INA KESS PRIVACY POLICY

1. ABOUT INA KESS AND THIS PRIVACY POLICY
We are INA KESS Ltd. (“we”, “us”, “our”), and are committed to protecting your privacy.

This Privacy Policy provides information on how we collect and use personal data. INA KESS Ltd. operates INAKESS.com, various international websites (including INAKESS.ch, INAKESS.co.uk, INAKESS.fr, and INAKESS.it, amongst others), collectively, the "website". This Privacy Policy sets out the information that we collect, the reasons for which we collect the information, and how we can use and share the information.

The website and services provided by INA KESS are not intended to be used by children. If you have any questions about this Privacy Policy you can contact us at contact@inakess.com.

If you have any requests to exercise your privacy rights, check section 11 (“What are my privacy rights?”) below.

2. THIRD PARTY WEBSITES

Our website can contain links to and from the websites of our retailers and brand ambassadors, amongst others. If you follow a link to any of these websites, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.

3. WHAT INFORMATION DO WE COLLECT, AND HOW?

When you interact with us, whether by using our website or communicating with us, we may collect the following information about you:

- Information you give us: you may give us information about yourself if you sign up for an account on our website, place an order for products, complete any online forms (such as registration forms, competitions, surveys or by reviewing the products you’ve ordered), opt in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions, or correspond with us (by email, telephone, instant messaging apps, social media or otherwise).

Depending on what you provide, this information can include your name, address or location, phone number, email address, date of birth, gender, purchase information, shopping preferences, reviews, images and financial information (including your credit or debit card details, although we do not hold them, our payment processors do).

- Information we receive from other (public) accounts or sources: we can receive information about you from other sources, such as from your other accounts (like when you use your Apple ID or Google Sign In to sign in on our website) or other websites, including data brokers, our partners, social media providers like Facebook and Twitter, advertising networks and analytics partners, and payment and delivery service providers.

By linking your INA KESS account on our website to your Apple, Google, Facebook, Pinterest, Tiktok or Twitter accounts, you are giving us permission to obtain certain information and content from these accounts such as @ina_kess (Instagram) and all other social media profiles connected to our company. The specific types of information that we may obtain depends on your settings for that account or website, and will be subject to their privacy policies.

We supplement the data you provide us with data from data appending services such as public or social graph data in order to better serve you with content or promotions. We will append this data to our existing customer account information to better understand customers’ interests and to provide more relevant product recommendations and advertising, to increase our customer’s security when using our website and to comply with our legal obligations, such as sanctions laws. This information may include household size, household income, or profession. This information can be associated with your personal information such as name, email, address, physical address or phone number.

Cookies: you can see more details about cookies in section 7, but these small text files can help improve your experience with the website and make it easier to interact with us. This may include storing your location or language preferences to save you having to re-enter information when returning to, or ensuring that items you wish to order don’t disappear as you navigate between pages on our website. We also use cookies to provide you with tailored advertising. You can opt-out of the use of your personal data for tailored advertising at any time, as described below in section 11.

Device information: the information provided by your device will differ depending on your operating system and device settings (eg. PC, Mac, iPhone, Android, or otherwise), but includes the type of device you have, the device’s IP address and location, the browser you're using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.

- Information we collect in store: INA KESS is always looking for new opportunities to improve your shopping experience and this extends to your experiences in-store. When you visit the INA KESS Stores (including our store in stores in various department stores), you may give us information about yourself in-store if you make a purchase using a credit or debit card, complete a survey or questionnaire, enter a competition or promotion, provide us with feedback or a request for future product releases or reorders or otherwise interact or correspond with us in-store or after your visit. The information we may collect in such cases are name, email, credit or debit card details, other contact information, date of birth, and interests. Where you use a WiFi-enabled device in-store, certain information may be provided by your device, which will differ depending on your device and settings. The information that may be provided is the type of device you have, the device identifier/media access control (MAC) address, the proximity of the device from the access point, location of the device, and where relevant, when and for how long the device is connected to the Wi-Fi network. You can prevent information being provided by turning off the Wi-Fi feature on your device. We might also register your interactions with the products, in order to enhance your in-store experience by providing you a more personalised service during your visit and after.

4. WHAT DO YOU USE MY INFORMATION FOR?

To provide you with our services, including to allow you to order and receive products using our website, administer your INA KESS account and to optimise your experience, we need to use your information in a number of different ways.

We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications or when you have made a purchase using our services, we and our partners will use your personal information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing customer information as described below), to tailor these messages to you.

You may unsubscribe from our email marketing communications by following the opt-out instructions in the pro- motional emails that are sent to you or, by contacting us on contact@inakess.com where someone will assist you with your request. You can also opt-out of the use of your personal data for advertising purposes at any time, as described below in section 11.

Should your country be covered by such services, we may use your information to provide you with shopping recommendations and personal styling-related services, therefore, you'll have access to an improved and more interactive shopping experience. Such services will be provided along with third-party providers, which will be acting as processors. You can opt-out of the use of your personal data for these purposes at any time, as described below in section 11.

We use third-party service providers to serve advertisements most relevant to you across your different devices and on our own and others’ websites and mobile applications. In addition to the information about your visits to our website, our service providers may also use the information about your interactions with other websites or

applications to target advertisements for products available from INA KESS. For information about opting out of targeted advertising and controlling the use of cookies, please see the cookies section of this Privacy Policy.

We also carry out research, analysis, and surveys on your use of our website, and views. We keep tracking of your spend on our website to better understand your needs and preferences. Finally we use your information to confirm your identity and perform credit checks or anti-fraud checks, in order to ensure your, and our, financial security. Please scroll down to find out the detailed purposes for which we collect your information, what specific information is collected and the legal basis for which we purpose that data.

- To register and manage your INA KESS account on our Website, we collect your name, email, password and other additional details you may wish to add to your account, like phone number, addresses and gender. The legal basis is the performance of a contract with you.

- To fulfil the orders you make through our website, we collect your name, addresses, phone number, order details, like the products you are buying, the size and price. The legal basis is the performance of a contract with you.

- To collect payment from you we collect your payment information, which comprises the credit/debit card’s number, holder’s name, expiry date and CVV. We don’t store them and only transfer them to our authorised payment providers. The legal basis is the performance of a contract with you.

- To provide you with our customer services (including helping you to solve any issue you have with our services, updating you about any change to our terms of service, or contacting you to know how your experience with us was): we collect your name, email, phone number and addresses and your contact history with us. The legal basis is the performance of a contract with you and our legitimate interests in retaining you as a customer by answering any issues or queries you may have.

- To monitor the quality of our customer services, we collect your name, email, phone number and addresses, your response to our Whatsapp inquiries about the quality of the service and your contact history with us (including phone records of our conversations and conversations through email or other instant messaging apps). The legal basis is the legitimate interests in running our business.

- To review and post your reviews on your orders: we collect your name, age range and your written review. The legal basis is your consent.

- To administer, maintain and optimise our Website and our services, we collect your device information (such as your device IP address and device type), cookie identifiers and browsing information. The legal basis is the legitimate interests in running our business.

- To perform fraud and credit checks and if we can do business with you, we collect your name, email, addresses, credit/debit card details, browsing history, purchase history, date of birth, gender, specific behavioural cookies, device information (such as IP address and device type), any national identifiers (like driver’s license or ID cards) and any publicly available information (like social media profiles or news). The legal basis is the legitimate interests to protect INA KESS and its customers from fraudulent activities and compliance with a legal obligation.

- To send you marketing communications and personalised offers, we collect your name, email, phone number, addresses, date of birth, purchase history, browsing history and behaviour, device information, shopping preferences, cookie identifiers, internal identifiers and country. The legal basis is the legitimate interests in electronic direct marketing of similar products and services which you have acquired using our website.

- To manage our loyalty programmes, we collect your name, email, phone number, addresses, date of birth, purchase history, browsing history and behaviour, device information, shopping preferences, nickname, cookie identifiers, internal identifiers, country, spent tier level and wealth. The legal basis is our legitimate interests in running our business and improving your shopping experience.

- To provide you with personalised recommendations and enhance your experience, we collect your name, email, phone number, addresses, date of birth, purchase history, browsing history and behaviour, in-stores interactions with products, device Information, shopping preferences, nickname, cookie identifiers, internal identifiers, country, spent tier level and wealth. The legal basis is our legitimate interests in running our business and improving your shopping experience.

- Third parties where we are considering a corporate transaction: INA KESS is always looking for new opportunities and directions in which to grow. This means sometimes we may consider corporate transactions such as merger, acquisitions, reorganisations, asset sale, or similar. In these instances, we may transfer your information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, your personal information may be one of the assets that are transferred.

- Third parties which help us provide you with a styling service: we’re always trying to find new and interactive ways to improve your shopping experience and provide a unique personal styling journey. To do so, we may rely on third-party service providers.

- To comply with legal obligations and requests: on occasion we may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands.

- Aggregated information with third parties: we may aggregate your information with the information of other customers, creating a dataset of information about the usage of our website, purchase of products, and other general, grouped information about our customers. The legal basis is our legitimate interest to understand the usage of our service and demand for our product. Although this dataset is aggregated and anonymised, meaning it cannot identify you as an individual, it provides a valuable insight into the use of our website and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies (to help measure traffic), our partners and other providers (to allow them to better stock products), and our investors.

6. TRANSFERS OF YOUR PERSONAL DATA

In order to fulfill the purposes described above and to share your personal information with third parties, we may transfer your personal data to countries outside of Switzerland or the European Economic Area that do not provide an adequate level of data protection such as the United States. Before we transfer your information abroad, we ensure that all requirements for a safe transfer to and storage in that country are met, in particular, by implementing protective measures and signing approved data transfer agreements with the recipients.

7. COOKIES

We use technology such as "cookies" to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.

We use the following categories of cookies on our website:

- Strictly necessary cookies: these cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided. These cookies will also inform us about your behaviour on our website, if we can do business with you and protect INA KESS and its customers from fraudulent activities.

- Performance cookies: These cookies collect anonymous information on how you use our website (eg. we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site) and highlight areas we can improve such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. They are also used to help measure the effectiveness of an advertising campaign. We only use these cookies if you have consented to their use.

- Functionality cookies: These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. We only use these cookies if you have consented to their use.

- Targeting cookies or advertising cookies: These cookies collect information about your browsing habits and limited aggregated demographic information in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies to provide you with more personalised adverts when visiting other websites. We only use these cookies if you have consented to their use.

You can withdraw your consent to the use of these cookies at any time through the following options: § By changing your options here: [Link]

- Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;

- For any type of cookies, you can disable them through your browser settings.

Please note that refusing cookies does not mean you will no longer receive any online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.

8. GOOGLE ANALYTICS

Google Analytics is a service from Google Inc. (“Google”) which is used to analyse website usage. Google uses the data that is collected to track and study how the website is used, to generate reports on its activities and to combine this information with other Google services.

Google itself can combine this information with data from other websites that you have visited and that are also analysed by Google and can use its findings for its own purposes (e.g. controlling advertising). Google will be able to recognise you if you have a Google account that you are signed into. If your usual residence is in the European Economic Area or Switzerland, Google Ireland Limited is responsible for processing your personal data.

For further information please read the Google Inc. privacy policy.

9. SECURITY

Keeping you and your personal information secure is very important to us. We take a number of reasonable steps to try to protect the personal information that you provide securely in electronic and physical form to protect it from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss, including:

- Using a Transport Layer Secure (TLS) to encrypt the personal data that you send us during the order process.

- Not keeping details of your credit or debit card that would enable any third party to transact using that credit or debit card (such as your CVV number).

- Ensuring that our premises are access controlled and surveyed by video recording where required and our electronic databases require logins and password authentication.

- Regularly monitoring our servers and IT systems for possible vulnerabilities and attacks. Unfortunately, despite this, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal data transmitted to or through our website, and any such transmission is at your own risk. In particular, please keep in mind that if you voluntarily disclose personal information through other means of communication than the website in a non-protected environment (such as through email, sms, online messages) then that information can be collected and used by others outside of our or your control.

10. HOW LONG WILL YOU USE MY INFORMATION FOR?

We retain the data you provide to us for as long as is necessary for the purpose for which it was collected for, e.g. as long as claims could be brought against us, to fulfill our contractual obligations or as long as you may have questions or a claim in relation to our services, notwithstanding any statutory retention obligations that we may be obliged to observe in accordance with legal requirements applicable to us.

In some circumstances, you can ask us to delete your data as set out below.

After you have terminated your use of our services, we may store your information in an aggregated and anonymised format.

11. WHAT ARE MY PRIVACY RIGHTS?

You have certain rights in relation to the personal data we hold about you, which we detail below, and which you can exercise by contacting us as detailed in section 12. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights and that can include asking a set of security questions to ensure it is you. When you have appointed someone else to do the request on your behalf, that person and/or organisation needs to show a valid power of attorney issued by you. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances).

We may not provide you with certain personal data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person) or where another exemption applies.

- Portability: you have the right to receive a subset of the personal data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such personal data to another party. The relevant subset of personal data is data that you provide us with your consent or for the purposes of performing our contract with you. If you wish for us to transfer the personal data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the third party. We also may not provide you with certain data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person or our trade secrets or intellectual property).

- Correction: you have the right to correct any personal data held about you that is inaccurate. You can request the correction by emailing us. Please note that in some cases we can ask you to explain in detail why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that whilst we assess whether the personal data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

- Erasure: you may request that we erase the personal data we hold about you in certain circumstances. Please scroll down to know what those are:

o You believe that it is no longer necessary for us to hold the personal data we hold about you.
o We are processing the personal data we hold about you on the basis of your consent, and you wish to

withdraw your consent and there is no other ground under which we can process the personal data.

o We are processing the personal data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such personal data.

o You no longer wish us to use the personal data we hold about you in order to send you promotions and special offers.

o You believe the personal data we hold about you is being unlawfully processed by us.

Also please note that you may exercise your right to restrict our processing of the data whilst we consider your request for erasure of your personal information as described below.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note that we may retain the personal data if there are valid grounds under law for us to do so (eg. for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Where you have requested that we erase data that we have made public and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the data or providing links to the data to erase the data too.

- Restriction of Processing: You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. Please note that if we stop processing the personal data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection).

o You believe the personal data is not accurate for the period it takes for us to verify your claim.
o You wish to erase the personal data as the processing we are doing is unlawful but you want us to retain

the personal data for storage only and stop processing it.

o We wish to erase the personal data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims.

o You have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.

- Objection: at any time you have the right to object to our processing of data about you in order to send you promotions and special offers, including where we build profiles for such purposes and we will stop processing the data for that purpose. You can do this by contacting us via email or at the bottom of our marketing emails. Please note that you will still receive emails related to the orders you make through our website or updates to our Terms & Conditions and Privacy Policy.

o We are processing the data we hold about you (including where the processing is profiling) on the basis of our or a third party’s legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or if we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the data whilst we make the assessment on an overriding interest.

- Withdrawal of Consent: You can withdraw your consent at any time by contacting us via email. 

12. CONTACT
If you have any questions or concerns about this Privacy Policy, please contact us:
- by emailing us at contact@inakess.com; or

- by writing to the head office: INA KESS Ltd., Schwyzerstrasse 41, CH-8832 Wollerau, Switzerland.

13. UPDATES TO THIS POLICY