Last Updated: _______, August 2022
Introduction
Skechers Poland Sp. z o.o. and its parent companies, Skechers S.A.R.L. and Skechers USA, Inc. (“Skechers”, “we”, “our”) is strongly committed to protecting your privacy and providing a safe online experience for all of our users while offering the highest quality user experience.
Because we gather certain types of information about and from you in order to fulfill your requests and better serve your needs, we feel you should fully understand the terms and conditions surrounding the collection and use of this information. This Privacy Notice discloses what information we may collect or that you may provide when you visit www.pl.skechers.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
Please read this Privacy Notice carefully, as well as our Terms of Use, to understand our policies and practices regarding how we handle your personal information. If you do not agree with our policies and practices set forth in this notice, you should not use our Website. By accessing or using our Website, you agree to this Privacy Notice. This notice may change from time to time. Please see the section below called “Changes to our Privacy Notice.” Your continued use of this Website after we make changes is deemed to be acceptance of those changes.
Data Controllers:
Skechers S.A.R.L.
Alte Steinhauserstrasse 14
6330 Cham
Switzerland
+41 56 418 35 40
PrivacyInt@skechers.com
Skechers USA, Inc.
228 Manhattan Beach Blvd.
Manhattan Beach, CA 90266
800-746-3411
Privacy@skechers.com
Skechers Poland Sp. z o.o.
ul. Wybrzeże Gdyńskie 6A
01-531 Warsaw
Poland
PrivacyInt@skechers.com
Skechers USA, Inc.’s Designated EU Representative:
Skechers USA France S.A.S.
Immeuble Bercy Crystal, 14 rue
Gerty Archimède, 75012 Paris – France
+33 1 44 55 31 31
Privacyfr@eu.skechers.com
If you have any questions or comments about this Privacy Notice or our privacy practices, please our data protection officer:
Frederic Pariente
privacyfr@eu.skechers.com
Skechers Data Protection Officer: Frederic Pariente
Lead Supervisor Authority:
Commission Nationale de l’Informatique et des Libertés (CNIL)
3 Place de Fontenoy
TSA 80715
75334 PARIS CEDEX 07
France
+33 (0)1.53.73.22.22
The Information We Collect About You and How We Collect It
Depending on how you use the Website, we may collect several types of information from you, including:
- Information by which you may be personally identified, such as name, loyalty account number, mailing (shipment) address, email address, telephone number, and purchasing history.
- Information about your internet connection (such as your IP address), the equipment you use to access our Website, marketing that led you to our Website, and Website usage details.
- Information about products or webpages that you view, products you add to your cart, products you choose to review, and purchases that you make through the Website.
- Information about your location in order to, for example, identify Skechers stores near you.
- An order number and email address to allow you to find information about orders and returns.
We collect this information:
- Directly From You When You Provide It To Us.
- When making an online or retail purchase, we may ask for your:
- Full Name
- Mailing or shipping address
- Billing address (if different)
- Email address
- Telephone number
- Payment information
- When registering for a Skechers Website account, for Skechers marketing emails, for a Skechers sweepstakes or giveaway, or for a Skechers customer loyalty program, if any is available, either in person, at an event, or online, we may ask for your:
- Name
- Email address
- Phone number (optional)
- Confirmation that you are age 18 or older
- If you contact our customer service department, you may need to provide us with additional information so we can respond to your questions and concerns as completely and thoroughly as possible.
- In order to provide you with information about our products that are more relevant to your interests, we may occasionally request additional information such as your gender, shopping preferences, product interest, and email notification preferences. Whether you provide this information is completely optional and up to you. For this same purpose of helping us identify information that is relevant to you, we will retain your shopping and purchase history.
- When making an online or retail purchase, we may ask for your:
- Automatically As You Navigate Our Website. We use automatic data collection technologies, including third-party services, to collect additional information about your equipment and browsing actions. Unless the technologies are required for core website functionality, you may choose whether to consent to the cookies and you may withdraw your consent at any time:
- (1) details of your visits to our Website, including page views and clicks, search activity, cart activity, location data, and the resources you access and use on the Website.
- (2) information about your computer and Internet connection, such as browser type, browser version, operating system and IP address. This information allows us to see which areas of our Website are most visited, and helps us improve the quality of your online experience by recognizing and delivering more of the most desired features and services. To better understand and optimize the user experience, we also use third-party user session recording technology. The recording does not show us personal information that the user inputs into our website.
- (3) information about your online activities over time and across third-party websites or other online services (behavioral tracking).
- Why We Automatically Collect This Information. Automatically collecting this information helps us to maintain and improve our Website. It also allows us to verify system and server integrity and to provide you with more personalized service. For example, using cookies or through your logging in as a Skechers customer loyalty program member, we can recognize you when you return to our Website and provide you with a customized Website experience based on your stored preferences and individual interests.
- How We Automatically Collect This Information. We automatically collect this information using cookies and web beacons.
- A cookie is a small removable text file that is downloaded onto your computer, mobile phone, tablet or other device when you access a website. Skechers uses three types of cookies: (1) cookies required to enable core site functionality such as log-in, the shopping cart, checking out, product searching, store locator services, and estimated shipping costs; (2) cookies that enable additional site functionality such as recognition of Skechers customer loyalty program membership and promotion codes; and (3) advertising cookies that are used by Skechers and/or third party companies to track your Website use and links you have followed in order to deliver content tailored to your interests both on our Website and elsewhere. Information collected by advertising cookies may be shared with third party advertisers. For the second and third categories, you may choose whether to consent to those cookies and may withdraw your consent at any time. For more information on our use of cookies, please see our Cookies Policy. [Hyperlink to Cookies Policy] To change your cookie preferences, please visit our Cookie Preferences tool, [Hyperlink]
- A web beacon is a small electronic file contained on pages of our Website that permits Skechers to count users who have visited those webpages or opened an email.
Third-Party Use of Cookies and Other Tracking Technology. Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks, and providers of external services like web traffic analysis services. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information about your online activities over time and across different websites and other online services. They may also use this information to provide you with behavioral advertising or other targeted content. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. We also work with other companies who use cookies to serve ads on our behalf across the Internet. These companies may collect information about your visit to our website and about your interaction with our communications including advertising and emails.
Lawful Grounds for Processing Personal Information
We rely on several lawful grounds for processing your personal information, depending on how you interact with us and/or our Website:
- When Necessary For Us To Enter Into And To Perform A Contract With You.
- In order to fulfill an order you placed on our Website we may need to process your payment information; your contact and shipping information, and information regarding your purchase;
- To respond to your requests when you contact us regarding customer service issues;
- To register your Skechers account upon your request.
- When You Provide Us With Consent To Process Your Personal Information.
- When you choose to consent to our use of certain cookies (as described above and in our Cookie Policy) .
- When Complying With A Legal Obligation. For example, certain laws and/or regulations may require Skechers to collect and retain information for a certain amount of time for tax purposes, or to prevent fraud and other illegal activities.
- We May Also Process Your Personal Information For Our Legitimate Interests. These interests include, but are not limited to,
- improving our products and services;
- understanding how our customers use our products, services, and Website;
- researching and analyzing the products and services our customers want;
- researching, measuring, and analyzing the effectiveness of marketing techniques;
- soliciting customer feedback on product satisfaction;
- personalizing our offers and Website to you for a better experience;
- replying to your enquiries and requests for information;
- organizing promotions and communications about our products and services;
- exercising and defending our legal rights, and protecting the companies’ interests;
- preventing fraud;
- direct marketing (if you consent to receiving information on special offers, launches, and events and you have not withdrawn that consent);
- transferring data among Skechers entities for internal administrative purposes; and/or
- keeping our Website safe and secure.
If you choose not to provide data needed to conclude or perform a contract with you or for us to comply with a legal obligation, we will not be able to conclude the contract.
Skechers generally stores personal information about consumers for a period of 6 years after the consumer’s last transaction with Skechers. For data analysis and business intelligence purposes, Skechers may store information for longer periods if it is in an aggregated form that cannot be reasonably linked to particular individuals.
How We Use the Information
We may use information that we collect about you or that you provide to us, including personal information, to provide products and services to you, for example:
- To present our website and its contents to you. Our legal basis for this processing is our legitimate interest.
- To fulfill and deliver orders placed through our website, and any other purposes for which you provide personal information, such as for the processing of returns. Our legal basis for this processing is our legitimate interest and to perform contracts to which you are a party.
- To administer contests, promotions, surveys or other site features and to provide you with the relevant products or services (for instance, to deliver a prize you may have won in a contest). Our legal basis for this processing is our legitimate interest.
- To send you information via email about products, offers and news we think could interest you. We only send you this if you have opted-in to receive Skechers email messages. Our legal basis for this processing is our legitimate interest and your consent.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection purposes. Our legal basis for this processing is to perform contracts to which you are a party.
- To notify you about changes to our Website or our policies. Our legal basis for this processing is our legitimate interest.
- To analyze visits to the Website and learn about the interests of our visitors in the aggregate and better understand your personal interests and needs, so we can improve our products and services and deliver the type of content, features and promotions that you are most interested in. Our legal basis for this processing is our legitimate interest and your consent.
- The information obtained from online registration is utilized to improve your shopping experience with Skechers by enabling you to earn reward points, obtain a faster checkout for purchases and/or opt-in to receive promotional emails, which provide you with the latest and greatest information regarding Skechers and its products. Our legal basis for this processing is our legitimate interest and your consent.
- The telephone and credit card number information we ask for when you order online is used only to complete the order, confirm the order and confirm shipment of the order. Limited credit card information is then stored only for the purposes of faster checkout (for Skechers customer loyalty program members only), and is not used for any other purpose. Our legal basis for this processing is to perform contracts to which you are a party.
- In any other way we may describe when you provide the information or for any other purpose with your consent.
Sharing Information with Third Parties
Except as described in this Privacy Notice, Skechers does not sell, rent or trade any personal information you provide to us online or at our stores, nor do we share such information with third parties. We may disclose personal information that we collect or you provide as described in this Privacy Notice:
- To our agents, contractors, business partners, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfillment and shipping, advertising strategies, marketing and promotional material distribution, website usage evaluation, data analysis and, where applicable, data cleansing. We also may share non-personal information (such as the number of users who visited the website during a specific time period or who purchased a specific product through the website) with our marketing partners, advertisers and others from time to time. This information generally is shared in an aggregated form.
- To our subsidiaries and affiliates, which may require transferring your information outside of the European Economic Area (“EEA”) and to the United States or other countries outside of the EEA (see the section below entitled “International Transfers of Personal Information”).
- To third parties, such as credit agencies, to verify delivery names and addresses for online orders. If you provide us with a delivery name and address which is not your own, you must have that person’s permission to give us their personal information and for us to use it for the purposes specified. By providing it, you are affirming that you have their permission to do so.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Skechers assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Skechers about our Website users is among the assets transferred. If that happens, your personal information may be disclosed to another company, but that disclosure will be subject to Skechers’ Privacy Notice.
- To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request
- If we believe disclosure is necessary to protect the rights, property, or safety of Skechers or any of our respective affiliates, business partners, customers, or others.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
International Transfers of Personal INformation
When you use this website, you are disclosing directly and by your own initiative data to the data controllers set forth above, including Skechers USA, Inc.. Skechers USA, Inc. is based in the United States of America (“U.S.A.”) and stores and processes personal information collected through this website on computer systems located in the U.S.A. Please be aware that the European Court of Justice has found that in light of U.S. government surveillance laws, the U.S.A. as a general matter does not provide a level of data protection that is essentially equivalent to that provided for in EU law. The European Commission also has not found that the U.S.A. provides an essentially equivalent level of protection to the protections afforded by EU privacy laws. Please do not use this website if you do not intend to disclose data to Skechers USA, Inc. In certain circumstances, Skechers may deem it necessary to store, share, or process your Personal Information outside of the country in which your personal information was originally collected, including the United States and/or countries outside the European Economic Area that have not been recognized by the European Commission to provide an adequate level of data protection. If these entities transfer your personal information from the European Economic Area to a country outside the European Economic Area, they will use measures to ensure that your personal information receives adequate protection in accordance with data protection rules, such as standard contractual clauses. Please reach out to us if you would like to receive further information on the appropriate safeguards taken by us.
Children's Privacy
Skechers takes special care to protect the safety and privacy of children. Our Website is not intended for individuals under 18 years of age. We do not permit anyone under the age of 18 to register with us, nor do we knowingly send email correspondence or knowingly collect personal information from individuals under 16. If you are under 18 years of age, do not use or provide any information on this Website. If we learn we have collected or received personal information from an individual under 18 without verifiable parental consent, we will delete that information.
Skechers’ EMail and Text Communications
From time to time, Skechers communicates to customers by email or text to inform them of changes to Skechers.com, special offers that might become available, and other information Skechers believes will be of interest to site visitors. Skechers will send these types of communications to you only if you opt-in to receive Skechers marketing messages (by registering to receive our email or text updates, registering for the Skechers customer loyalty program, signing up in person at a Skechers event, or by contacting our customer service department and specifically requesting to be added to our marketing list(s)).
Opt-out / Unsubscribe
You may request that you stop receiving electronic communications from Skechers anytime. You can cancel emails by updating your contact preferences on our website or following the instructions contained in the footer of our marketing emails. To unsubscribe from SMS, MMS or other mobile messaging, you may also follow the instructions in the messages you receive. Alternatively, if you would like to have your name and contact information removed from Skechers’ email or text marketing list, please contact us by calling Customer Service at 008004912064 (Monday - Friday 9am - 5pm Central European Time) or by sending an email to info.pl@skechers.com. You may also write to us at:
Skechers Poland Sp. z o.o.
ul. Wybrzeże Gdyńskie 6A
01-531 Warsaw
Poland
We shall process your request within the term established by applicable privacy law. Your right to unsubscribe does not affect the lawfulness of processing based on your consent prior to your withdrawal of that consent.
Please note this opt-out does not apply to emails sent by Skechers related to your orders such as order and shipment confirmations, nor does it apply to Skechers’ email responses to inquiries you make online.
Data Subject Rights
Under the EU’s General Data Protection Regulation (“GDPR”), EU data subjects may:
- Withdraw consent to processing at any time where the basis for processing is consent;
- Request access to his/her data that Skechers holds consistent with and to the extent set forth in Article 15 of the GDPR;
- Ask Skechers to erase his/her data consistent with and to the extent set forth in Article 17 of the GDPR;
- Request that Skechers rectify inaccurate data or to complete incomplete data consistent with and to the extent set forth in Article 16 of the GDPR;
- Restrict processing of his/her data in specific circumstances consistent with and to the extent set forth in Article 18 of the GDPR;
- Object at any time to processing of personal data, consistent with and to extent set forth in Article 21 of GDPR, including to object to direct marketing and to object where the lawful basis for processing is our legitimate interests;
- Make a complaint to a Polish supervisory authority, i.e. President of the Personal Data Protection Office; and
- In certain circumstances, receive or ask for his/her data to be transferred to a third party in a structured, commonly used and machine readable format consistent with and to the extent set forth in Article 20 of the GDPR.
Exercise the right not to be subject to a decision based solely on automated processing, including profiling, consistent with and to extent set forth in Article 22 of GDPR (We do not process your personal data for the purpose of taking decisions based solely on automated processing, including profiling, that produce legal effects concerning you); and
In certain jurisdictions, provide instructions regarding the processing of his or her data after death.
These rights are not absolute and may be subject to one or more exceptions, , such as where it is necessary to store the data and not erase it to satisfy legal obligations. We need some personal information to provide goods that you seek to purchase, for your membership in our loyalty program, or in order comply with legal obligations we are subject to. If you refuse to provide personal information that is required for these purposes, it may prevent or interfere with our ability to conduct a commercial relationship with you.
Exercising Your Rights
To exercise the rights described above, please submit a verifiable consumer request to us by either:
· Calling us at 008004912064; or
· Sending e-mail at: info.pl@skechers.com
We reserve the right to deny data subject requests if we believe the request is manifestly unfounded or excessive, or if we cannot confirm and have reasonable doubts about whether the data that is the subject of the request is associated with the person making the request.
In order to protect your privacy, Skechers takes steps to verify your identity before granting data subject access requests. Skechers will accomplish this through the use of passwords and personal data. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 1 month of its receipt. If we require more time (up to 3 months total), we will inform you, within the first month of receiving your request, of the reason and extension period in writing.
Unless you tell us otherwise, if you have an account with us that is linked to an email address, we will deliver our written response to that email address. If you do not have an email address registered with us, we will deliver our written response by mail or electronically, at your option. If applicable, the response we provide will also explain the reasons we cannot comply with a request.
For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
Data Security
Skechers has in place technologies and processes that are intended to reduce the likelihood of unauthorized access to information and to help improve data security. However, no method of transmitting information over the Internet or method of electronic storage is completely secure and we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.
Changes to Our Privacy Notice
It is our policy to post any updates we make to our Privacy Notice on this webpage. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account and/or through a notice on the Website home page. The date the Privacy Notice was last updated is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.