PRIVACY POLICY

1. Introduction

  • 1.1 Shoe Zone Retail Limited (“we”, “us” or “our”) takes the privacy of your information very seriously and is committed to protecting your personal data. This policy (together with our Terms of Use and any other documents referred to in it) explains how and for what purposes we use the information collected about you through your use of through our website, www.shoezone.ie (referred to below as the “Site”), or when you purchase our products or services.
  • 1.2 This Site is not intended for children and we do not knowingly collect data relating to children.
  • 1.3 It is important that you read this policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This policy supplements those other notices and is not intended to override them.
  • 1.4 We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this policy. If you have any queries about this policy, please get in touch with our Data Protection Officer using the contact details set out at paragraph 14 below or by email to customerservices@shoezone.ie and we will do our best to answer your questions.
  • 1.5 For the purpose of data protection laws in the UK, the data controller is SHOE ZONE RETAIL LIMITED of Humberstone Road, Leicester, LE1 2LH.

2. Personal information collected

  • 2.1 Personal data means any information about an individual from which that person can be identified. Where you are purchasing goods or services from us, as you use the site and except where you are under 14 years old we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
    • 2.1.1 Identity Data includes your first name, maiden name, last name, marital status, title, date of birth or age, gender, shoe size.
    • 2.1.2 Contact Data includes your address (home, postal or other physical address), email address and telephone numbers.
    • 2.1.3 Financial Data includes your means of payment, such as your bank account or payment card details.
    • 2.1.4 Transaction Data includes details about payments to and from you and other details of services you have purchased from us and our fulfilment of your order.
    • 2.1.5 Profile Data includes, in relation to your website account, your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    • 2.1.6 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    • 2.1.7 Technical Data includes traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access our Site.
    • 2.1.8 Usage Data includes information about how you use our Site, products and services.
  • 2.2 Personal data does not include data where your identity has been removed or which not associated with or linked to your personal data (anonymous data).
  • 2.3 Although it is not compulsory to give us all of this information (and although you will need to give us some of this information to make any purchases), if you do not then we may not be able to provide you with the full range of goods and/or services the Site has to offer, or tailor such range of goods and/or services/offers at the time of your visit. If we are not able to complete your order because you have not provided us with sufficient personal data to do so, we will notify you that this is the case at the time.
  • 2.4 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

3. How we collect personal data

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, by corresponding with us by post, phone, email, via our Site or otherwise, or when you enter into a contract with us for the provision of our products or services.
  • Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy (https://www.shoezone.ie/Cookie-Policy) for further details.

4. The purposes for which we use personal data

  • 4.1 We will only use your personal data when the law allows us to. We may collect and process the personal data about you for the following purposes (where relevant):
    • 4.1.1 Website account - when you sign up for an account on our Site, we will need your Identity and Contact Data so that we can identify you as an account holder. You will also be asked to create Profile Data including a username and password. Your account will also hold details of previous purchases or orders made by you (Transaction Data), and any preferences that you set for your account (Marketing and Communications Data).
    • 4.1.2 Ordering our products and services - we will use your Identity, Contact, Financial and Transaction Data in order to register you as a customer and to process and deliver products and services to you, including the management of payments, fees and charges. This is necessary for the purpose of performing our contract with you.
    • 4.1.3 Verifying your identity – we will use your Identity, Contact and Financial Data to verify your identity and where you are under 18 years old, the identity of your parents or the relevant guardians/cardholders. This is necessary for the performance of our contract with you.
    • 4.1.4 Contacting us - when you contact us with an enquiry or to request information about our products and services, we will use your Identity and Contact Data to respond to you.
    • 4.1.5 Advertising, marketing and public relations – where you have signed up to receive promotional communications from us (including special offers and promotions) we will use your Identity, Contact and Profile Data to sent you those communications. We may also use your Identity, Contact, Technical, and/or Usage Data to form a view on what we think you may want or need from us, or what may be of interest to you and in doing so we will only send information that is deemed relevant to your use of our products and services. This is necessary for our legitimate interests in growing and developing our business including our products and services. Customers will receive marketing communications from us if they have requested information from us or purchased products or services from us and, in each case, have not opted out of receiving that marketing. We will however ask for express consent before we share personal data with any third party for marketing purposes. You can ask us to stop sending marketing communications at any time by contacting us.
    • 4.1.6 Surveys – if you choose to complete a survey that we use for research purposes we will retain the information that you provide in response to that survey. This is necessary for our legitimate interest in understanding our customers, developing our business and to informing our marketing strategy.
    • 4.1.7 Reviews - if you choose to complete a review of a product that you have purchased from us, we will retain a copy of your review. This is necessary for our legitimate interest in understanding our customers, developing our business (including our products and services) and to informing our marketing strategy.
    • 4.1.8 Competitions – if you enter a competition or promotion, we will use your Identity and Contact Data to make contact with you in the event that you are a winner and for our legitimate interest in planning other promotional activities.
    • 4.1.9 Administration - we may use your Identity, Contact and Technical Data for the purpose of protecting our business and our Site, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data. This is necessary for our legitimate interest in for running our business, the provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, and for compliance with our legal obligations.
    • 4.1.10 Website Analytics - as you navigate our Site, Technical and Usage Data may be collected automatically. We do this to find out things such as the number of visitors to the various parts of our Site, and to help us to improve the content of the Site and to customise the content or layout of our Site for you and your device, in accordance with our legitimate interests. We may also use Technical Data, where you are a registered customer, to enquire why a transaction that initiated via our Site was not completed. This is necessary for our legitimate interest in defining types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy.
    • 4.1.11 Fault reporting - if you contact us to report a fault with our Site, we will use the Identity and Contact Data provided for the purposes of rectifying that fault in accordance with our legitimate interests.
    • 4.1.12 Recruitment - personal data provided for an employment opportunity will be processed so as to allow us to process and evaluate the merits of that application in accordance with our legitimate interests.
    4.2 We may also use personal data which you provide to us, where the law allows us to do so, as follows:
    • 4.2.1 To deal with and/or respond to any enquiry or request made by you prior to entering into any contract or agreement with us or as a result of such contract or agreement.
    • 4.2.2 Where we need to perform the contract we are about to enter into or have entered into with you.
    • 4.2.3 Where we need to comply with a legal or regulatory obligation, including the prevention of crime.
    • 4.2.4 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • 4.3 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by logging into your account and updating your preferences or by contacting us using the details at paragraph 14 below.
  • 4.4 Where we process personal data on the basis of a legitimate interest, as set out in this privacy notice, legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the details at paragraph 14 below.
  • 4.5 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details at paragraph 14 below. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
  • 4.6 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. This may include removing you from our marketing database where there has been no interaction between us over a prolonged period.

5. Sharing your personal data with third parties

  • 5.1 Your personal data will only be disclosed to those of our employees or workers that have a need for such access for the purpose for which it was collected. Your personal data will not disclosed to any other individuals or other entities except in the following circumstances:
    • 5.1.1 Where it is necessary for the performance of our contract with you, including where you have asked us to do so or where we need to take steps to enforce any contract which may be entered into between us.
    • 5.1.2 On occasion, we need to hire other companies to help us to serve you better and in some of these cases we may need to share personal data that is necessary to perform tasks for us, such as courier services and market research companies.
    • 5.1.3 Certain goods or services available on this Site are offered in conjunction with one of our business partners, Ingenico ePayments (or any replacement partner) who we engage to authorise card details for payment purposes. In order for those products or services to be provided we provide some necessary details about you to Ingenico ePayments or their replacement. They will be given data to help them process payments and deal with refunds. We tell you about this at the point we collect that information on the Site. Please note that certain goods or services may be unavailable if you do not want to disclose the personal information you are asked for.
    • 5.1.4 We may transfer your personal information to a third party or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.
    • 5.1.5 We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as such terms are defined in section 1159 of the UK Companies Act 2006 (as amended from time to time).
    • 5.1.6 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by law, a court order or for the purposes of prevention of fraud or other crime) or in order to enforce or apply our Terms of Use, Terms of Sale and other agreements, or to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
    • 5.1.7 We use third party providers such as Google, but not exclusively, together with some of your browsing data and cookie information to show you appropriate remarketing ads on other websites. These ads will appear within another site advertising Shoe Zone products and offers but will be served by our third party providers with that site’s permission. If you wish to opt out of Google's use of cookies in ads you can do so here. If you wish to opt out of other third party cookie use you can do so here by clicking on the Opt Out links at the bottom of the page.
  • 5.2 We require all third parties that process personal data on our behalf to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
  • 5.3 Other than as set out above, and in paragraph 6 below we will not disclose any of your personal information without your permission.

6. Cookies

  • 6.1 When you visit the Site we may store some information (commonly known as a “cookie”) on your computer. Cookies are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. Cookies are specific to the server that created them and cannot be accessed by other servers, which means that they cannot be used to track your movements around the web. Passwords and credit card numbers are not stored in cookies. A cookie helps you get the best out of the Site and helps us to provide you with a more customised service. We use cookies for the following purposes:
    • 6.1.1 so that we can recognise you when you revisit the Site and so that you will not have to re-enter your details each time you visit the Site;
    • 6.1.2 to speed up your searches and store information about your preferences, in order to customise the Site to your individual interests; and
    • 6.1.3 to track how our Site is used and to improve and update our content.
  • 6.2 You can block or erase cookies from your computer if you want to (your browser’s help screen or manual should tell you how to do this), but certain parts of the Site are reliant on the use of cookies to operate correctly and may not work correctly if you set your browser not to accept cookies.
  • 6.3 Please note that our advertisers, sponsors, partners, and affiliates may also use cookies, over which we have no control.
  • 6.4 Please see our cookies policy (https://www.shoezone.ie/Cookie-Policy) for further information about the cookies that we use on our Site.

7. Information about other products and services

  • 7.1 Except as we have otherwise said in this policy from time to time we may send you information about our products and services which we think may be of interest to you. .
  • 7.2 You can tell us to stop sending such information at any time by contacting us at the address at paragraph 14 below, by sending an e-mail to customerservices@shoezone.ie, or if the information has been sent to you via SMS, you can tell us to stop at any time by replying to the message with the word “STOP”. The cost of this message will be your operator’s normal standard rate.
  • 7.3 We may pass your information onto one of our business partners or to other selected third parties to enable them to send you information which may be of interest to you but only if you have given us permission to do so. If you have given us permission, you can tell us to stop this at any time by contacting us at the address at paragraph 14 below or by sending an e-mail to customerservices@shoezone.ie.

8. Changes

  • 8.1 We aim to keep our information about you as accurate as possible. If you would like to review or change the details you have supplied us with, please contact us as set out below in paragraph 14.
  • 8.2 Any changes we may make to our privacy policy in the future will be posted on this page.
  • 8.3 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

9. Security

  • 9.1 We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, we have implemented technology and policies to safeguard your privacy from unauthorised access and improper use and we use secure server software (SSL) to encrypt any financial information you need to input before it is sent to us. In addition, the access to and use of the personal data that we collect is restricted to our employees who need the personal data to perform a specific job role or activity. Where personal data is shared with third parties in line with this privacy notice responsible measures are used to protect your personal data.
  • 9.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
  • 9.3 Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site, therefore any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. We urge you to take every precaution to protect your personal data when you are on the Internet.
  • 9.4 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask that you do not share a password with anyone.

10. International Transfers

  • 10.1 Some of our external third parties, such as international couriers / mail services and payment providers, are based or operate outside the European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside the EEA.
  • 10.2 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
    • 10.2.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
    • 10.2.2 Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
    • 10.2.3 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
  • 10.3 Please contact us (details at paragraph 14 below) if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

11. Data Retention

  • 11.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
  • 11.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
  • 11.3 For example:
    • 11.3.1 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.
    • 11.3.2 We will retain details of your customer order, including your personal data, for a period of 6 years to enable us to deal with any follow-up communications from you or to ensure that we are in possession of all relevant papers in the event of a legal claim relating to the contract between us.
  • 11.4 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

12. Linking to third party websites

  • 12.1 Our Site may contain links to other websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third party websites and are not responsible for their privacy notices or for the content, accuracy or opinions express in such websites.
  • 12.2 We do not investigate, monitor or check third party websites for accuracy or completeness and the inclusion of any linked website on or through our website does not imply approval or endorsement by us of the linked website.
  • 12.3 We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our Site and recommend that before submitting any personal data, you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
  • 12.4 In addition, if you linked to this Site from a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that before submitting any personal data, you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

13. Your rights

  • 13.1 You have the right to:
    • 13.1.1 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
    • 13.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data that we hold about you corrected, although we may need to verify the accuracy of the new personal data that you provide to us.
    • 13.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
    • 13.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
    • 13.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    • 13.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    • 13.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can ask us to stop sending you marketing messages at any time by following the “unsubscribe” (or similar) links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, product/service experience or other transactions.
  • 13.2 If you wish to exercise any of your above rights please send a written request to us at the address listed at paragraph 14 below, addressed for the attention of the Data Protection Officer.
  • 13.3 You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
  • 13.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
  • 13.5 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

14. Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, or you wish to inform us of changes to your personal details held by us you can do so by sending an e-mail to the Data Protection Officer at customerservices@shoezone.ie or write to us at Shoe Zone Retail Limited, Humberstone Road, Leicester, LE1 2LH.

15. Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Last updated 9th May 2018