UPDATED: JUNE 2026

This Privacy Policy explains how ORLOV Monte Carlo SARL (together with its affiliates and subsidiaries, “ORLOV,” “we,” “our,” or “us”) collects, uses, retains, and discloses personal data when you visit or make a purchase through our website at https://www.orlov.com (the “Website”). It applies to your use of the Website and to your interactions with the ORLOV Concierge.

DATA CONTROLLER

The data controller responsible for your personal data is ORLOV Monte Carlo SARL, 108 rue de l’Alzette, 4010 Esch-sur-Alzette, Luxembourg. For any privacy question or to exercise your rights, contact us at info@orlov.com.

YOUR CONSENT

Please read this Privacy Policy carefully. It should be read together with our Terms of Sale, which govern your use of the Website. Where we rely on your consent to process your personal data — for example, for certain marketing communications — you may withdraw that consent at any time.

WHAT WE COLLECT

To provide certain features of the Website and to fulfil your orders, we may collect the following personal data: name, email address, postal address, telephone number, billing and payment details (processed securely by our payment providers), date of birth where provided, products purchased, and the names and contact details of gift recipients you provide. We may also collect information you have begun to provide where an order or registration is started but not completed.

We also collect data generated by your use of the Website (“usage data”), such as pages visited, features used, time spent, referring website, approximate location, language, device identifiers, and IP address. Where usage data identifies you or is combined with your personal data, we treat it as personal data.

COOKIES

We use cookies and similar technologies to operate the Website, remember your preferences, and understand how the Website is used. Non-essential cookies are set only with your consent, which you may manage or withdraw through your browser settings or our cookie controls. Some features may not function fully if cookies are disabled. Third parties may also set cookies through our services; we do not control their practices and recommend reviewing their privacy policies.

HOW AND WHY WE USE YOUR DATA — LEGAL BASES

We process your personal data on the following legal bases under the EU General Data Protection Regulation (GDPR) and Luxembourg data-protection law:

• To perform our contract with you — to process and deliver your orders, arrange Concierge services, handle returns, and provide customer support.

• To comply with our legal obligations — including tax, accounting, customs, and anti-fraud requirements.

• For our legitimate interests — to operate, secure, and improve the Website, prevent fraud, and understand how our Website is used, provided these interests are not overridden by your rights.

• With your consent — to send you marketing communications about our products, collections, and events, and to set non-essential cookies. You may withdraw consent at any time.

MARKETING COMMUNICATIONS

Where you have consented, or where permitted by law, we may send you emails about our products, collections, services, and events. Every marketing email includes a link to unsubscribe. Withdrawing consent does not affect essential transactional messages, such as order confirmations or important notices about changes to our terms and policies, which you may continue to receive.

DISCLOSURE OF YOUR DATA

We do not sell your personal data. We may share it with trusted service providers who act on our behalf — such as payment processors, secured logistics and shipping partners, IT and hosting providers, and marketing service providers — under contracts that require them to protect your data and use it only for the purposes we specify.

We may also disclose personal data where required to comply with applicable law, regulation, legal process, or a governmental or law-enforcement request; to prevent fraud or protect the rights, property, or safety of ORLOV, our clients, or others; or in connection with a sale, merger, or transfer of all or part of our business, in which case we will require the recipient to honour this Privacy Policy.

INTERNATIONAL TRANSFERS

As ORLOV operates internationally, your personal data may be transferred to and processed in countries outside the European Economic Area. Where this occurs, we put in place appropriate safeguards — such as European Commission adequacy decisions or Standard Contractual Clauses — to ensure your data remains protected.

DATA RETENTION

We keep your personal data only for as long as necessary for the purposes set out in this Policy, including to satisfy any legal, accounting, tax, or reporting obligations. Order and transaction records are retained for the periods required by applicable law; marketing data is retained until you withdraw consent or object.

YOUR RIGHTS

Subject to applicable law, you have the right to access the personal data we hold about you; to request correction of inaccurate data; to request erasure; to restrict or object to certain processing, including direct marketing; to data portability; and to withdraw consent at any time. To exercise any of these rights, contact us at info@orlov.com. We will respond in accordance with applicable data-protection law.

If you believe we have not handled your personal data properly, you have the right to lodge a complaint with the Luxembourg supervisory authority, the Commission Nationale pour la Protection des Données (CNPD), or with the supervisory authority in your country of residence.

CHILDREN

The Website is intended for those aged 18 or older. We do not knowingly collect personal data from anyone under 18. If you are a parent or guardian and believe a minor has provided us personal data, please contact us at info@orlov.com and we will delete it.

THIRD-PARTY LINKS

The Website may contain links to third-party websites that have their own privacy practices. This Privacy Policy does not apply once you leave the ORLOV Website, and we are not responsible for the privacy practices of other sites. Please review their policies before providing personal data.

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Material changes will be posted on this page, and where required by law we will provide advance notice or seek your consent. By continuing to use the Website after changes take effect, you accept the updated Policy.

CONTACT US

For any question about this Privacy Policy or how we handle your personal data, email us at info@orlov.com or write to ORLOV Monte Carlo SARL, 108 rue de l’Alzette, 4010 Esch-sur-Alzette, Luxembourg.