s name and contact information. The transferee shall continue to fulfill the obligations under this Policy.

If the transferee changes the original purposes or methods of processing, the Company shall require the transferee to obtain the user’s consent again.

6.3 Circumstances Where Consent Is Not Required

The Company may disclose users’ personal information without obtaining user consent only under the following circumstances:

(1) where necessary for the performance of statutory duties or obligations, such as cooperating with investigations by public security authorities or market regulatory authorities;

(2) where necessary to respond to public health emergencies, or in emergencies to protect the life, health, or property safety of users, the Company, or third parties, such as preventing or handling illegal or criminal activities;

(3) where processing personal information within a reasonable scope for news reporting, public opinion supervision, or other activities in the public interest;

(4) where processing personal information that has been voluntarily disclosed by users or otherwise legally disclosed, within a reasonable scope, in accordance with the Personal Information Protection Law.

Article 7 Cookie Policy

7.1 Necessity of Cookies

The normal operation of the Website relies on cookie technology. If users completely disable cookies, they will not be able to use the core functions of the Website, including but not limited to user login, session management, and security verification. Therefore, the use of the Website’s services requires users to allow the use of necessary cookies.

7.2 Types and Purposes of Cookies

The Website uses the following types of cookies:

(1) Necessary Cookies: Cookies essential for the normal operation of the Website, including login status verification, session management, and security protection. These cookies are fundamental to the operation of the Website and must be accepted in order to use the Website’s services.

(2) Functional Cookies: Cookies used to record user preferences, including browsing history, language settings, and page layout preferences, for the purpose of optimizing the user’s browsing experience. Users may choose to disable such cookies, but this may affect the use of certain personalized functions.

7.3 Collection and Use of Cookies

7.3.1 When users first visit the Website, the Website will inform users of the types, purposes, and management methods of cookies through pop-ups or prominent banners.

7.3.2 User Consent Mechanism:

(1) When users first visit the Website, the Company will clearly inform them of the use of cookies. By clicking “Agree” or “Accept”, or by continuing to use the Website, users shall be deemed to have consented to the Company’s use of cookies.

(2) If users refuse necessary cookies, they will not be able to use the Website’s services. Users may choose to leave the Website or adjust their browser settings to allow cookies before accessing again.

(3) Users may choose to accept only necessary cookies while refusing functional cookies; however, this may affect the use of certain personalized features.

7.3.3 Users may manage their cookie preferences at any time through browser settings.

7.4 How to Manage and Delete Cookies

Users may manage or delete cookies in the following ways:

(1) Managing cookies through browser settings:

•Google Chrome: Click “Settings” > “Privacy and Security” > “Cookies and other site data”, then choose “Block third-party cookies” or “See all cookies and site data”.

•Microsoft Edge: Click “Settings” > “Cookies and site permissions” > “Manage and delete cookies and site data”.

•Safari: Click “Preferences” > “Privacy”, then choose “Block all cookies” or “Manage Website Data”.

•Firefox: Click “Options” > “Privacy & Security” > “Cookies and Site Data”, then choose “Manage Data” or “Clear Data”.

(2) Deleting stored cookies:

Users may delete cookies through the browser’s “Clear browsing data” or “Clear history” function. For specific operation paths, please refer to the help documentation of each browser.

(3) Important Notice:

If users choose to disable or delete necessary cookies, they will not be able to continue using the Website’s services. Users must re-enable cookies and refresh the page to access the Website normally.

7.5 Third-Party Cookies

7.5.1 Certain sections of the Website (such as Rolex sections) may use cookies provided by third-party service providers (such as ROLEX) to provide specific functions or services.

7.5.2 The collection and use of third-party cookies are governed by the privacy policies of the third-party service providers. When users access such sections, the Company will inform users through pop-ups or prominent notices and provide links to the third-party privacy policies.

7.5.3 Users may choose whether to consent to third-party cookies. Refusing such cookies may affect the use of certain functions in the relevant sections.

7.6 Cookie Retention Period

7.6.1 Session Cookies: Automatically deleted when the user closes the browser.

7.6.2 Persistent Cookies: The retention period is specified when the cookies are set by the Website and shall not exceed 60 days. After expiration, cookies will automatically become invalid and be deleted by the browser.

7.6.3 Users may delete stored cookies at any time through browser settings; however, deleting necessary cookies will result in the inability to continue using the Website’s services.

7.7 Cookies and Personal Information Protection

7.7.1 Cookies may contain users’ personal information (such as user ID and browsing preferences). The Company will protect such information in accordance with this Policy.

7.7.2 The Company will not use information collected through cookies for purposes other than those stipulated in this Policy, nor will it share such information with third parties, except as otherwise provided by laws and regulations.

Article 8 Users’ Rights to Personal Information

8.1 Overview of Rights

In accordance with the Personal Information Protection Law, users enjoy the following rights with respect to their personal information. The Company will provide convenient means for users to exercise these rights.

8.2 Right to Know

Users have the right to review the provisions of this Policy regarding the collection, use, storage, and protection of personal information, and to request explanations of the purposes, methods, and scope of processing.

8.3 Right of Access

Users have the right to access their submitted personal information (such as name, mobile number, and membership information) through the “My – Personal Information” section of the Website.

8.4 Right to Rectification

If users’ personal information is incorrect or incomplete, they have the right to correct it through the above entry or request correction through customer service channels. The Company will process such requests within 7 working days after receipt.

8.5 Right to Erasure

Under the following circumstances, users have the right to request the Company to delete their personal information, and the Company will do so within 15 working days after receipt of the request:

(1) the purpose of collection or use has been fulfilled, cannot be fulfilled, or is no longer necessary;

(2) the user withdraws consent to the processing of personal information;

(3) the user terminates the use of the Website’s services;

(4) the Company violates laws, regulations, or this Policy in collecting, using, or storing personal information.

8.6 Right to Withdraw Consent

Users have the right to withdraw their consent to the processing of personal information at any time, either through the “My – Privacy Settings” section of the Website or via customer service channels. Upon withdrawal, the Company will immediately cease the corresponding processing activities, without affecting the validity of processing conducted prior to withdrawal.

8.7 Right to Account Deletion

Users have the right to apply for account deletion at any time through “My – Account Settings – Delete Account” on the Website. Upon deletion, the Company will delete the user’s personal information (unless otherwise provided by laws and regulations).

Article 9 Third-Party Services

9.1 Integration of Third-Party Services

The Website may integrate third-party services (such as payment interfaces and map interfaces). Providers of such services may collect users’ personal information. The Company has conducted compliance reviews of such providers and requires them to comply with applicable privacy protection laws and regulations.

9.2 Notification of Third-Party Services

Before users use third-party services, the Company will inform users in a prominent manner that such services are provided by third parties and will provide links to the third parties’ privacy policies for users’ reference.

9.3 Responsibility of Third-Party Services

The privacy protection of third-party services is the responsibility of the respective providers. Matters not covered in this Policy shall be governed by the third-party providers’ privacy policies. Although the Company requires third-party providers to comply with relevant laws and regulations, the Company shall not bear responsibility for their privacy protection practices.

9.4 Protection of User Rights

If users’ personal information is leaked due to third-party services, the Company may assist 

Article 10 Protection of Minors

10.1 Target Users

The Website is intended for individuals aged 18 or above with full civil capacity. It does not provide VIP membership services to minors and does not proactively collect minors’ personal information.

10.2 Processing of Minors’ Information

If it is discovered that a minor has used the Website and submitted personal information without guardian consent, the Company will immediately delete such information and terminate services.

10.3 Rights of Guardians

If a guardian discovers that a minor under their guardianship has submitted personal information on the Website, they have the right to request deletion via customer service channels. The Company will process such requests within 3 working days after receipt.

Article 11 Amendments and Updates to the Policy

11.1 General Amendments

The Company may revise this Policy in accordance with changes in laws and regulations or business adjustments. Revised versions will be announced at least 7 calendar days in advance through one or more of the following methods:

(1) announcements in prominent positions on the Website homepage;

(2) fixed banners at the top of the Website;

(3) pop-up notifications;

(4) email notifications to registered users;

(5) in-site messages (for registered users).

The revised Policy will take effect upon expiration of the announcement period.

11.2 Special Provisions for Material Changes

Where revisions involve the following material matters, the Company will obtain users’ explicit consent again in accordance with the Personal Information Protection Law:

(1) significant changes to the purposes or methods of processing personal information;

(2) changes to rules on sharing, transfer, or public disclosure;

(3) significant adjustments to the methods for exercising user rights;

(4) other changes that may have a significant impact on users’ rights and interests.

11.3 User Choice

The revised Policy will replace the original Policy and become the sole basis for the Company’s processing of users’ personal information. If users do not agree to the revised Policy, they shall immediately cease using the Website. Continued use shall be deemed acceptance of the revised Policy.

Article 12 Contact Information

12.1 Contact Details

If users have any questions about this Policy or wish to exercise their personal information rights, they may contact the Company through the following methods:

(1) Customer Service Hotline: (+86)20 3785 8607 (Working days 10:00–17:00);

(2) Customer Service Email: info@orientalwatch.com;

(3) Online Entry: “Contact Us”.

12.2 Response and Handling

The Company will respond and process requests within 15 working days after receipt.

Article 13 Miscellaneous

13.1 Relationship with Agreement

This Policy forms an integral part of the Oriental Watch Company (Mainland China) Website User Service Agreement and has the same legal effect.

13.2 Severability

If any provision of this Policy is held invalid or unenforceable, it shall not affect the validity and enforceability of the remaining provisions.

13.3 Right of Interpretation

The right of interpretation of this Policy shall be vested in Oriental Watch Company (China) Trading Co., Ltd.

13.4 Effective Date

This Policy shall take effect on 7 January 2026