Privacy Policy

1. Controller and contact

The controller is PINDORO S.R.L.S. UNIPERSONALE.

DPO details will be published only if one is formally appointed.

2. Scope

This policy covers RW Watch Management and connected services, including RW Suite, RW MyWatch, RW Control Panel, RW Exchange, connected dealer websites and related web and mobile services. Processing applies only where the relevant feature is actually used.

3. Data processed

We may process identification and contact details; accounts, roles, companies, sessions and devices; dealer customers and suppliers; inventory, purchases, sales and deals; watch data, serials, condition, set, origin and value; photos, documents, notes and attachments; purchase, valuation, sale and trade-in requests; offers, messages, support, wishlists, searches, preferences and consents; technical identifiers, push tokens, IP addresses, logs, errors and diagnostics.

4. RW MyWatch private data

The MyWatch collection is private by default. Full serials, documents, purchase prices, private notes, precise location and total collection value are not public. An owner-reported watch is not verified until the relevant RW process is completed. Consumers choose what to share for each request.

5. Sources

Data may be provided by users or dealers, generated while services are used, received from an authorised party in a sale or request, or obtained from lawfully enabled sources. Dealers entering customer data must have a valid legal basis.

6. Purposes and legal bases

Data is processed to provide accounts and requested services, operate inventory and CRM, manage requests and support, meet legal and accounting duties, protect security and prevent abuse, share consumer requests as instructed, send permitted communications and improve technical performance. Applicable bases are contract or pre-contractual steps, legal obligations, legitimate interests and consent.

7. Dealer customer data

RW Suite is a B2B service and may host dealer-entered data. Contracts define controller and processor roles. PINDORO may act as an independent controller for accounts, security, billing, its own legal obligations and clearly communicated purposes. Dealers remain responsible for data they upload and communications they send.

8. Consumer–dealer relationship

Dealers cannot freely browse the identifiable consumer base or MyWatch collections. Identifiable data is disclosed only through an authorised relationship, a request addressed or routed to that dealer, or an explicit sharing choice. Before then, only aggregated or limited non-identifying information may be shown.

9. Messaging, WhatsApp and notifications

RW messaging supports service communications, support, requests and offers. Private messages are not used for behavioural advertising. WhatsApp may be an optional hand-off and may involve Meta under its terms. Service and promotional notifications are separate. Push may use minimum technical tokens through Apple or Google when configured.

10. Marketing and consent

Optional consent is not preselected. RW marketing, dealer marketing, promotional push, non-essential personalisation and dealer sharing are handled separately where required. Status, notice version, date, source and withdrawal are recorded. RW does not sell personal data.

11. Analytics, cookies and tracking

Minimised technical data and optional product events may support operation, security, diagnostics and measurement. Full serials, documents, addresses and free-form messages are excluded. The current configuration does not use cross-app or cross-site advertising tracking. Non-essential web tracking requires the applicable legal basis.

12. Market values

Watch values and trends are indicative estimates, not guaranteed prices or financial advice. Brand, model, reference, year, condition, set, currency, date and source may be used; unnecessary identifying data is excluded or aggregated.

13. Recipients and providers

Data may be accessed by authorised personnel, authorised recipient dealers, confidential advisers, competent authorities and providers needed for hosting, databases, storage, authentication, e-mail, notifications, support, security and diagnostics. WhatsApp, push, payment and market-data providers are involved only when enabled. The current subprocessor list is available from info@rwsuite.com.

14. International transfers

Transfers outside the EEA are protected through an adequacy decision, Standard Contractual Clauses or another valid mechanism, with supplementary measures where required.

15. Retention

• accounts: for the relationship, then deletion or anonymisation subject to duties;
• MyWatch collection and files: for the account and technical deletion cycle;
• requests, offers, deals, related messages and support: 24 months after closure;
• ordinary application logs: 6 months;
• security and anti-fraud logs: 12 months, longer for a documented incident;
• identifiable or pseudonymous analytics: 14 months;
• mandatory accounting, tax and contractual records: 10 years or the applicable legal term;
• operational backups: indicative 30–90 day rotation;
• sensitive administrative audit: 24 months, subject to duties or incidents.

Consent and objection evidence is kept as necessary to demonstrate compliance and honour the user’s choice.

16. Security

Risk-based measures include encrypted transport, role and object-level controls, tenant separation, protected documents, temporary URLs where appropriate, logging, backups and incident procedures. Full serials and sensitive documents are not public by default. No system can guarantee absolute security.

17. Rights and account deletion

Where applicable, individuals may request access, rectification, erasure, restriction, objection, portability and withdrawal of consent, and complain to the competent authority. Contact info@rwsuite.com. The intended path is Settings → Account → Delete account. Legally retained records are isolated and not used for marketing.

18. Automated decisions and verification

Matching, routing, abuse prevention and suggestions may use automated rules to assist the service. Unless specifically stated otherwise, RW does not make solely automated decisions with legal or similarly significant effects. A watch is not authenticated or sealed automatically from owner-reported information alone.

19. Children

RW Suite is for professionals. RW MyWatch is not specifically directed to children and must not be used by anyone lacking the legal capacity required to enter the applicable contract.

20. Updates and contact

The revision date appears above. Material changes are communicated appropriately and renewed consent is requested where necessary. Privacy: info@rwsuite.com. Support: support@rwsuite.com. Formal notices: pindorosrl@legalmail.it.