Foot Locker

Europe Privacy Statement (English)

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CUSTOMERS PRIVACY STATEMENT   Europe   When you are shopping at Foot Locker in Europe or when using our Sites, you will be sharing certain personal data (“Personal Data”) with us. With this Customers Privacy Statement (“Statement”) we inform you on how we process your Personal Data.   This Statement has the following chapters: 1.         &nbsp. Introduction 2.         &nbsp. Who are we? 3.         &nbsp. What Personal Data do we collect from you? 4.         &nbsp. Why do we use your Personal Data? 5.         &nbsp. How long do we retain your Personal Data? 6.         &nbsp. What automated decisions, including profiling, do we make about you? 7.         &nbsp. Who do we disclose your Personal Data to? 8.         &nbsp. Do we transfer your Personal Data outside of the European Economic Area (“EEA”)? 9.         &nbsp. Children’s data privacy 10.      &nbsp. How do we protect your Personal Data? 11.      &nbsp. Links to other sites 12.      &nbsp. What are my rights? 13.      &nbsp. How can I file a complaint? 14.      &nbsp. Updates to this Privacy Statement 15.      &nbsp. Contacts     1.         &nbsp. Introduction   Transparency is one of the key principles of data protection legislation. With this in mind, we inform you on how your Personal Data is being processed and we promote the objective of strengthening your rights as an individual, our accountability and the lawful and fair processing of Personal Data.   This Statement contains information on how we process your Personal Data when you visit our websites and stores (“Sites” and “Stores”), sign up for our Loyalty Program Membership (“FLX Membership”) and our newsletters (“Newsletter”), use our mobile applications (“Apps”), register through the creation of a personal account (“Personal Account”), respond to a survey (“Customer Satisfaction Program”) and when you contact us (collectively the “Services”). This Statement applies to all Personal Data of Customers collected by Foot Locker Europe B.V. or any of its EU affiliates or brands, including Kids Foot Locker and Sidestep (“Foot Locker”).     2.         &nbsp. Who are we?   Foot Locker Europe B.V. is the Data Controller responsible for Personal Data in respect of Customers that are subject to the EU General Data Protection Regulation (“GDPR”).   Foot Locker Europe B.V. is incorporated under Dutch law and has its principle address at Ir. D.S. Tuijnmanweg 3-5, 4131 PN, Vianen, The Netherlands. Foot Locker Europe B.V. is registered at the Dutch chamber of commerce under the registration number 23067735.     3.         &nbsp. What Personal Data do we collect from you?   3.1      &nbsp. Personal Data you share with us directly   We collect the following categories of Personal Data when you use our Services (depending on which of the Services you are using):       a.    &nbsp. Customer personal details: full name, title/salutation, contact details, date of birth, gender, preferred language, address;     b.    &nbsp. Interests and preferences: historical product purchases (including returns or orders cancelled), shoe and/or apparel size, interests, feedback and survey data;     c.    &nbsp. Customer account details: customer ID, account information, choice and opt-in of Foot Locker communications (FLX Publications/Newsletters);     d.    &nbsp. Order information: order (tracking) number, order status and history, sales order information, invoice and shipping address, bank account information, purchase history. and     e.    &nbsp. Communications with Customer Service.   3.2      &nbsp. Special categories of Personal Data   Foot Locker does not collect Personal Data belonging to the so-called special categories, being such data regarding ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, health data, political opinions or trade union memberships during your use of our Services.   3.3      &nbsp. Personal Data we collect from you indirectly   We collect the following categories of Personal Data when you use our Services:       a.&nbsp. &nbsp.  Online activity: your online interaction with us through the use of cookies, web beacons, pixel tags, log files or other similar technologies when you use our Services or&nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp.       interact with our emails or advertisements on our Site, our App, or other sites. For more information, please read our Cookies Statement;     b.&nbsp. &nbsp.  Customer personal details: for example, name, email address, profile image, gender, date of birth, place of residence, list of friends, interests and likes. Only information you             have consented to be used is shared with us. For more information, please read our Cookies Statement. and     c.&nbsp. &nbsp.  Your image(s) from you when you visit our Stores to record you on video through the use Closed-Circuit Television (“CCTV”). For more information, please read our CCTV             Statement.   3.4      &nbsp. Personal Data we receive from other sources   We receive the following Personal Data when you use our Services:     a.&nbsp.  Customer personal details: for example, name, username, demographic information, address, contact information, interests and online activity. We obtain such Personal Data&nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp. from other sources that you use to connect with us. For example, from social networks. To disable this, please adjust your privacy and advertising settings through the&nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp. &nbsp. applicable (browser) service provider used. and     b.&nbsp.  Online activity: your online interaction with us if you have provided your consent for the use of third party (tracking) cookies. For more information, please read our Cookies &nbsp.      &nbsp. &nbsp.  Statement.     4.         &nbsp. Why do we use your Personal Data?   We use your collected Personal Data for the following specific purposes and categories of use:   4.1      &nbsp. To process and execute your order   This includes processing and delivering your order, contacting you concerning the status of your order or any other information related to your order which we have to communicate with you. Ground for processing: the processing of your Personal Data is necessary for the performance of a contract with you. The failure to provide us the required Personal Data means that we cannot execute such contract and deliver you the purchased or requested product or service.   4.2      &nbsp. To provide you with customer service   We wish to answer any of your questions or requests, and we communicate with you with regard to a purchase, the use of our Services and to solve any of your possible issues in relation to the Services. Ground for processing: the processing of your Personal Data is necessary for the performance of a contract with you. The failure to provide us the required Personal Data means that we cannot execute such contract and deliver you the purchased or requested product or service.   4.3      &nbsp. To comply with applicable laws and regulations   When you purchase products or take services from us, we are required by law to keep certain Personal Data. We may also need to process your Personal Data to comply with court orders or governmental requests. Ground for processing: the processing of your Personal Data for legal and regulatory purposes is necessary for compliance with legal obligations that we are subject to.   4.4      &nbsp. Personal Account   When you shop at Foot Locker, you can register your Personal Data and create your own profile. Even though the registration is not required, it provides you with a quick and simple checkout experience. Ground for processing: the processing of your Personal Data is based on your consent. Please note that you can always withdraw your consent by deleting your Personal Account.   4.5      &nbsp. FLX Membership   Our Loyalty Program Membership is currently only operational in the Netherlands, in France and in the UK. Therefore, the information related to the FLX Membership is only applicable to the countries mentioned above. As a valued customer of Foot Locker, you can sign up for our FLX Membership by creating a FLX Membership account or signing in with your existing Personal Account: in this case, we will link your Personal Account with the FLX Membership account, including your purchase history. FLX Membership is offered in order to provide you the ultimate shopping experience and to reward you for being a loyal customer and engaging and interacting with our brand through granting FLX points and benefits. By joining FLX Membership, as integral part of this program, you will be informed of special products, launches, offers, membership activity history, points balance and expiration, opportunities and offers for earning and redeeming of points and other news through communications (“FLX Publications”) sent by e-mail, direct message and/or mail. Ground for processing: the processing of your Personal Data is based on your consent. Please note that you can always withdraw your consent by using the unsubscribe link at the bottom of our FLX Publications, change your communication preferences settings and/or delete your FLX Membership account. For more information, please read our FLX Membership Terms and Conditions.   4.6      &nbsp. Newsletter   You can subscribe for our Newsletter in order to receive future e-mails about sneaker releases, news, surveys, initiatives and events, to remind you to complete a purchase or a transaction and to send you specific content based of your preferences and interests. Ground for processing: the processing of your Personal Data is based on your consent. Please note that you can always withdraw your consent by using the unsubscribe link at the bottom of our emails or change your communication preferences settings in your Personal Account.   4.7      &nbsp. Customer Satisfaction Program   When you shop you have the possibility to participate in our survey for research program and opinion polling to develop and improve our Services obtaining your feedback. The data collected in this context is not used by us for advertising purposes. Your answers are neither passed on to third parties nor are published. Ground for processing: the processing of your Personal Data is based on your consent.   4.8      &nbsp. For marketing purposes to provide you with customized content, targeted offers and advertising on our Services   We provide you with customized content, targeted offers, and advertising in order to improve your shopping experience, to provide you more relevant content and to know more about you. This may include generating tailored adds on social media like Facebook. Ground for processing: the processing of your Personal Data is based on our legitimate interest in operating our business by analyzing you as (potential) customers, how you purchase and use our Services and to maintain or establish the relationship with you. We will only process this Personal Data when your interests or fundamental rights do not override our legitimate business interest. Where we cannot rely on legitimate interest, the processing of your Personal Data is based on your consent. Please note that you can always withdraw your consent.   4.9      &nbsp. To operate our business and analyze, develop and improve our Services   We maintain security of our Services. We also enable your use of our Services to administer accounts, diagnose and resolve technical and Service related problems and other internal functions. This includes analyzing trends and Site traffic and administer and optimize our Services. This is partially done via the use of internet Cookies. For more information, please read our Cookies Statement. Ground for processing: the processing of your Personal Data is based on our legitimate interest in operating our business and to develop and improve our Services in an efficient and appropriate manner and in enhancing the effectiveness, user experience, functioning and security of our systems, networks and services. We will only process this information if your interests or fundamental rights do not override our legitimate business interest. Where we cannot rely on legitimate interest, the processing of your Personal Data is based on your consent. Please note that you can always withdraw your consent.   4.10  &nbsp. For litigation case management and evidentiary purposes   We may store your Personal Data if relevant for any possible future court case, legal advice and/or any other litigation and disputes. Ground for processing: the processing of your Personal Data is based on our legitimate interest to manage litigation cases and to defend Foot Locker against any possible (third party) claims.   4.11  &nbsp. To prevent and detect offences and to protect you, our employees and your and our property   We record how you use our Services to prevent and/or detect fraud, abuse, illegal use or violations of our policies and procedures or our general terms and conditions. This include the use of CCTV. For more information, please read our CCTV Statement. Ground for processing: the processing of your Personal Data is based on our legitimate interest to prevent and detect offences which may affect you, our employees and your and our property.   4.12  &nbsp. Or otherwise as described to you at the point of Personal Data collection     5.         &nbsp. How long do we retain your Personal Data?   We retain your Personal Data for as long as is necessary to fulfil the relevant purposes we collected it for, as described in this Statement, unless a longer retention period is required by the applicable law. We typically keep your personal data between 3 and 15 years depending on your country of residence, from the purchase in order to enable us to deal with any issues or concerns you may have about the products or services you have received, and to allow us to bring or defend legal proceedings. In some circumstances, some of your Personal Data will be deleted in much shorter timescales, for example:   5.1      &nbsp. CCTV footage is stored between 24 hours and 1 month depending on the country where the footage is taken;   5.2      &nbsp. Marketing consents will be kept as long as you want to continue being informed by us. and   5.3      &nbsp. Litigation cases are usually kept for 10 years depending on your country of residence.   If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent and combat fraud and abuse, or enforce our terms and conditions, we will also keep hold of some of your Personal Data, even if it is no longer needed to provide our Services to you.     6.         &nbsp. What automated decisions, including profiling, do we make about you?   For our mutual security, each credit/debit card and PayPal payment is processed through an automatic payment verification system. The order details you entered are then compared to those registered to the payment card. In case the system cannot verify these details, it will automatically cancel your order.   We combine the information (including Personal Data) we receive from and about you, including the information you provide to us on one of the Services, information we receive from third parties, information we automatically collect (as explained above), and information provided or collected offline when you shop in our Stores. We carry out some profiling of you for the purposes of improving and developing our products and Services and to help us to tailor our marketing to you. We use information that we learn about you such as Personal Data collected online, through your online behavior patterns, online interaction with us, online activities, tracking of visits, your preferences, hobbies, interests and your historical purchase data, including your return or order cancelled,  to make sure the marketing you receive from us and the way our websites are displayed to you are appropriate and tailored to you. The impact of any automated decision is to ensure you experience the best service possible from Foot Locker.     7.         &nbsp. Who do we disclose your Personal Data to?   We may disclose your Personal Data in the following ways:   7.1      &nbsp. With other Foot Locker entities that are part of the Foot Locker Group   We may share your Personal Data with entities that are part of our group organization, to the extent required for internal and administrative management or for the fulfillment of our Services and related actions and requirements.   7.2      &nbsp. With third party vendors   We use third party vendors for business, professional and technical support as Processors (as meant in the GDPR). These companies only use your Personal Data on behalf of us and under our written instructions. Specifically, we use such third party vendors and their servers and services for our web platforms, storage and business related data processing. In limited circumstances these vendors might have access to your Personal Data when this is required for maintenance or problem solving. For more information, please read our Third Party Vendors List. We have data processing agreements in place with such vendors where required by law.   7.3      &nbsp. With a competent public authority   In order to comply with a subpoena or other legal process or obligations, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to legitimate government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.   7.4      &nbsp. With cardholder and credit card issuing companies and investigative, criminal or judicial authorities   In case of fraud, confirmed by the cardholder and or credit card issuing company, we will share your Personal Data with investigative, criminal or judicial authorities for fraud prevention, investigation and prosecution purposes. This includes the transfer to the specialized eCommerce prevention department of Europol. In case of governmental inquiries or requests, we share the requested Personal Data to comply with the law.     8.         &nbsp.  Do we transfer your Personal Data outside of the European Economic Area (“EEA”)?   Some of your Personal Data that we collect may be transferred and stored in countries outside of the EEA. The laws in those countries may not provide the same level of data protection compared to the country in which you initially provided your data. When we transfer your Personal Data to recipients in other countries, we will protect that Personal Data as described in this Statement and in compliance with applicable laws.   We use various measures to ensure that your Personal Data transferred outside of the EEA receives adequate protection in accordance with data protection legislation. This includes in some cases signing the EU Standard Contractual Clauses or verifying if the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.   Foot Locker Inc. (US) is Privacy Shield certified. Click here to access our EU-U.S. Privacy Shield Policy. Foot Locker Europe B.V. and its affiliates in Europe have concluded a data transfer agreement (Controller to Controller) with Foot Locker, Inc. according to the Model of the European Commission. Foot Locker, Inc. has in its turn concluded a data transfer agreement (Controller to Processor) with its third party vendors according to the Model of the European Commission.     9.         &nbsp. Children’s data privacy   Our Services do not target children under the age of sixteen, and we do not knowingly collect their Personal Data. We will only knowingly collect and process Personal Data of children under the age of sixteen if explicit parental consent is provided. If you are concerned about your child’s data privacy, we encourage you to use web-filtering technology to supervise your child’s access to our Services.     10.     &nbsp. How do we protect your Personal Data?   Foot Locker has implemented appropriate physical, organizational, administrative and technical security measures to protect your Personal Data against unlawful access, loss, misuse or alteration. Foot Locker uses a variety of secure techniques to protect your Personal Data, including secured servers, firewalls, and encryption of application data and of your communications via the Internet. To safeguard your transactions, we encrypt your Personal Data using encryption technology Secure Socket Layer (SSL) coding. Our systems will only be accessed by authorized staff involved in the performance in their tasks. Personal Data is only made available internally on a need to know basis and per department or even per associate if so applicable. We also have an ongoing Foot Locker privacy training program to raise awareness on privacy compliance.     11.     &nbsp. Links to other sites   Our Services contain links to other sites and applications. We are not responsible for the privacy practices or content of such other sites or applications that are not affiliated with or maintained by Foot Locker. We recommend that you review the privacy statement posted on any external site or app that you access through our Services.     12.     &nbsp. What are my rights?   You have the right:   12.1  &nbsp. Of access to your Personal Data that we process on you; 12.2  &nbsp. To rectification of inaccurate or incomplete Personal Data; 12.3  &nbsp. Of erasure of your Personal Data; 12.4  &nbsp. To restrict of processing of your Personal Data; 12.5  &nbsp. To move, copy or transfer your Personal Data (data portability). This right only applies when you             have directly provided the Personal Data and where the processing relies on consent or where it             is necessary for entering into, or performance of, a contract between us; 12.6  &nbsp. To object to:             a.    &nbsp. processing based on legitimate interests (including profiling);             b.    &nbsp. direct marketing (including profiling). and             c.    &nbsp. processing for purposes of scientific/historical research and statistics. 12.7  &nbsp. Not to be subjected to a decision based solely on automated processing, including profiling: (e.g. automated processing of Personal Data to evaluate certain aspects about            you), which produces legal effects concerning you or similarly significantly affects you, unless it is:             a.    &nbsp. necessary for entering into, or performance of, a contract between us. or             b.    &nbsp. authorized by law (e.g. for the purposes of fraud or tax evasion). or             c.    &nbsp. you provide your explicit consent. and 12.8  &nbsp. To revoke your consent for further processing of your Personal Data when such processing is based on your consent.   To exercise any of these rights, please use the following webpage www.footlocker-emea.com/privacy. We will provide you with information on the action taken within one month after the successful submission of your request via this webpage.   We are required to verify your identity including, but not limited to, the verification of your email address. If you do not allow us to verify your identity, we cannot proceed to process your request.   Please note that the above-mentioned rights, with the exception of the right to object to direct marketing, are not absolute. Under certain conditions and in line with applicable data protection legislation, we may refuse a request. When such a restriction (partially) applies to your request, we will inform you on the reason of our refusal to comply to your request.     13.     &nbsp. How can I file a complaint?   If you are unsatisfied with the way we have handled your Personal Data, please contact us at: privacy@footlocker.com. Please note that you also have the right to lodge a complaint with the competent Data Protection Authority.     14.     &nbsp. Updates to this Privacy Statement   We amend this Statement from time to time to keep the information provided up to date. We encourage you to review this Statement periodically.   Last Updated: June 2020     15.     &nbsp. Contacts   If you have any questions, concerns or complaints regarding this Statement or the processing of your Personal Data, please contact us at: privacy@footlocker.com. In case you desire to exercise any of your rights, please use the following webpage www.footlocker-emea.com/privacy.