Last updated: 17/12/2018

At Roger W. Smith Watches we’re committed to protecting and respecting your privacy by being fully compliant with all applicable Isle of Man data protection legislation and the General Data Protection Regulation ((EU) 2016/679) as applied to the Isle of Man (GDPR) in respect of personal data, as well to safeguarding the rights and freedoms of natural persons whose information the Company collects.

This notice explains how and why we collect, use and store your data and sets out your rights regarding this data. This Privacy Policy applies to all personal data collected by us either through our website or through email, telephone, social media or other contact. This Privacy Policy does not apply to information collected by third party websites that may link to or be accessible from the Website.

For employees or those who want to join our business, there is a separate privacy notice.

Please read the following carefully to understand our policies and practices regarding the treatment of personal information.

Who we are

Any information you provide to us is held by Roger W. Smith Ltd., a company registered in the Isle of Man under company number 099616C. Roger W. Smith Ltd may be referred to as "we", "us" or "our" in this Privacy Policy. Roger W. Smith is the trading name of Roger W. Smith Ltd.

Changes to this Privacy Policy

We reserve the right to amend this privacy policy at any time and you agree to be bound by any changes. The date at the top of this page will be amended each time this policy is updated. Please check back periodically and/or before you provide any personally identifiable information.

How we collect your data

Roger W. Smith Ltd. does not collect your personal data without your knowledge or permission. We obtain information about you when you use our website or contact us.

We primarily collect your data when you place an order with us, contact us about products and services, or if you register to receive our email newsletter.

When you visit our website, we may automatically collect certain information about your visit.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

What data we collect

Roger W. Smith Ltd. may collect the following data from you:

Information collected through direct communication

Many of the services that we offer are only available to you if you provide certain personal information. When placing an order with us you will be asked to provide your name, telephone number, email and postal addresses and/or those of any nominated representatives. Such information may be provided by you or on your behalf. We may also collect this data if you register your ownership of a Roger W. Smith or Daniels London timepiece with us.

If you fail to provide personal data

Where we need to collect such personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide you with the services we offer. In this case, we may have to cancel the service we provide to you. We will notify you if this is the case at the time.

If you sign up for our email newsletter you will be asked to provide your name and email address.

We do not process payment information.

Information collected automatically through use of our website

As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience.

Like most websites we use cookies to help improve the performance of our website and provide you with a better user experience. Cookies are widely and commonly used to make websites function more efficiently as well as providing different types of information to website owners.

You can set your personal browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Data from children

Our services are not directed to children under the age of 18 and we do not knowingly collect personal information from children. If you are under the age of 18, please stop using our services. If we are made aware that we have received information from anyone under the age of 18 we will remove that information from our records unless we are required to hold it for legal or regulatory purposes.

How we use your data

Information collected through direct communication

If you order a watch from us, we will use your personal data to fulfil your order and to provide after-sales services such as repairs, valuations and registration of ownership. Similarly, if you choose to register your Roger W. Smith or Daniels London watch with us, your personal data will be used to provide after-sales services.

We will only share information about you with your prior permission, such as when arranging shipments to or from you. We will take all reasonable steps to ensure that your data is treated securely by our suppliers as processors. If you use our services while you are outside the Isle of Man, UK or EEA, your information may be transferred to other jurisdictions in order for us to provide you with these services.

If you have requested to be added to our mailing list, your personal data may be used to provide you with our newsletter or other marketing material such as invitations to special events. By signing up to our mailing list you acknowledge that your personal data will be used for such legitimate purposes. If at any time you wish to unsubscribe, please let us know by contacting us.

We will never sell, rent or publish your data.

We will only process your data and, in certain circumstances we may be obliged to disclose personal data to a third party where:

  • We need to perform the contract we are about to enter into or have entered into with you;
  • It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
  • We need to comply with a legal or regulatory obligation, such as helping to detect or prevent fraud or money laundering.

Data collected through use of our website.

We may use the data collected through our website to improve the content of the Website or customize the Website to your preferences. For further information please see our cookies page.

Data processed by way of consent.

Generally, we do not rely on consent as a legal basis for processing your personal data.

Security

At Roger W Smith Ltd., we have put in place appropriate technical and organisational security measures to prevent your personal information from being used, accessed or disclosed in an unauthorised way. The information you provide, is stored on secure servers and we otherwise take reasonable precautions to protect it. Within the company, access to personal information is limited to those who are required to process such data, and they are subject to a duty of confidentiality.

No internet transmission can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

We will notify you and the Isle of Man Information Commissioner of any data breach where legally required to do so.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Details of retention periods for different aspects of your personal data are available on request by contacting us.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact information

If you have any questions, comments or requests regarding this privacy policy you can contact us as follows:

Roger W. Smith Ltd.
PO Box 67, Ramsey, Isle of Man, IM99 4LN, British Isles

Tel: +44(0)1624 897943
Email us through our contact form

If you have any complaints regarding our use of your personal information, you can contact us at the address above. Alternatively, you can contact the Isle of Man Information Commissioner whose website is: www.inforights.im.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.