PRIVACY NOTICE FOR AMBASSADORS IN DANIEL WELLINGTON’S AMBASSADOR PROGRAM

Daniel Wellington AB, reg.no 556875-5937 (“DW”, “Daniel Wellington,” “we,” “us” or “our”) will receive personal data about you when you chose to apply for being a DW Icon through Brandbassador. We will process your personal data for the purposes of evaluating a potential participation and performance of the participation in Daniel Wellington’s ambassador program. We strive to be transparent in what we do with your personal data and have therefore adopted this privacy policy. Below, you will find information on what kind of personal data we process, why we do it, what we use it for and how we may share it. Daniel Wellington is the data controller of any processing of your personal data.

PURPOSE, LEGAL GROUND AND STORAGE PERIOD

We will only use your personal data for the purposes, and on the legal grounds, as set out below. We will not use your personal data for any purpose that is incompatible with the below purposes. Further, we will only use your personal data during the period as set out in “storage period”, after which, your personal data will be erased.

POTENTIAL PARTICIPATION IN DW’S AMBASSADOR PROGRAM

Personal data: name, e-mail address, phone number, postal address, social media account, birthday, social media posts, social media statistics Purpose of processing: To evaluate new potential ambassadors for participation in DW’s ambassador program. Legal ground for processing: The processing is necessary for our legitimate interest of establishing a successful participation in DW’s ambassador program and marketing of our products. Storage period: We will process your personal data for two years after the initial collection of your personal data.

PERFORMANCE OF YOUR PARTICIPATION IN DW’S AMBASSADOR PROGRAM

Personal data: name, e-mail address, phone number, postal address, social media accounts. Purpose of processing: To follow and administrate your participation in DW’s ambassador program and fulfil our obligations towards you as an ambassador in DW’s ambassador program. Legal ground for processing: The processing is necessary for the performance of our contract regarding your participation in DW’s ambassador program. Storage period: We will process your personal data during the term of your participation in DW’s ambassador program.

ADMINISTRATION AFTER YOUR PARTICIPATION IN DW’S AMBASSADOR PROGRAM

Personal data: name, address,, e-mail address, phone number Brandbassador account details, including user name and account image Purpose of processing: To fulfil our contractual obligations with you after a mission has been completed, including administrating payouts. Legal ground for processing: The processing is necessary for the performance of our contract regarding your participation in DW’s ambassador program. Storage period: We will process your personal data for the period necessary to administrate your participations in our missions at the Brandbassador platform over time.

FOLLOW-UP OF PARTICIPATION IN DW’S AMBASSADOR PROGRAM

Personal data: name, e-mail address, phone number, address, social media accounts, birthday, gender, photos/social media posts, social media comments social media statistics, target group of the account. Purpose of processing: To measure success of DW’s ambassador program and to create statistics thereof. Legal ground for processing: The processing is necessary for our legitimate interests to follow-up and evaluate DW’s ambassador program and our business and evaluate potential future participations in DW’s ambassador program. Storage period: We will process your personal data for two years after termination of your participation in DW’s ambassador program (or when the last discount code expired if later than the expiration date).

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Only the people who need to process personal data for the purposes mentioned above have access to your personal data.

We may need to share your personal data with our group companies. We further may need to allow our suppliers access to your personal data when they perform services on our behalf, mainly to provide support and maintenance of IT systems, storage services and marketing, as well as couriers for sending products to you.

Any transfer of data outside the EU/EEA is made in line with data protection laws. Our international transfers of personal data (including transfers to our group companies and suppliers outside the EU/EEA) are, where applicable, based on the EU Commission’s standard contractual clauses. For further information about this, please contact us.

YOUR RIGHTS

You are entitled to the following rights under applicable data protection laws:

• The right to access: you may at any time request to access your personal data. Upon request, we will provide a copy of your personal data in a commonly used electronic form. • The right to rectification: you are entitled to obtain rectification of inaccurate personal data and to have incomplete personal data completed. • The right to erasure (“right to be forgotten”): under certain circumstances (including processing on the basis of your consent), you may request us to delete your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us. • The right to object: you may have the right to object to certain processing activities conducted by the us in relation to your personal data, such as where our processing of your personal data is based on our legitimate interest. • The right to restriction of processing: you may under certain circumstances request from us to restrict the processing of your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us. • The right to data portability: you are entitled to receive your personal data (or have your personal data directly transmitted to another data controller) in a structured, commonly used and machine-readable format. Finally, you also have the right to lodge a complaint with the Swedish Authority for Privacy Protection (IMY).

CONTACT INFORMATION

If you have any questions relating to our handling of your personal data or if you would like to invoke any of your rights under applicable privacy legislation, please contact us at dataprotection@danielwellington.com.

TERMS AND CONDITIONS DW ICONS – DANIEL WELLINGTON (DW) AMBASSADOR PROGRAM

The following terms and conditions apply to all participants (“DW Icons” or “you”) in Daniel Wellington’s (“DW”, “Daniel Wellington,” “we,” “us” or “our”) ambassador program at the Brandbassador platform. In addition to these general terms and conditions, specific terms may also apply for certain missions within the DW ambassador program (the ”specific terms”). By applying to become a DW Icon and by applying for and performing collaborations and missions for DW within the DW ambassador program, you confirm that you have read and agree to these terms and conditions. If you do not accept these terms and conditions, you are free to at any time leave our ambassador program.

The discount code The discount created through the DW ambassador program may not be shared publicly, unless instructed otherwise by DW in the missions. In no event may discount codes be shared publicly on platforms other than the registered social media accounts in the ambassador program, including code sharing websites, discount code websites and public forums. Violation of this clause will lead to immediate exclusion of the DW Ambassador program and the participant in the ambassador program looses all claim to further payments including but not limited to cash, gift cards and vouchers.

Advertising Commitments As a DW Icon, you must comply with all current and future applicable laws and regulations regarding advertising, when performing any missions within the DW ambassador program or in any other way perform marketing services for DW or otherwise when performing your obligations as agreed upon between you and us. This means that you as a participant in Daniel Wellington ambassador program have a duty to investigate which applicable laws and regulations need to be complied with in this regard and act accordingly. This includes (but is not limited to) inserting disclosure language such as #SPONSORED or #AD (or any additional information required by applicable laws, including but not limited to necessary language translations) clearly stated in the caption of a post and/or inside photo/video (as required by law), in order to make it directly clear to the viewers of the publication that the publication is an advertisement for DW, in accordance with applicable laws. The aforementioned disclosures must not be hidden, and disclosures must instead be made in a clear and prominent way, apart from the rest of the text in an easy-to-read font, in the beginning of a publication and above the “show more”-button, if any, on the social media account where a publication is made, and/or inside the image/video (as required by law). In videos (if applicable law so requires), you must also orally disclose that the video is advertisement for DW in the beginning of the video. Such oral disclosure shall be made in addition to the publication in question, so that the total agreed length of the publication is not reduced by the disclosure. Regardless of the circumstances you shall always be obligated to comply with this section in each case. This means, for example, inserting necessary disclosures, in accordance with local laws and standards, into a caption provided by DW and/or inside the photo/video (as required by law).

Publication requirements As a DW Icon in the DW ambassador program, you agree to at all times comply with the following:

You shall be well informed about and compliant with the applicable terms and conditions of Brandbassador as well as any and all social media platforms or other third party platform (“third-party terms”) you use when participating in the DW ambassador program. Should it come to DW’s attention that you are, or in DW’s sole discretion, might be breaching any such third-party terms, DW reserves the right to block you from further participation in the DW ambassador program.

Not to make any false statements regarding DW or its products or present information that otherwise is not consistent with DW’s image (such as fraudulent, violent or sexual content), misleading towards consumers or is not compliant with applicable regulations and the user terms and conditions of the social media platform where a poublication is made. You may not include any of DW’s trademarks in any domain name or user/account name on a website or application.

If a publication does not correspond to what has been agreed, you shall immediately correct the publication or create and upload a new publication which is correct. DW reserves the right to decide which of the two alternatives that should apply in each case. DW reserves the right to not make any payments of rewards of any kind (including but not necessarily limited to cash payouts, gift cards or free products) before the non-corresponding publication has been mended.

Further, participation in the DW ambassador program requires that DW is granted access to all insights to all publications made by you though the Brandbassador platform.

License and advertising DW and its affiliated companies has the right to freely use, repost, reproduce and edit the pictures/videos posted by you within the DW ambassador program, in order to promote DW’s products. This license also includes a right, but not an obligation, to refer to you and the social media account where you have uploaded the content for the DW ambassador program. This right granted to DW has no geographical limits and is perpetual. You guarantee i) that you have all the rights (including but not limited to copyright) to the content uploaded by you within the DW ambassador program, ii) that you have obtained all necessary consents of all individuals appearing in the content, and iii) that you have the right to grant DW the use of the content in accordance with these terms and conditions.

DW has the right (but no obligation), by monetary means, to advertise the publications you make within the DW ambassador program via Instagram/Facebook/TikTok/Snapchat or any other now known or future social media platforms, in order to boost the visibility of the publications. You shall therefore give DW advertiser rights to each publication you make within the DW ambassador program when uploading a publication (i.e. by clicking on “Allow business partners to promote” in advance settings for your social media account or similar procedure available on the applicable platform), and maintain such advertiser rights for each and every publication during your participation in the DW Ambassador Program.

You must keep all communication between yourself and us confidential, including information that you receive about how DW carry out its operations in social media or any other information that might be sensitive to DW from a business perspective. This confidentiality obligation shall survive any termination of these terms and conditions.

If we have decided to provide you with DW products to be featured when performing a mission, the products will be sent to the address provided by you, if you wish DW to send the DW products to another address it is your responsibility to inform us in writing about such address.

Breach of the terms, non-compliance and indemnification If you do not comply with these terms and conditions and/or, any applicable specific terms, DW is entitled to, at DW’s sole discretion, immediately block you from the DW ambassador program and, stop any payments or rewards for the non-compliant missions. If DW choses to block you from the DW ambassador program based on these terms and conditions or any specific terms, DW has no obligation to compensate you for non-compliant missions.

You are and shall always be solely responsible for your publications on your social media accounts. DW shall have no liability for you publish on your social media accounts, and you agree to indemnify and hold DW harmless if any acts or omissions performed by you causes damage to DW.

Independent parties By partaking in the DW ambassador program and performing missions within the same, you represent and warrant that you hold all licenses required in order to comply with your obligations under these terms and conditions and/or any applicable specific terms, including, but not limited to, any and all required tax certificates where applicable. The relationship between the you and us is that of independent parties.

Nothing contained in these terms and conditions or your participation in the DW ambassador program shall be construed as creating any employment, agency, partnership, joint venture, or other form of joint enterprise, or fiduciary relationship between the you and us, and neither you nor us shall have authority to contract for or bind the other in any manner whatsoever. As such, DW shall have no obligation to carry out specific payments (other than those explicitly mentioned herein or as otherwise agreed between you and us) or be responsible for any taxes, employee benefits or similar (i) to, (ii) on behalf of, or (iii) for the benefit of you.

You acknowledge and agree that DW will not provide you with any insurance and that you will solely maintain the obligation to pay any and all taxes (including payroll taxes) payable in connection with any compensation (or similar) of any kind provided under these terms and conditions or otherwise applicable on your participation in the DW ambassador program.

Miscellaneous Daniel Wellington reserves the right to update these terms and conditions and/or any specific terms at any time. Where a change is material, you will be informed before.

These terms and conditions and any applicable special terms sets out the entire agreement and understanding between you and us with respect to the subject matter hereof. Any changes or amendments to these terms must be made in writing to be legally binding by us.

Governing law These terms and conditions and any and all specific terms shall be governed by the laws of Sweden, excluding the conflict of law rules thereof.