PRIVACY NOTICE VICTORINOX MÉXICO, S.A. DE C.V.

This document constitutes the Privacy Notice in compliance with the provisions of the Federal Law for the Protec-tion of Personal Data in Possession of Private Parties (the “LFPDPPP”), its Regulations, as well as the Privacy Notice Guidelines (collectively referred to as the “Legislation”). Consequently, this Privacy Notice (hereinafter re-ferred to as the "Notice") applies to the personal information collected from the Data Subject by Victorinox México S.A. de C.V. ("Victorinox"). For the purposes of this Notice, capitalized terms used in this document and not defined herein shall have the meanings ascribed to them in the Legislation.

I. IDENTITY AND ADDRESS OF THE PERSON RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

Victorinox, a company domiciled at: Blvd. Hermanos Serdán 717 Col. San Rafael Poniente C.P. 72029 Puebla, Puebla, acts as Data Controller and thus is responsible for the collection, use, storage, and disclosure of your Personal Data, in accordance with the provisions of this Notice, ensuring at all times the proper use, protection, and confidentiality thereof, and observing the principles of legality, consent, information, quality, purpose, loyalty, proportionality and responsibility as provided by the Legislation.

II. PERSONAL DATA SUBJECT TO PROCESSING

In order to carry out the purposes described in this Notice, as well as to enforce the rights and comply with the obligations within the framework of the specific legal relationship with each Data Subject, Victorinox may collect and process, in whole or in part, the following categories of Personal Data:

  1. Identification and contact data of yourself (including your personal image) and third parties who act as your personal references and/or emergency contacts.

  2. Employment and academic data;

  3. Financial and economic data;

  4. Data enabling your geolocation, as well as identifying browsing and consumption preferences; and

  5. Information on economic dependents (Name(s), surnames, ages, addresses, zip codes, type of relationship).

The aforementioned items are categories of Personal Data that Victorinox collects and processes through our website https://www.victorinox.com/es-MX/, in person at our stores and offices through our corresponding forms and/or if you voluntarily share them with us by providing your information to establish some kind of legal relationship with Victorinox. If you wish to know each specific Personal Data collected and processed by Victorinox, please contact us through the means indicated in this Notice.

The Personal Data that we may request and collect from you will be processed under the strictest physical, technical, and administrative security measures, , that ensure their protection and confidentiality once we obtain your Consent.

III. SENSITIVE PERSONAL DATA

We inform you that Victorinox will not collect Sensitive Personal Data from you under any circumstances. Therefore, if at any time one of our employees or representatives requests any data considered sensitive as defined by the Legislation, we ask you to notify us immediately through the contact means indicated in this Notice.

Sensitive Personal Data shall be understood as those that may affect your most intimate sphere, or whose misuse by us may give rise to discrimination or pose a risk to you. In particular, they are data that may reveal aspects such as racial or ethnic origin, your current or future health status, genetic information, religious, philosophical, or moral beliefs, union membership, political opinions, or sexual orientation.

IV. PERSONAL DATA OF MINORS AND PERSONS REQUIRING DECISION-MAKING SUPPORT

Please be informed that it is of our special interest to safeguard the Personal Data of minors and individuals who must or choose to make decisions with support according to the Legislation, through the implementation of specific measures, such as:

  1. Obtaining Consent from parents or guardians for the Processing of Personal Data of this group of people.

  2. The verification of the authenticity of the Consent granted by parents or guardians.

  3. The implementing and maintaining stricter security measures to ensure the confidentiality of the Personal Data of minors and all other individuals referred to herein.

V. PURPOSES OF THE PROCESSING OF PERSONAL DATA

Victorinox may process your Personal Data for various primary purposes, which are those necessary for the creation and maintenance of the legal relationship with Victorinox and, unless you expressly object, for the secondary purposes listed here, which are those that, although not essential or necessary for the provision or contracting of our products or services and/or preservation of our legal relationship, allow us and facilitate providing you with better attention and experience.

In this regard, the Processing of the collected Personal Data will depend on the legal relationship you have with Victorinox, which are detailed below:

1. Employees, Former Employees, Job Applicants, and Distributors

Primary Purposes

  • Generate a labor or distributor file, as applicable, and asses your profile for potential hiring;

  • Contact you, interview you, and/or involve you in a recruitment process or contest, validate your identity, skills, and capacities, and request personal and work references;

  • Preparation and signing of your employment or distributor contract;

  • Creation of a profile in our records and database appropriate to the legal relationship you have with Victorinox;

  • Presentation of an economic proposal and/or job offer;

  • Grant you access to Victorinox offices and stores, as well as electronic access to the Victorinox website and digital administrative systems necessary to maintain our legal relationship;

  • Payment of the consideration agreed upon between you and Victorinox and fulfillment of our contractual obligations;

  • Compliance with our labor and social security obligations, where applicable;

  • To facilitate medical care in case of emergency.

Secondary Purposes

  • Continuous improvement of the work environment and atmosphere (such as sending birthday congratulations and other celebrations and special days);

  • Sending internal communications by Victorinox that may be of interest to you and are not strictly related to your job position;

  • Sending commercial offers and promotions, as well as open job positions that may be of interest to you based on your profile, experience and skills.

  • Providing work references and information on your job performance if requested

2. Customers

Primary Purposes

  • Including you in the Victorinox’s customer database;

  • Create a user account on our website, as well as for you to purchases in Victorinox physical stores or through our website;

  • Presenting offers and services according to your request;

  • Processing your purchases, as well as for the shipping and delivery of the products and items you acquire;

  • Contacting you and informing you about the status of your order and, in case of any shortages, offering you similar products or alternatives;

  • Processing payment in our stores, or through our website, or at your address;

  • Processing returns and warranty requests, as well as providing customer service regarding any concerns or complaints you may have;

  • Ensuring the safety of people visiting our facilities (video surveillance);

  • Compliance with legal obligations, internal policies, and procedures, including internal and external audits and authority requirements.

Secondary Purposes

  1. Contacting you and inform you of our promotions, discounts, and new products, as well as sending you promotions and advertising materials through the contact channels you have provided;

  2. Generating profiles and conducting profiling campaigns to understand your purchase habits and preferences regarding our products and services and present you with personalized offers;

  3. Conducting market research and consumer behavior habits studies;

  4. Sending you satisfaction surveys regarding our products and services and improving their quality.

3. Persons designated as Reference and Emergency Contact

Primary Purposes

  • Regarding individuals listed as references: request academic and employment references about candidates and job applicants;

  • Regarding individuals listed as emergency contacts: contact them only in case of any emergency related to the person who provided their data to Victorinox.

4. Providers of godos or services

Primary Purposes

  • Registering you as a supplier in our systems and platforms and informing you of any changes in our policies and processes;

  • Entering into and formalizing contracts and agreements with Victorinox, as well as fulfilling the obligations arising from such instruments;

  • Contacting you for the sale/provision of the products/services that Victorinox may require;

  • Issuing, receiving, and processing invoices and/or debit notes, as well as making or receiving payments related to them.

In this regard, unless you expressly indicate otherwise, we understand that you consent to Victorinox processing your Personal Data for the purposes described above as applicable. In cases where we require your explicit Consent, Victorinox will implement the necessary measures to obtain it in accordance with the provisions of the Legislation.

VI. MECHANISMS TO OBJECT THE PROCESSING OF YOUR PERSONAL DATA

We remind you that the aforementioned primary purposes are necessary and essential to maintain the legal relationship between you and Victorinox, as well as to comply with the legal obligations arising from it. Therefore, you cannot object or refuse Victorinox from processing your Personal Data for such primary purposes. Moreover, in terms of the Legislation, once the legal relationship between you and Victorinox has ended, we may keep your Personal Data in our database until all existing statues of limitations for exercising any rights related to such legal relationship have expired.

If, despite the above, you object Victorinox to process your Personal Data for the primary purposes, we inform you that we will be unable to continue and maintain the legal relationship with you, and we may terminate it.

In the event you do not want your Personal Data to be processed for any or all of the secondary purposes, you can object it at any time by sending an email to our personal data department via the following means: datos.personales.mx@victorinox.com or to the telephone number 222-266-8330 EXT. 160 or by sending a written request to our address: Blvd. Hermanos Serdán 717 Col. San Rafael Poniente C.P. 72029 Puebla, Puebla.

VII. TRANSFERS AND DISCLOSURES OF PERSONAL DATA.

We hereby inform you that, in principle, Victorinox does not transfer Personal Data to third parties for any purpose. Should we need to transfer your Personal Data and require your Consent to do so, we will inform you and obtain it in accordance with the Legislation.

However, Victorinox may engage one or more external third parties as service providers to facilitate and enhance our operations. In such case, although these third parties will have access to your Personal Data, they will only act as Data Processors, meaning they may handle and process your Personal Data solely under our instructions and supervision, which will be always aligned at all times with this Notice.

Additionally, please be advised that, as an exception authorized by the Legislation, we may transfer Personal Data among sister companies, subsidiaries, and/or any entity forming part of the same corporate group as Victorinox without your Consent.

VIII. EXERCISE ARCO RIGHTS

At any time, you may exercise the following rights concerning the Personal Data we process about you:

  • Know the Personal Data we have from you, how we use them, and the conditions of their use; (Access).

  • Request any correction of your Personal Data if they are outdated, inaccurate or incomplete; (Rectification).

  • Demand that we delete your Personal Data from our records or database when you consider that it is not being used properly, in accordance with the deletion requirements outlined in this Notice or as per the Legislation (Cancellation).

  • Object to the Processing of your Personal Data for any legitimate reason (Objection).

To exercise these rights (collectively known as "ARCO Rights"), you must request and send a petition to our personal data department through email at datos.personales.mx@victorinox.com or to our address located at: Blvd. Hermanos Serdán 717 Col. San Rafael Poniente, C.P. 72029 Puebla, Puebla.

This request and petition must contain:

  • Name(s) and surname (s) of the applicant;

  • Address of the applicant;

  • Telephone, email, or other means to communicate the response to your request;

  • Official identification that proves your identity or, if applicable, the legal representation of the person acting on your behalf;

  • A clear and precise description of the Personal Data for which you seek to exercise any of the ARCO rights;

  • The reasons why you request to exercise the respective ARCO right(s);

  • In the case of rectifications, indicate the modifications to be made and the documentation supporting these changes;

  • Any other element that facilitates the location of the Personal Data

Once we receive your request, we will have a period of twenty (20) business days to issue and inform you our response. If your request is successful, it will be effective within a maximum period of fifteen (15) business days after the date of the response to your request. These deadlines may be extended only once, for equal periods, respectively, in which case we will inform you so.

For any questions regarding the procedures for exercising your ARCO rights and/or for any questions about this Notice and our personal data protection practices, you can contact our personal data department at any time via email: datos.personales.mx@victorinox.com and/or by phone: 222-266-8330 EXT. 160.

At any time, you can revoke the Consent granted to Victorinox for the Processing of your Personal Data by sending a written request to our personal data department at datos.personales.mx@victorinox.com or by sending a written notification to our address located at: Blvd. Hermanos Serdán 717 Col. San Rafael Poniente C.P. 72029 Puebla, Puebla, detailing clearly the data for which you revoke your Consent.

Under no circumstances shall the revocation of your Consent have retroactive effect to the date on which it becomes effective.

We ask you to consider that if you revoke the Consent granted to Victorinox for the Processing of your Personal Data, we may be unable to continue the legal relationship. In such case, Victorinox may choose to terminate it. However, in accordance with the Legislation, we may retain your Personal Data in our databases until all the statutes of limitations for exercising any right or demanding compliance with any obligation related to that legal relationship have expired.

X. LIMITATION OF USE OR DISCLOSURE OF PERSONAL DATA

You have the right to limit the use and disclosure of your Personal Data for commercial prospecting, advertising, and marketing purposes. To do so, you may inform us via email at: datos.personales.mx@victorinox.com or by sending a written request to our address located at: Blvd. Hermanos Serdán 717 Col. San Rafael Poniente C.P. 72029 Puebla, Puebla, addressed to the personal data department, indicating:

  • Name(s) and surname(s) of the applicant;

  • Address of the applicant;

  • Telephone, email, or other means to communicate the response to your request;

  • Official identification proving your identity or, if applicable, legal representation.

  • A clear and precise description of the secondary purposes for which you want to limit the Processing of Personal Data

Victorinox will respond to your request within twenty (20) business days.

In some cases, you may exercise this right by clicking the "Unsubscribe" link found at the end of the advertising emails you received from Victorinox. It is important to note that the limitation made in response to these requests will not have retroactive effects.

We hereby inform you that on our website, we use cookies, through which we can monitor your behavior as an Internet user as well as provide you with better service and user experience while navigating our site.

Victorinox does not obtain Personal Data through this technology; it only tracks browsing preferences to provide better service.

In some cases, you can partially or fully reject the collection and processing of cookies by Victorinox through the pop-up window that appears when you visit our website, selecting those cookies you authorize and those you do not, or denying all of them.

However, if this option is unavailable, cookies can be disabled in the browser settings you use. In most browsers, cookies can be disabled as follows:

  1. Open your preferred browser.

  2. Click or tap the TOOLS button; in some browsers, this option may appear as SETTINGS, then click or tap Internet Options.

  3. Click or tap the PRIVACY tab, then in Settings, move the slider all the way to block all cookies or all the way down to allow all cookies (INTERNET EXPLORER); in some browsers, only one option to enable or disable cookies may appear.

For your convenience, you can learn more about cookies at the following website: https://allaboutcookies.org/ and/or consult the steps to follow depending on the browser you use.

Finally, it is possible that our website contains links to external sites or platforms managed by third parties, over which Victorinox has no influence or control. In this regard, Victorinox assumes no responsibility for the Personal Data you may provide to such third-party websites, so we recommend that you always review the relevant Privacy Notices and practices.

XII. VIDEO – SURVEILLANCE IN OUR STORES

Our stores are monitored by video surveillance systems for real-time images. The images and audio captured by the surveillance cameras will be used for your security and that of the security of visitors to Victorinox stores. Recordings and images captured by our system may be stored on a device in accordance with our security measures.

XIII. SECURITY MEASURES

Victorinox has implemented administrative, technical, and physical security measures to protect your Personal Data, which we also require our service providers to comply with.

XIV. RIGHT TO INFORMATION OF DATA SUBJECT AND COMPETENT REGULATORY AUTHORITY

At all times, you are the owner of your Personal Data and can decide how they are processed and shared, and Victorinox will always comply with the Legislation and this Notice. If you believe your privacy has been violated by any conduct of our employees or our actions or responses, you can contact us through the provided means, without prejudice to the right to appeal to the National Institute of Transparency, Access to Information, and Protection of Personal Data ("INAI"), which is the supervisory authority in Mexico for the right to the protection of Personal Data held by private parties.

XV. MODIFICATIONS TO THE PRIVACY NOTICE.

We reserve the right to make modifications or updates to this Notice at any time, to address legislative changes, internal policies, or new requirements for the provision or offering of our services or products. In the event of any change to this Notice, we will communicate it through our website https://www.victorinox.com/es-MX/ and by direct communication sent to the contact information you have provided us.

Laws and regulations of other countries may impose different requirements for the protection of information in general and Personal Data collected via the internet. Victorinox is located in Mexico, and all matters relating to our website are governed by the laws of Mexico. If you are located in a country other than Mexico and contact us, please note that any information you provide to us will be transferred to Mexico, and by entering your information you authorize this transfer and accept this Privacy Notice

Last revision: April 2024