Privacy Policy | Franck Muller APAC

Last Updated: July 2026

This Personal Data Protection Policy (“Policy”) sets out the basis on which FRANCK MULLER PRIVATE LIMITED (“FMPL”), collectively referred to herein as “FMPL”, “the company”, “we”, “us”, or “our”, may collect, use, disclose or otherwise process personal data (“Personal Data”) of persons in accordance with applicable personal data protection laws and regulations.

As part of our efforts in implementing the latest policies, practices and processes, we will review these policies, practices and processes from time to time. We reserve the right to amend the terms of this Policy at our absolute discretion. This Policy, if amended, will be posted on our website. You are encouraged to visit our website from time to time to ensure that you are well informed of our latest policies in relation to Personal Data protection. By continuing to have a relationship or dealings with FMPL, you shall be deemed to have accepted this Policy as amended and be bound by the prevailing terms as updated from time to time.

This Policy applies to Personal Data in our possession or under our control, including Personal Data in the possession of organisations which we have engaged to collect, use, disclose or otherwise process Personal Data for our purposes. At FMPL, safeguarding your Personal Data is our top priority, and we take reasonable care and implement reasonable security measures to protect your Personal Data.

The purpose of this Policy is to inform you of how we manage Personal Data in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”).

1. Your Personal Data

1.1 The PDPA defines Personal Data as data, whether true or not, about an individual who can be identified either:

(a) from that data; or

(b) from that data and other information to which an organisation has or is likely to have access.

1.2 FMPL considers certain types of Personal Data as “sensitive information”. This includes, but is not limited to, personal details regarding a person's racial or ethnic origin, political opinions or affiliations, religious or philosophical beliefs, membership in professional or trade associations or unions, sexual orientation or practices, criminal history, and health information, including genetic and biometric data.

FMPL generally does not collect sensitive information about individuals. However, should you voluntarily provide us with sensitive information—for example, health-related data such as information about allergies or skin conditions—you are deemed to consent to our collection, use and disclosure of that information solely for the purpose for which it was provided, where it is reasonable that you would voluntarily provide the information, and in accordance with the provisions of the PDPA. We will handle any sensitive information we receive with reasonable care and in compliance with applicable legal requirements.

1.3 We may use your Personal Data for the following purposes:

(a) the purpose for which it was collected and related purposes which would be reasonably expected by you;

(b) purposes to which you have consented; or

1.4 Depending on the nature of your interaction with us, some examples of Personal Data which we may collect from you include your name, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information, educational background, and information about your usage of and interaction with our website.

2. Collection of Personal Data

2.1 We may collect Personal Data from our customers, business partners, contractors, employees and other individuals such as job applicants. We will only collect data:

(a) for which you give, or are deemed to have given, consent to the collection; or

(b) where the collection is required or authorised under the PDPA or any other written law.

2.2 We collect your Personal Data in several ways, including but not limited to:

when you complete forms related to our products or services, such as subscription forms;
when you register for or use our website or services, such as creating an account or logging in;
when you provide feedback or interact with our customer service officers, such as through meetings, emails or telephone calls;
when you send items for servicing, such as watches or electronics;
when you participate in promotions or surveys, such as responding to feedback requests;
when you apply for a job with us, such as by submitting a résumé or application;
through CCTV recordings when you visit our premises, or through photographs or video recordings taken at events;
when you submit your Personal Data to us for any other reason; and/or
when we collect your Personal Data by other lawful means.

2.3 If you provide us with Personal Data relating to a third party, such as your spouse, children, parents, employees or authorised representatives, for any purpose, you represent and warrant that you have obtained the necessary consent from the third party for FMPL to collect, use and/or disclose such Personal Data for that particular purpose.

2.4 While browsing our website, you generally do so anonymously, although certain data such as cookies and IP addresses may still be collected. Please refer to the section on cookies for more details.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 FMPL takes reasonable steps to protect your Personal Data from unauthorised disclosure. Subject to the provisions of applicable laws, your Personal Data will be collected, used and disclosed only for legitimate purposes, including but not limited to:

performing obligations in the course of or in connection with our provision of the services and products requested by you;
managing your relationship with us;
responding to, processing and handling your queries, requests and complaints;
processing your job application, including conducting pre-recruitment checks to assess your suitability for an available employment position;
verifying your identity;
complying with laws, regulations and codes of practice, and assisting law enforcement authorities in Singapore;
conducting aggregated and anonymised data analytics to improve our products and client services; and
with informed consent, using data for any other related purposes in the course of business.

3.2 We may disclose or provide access to your Personal Data to third parties in connection with the purposes described in Section 3.1 of this Policy. We may disclose your Personal Data:

where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you;
to comply with any applicable laws, regulations, codes of practice, guidelines or rules, such as in an emergency or when we receive a subpoena requiring us to disclose your Personal Data; or
to third-party service providers, agents and other organisations we have engaged to perform any of the functions listed in Section 3.1 above on our behalf. Any third parties engaged by us will be contractually bound to keep all Personal Data confidential.

4. Cross-Border Transfers of Personal Data

4.1 As FMPL is an international business, you acknowledge and agree that some information, including Personal Data, may be transferred to regions or countries outside Singapore in the ordinary course of our business. Currently, such locations include the following, although this may change to include additional locations as may be made known to you from time to time:

Malaysia
Thailand
Taiwan
Hong Kong (SAR) of China
Macau (SAR) of China

4.2 When FMPL discloses Personal Data outside Singapore, we will comply with this Policy and the requirements of the PDPA relating to the transfer of Personal Data outside Singapore, including any guidelines issued by the Personal Data Protection Commission.

If we do so, we will notify you of the transfer and provide confirmation that the transfer of Personal Data to the recipient is necessary for the purposes of fulfilling our obligations under applicable laws. We will also take reasonable steps to ensure that your Personal Data will not be used or disclosed by the recipient for purposes other than those permitted under the PDPA, and that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the applicable personal data protection laws and regulations of Singapore.

Additionally, where necessary, FMPL shall enter into legally binding data-sharing agreements with recipients. By continuing to have a relationship with or deal with FMPL, you acknowledge that such transfers may occur and that you have consented, or are deemed to have consented, to the disclosure by FMPL of your Personal Data to the relevant overseas recipients. If you have any questions or wish to withdraw your consent, please contact our Data Protection Officer using the email address set out in Section 15 below.

5. Disclosure Without Consent and Deemed Consent

5.1 Subject to applicable data protection legislation, we may disclose your Personal Data without your prior consent in certain situations, including where required by law or where necessary for law enforcement or legal processes.

5.2 Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your Personal Data to us for the stated purposes. By providing your Personal Data to us, you acknowledge and agree that you have fully read and understood this Policy and consent to the collection, use, processing and disclosure of your Personal Data as described in this Policy.

The exceptions under which Personal Data may be collected without consent are set out in the Second Schedule of the PDPA, which is available through Singapore Statutes Online.

5.3 The purposes listed above may continue to apply for a reasonable period after your relationship with us, such as under a contract, has been terminated or altered in any way, including where necessary to enable us to enforce our rights under any contract with you.

6. Direct Marketing

6.1 Direct marketing involves communicating directly with you for the purpose of promoting the sale of goods and services. Direct marketing may be delivered through various methods, including mail, telephone, email, WhatsApp, LINE, REDnote or SMS.

We may use and disclose your Personal Data for the purpose of sending you direct marketing materials where you have consented to us doing so or where it is otherwise permitted by law.

6.2 You may unsubscribe from receiving direct marketing materials at any time by contacting us using the details in Section 15 of this Policy, ticking the unsubscribe box and returning any mail to the sender, or using the unsubscribe link in our digital communications. We will act upon your request within ten (10) business days of receiving it or otherwise inform you of the timeframe within which the withdrawal of consent will take effect.

7. Security

7.1 FMPL shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession. Please notify us immediately if you become aware of any security breach.

7.2 FMPL requires our contractors and third parties to keep Personal Data confidential, not to use or disclose it for any purpose other than performing services for us or on our behalf, and to comply with this Policy and the requirements of the PDPA.

7.3 While FMPL implements security measures to protect your Personal Data, no system can be entirely free from risk. We will continuously review and enhance our security measures to mitigate potential threats and safeguard your data to the extent reasonably possible.

You should be aware that information uploaded to our social media pages may be publicly viewable. You should use discretion when deciding what information to upload to such sites. FMPL is not responsible for the security and/or management of Personal Data shared by individuals with third-party websites accessible through links on FMPL’s website.

8. Withdrawal, Access and Correction of Your Personal Data

8.1 FMPL provides procedures to manage your Personal Data in compliance with applicable regulations, including the PDPA. Your consent to the collection, use and disclosure of Personal Data remains valid until it is withdrawn in writing.

Withdrawal of Consent

8.2 You may withdraw your consent to the collection, use or disclosure of your Personal Data at any time by submitting your request in writing or by email to our Data Protection Officer.

Upon receiving your request, we will process it within ten (10) business days or otherwise inform you of the timeframe within which the withdrawal of consent will take effect. We will thereafter cease collecting, using or disclosing your Personal Data in accordance with your instructions, although this will not affect FMPL’s right to continue processing Personal Data where such processing is permitted or required under applicable laws.

Depending on the extent to which you withdraw consent to the use and/or disclosure of your Personal Data by FMPL, such withdrawal may result in FMPL being unable to provide services to you and may be considered a termination of the relevant agreement between you and Franck Muller Private Limited or a cessation of services provided by Franck Muller Private Limited. FMPL’s legal rights and remedies are expressly reserved in such an event.

Access and Correction of Personal Data

8.3 You may request access to or correction of your Personal Data by submitting your request in writing or by email to our Data Protection Officer. To respond to your request, we may ask you to provide proof of your identity.

We aim to provide access to your Personal Data within thirty (30) business days. If the request cannot be completed within this timeframe, we will notify you within thirty (30) days of receiving the request.

For correction requests, we will make the necessary changes as soon as practicable unless we are satisfied on reasonable grounds that the correction should not be made.

Depending on the scope and nature of your request, we may charge an administrative fee to cover processing costs. This will be assessed on a case-by-case basis, and you will be informed of any applicable fee in advance. In some cases, a deposit may also be required.

We may request specific information from you to confirm your identity and ensure your right to access your Personal Data or exercise any of your other rights. This is a security measure intended to ensure that Personal Data is not disclosed to anyone who is not entitled to receive it. We may also contact you for further information in relation to your request to help expedite our response.

9. Accuracy of Personal Data

9.1 You must ensure that all Personal Data submitted to us is complete, accurate, true and correct.

9.2 We will make every reasonable effort to ensure that Personal Data collected by us or on our behalf is accurate and complete.

9.3 We generally rely on Personal Data provided by you or your authorised representative. To ensure that your Personal Data remains current, complete and accurate, please inform our Data Protection Officer of any changes using the contact details provided in Section 15 below.

10. Data Retention

10.1 We will retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected and to satisfy any applicable legal, accounting, reporting or business requirements.

10.2 When determining the retention period for your Personal Data, we consider, among other things, the nature of the Personal Data, the risk of unauthorised use or disclosure, the purposes for which we process it and applicable legal requirements.

10.3 Details of retention periods for different categories of Personal Data are available upon request by contacting us.

10.4 Should you require your Personal Data to be deleted from our records, please submit your request in writing using the email address provided in Section 15.

11. Links

11.1 Our websites may include links to other websites or internet sources. FMPL does not control these external sites or sources and cannot be held responsible for them. FMPL disclaims responsibility for the content, advertising, products, services and other materials available on or through such sites or sources. FMPL is also not responsible for any actual or alleged damage or loss arising from the use of, or reliance on, content, goods or services available through such sites or external sources.

12. European Union

12.1 For individuals residing in the European Union, we will obtain your explicit written or electronic consent to process your Personal Data unless such processing is otherwise permitted under the General Data Protection Regulation (“GDPR”).

12.2 We will also obtain your explicit written or electronic consent before disclosing any of your Personal Data unless such disclosure is permitted without consent under the GDPR.

12.3 Under the GDPR, you have several rights regarding your Personal Data. These rights may be exercised by submitting your request in writing or by email to our Data Protection Officer using the contact details below, or by writing to 391B Orchard Road, #18-01 Ngee Ann City Tower B, Singapore 238874. These rights include access to your data, the right to request corrections, deletion in certain circumstances, restriction of processing, data portability, and the right to object to processing, including processing for direct marketing or legitimate interests.

13. Use of Cookies

13.1 FMPL uses HTTP cookies (“Cookies”) on the website to improve your online experience. A Cookie is a small data file stored on your device when you use our website.

You may block or deactivate Cookies through your browser settings. However, blocking or deactivating Cookies may affect the quality of your experience on our website. By continuing to use our website, you agree to the use of Cookies.

13.2 Cookies record information relating to your use of the website. This information is collected and stored on your computer by your web browser and may be used to personalise your online experience. For example, the website may remember stateful information, such as an item added to your wishlist, or record browsing activity, such as logging in.

13.3 By using and accessing the services provided through the website, FMPL may place several Cookie files in your web browser. We use Cookies for the following purposes:

to enable functions of the service;
to provide analytics;
to improve your online experience by remembering your preferences; and
to improve the delivery of advertisements, including behavioural advertising.

13.4 You may accept or decline Cookies by modifying your browser settings. Please refer to your browser’s help menu for instructions. However, you may not be able to use all interactive features of our website if Cookies are disabled.

13.5 In addition to our own Cookies, we may use third-party Cookies to report service usage statistics, deliver advertisements on and through the website, or for other purposes described above.

14. Complaints

14.1 If you have any complaints or concerns regarding our handling of your Personal Data, please contact our Data Protection Officer by submitting your request in writing or by email. We take such concerns seriously and will address them promptly.

14.2 When submitting a complaint, please provide sufficient details about your concern, including the nature of the complaint, the Personal Data involved and any relevant information that may assist us in investigating the matter.

14.3 We aim to acknowledge your complaint within ten (10) business days and will keep you informed of its progress. We will investigate the matter thoroughly and endeavour to resolve it within a reasonable timeframe.

15. Data Protection Officer

15.1 You may contact our Data Protection Officer if you have any enquiry, feedback or complaint regarding our Personal Data protection policies and procedures, wish to make a request, or believe that information we hold about you is incorrect or outdated.

You may contact our Data Protection Officer by email at [email protected].

Addendum to the Personal Data Protection Policy for Australia

This Addendum (“Addendum”) forms part of and supplements the Personal Data Protection Policy of Cortina Holdings Limited, located at https://www.cortinawatch.com/en/personal-data-protection-policy/ (“Global Policy”).

This Addendum applies to the collection, use, disclosure and processing of Personal Data of individuals located in Australia by the Cortina Group, including Cortina Watch Pty Limited (ACN 120 699 149). This Addendum has been prepared to address and reflect the requirements of the Privacy Act 1988 (Cth) (“Privacy Act”), and in particular, the Australian Privacy Principles (“APPs”).

In the event of any conflict between this Addendum and the Global Policy, the terms of this Addendum shall prevail in respect of the Personal Data of individuals located in Australia or Personal Data processed in Australia.

In this Addendum, “Personal Data” includes any information or opinion about an individual whose identity is apparent or can reasonably be ascertained.

1. Cross-Border Transfers of Personal Information

As part of an international business, your Personal Data may be disclosed by the Cortina Group to recipients located outside Australia, including but not limited to members of the Cortina Group located outside Australia and third-party service providers that provide services such as data processing or storage.

Such overseas recipients are likely to be located in the following regions or countries:

Singapore
Malaysia
Thailand
Taiwan
Hong Kong (SAR) of China
Macau (SAR) of China

Where we disclose Personal Data to another party, including a party located outside Australia, we will require that third party to use the Personal Data only for the specific purposes for which we provide the information.

We take reasonable steps to ensure that overseas recipients do not hold, use or disclose your Personal Data in a manner that is inconsistent with the obligations imposed under the Privacy Act and the APPs.

2. Disclosure

In addition to the circumstances and purposes of disclosure set out in the Global Policy, we may disclose your information where we are permitted or required by Australian law to make the relevant disclosure, including to law enforcement bodies, regulators or in other circumstances permitted under the Privacy Act.

3. Artificial Intelligence

We may use artificial intelligence (“AI”) technologies to undertake our operations, enhance our services, and better manage and improve your experience with Cortina. AI may be used for tasks including data analysis or report generation.

Your Personal Data may be processed by us or our third-party service providers using AI or other technologies for the purposes described in this Privacy Policy. However, we do not use your Personal Data in AI or other automated programs to make decisions that significantly affect your rights or interests.

If you have questions about how an AI-based process may have affected you, or wish to seek further information or review, you may contact us at [email protected].

4. How to Request Access to or Correct Personal Information

Under the Privacy Act, you have the right to seek access to and correction of the Personal Data we hold about you.

To request access to or correction of your Personal Data, or to obtain more information about this Addendum or the Global Policy, you may contact our Data Protection Officer:

By email: [email protected]

We will endeavour to respond to requests for access to or correction of Personal Data within a reasonable period, which will generally be within thirty (30) days after the request or complaint is received by the Data Protection Officer.

Where we refuse access, we will, where possible, provide you with written notice setting out the reasons for the refusal and the avenues available to complain about the refusal.

If you are dissatisfied with our refusal to grant access to or correct your Personal Data, you may make a complaint to us using the process set out in Section 5 below or contact the Office of the Australian Information Commissioner.

We may charge a reasonable fee for providing access to Personal Data. No fee will be charged for making a request for access or correction.

5. Complaints

Please direct any questions about this Addendum, or complaints regarding a breach of privacy by us, to our Data Protection Officer:

By email: [email protected]

Any complaint should be made in writing. At all times, privacy complaints:

will be treated seriously;
will be dealt with promptly; and
will be dealt with confidentially.

Our Data Protection Officer will investigate your complaint, and you will be informed of the outcome following completion of the investigation. If you are dissatisfied with the outcome of your complaint, or with an extension to the timeframe within which we will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.