AUDEMARS PIGUET CHINA PRIVACY NOTICE

Last updated: August 2025

Your personal information is very important to Audemars Piguet. This  personal information protection policy (the “Privacy Notice”) is to inform you about the processing of personal information that we may collect when you access our online and offline services, including the personal information we gather through our various channels, such as our websites, mobile applications, social media, our customer relations centres, boutiques, our Musée Atelier Audemars Piguet (MAAP), points of sale and the events we organise.

The Audemars Piguet Cookie Policy is a supplement to this Privacy Notice and describes how Audemars Piguet collects information through the use of Cookies and related technologies when you use our Sites and the way in which any person can accept or refuse to receive cookies operated by Audemars Piguet on his/her terminal. You can access our Cookie Policy here. 


Whenever you provide your personal information to a given Audemars Piguet affiliate, it is responsible for the collection and processing of your personal information, at the local level, for the purposes of managing the commercial or contractual relationship relating to Audemars Piguet products and services, in accordance with the applicable local laws. Audemars Piguet Watches (Shanghai) Trading Co, Ltd is Audemars Piguet affiliate in P.R. China and has its registered office at Unit 1601-1604, Level 16, Jing'an Kerry Centre Office Building Tower II, No.1539 West Nanjing Road, Jing'an District, Shanghai, PRC, 200040. At the group level, the Swiss company Audemars Piguet (Marketing) SA,  having its registered offices at route de France 16, 1348 Le Brassus, Switzerland, is responsible for defining the overall policy regarding processing and management of your personal information for commercial and marketing purposes (such as management of the group’s central CRM system and promotional campaigns at group level as opposed to local campaigns), as well as management of the www.audemarspiguet.com  website. In this Privacy Notice, we use the term “Audemars Piguet”, “we” or “our” to refer to Audemars Piguet (Marketing) SA at the registered address above and Audemars Piguet affiliates.

We invite you to take the time to read this Privacy Notice in its entirety. You can also request a copy of the Privacy Notice in our boutiques operated directly by us in China. We process your personal information in accordance with this Privacy Notice in order to provide the services you request. If you do not agree with the content of this Privacy Notice, Audemars Piguet service may not be used or the full range of services may be affected as a result.

We are available to answer any questions you may have, particularly in the exercise of your rights to your personal information, as described in Section X (“Contact Us”).

Personal Information refers to various information related to an identified or identifiable natural person recorded electronically or by other means, but does not include anonymized information.

Sensitive personal information means personal information that, if leaked or illegally used, may easily lead to infringement of the human dignity or harm to the personal or property safety of a natural person, including biometric recognition, religious belief, specific identity, medical and health, financial account, personal location tracking and other information of a natural person, as well as any personal information of a minor under the age of 14.

We may collect personal information either directly from you (for example when you purchase a product in a boutique, when you use our online services, from electronic devices that interact with our Sites) or indirectly (for example, collecting your personal information from your family members) If any sensitive personal information is involved in the information we may collect, we will draw your attention in bold and underlined form. We recommend that you only provide the data requested or necessary for your query. Please carefully consider whether to provide us with sensitive personal information.

This Privacy Notice applies to any personal information we may collect from you or about you (see below) from the sources detailed below. If there is any source not listed in the Privacy Notice, but your personal information will be collected, we will provide you with the necessary information separately.
• Purchase of an Audemars Piguet product or an after-sales service. If you pick up a watch in our boutiques, we need to check your ID card/passport to identify you and verify your identity, but we will not keep any of your ID card/passport information;

• Visits to Audemars Piguet boutiques and points of sale, as well as to the MAAP and participation in events organised or sponsored by Audemars Piguet;

• Registration forms that we collect, whether printed or available on electronic tablets, especially in our boutiques and points of sale;

• Electronic and telephone communications, as well as face-to-face exchanges, even informal, between Audemars Piguet and yourself;

• Electronic and telephone communications with Audemars Piguet customer relations centres;

• Visits to our websites and use of Audemars Piguet mobile applications (“Sites”): in particular when creating and using an account on our Sites, responding to a form or using a service (including subscription to our newsletter, contact request, booking an appointment, list of favourites, pick-up service, AP Coverage, Find a boutique), or of a feature or resources published on our Sites. You will be asked to identify yourself, but you may also visit our Sites without registering;

• Participation in contests, sweepstakes, games and other promotional activities (whether online or in person, with or without a registration);

• Online submission of job applications;

• Data that you share publicly in the course of your interaction with Audemars Piguet on social media (for example, when you “like” an Audemars Piguet page on social media platforms such as WeChat, Weibo and Youku) or on public discussion platforms;

• Data about Audemars Piguet products and services that are publicly available on third-party websites or social media or collected indirectly from third parties;

We may collect different types of information from the above sources depending on the purpose and the manner in which you interact with Audemars Piguet (face-to-face, online, by telephone, etc.), as indicated below:

• Identity and contact information: any information you provide us that would enable us to contact you or to identify you, such as your name, last name, title, e-mail address, postal address or telephone number, as well as your picture, such as you may have uploaded it to your personal account or that you have agreed to provide to us in the context of events organised or sponsored by Audemars Piguet. We may also process the images taken as part of the surveillance systems in place in boutiques and points of sales managed by Audemars Piguet.

• Personal status, preferences and purchase history: any information describing your demographic and behavioural characteristics that you have shared with us. These include, for example, your date of birth, age range, gender, citizenship, language preference, employment status (job title and contact details, company/employer, other professional information), marital status, your links with other Audemars Piguet customers or prospects, interests (sports, leisure, art), lifestyle or your dietary preferences (including dietary allergies), as well as other preferences, such as your list of favourites, watches registered in your account and the history of your purchases and sales  and the services you have requested.

• Participation information: any information you provide us when you participate in contests, sweepstakes, games and other promotional activities such as answers to questions, surveys, or quizzes, timestamp, place and method of participation, levels reached, awards/badges won, tasks completed, progress.

• Data relating to the traffic and use of our Sites: when you interact with our Sites or connect to our WiFi (APGuest), we may collect browsing data using automated data collection technologies, including a dialogue between the website server and your browser. Traffic data may include the browser name and the type of device you are using, as well as technical data about how you connect to our Sites, including your operating system, the IP address of your device connected to the Internet, the identifier of your Internet access point, the date and time of your last visit and the Internet service providers you use (including browsing records). Such data is used for statistical purposes and the analysis of such data is used to improve our Sites, so as to provide you with a personalised browsing experience tailored to your preferences and interests, for example, by directly displaying the pages in your preferred language on your next visit. Such information is captured using automated technologies such as cookies (browser cookies) and web beacons (such as JavaScript); they are also collected through external tracking services (Google Analytics). Please consult our Cookie Policy to obtain detailed information about cookies we use and how we use them.

• Location Information and Permission:

-  when you use the “Find a Boutique” function on our Sites, we may pop up and ask if we are allowed to access your location information;

-  when you enter into a boutique managed by Audemars Piguet or attend an event or otherwise connect to our Wi-Fi (AP Guest), we may also use technologies that connect to the functionality on your device (typically your mobile phone) such as Bluetooth and GPS and collect information based on Wi-Fi and other in-store technologies. You can view the status of the above permission item by item in the device system, and you can decide whether to turn on or off at any time.

Please note that by granting a permission means that you authorize us to collect and use relevant person information to provide you with the relevant services. If you cancel the permission by tuning off the function, it means that you withdraw the authorization, we would not be able to continue to collect and use the relevant personal information, nor would we be able to provide you with the corresponding services. However, your decision to turn off permissions does not affect the effectiveness of previous personal information processing activities based on your authorization.

• Customer feedback: any information that you voluntarily share with us about your experience using our products and services (i.e. in the event of a complaint or in the context of discussions, even informal ones, with our employees). Our sales staff may invite you to add his/her company WeChat account. If you agree, we may collect your WeChat account, WeChat profile picture, nickname or other information. We may also know your need, and your opinions on our products and services through your communication with sales staff.

• Information from social media: we may have access to information that you share publicly on third-party social media, such as the social media listed above or other public discussion forums. If you wish to stop sharing this information, we recommend that you read the terms of use of the social media concerned.

• Payment information: any of the information that we need to fulfil an order or that you use to make a purchase (including billing information, transaction amount, payment type or method, bank account and billing number), and information or documents required by applicable legislation (including your passport or ID card), in particular anti-money laundering laws, anti-corruption legislation as well as embargo and sanction-related decisions, as part of “know your client” type verifications.

Links to other websites. Our Sites may contain or use links to third-party websites (such as advertising, our partners or social media). Such third-party websites have their own privacy policy (including on the use of cookies), which we invite you to review. We do not accept any responsibility for the privacy policies of any such third-party websites that you access at your own risk.

Children’s personal information. Our Sites are not intended for users under 16 years old. We do not knowingly collect personal information from persons under 16 years. If you are a parent or guardian and you know that your child has provided us with personal information, please contact us. If we become aware that we collected personal information from a person under the age of 16 without verification of parental consent, we will take steps to remove such information from our servers, unless we are required to retain it by law (accounting or purchase data, data necessary for applicable guarantees or the management of complaints, etc.). In any event, users under 16 who provide us with personal information have a discretionary right to the erasure of their data which they can exercise, at any time and without cause, alone or through their usual guardian, by contacting us at the address mentioned in Section X “Contact Us”. Requests for erasure will be processed under the conditions and subject to the reservations described above.

Depending on the context, we may use your personal information for the purposes described below. Please note that the types of use listed below depend on your use of our services and do not systematically affect each user:

• Process your orders, your requests for products (including your registration on waiting lists), purchases (including any refund requests) and deliveries;

• Provide the services you have requested, including warranty and after-sales services;

• Conduct checks to identify you and verify your identity;

• Answer your queries, including your requests to exercise your rights;

• Improve our customer service and manage our relationship with you. The data collected, which can be cross-checked from the various sources mentioned in Section II, helps us respond to your requests, meet your needs more effectively and improve our products, services and customer experience according to your preferences and the history of your relationship with Audemars Piguet;

• Manage the events you have registered for and/or attended;

• Send you marketing communication, in particular about Audemars Piguet, our products and services, our events, the opening of new boutiques or points of sale, with your consent when required. Therefore, if you no longer wisht to receive such information, you can unsubscribe at any time, as described in Section VIII;

• Address you advertising offers and chatting with you on social media when you interact with third-party social media features such as “likes”. We recommend that you review the terms of use of the relevant third-party media to learn about these features and, if necessary, terminate your registration;

• Manage and improve our Sites and the services offered, in particular your account, including personalize and facilitate your user experience on our Sites by presenting you – whether when you visit our Sites or in the personal space of your account – with Audemars Piguet-specific content that corresponds to your interests. We are also likely to cross-reference this data to better understand how users, as a group, use the services and/or resources available on our Sites;

• Organizing contests, sweepstakes, games and other promotional activities;

• Manage and register lost, stolen or counterfeit products;

• Manage the stock of certain high-demand products to ensure fair allocation of the products we sell;

• Detect prevent and fight against any fraudulent or illegal activity, including to protect your transactions from payment fraud, to act against counterfeiting and resale of our products in violation of our general terms and conditions and/or the rules applicable to our distribution network;

• Comply with our billing and accounting obligations, as well as our legal and regulatory obligations (such as those arising from anti-money laundering or anti-corruption laws and embargo or sanction-related decisions);

• Deal with any claims or litigation;

• Conduct statistics, particularly for the purpose of measuring traffic on our Sites;

• Manage the recruiting applications submitted on our Sites;

• Protect you, our employees and other persons in our boutiques and points of sales, as well as our property;

• Guarantee IT security and IT operations.

We process your personal information for the period necessary for the purposes for which they have been collected, as described in Section III, to comply with legal and regulatory obligations and for the duration of any period necessary to establish, exercise and defend any legal rights.

In order to determine the most appropriate retention periods for your personal information, we have specifically considered the amount, nature and sensitivity of your personal information, the reasons for which we collected your personal information, the service you deserve and expect from us together with the applicable legal requirements. In particular:

• The personal information used to manage our relationship with you or to send you information, especially about Audemars Piguet, news on our products or services or events will be kept for the duration necessary for the management of our relationship with you, and, whichever date is the latest, a three-year period from the end of your business relationship with Audemars Piguet (i.e. from the end of the warranty period applicable to your purchase, as the case may be) or from your last use of the services available on our Sites or your last contact with Audemars Piguet.

• personal information related to your purchases and the services provided to you, as well as the management of complaints and warranty claims will be kept for a maximum period of ten years from the last event.

These maximum periods apply unless you request the deletion or termination of the processing of your personal information before the expiry of these periods for any ground provided that it complies with any legal obligation applicable to Audemars Piguet.

Sharing your personal information

We may share your personal information to the parties indicated below and for the following reasons:

• We may disclose your personal information to Audemars Piguet (Marketing) SA, in charge of customer relationship, retail, communication, internal audit and IT management for the purposes set out in this Privacy Notice. Such disclosure is necessary for the purpose of providing you with online services, order management and delivery of products. This may include providing you with the products and services that you have requested, improving the services provided and – with your separate consent – sending you marketing communication concerning products, services and events of Audemars Piguet. In order to provide you with products and services, Audemars Piguet (Marketing) SA will process your account and purchase and other information and ensure that your personal information is protected to the same extent as required by the Privacy Notice. You can find the contact details of Audemars Piguet (Marketing) SA under the Section X “Contact Us”.

• For the purpose of delivering the products you ordered and performing the service you requested, we will share your specific personal information with the payment service provider and logistics service provider to assist you in completing the payment of the purchase and delivering or picking up the products.

• For the purpose of complying with our statutory duties and obligations, we will disclose your personal information in accordance with applicable legislation and regulation. We may also disclose your personal information to regulatory authorities, court government authorities or other third parties if we believe it is necessary to comply with legal requirements or to protect our rights or those of third parties or to combat fraud. In which case, we are not obliged to request your consent.

Entrusting your personal information

• We may also disclose your personal information to other Audemars Piguet affiliates and to third-party providers acting on behalf of, and entrusted by, Audemars Piguet Watches (Shanghai) Trading Co, Ltd or Audemars Piguet (Marketing) SA, as the case may be, to process personal information necessary for the purpose of ensuring the continuity of our services and our relationship with our customers and potential customers, helping us provide relevant products and service support (online and offline). Such entrusting of personal information is made for different purposes, including:

• IT development and IT support;

• hosting and carrying out marketing campaigns and business studies. For this purpose, we may disclose to our commercial and advertising partners cross-references of demographic information by user groups (thus containing no direct identification of our visitors), for statistical purposes and for advertising Audemars Piguet products and services;

• management of our Sites and the services offered therein, in particular by the use of Google Analytics, as described in the Cookie Policy. You can access our Cookie Policy here.

• Verifying your information, payment or order fulfillment services, fraud prevention and detection, ID verification.

We will use reasonable efforts (e.g., through contractual arrangements and regular review of personal impact assessments) to ensure that our entrusted third parties have adequate organizational and technical measures in place to protect your personal information and only process the information for the entrustment purposes and processing methods.

Transfer of your personal information

If we need to transfer personal information in connection with a merger or acquisition, purchase or transfer, or similar transaction of all or substantially all of our assets and business, we will require the recipient to continue to perform its obligation under this Privacy Notice or to obtain your new consent.

As just mentioned in Section V, we may disclose your personal information to Audemars Piguet (Marketing) SA, in charge of customer relationship, retail, invoicing, communication, internal audit and IT management, located in Switzerland, as well as to other Audemars Piguet affiliates or third-party providers for the purposes set out in Section V.  As a result, your personal information may be transferred or accessed from a jurisdiction outside of mainland China with your consent when necessary.

We will ensure that your personal information can be protected at a no less than the same and adequate protection level under the Personal Information Protection laws and regulations of the People’s Republic of China and in compliance with our security measures described in Section VII below. The list of jurisdictions to which we may transfer personal information may change. You may request an up-to-date list of jurisdictions to which we may transfer your personal information for specified purposes to the contact details mentioned in Section X (“Contact Us”).

We have put in place reasonable organizational, human, physical and technical security measures to adequately protect your personal information in the Sites, as well as our processing of it. In order to prevent any unauthorized access to your personal information and thus prevent them from being altered, disclosed or destroyed, we apply measures that are aligned with recognized information security standards, like ISO 27001, CIS and NIST. They are regularly adapted and improved in line with technological advances.

Our data security capability includes, but are not limited to, the following:

• Only necessary data: We will take all reasonable and practical measures to ensure that we collect only personal information necessary for the purposes described in the Privacy Notice.

• Risk management process: We identify, assess and control risks in order to manage them successfully and mitigate the likelihood of a negative event affecting your personal information.

• Assure Accountability and Control Access: We implement logical and physical access controls with strong passwords policies, role-based access controls (RBAC), multi-factor authentication (MFA) mechanisms for our employees. We maintain strict accountability for data handling and control access to ensure that only authorized persons can access your personal information in the context of their duties and to provide you with Audemars Piguet  products and services that you request.

• Anonymization and Encryption of Data: We use encryption technology to encode data (e.g., TSL, SSL) and technical anonymization process to ensure the confidentiality and integrity of your personal information. This ensures that your personal information remains confidential and secure, even in the event of a security breach.

• Security Awareness Training: We train our employees to comply with cybersecurity best practices, such as data protection, and raise awareness of common threats such as phishing, social engineering and ransomware attacks, to help our employees recognize and mitigate security risks effectively.

• Regular Testing, Assessing and Evaluating the Effectiveness of Technical and Organizational Security Measures: We regularly conduct testing, assessment, and evaluation of our technical and organizational security measures to ensure their effectiveness. This proactive approach allows us to identify and address vulnerabilities promptly, enhancing the overall security posture of our systems.

• Network security: We implement systems to protect and continuously monitor network activity and availability to detect and respond to security incidents promptly. This proactive approach allows us to mitigate potential risks and safeguard your data effectively.

However, internet is not 100% safe. To connect to the Sites that require a password, we ask you to choose a strong password, not to share it and therefore keep it confidential, and not to use it on other sites.

• Ensure Availability and Resilience: In the event of an unfortunate security incident, we will comply with all applicable laws and deploy all reasonable technical and organizational measures we have put in place to properly manage the information security incident (e.g., incident response plans) to restore data properly (e.g., backups) and minimize disruption to our services (e.g., Business Continuity and Disaster Recovery plans).

In accordance with the Personal Information Protection law, you can, at any time, request access, make copies, rectification and deletion of your personal information or restrict and object to the processing of your personal information. A summary of these rights is provided below:

Your right of access and rectification: unless applicable law prohibits or limits you to do so, you may request access to the personal information that we hold about you in our records, or to correct or help you correct any inaccuracies and to update any out-of-date information. You can make relevant requests through the contact information in the “Contact Us” Section.

Your right to make copies: when technically workable and in accordance with the relevant laws and regulations, you may request us to provide a copy of your personal information that we have. You can make relevant requests through the contact information in the “Contact Us” Section.

Your right of deletion: if you may consider that the purpose of processing your personal information has been achieved or is unable to be achieved, or the personal information is no longer necessary for achieving the purpose of processing; or we cease the provision of the product or service involved, or you withdraw your consent of processing; you may request us to delete your personal information. You can contact us through the "Contact Us" Section to make relevant requests. Kindly note that if the personal information that you request to delete is the necessary information that we need for the provision of certain service, we may not be able to continue with the service provision. In some cases, we may not be able to delete your personal information without also deleting your user account. We may also have to keep some of your personal information after a removal request, in order to meet our legal or contractual obligations. We may also be permitted by applicable law to retain some of your personal information to comply with our legal obligations.

Your right to cancel your account: You may require us to cancel your account by contacting our Customer Service or by writing at the address indicated in Section X “Contact Us” below and we will delete or anonymize your personal information accordingly. The cancellation of your account will not affect the validity of the personal data processing activities that have been carried out before the cancellation. Once you cancelled your account, we will stop providing online services to your and delete your personal information according to your requirements or requirements of law. If it is required by law that we shall keep any of the personal information, we will only deal with it within the scope stipulated by laws and regulations and will not use it in daily business activities.

Opt-out: you may also ask to no longer receive information or offers from us at any time, either by following the unsubscribe process described in the messages you may receive from us, or by writing to us at the address indicated in Section “Contact Us”, below. If you do so, we will update our database and take all reasonable steps to respond to your request as quickly as possible, but we may continue to contact you to the extent necessary in connection with any product or service you have requested.

You may exercise such rights by sending a written request to the Audemars Piguet entity with which you interact or to the postal or electronic address indicated in Section “Contact Us”, below. In general, we can verify the identity of the applicant by comparing the information you provide with information we have collected about you. However, we may need to ask you for additional information to verify your identity. Insofar as we are able to verify the applicant's identity with a satisfactory degree of certainty, we will endeavour to present you with the relevant personal data, or to correct or delete it, in accordance with your request and as provided for by the applicable law.

This Privacy Notice reflects our current practices and is subject to change and update from time to time. When we post changes to this Privacy Notice, we will modify the “update date” at the top of this Privacy Notice to indicate when such changes have come into effect.

If we change this Privacy Notice in a material way, we will inform you through a notice advising of such change at the beginning of the Privacy Notice and on the “audemarspiguet.com” website home page. We will also inform you by other means such as sending you notification emails and/or push notifications and/or pop-up windows prior to making any material changes, which may affect your rights and interests in this Privacy Notice.

If you have any questions about this Privacy Notice, or privacy matters generally, please contact us at the address provided below. You can also use this address if you wish to request access to your personal information, or to unsubscribe from any further marketing communications.  We may first ask you to prove your identity as mentioned under Section VIII. above and then handle your request within reasonable period of time but no longer than 30 calendar days.

Audemars Piguet Watches (Shanghai) Trading Co, Ltd

Email: privacy.china@audemarspiguet.com

You may also contact our Group Data Protection Officer in Switzerland (which implies your consent to the transfer and management of your request outside the Mainland of China) at the address below:

Audemars Piguet (Marketing) SA

Attn: Data Protection Officer

Route de France 16

1348 Le Brassus

Switzerland

Email : privacy@audemarspiguet.com

Unless you make unreasonably repetitive or unreasonably burdensome requests, our responses to your requests will not be charged. We may reject your request if it violates confidentiality or business secrets, or our obligations under applicable law, it directly relates to criminal investigations or trials, it may cause serious harm to your legitimate rights and interests, or those of other individuals or organizations, public security or it involves malice or abuse of rights.