PART I: GLOSSARY, PURPOSES AND SCOPE OF THE PRIVACY POLICY

I. GLOSSARY

The following terms, identified by a capital letter in the body of the provisions of the Privacy Policy, have the meaning given to them below:

• “Company” or “WATCH YOUR TIME HOLDING LTD.,”: refers to a limited liability company whose registered office is located at 2503 Bank America Tower 12, Harcourt Road, Central – Hongkong SAR, registered in Hong-Kong SAR under number 383948557.

• “Consent“: any free, specific, informed and unambiguous expression of will by which the Data Subject accepts, by a declaration or by a clear positive act, that Personal Data concerning him or her may be Processed.

• “Courts”: refers to all courts and tribunals, both judicial and administrative, as well as any body with the task of issuing a binding decision.

• “Data Controller“: the natural or legal person, public authority, department or other body which, alone or jointly with others, determines the purposes and means of processing. For the purposes of this Privacy Policy, the Data Controller is the WATCH YOUR TIME HOLDING LTD.

• “Data Subject“: a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity and whose Personal Data has been collected and processed by WATCH YOUR TIME HOLDING LTD.

• “Employee(s)” (or “Staff”) refers to all present and future employees, regardless of the type of employment contract (open-ended contract, fixed-term contract, temporary contract, etc.), work-study students, trainees and, more generally, any natural person placed, by virtue of a contract, under the hierarchical authority of WATCH YOUR TIME HOLDING LTD.

• “GDPR“: General Data Protection Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, which came into force in the territory of the European Union on May 25, 2018.

• “Human Resources“: refers to any department or member of a department involved in the integration of Employees, their management (payroll, mutual insurance and provident fund management) as well as their development (training, mobility, career development) within WATCH YOUR TIME HOLDING LTD.

• “Individuals Not Contractually Linked to the Company”: refers to any individual has never been contractually linked to WATCH YOUR TIME HOLDING LTD.

• “Limitation of Processing“: the marking of retained personal data, with a view to limiting their future processing.

• “Personal Data“: any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

• “Privacy Policy”: refers to the entirety of the present provisions as well as future updates to be made at the discretion of WATCH YOUR TIME HOLDING LTD.

• “Processing“: any operation or set of operations which may or may not be performed using automated processes and applied to Personal Data or sets of Personal Data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• “Prospects“: any individual or legal entity, who has never been contractually linked to WATCH YOUR TIME HOLDING LTD., contacting the Company or with whom the Company has made contact, without necessarily being in talks, to assess the opportunity of becoming a Supplier, customer, Employee, sub-contractor or to develop any partnership whatsoever.

• “Social Networks”: refers to all, current and future, Company’s official/certified accounts on social networks such as: Instagram, Facebook, LinkedIn, Wechat, X (ex-Twitter), Kuaishou, BiliBili, Douyin and XHS.

• “Subcontractor “: the natural or legal person, public authority, department or other organization that processes Personal Data on behalf of the Data Controller.

• “Supervisory Authority“: refers to a supervisory authority that is concerned by the Processing of Personal Data because:
  
  • the Data Controller or Subcontractor is established on the territory of the Member State to which this supervisory authority belongs;
  • Data Subjects residing in the Member State of that supervisory authority are or are likely to be significantly affected by the Processing; or
  • a complaint has been lodged with that supervisory authority.

• “Users” or “Internet Users”: refers to any natural person, regardless of nationality or domicile, browsing the Website for commercial or non-commercial purposes.

• “Third Party“: a natural or legal person, public authority, service or organization other than the Data Subject, the controller, the processor and the persons who, under the direct authority of the controller or processor, are authorized to process Personal Data.

• “Website”: refers to the website https://www.watchyourtime.com/ and all extensions that link directly to the Website.

1. PURPOSES OF THE PRIVACY POLICY

1. Purposes of the Privacy Policy

WATCH YOUR TIME HOLDING LTD., is committed to preserving the trust of the Website Users, its Prospects and Individuals Not Contractually Linked to the Company with regard to the confidentiality of their Personal Data and therefore ensures that it adopts and complies with all Asian, American and European regulatory (including the GDPR) as well as legislative provisions relating to the protection of Personal Data.

WATCH YOUR TIME HOLDING LTD., guarantees to the Website Users, its Prospects and Individuals Not Contractually Linked to the Company that the Personal Data collected will not be sold to any Third Party.

Through this Privacy Policy, WATCH YOUR TIME HOLDING LTD., pursues a dual objective:

– To report to the Website Users, Prospects and Individuals Not Contractually Linked to the Company on the Processing of their Personal Data;

– To inform the Website Users, Prospects and Individuals Not Contractually Linked to the Company of their rights with regard to Personal Data collected by the Company.

1. Unilateral changes to the Privacy Policy

The content of the Privacy Policy, although intended to be as complete as possible, is not exhaustive and may be updated at the Company’s discretion. Such updates will be binding on the Website Users, Prospects and Individuals Not Contractually Linked to the Company, from the time they are posted on the Website.

1. SCOPE OF THE PRIVACY POLICY

1. Website Users

The Privacy Policy applies to all Users of the Website.

1. Prospects

The Privacy Policy applies to all past, present and future Prospects who have contacted the Company or who have been contacted by the Company, whose Personal Data may have been collected, processed, archived and deleted.

1. Individuals Not Contractually Linked to the Company

The Privacy Policy applies to all Individuals Not Contractually Linked to Company whose Personal Data may be collected by the Company in connection with various events (publications on social networks, subscription to the Company’s newsletter, etc.).

PART II: WEBSITE USERS’ PERSONAL DATA

I. TYPE OF PERSONAL DATA COLLECTED

It should be noted that the collection of Personal Data from Users of the Website is carried out in accordance with the principles of minimization and relevance, so that the collection has been designed to strictly meet the objectives pursued by the Company.

All Personal Data that might be collected by the Company from Users of the Website are listed below.

1. Personal Data collected when filling in the form on the “CONTACT” page

The Personal Data collected from Website Users when they fill in the form on the “contact” page is as follows:

• Name;
• First name(s);
• Compagny;
• Email address;
• Message.
• For the purposes of this Privacy Policy, Personal Data collected when filling in the form on the “contact” page of the Website is classified as Category A.

1. Personal Data collecting when accessing, using and browsing the Website

The Personal Data collected from Website Users when they access, use or browse the Website is as follows:

• IP address;
• Device or browser type;
• The webpage visited by the Website User before coming to the Website;
• Identifiers associated with the Website User’s devices;
• Any log information.

• For the purposes of this Privacy Policy, Personal Data collected when accessing, using and browsing the Website is classified as Category B.

II. PURPOSES OF COLLECTING AND PROCESSING WEBSITE USERS’ PERSONAL DATA

The Personal Data of Users of the Website are collected and processed in order to meet the objectives described below.

1. To facilitate contact between the Website Users and the Company

The contact form described in point I) of this section, made available by the Company on its Website, allow any User to contact the Company directly on any subject.

In this way, the Personal Data collected allows the Company to contact by email the User at the origin of the contact request.

1. To improve and to customize the User experience on the Website

The collect of Personal Data classified in Category B allows the Company to improve and to customize the User experience on the Website. For example, the Company may use the User’s location information to determine local language preferences, or to geotag a post.

1. To manage the Website accessibility

The collect of Website Uses’ Personal Data enables the Company to carry out anti-fraud and blacklist management for any case in which a person has been implicated in fraud concerning the Company’s Website, the Company’s products and services as well as the Company’s brands, in particular with a view to permitting, modifying or refusing that person access to Company’s Website as well as any contact with the Company and to communicate and defend the rights of the Company before any authorities.

III. LEGAL GROUNDS FOR COLLECTING AND PROCESSING THE WEBSITE USERS’ DATA PERSONAL

1. Legal grounds for the Processing of Personal Data

In general terms, the legal provisions relating to the protection of Personal Data provide alternative bases for considering the Processing of Personal Data to be lawful, including:

1. The Data Subject’s consent to the Processing of his or her Personal Data for one or more specific purposes;
2. The performance of a contract (or pre-contractual measures) to which the Data Subject is a party;
3. Compliance with a legal obligation to which the Data Controller is subject;
4. The Processing is necessary to safeguard the vital interests of the Data Subject;
5. Performance of a task in the public interest entrusted to the Data Controller;
6. The pursuit of legitimate interests by the Data Controller.

1. Legal Basis for the Processing Personal Data of Website Users

IV. PERSONS WITH ACCESS TO WEBSITE USERS’ PERSONAL DATA

1. Company’s Employees

The Company’s Employees (sales representatives, administrative staff, IT specialists etc.) have access to the Personal Data of Website Users.

1. The legal representatives of the Company

The legal representatives of the Company may have access to the Personal Data of the Website Users.

1. Public authorities and Courts

The Website Users’ Personal Data may be communicated to public authorities whose communication is mandatory under applicable law.

Similarly, the Company may be required to disclose the Website Users’ Personal Data to Courts.

1. Subcontractors

The Company may subcontract the Processing of Personal Data to a Subcontractor. Where Processing is to be carried out on behalf of the Company, the Company only calls upon Subcontractors who present sufficient guarantees as to the implementation of appropriate technical and organizational measures so that the Processing meets the requirements of the legal provisions relating to the protection of Personal Data and guarantees the protection of the Users’ rights.

1. Supervisory Authorities

The Supervisory Authorities (when they exist, depending on the countries) may have access to Personal Data.

V. RETENTION PERIOD AND STORAGE OF THE WEBSITE USERS’ PERSONAL DATA

1. Duration of conversation of Website Users’ Personal Data

1. Principle of limited conversation of Personal Data

The legal provisions relating to the protection of Personal Data do not define the precise duration for which Personal Data must be kept by the Data Controller.  The latter must identify and precisely assess its operational needs, in particular by referring to sector-specific limitation periods in order to assess and determine the retention periods that should be applied to the various Personal Data.

1. Exception to the principle of limited conversation of Personal Data

As an exception to the above, the Company may keep Personal Data for longer than the above-mentioned periods, in particular to ensure its defense in the context of any proceedings, whether amicable or contentious, to which it may be a party or to prove its rights.

1. Intermediate archiving Personal Data

When Personal Data are no longer used on a day-to-day basis by the Company for the purposes for which it was collected, the Company may archive them for the retention period defined above.

Where archived Personal Data are of administrative or management interest, or to meet a legal obligation to which the Company is subject, they may be consulted by an authorized person within the Company, on an ad hoc basis and with justification.

1. Storage of Personal Data

Personal Data collected by the Company is stored in a manner and under conditions decided individually by the Company, in compliance with national legislation.

PART IV: PERSONAL DATA OF PROSPECTS AND INDIVIDUALS NOT CONTRACTUALLY LINKED TO THE COMPANY

I. TYPE OF PERSONAL DATA COLLECTED

As a preliminary point, it should be noted that the legislation on the collection and processing of Personal Data applies exclusively to natural persons; consequently, this section is devoted exclusively to Prospects and Individuals Not Contractually Linked to the Company who are natural persons. It is reminded that the collection of Personal Data from Prospects and Individuals Not Contractually Linked to the Company is carried out in accordance with the principles of minimization and relevance, so that the individual situation of each Prospect and Individual Not Contractually Linked to the Company is studied in order to collect the Personal Data strictly necessary for the purposes pursued by the Company.

1. Collected Information

All the Personal Data of Prospects and Individuals Not Contractually Linked to the Company that may be collected by the Company – depending on what the Prospect or the Individual Not Contractually Linked to the Company send to the Company’s contact e-mail address – are listed below.

1. Personal Data relating to the identification of Prospects seeking employment

• Civility;
• Last name;
• First name(s);
• Mailing address;
• Date and place of birth;
• Business e-mail address;
• Business telephone number (fixed and/or mobile);
• Employing company (if applicable);
• Employer’s job and position;   
• Qualifications, diplomas and professional certifications;
• Former employers;
• Academic background.

• Personal Data relating to the identification of Prospects seeking employment are classified in Category A.

1. Data relating to the identification of Prospects seeking partnership (supplier, customer, product co-development, etc.) with the Company

• Civility;
• Last name;
• First name(s);
• Business e-mail address;
• Business telephone number;
• Employing company;
• Job and position held within the company employer;
• Business sector.

• Personal Data relating to the identification of Prospects seeking a partnership with the Company are classified in Category B.

1. Data relating to the identification of Individuals Not Contractually Linked to the Company obtained as a result of communications from the Company (newsletter subscriptions, commercial offers subscriptions, registration for conferences or meetings organized by the Company etc.)

• Civility;
• Last name;
• First name(s);
• Business e-mail address;
• Business telephone number;
• Business sector.

• Personal Data relating to the identification of Individuals Not Contractually Linked to the Company, obtained following communication from the Company are classified in Category C.

1. Collected Documents

All documents that may be collected by the Company – depending on what documents the Prospect sends to the Company’s contact e-mail address – are listed below:

1. Documents relating to the identification of Prospects seeking employment

• Curriculum Vitae;
• Cover letter;
• Reference notices provided by the Prospect (where applicable).

• Documents collected relating to the identification of Prospects seeking employment are classified in Category 1.

1. Documents relating to the identification of Prospects seeking partnership (supplier, customer, product co-development, etc.) with the Company

• Business cards;
• Organization chart;
• Prospect company presentation documents.

• Documents collected relating to the identification of Prospects seeking partnership (suppliers, customers, product co-development, etc.) are classified in Category 2.PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA OF PROSPECTS AND INDIVIDUALS NOT CONTRACTUALLY LINKED TO THE COMPANY

The Personal Data of Prospects and Individuals Not Contractually Linked to the Company are collected and processed in order to meet the purposes described below.

1. The smooth running of the Company through the recruitment of qualified personnel

The collection and processing of Personal Data of Prospects seeking employment, whether through an unsolicited application or by responding to a job offer published by the Company directly on its Website or on its Social Networks, enables the recruitment of qualified individuals whose profile corresponds to the qualities sought, as well as the creation of a file of profiles that the Company is likely to recruit at a later date.

1. Technical and economic development of the Company through partnerships

The collection and processing of Personal Data from Prospects seeking partnerships (in particular suppliers and subcontractors) enables the Company to create new opportunities in its sector (or outside), to improve the services provided to the Customers and thus contributes to its technical and economic development.

1. The organization of events organized by the Company

The Personal Data of Prospects and Individuals Not Contractually Linked to the Company are collected and processed in order to enable the organization of events (or services) organized by the Company, mainly with regard to the registration and participation of individuals.

III. LEGAL GROUNDS FOR COLLECTING AND PROCESSING PERSONAL DATA OF PROSPECTS AND INDIVIDUALS NOT CONTRACTUALLY LINKED TO THE COMPANY

1. Legal grounds for the Processing of Personal Data

In general terms, the legal provisions relating to the protection of Personal Data provide alternative bases for considering the Processing of Personal Data to be lawful, including:

1. The Data Subject’s consent to the Processing of his or her Personal Data for one or more specific purposes;
2. The performance of a contract (or pre-contractual measures) to which the Data Subject is a party;
3. Compliance with a legal obligation to which the Data Controller is subject;
4. The Processing is necessary to safeguard the vital interests of the Data Subject;
5. Performance of a task in the public interest entrusted to the Data Controller;
6. The pursuit of legitimate interests by the Data Controller.

1. 1. Legal Basis for the Processing of Personal Data of Prospects and Individuals Not Contractually Linked to the Company

1. PERSONS WITH ACCESS TO PERSONAL DATA

1. Company’s Employees

Company’s Employees, strictly concerned with recruitment as well as technical and commercial development, have access to the Personal Data of Prospects and Individuals Not Contractually Linked to the Company.

1. The legal representatives of the Company

The legal representatives of the Company may have access to the Personal Data of Prospects and Individuals Not Contractually Linked to the Company in order to determine and implement their policy.

1. Public authorities and Courts

The Personal Data of Prospects and Individuals Not Contractually Linked to the Company may be communicated to public authorities whose communication is mandatory under applicable law. Similarly, the Company may be required to disclose documents containing the Personal Data of Prospects and Individuals Not Contractually Linked to the Company to Courts.

1. Subcontractors

The Company may subcontract the Processing of Personal Data to a Subcontractor. Where Processing is to be carried out on behalf of the Company, WATCH YOUR TIME HOLDING LTD., only calls upon Subcontractors who present sufficient guarantees as to the implementation of appropriate technical and organizational measures so that the Processing meets the requirements of the legal provisions relating to the protection of Personal Data and guarantees the protection of the Prospects and Individuals Not Contractually Linked to the Company’s rights.

1. Supervisory Authorities

The Supervisory Authorities (when they exist, depending on the countries) may have access to Personal Data.

1. RETENTION PERIOD AND STORAGE OF PERSONAL DATA OF PROSPECTS AND INDIVIDUALS NOT CONTRACTUALLY LINKED TO THE COMPANY

1. Duration of conversation of Personal Data of Prospects and Individuals Not Contractually Linked to the Company

1. Principle of limited conversation of Personal Data

The legal provisions relating to the protection of Personal Data do not define the precise duration for which Personal Data must be kept by the Data Controller.  The latter must identify and precisely assess its operational needs, in particular by referring to sector-specific limitation periods in order to assess and determine the retention periods that should be applied to the various Personal Data.

1. Exception to the principle of limited conversation of Personal Data

As an exception to the above, the Company may keep Personal Data for longer than the above-mentioned periods, in particular to ensure its defense in the context of any proceedings, whether amicable or contentious, to which it may be a party or to prove its rights.

1. Intermediate archiving Personal Data

When Personal Data are no longer used on a day-to-day basis by the Company for the purposes for which it was collected, the Company may archive them for the retention period defined above. Where archived Personal Data are of administrative or management interest, or to meet a legal obligation to which the Company is subject, they may be consulted by an authorized person within the Company, on an ad hoc basis and with justification.

1. Storage of Personal Data

Personal Data collected by the Company is stored in a manner and under conditions decided individually by the Company, in compliance with national legislation.

PART V: RIGHTS COMMON TO ALL DATA SUBJECTS

I. THE RIGHT OF ACCESS TO PERSONAL DATA (THE “RIGHT OF ACCESS”)

In accordance with the legal provisions relating to the protection of Personal Data, any Data Subject has the right to receive a copy of his or her Personal Data in the Company’s possession.

1. THE RIGHT TO RECTIFICATION OF PERSONAL DATA (THE “RIGHT TO RECTIFICATION”)

In accordance with the legal provisions relating to the protection of Personal Dat, any Data Subject has the right to obtain from the Company, as soon as possible, the rectification of Personal Data, concerning him or her, that are inaccurate.

1. THE RIGHT TO BE FORGOTTEN (THE “RIGHT TO BE FORGOTTEN”)

In accordance with the legal provisions relating to the protection of Personal Data, any Data Subject has the right to obtain from the Company, as soon as possible, the erasure of Personal Data, concerning him or her, except in the following cases:

• • • When the Processing is necessary to comply with a legal obligation to which WATCH YOUR TIME HOLDING LTD., is subject.

• • • When the Processing is necessary for the establishment, exercise or defense of legal rights of WATCH YOUR TIME HOLDING LTD.

1. THE RIGHT TO RESTRICT PROCESSING (THE “RIGHT TO RESTRICT”)

In accordance with the legal provisions relating to the protection of Personal Data, any Data Subject has the right to obtain from the Company the Limitation of the Processing of his/her Personal Data in the following hypotheses:

• • • If the Data Subject exercises his/her Right to Rectification, the Limitation of Processing may be required for the time necessary for the Company to verify the accuracy of the Personal Data;

• • • Where the Processing of Personal Data is unlawful, the Data Subject may demand the Limitation of its use rather than its erasure;

• • • When the Company no longer needs the Personal Data for the purposes of the Processing, but it is still necessary for the Data Subject to establish, exercise or defend legal claims.

1. THE RIGHT TO PORTABILITY (“RIGHT TO PORTABILITY”)

In accordance with the legal provisions relating to the protection of Personal Data, any Data Subject has the right to obtain from the Company the Personal Data it holds in a structured, commonly used and machine-readable format.

1. THE RIGHT TO OBJECT (“RIGHT TO OBJECT”)

In accordance with the legal provisions relating to the protection of Personal Data, any Data Subject may object at any time on grounds relating to his or her particular situation to the processing of his or her Personal Data unless there are compelling legitimate grounds for the Processing which override the interests and rights and freedoms of the Data Subject or for the establishment, exercise or defense of legal claims.

PART VI: TECHNICAL DATA PROCESSING

I. Definition of cookies

Cookies (hereinafter “Cookie(s)”) are files stored by a server on the terminal (computer or phone) of any User of the Website and associated with a web domain. This file is automatically sent back when the User contacts the same domain again.

Each Cookie is assigned an anonymous identifier. The Cookie file enables its issuer to identify the terminal in which it is stored for the duration of the Cookie’s validity or storage.

1. The different categories of Cookies

1. Necessary Cookies

Technical Cookies are necessary for browsing the Website and taking full advantage of its functionalities. They enable certain functionalities and the presentation of the Website to be adapted to the User’s browser and hardware.

1. Performance Cookies

Performance Cookies are used to understand and analyze the key performance indexes of the Website which helps in delivering a better User experience.

1. Functionality Cookies

Functionality Cookies are used to simplify Users’ browsing on the Website by enabling them to save some of their choices (language, country, information relating to a previously entered form, etc.).

1. Analytics Cookies

Analytics Cookies are used to understand how Users interact with the Website. These Cookies help provide information on metrics such as the number of Users, bounce rate, traffic source etc.

1. Cookie settings by Users

Each User may, at any time, set his/her browser parameters and thus decide on his/her choices regarding Cookies. Users may make the following choices and change his/her options over time:

• Accept the storage of all Cookies embedded in the pages and content consulted;
• Refuse the storage of Cookies on their terminal;
• Ask to be prompted, by his/her browser, to give his consent or refusal before the installation of a new Cookie on his terminal.

In the event of a Website User refuses all Cookies, some portions of the Website may not work properly.

To get help setting up his/her Cookies preferences, the Website User can use the “HELP” function on his/her browser and visit the website www.aboutcookies.org which contains comprehensive information on how setting up Cookies preferences on a wide variety of browsers.

1. Collaboration with other companies

WATCH YOUR TIME HOLDING LTD., may collaborate with other companies, including social or advertisement networks, which place Cookies, web beacons and other tracking technology on the Website, to collect or receive information from the Website and elsewhere on the internet and use that information to provide measurement services and target ads.

PART VII: PRIVACY POLICY REQUESTS AND DISPUTE RESOLUTION

I. REQUESTS MADE BY DATA SUBJECTS

Any Data Subject wishing to obtain information about this Privacy Policy or exercise any of the rights conferred on him or her by the legal provisions relating to the protection of Personal Data, in respect of Personal Data collected by the Company, should contact WATCH YOUR TIME HOLDING LTD., by e-mail at the following e-mail address: contact@watchyourtime.com.

1. SETTLEMENT OF DISPUTES

In the event of a dispute arising between a Data Subject and the Company, relating to the performance or interpretation of this Privacy Policy, and, more generally, to the collection of Personal Data or their Processing by the Company, the Data Subject is invited, in order to attempt to resolve the dispute amicably, to contact the Company directly by e-mail at the following e-mail address: contact@watchyourtime.com.

Failing amicable settlement, the dispute will be brought before the competent courts in accordance with the international or national rules of civil procedure.