Company Name: Footpatrol (under JD Sports Fashion PLC)
Company Number: 1888425
HOW WE USE YOUR DATA
If you have any questions in relation to this policy or generally how your personal data is processed by us, please contact our customer care team by letter addressed to: [Footpatrol, Hollinsbrook Way, Pilsworth, Bury, Lancashire, BL9 8R]; by email at [firstname.lastname@example.org].
This policy applies to any personal data that we collect about you when you:
visit our one of our websites;
purchase products from us;
visit one of our stores;
contact us, for example by telephone, email, post or through submitting a form on our websites.
WHO ARE WE?
The controller of your information for the purposes of the Data Protection Laws will depend on which member of the JD Group you are dealing with. The table below sets out each of the data controllers within the JD Group and each of the brands operated by those data controllers.
The relevant controller above is responsible for your personal data. This policy applies to all of the controllers above and the JD Group as a whole. Our brands each have their own websites. This central policy provides information to you about the basis on which the JD Group as a whole collects, uses, stores and shares your information. We will use your personal data fairly, lawfully and in a transparent manner and in accordance with the Data Protection Laws.
The brands and data controllers listed above within the JD Group may send you marketing messages by email, SMS, social media and post; about us and our products; where you have not unsubscribed and where you have purchased similar products and/or services from that brand or entity, or where you have otherwise signed up, or consented, to receive marketing messages from a brand or entity.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
If you have an account with us or make a purchase online with us, or enter a competition or respond to a survey with us, we collect your name and contact details (including your address, telephone number, details about your order, and your billing information (where you are purchasing products)).
We also collect details of your interactions with us through our customer contact centres, in store, online or via our apps. For example, when you telephone one of our contact centres, we collect notes of our conversations with you and details of your query and from time to time we may record your calls for training and monitoring purposes. We also collect information about the purchases that you make, your saved items, your payment information, any complaints and comments that you make and your shopping preferences. We also collect CCTV images in all of our stores.
Each time you visit one of our websites, we will also automatically collect information and personal data about your computer for system administration including, where available, your IP address, operating system and browser type. We do this to help us analyse how users use the websites (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account and improving your online experience. We also collect information about your activities on our websites, for example what device you are using and what products you're looking at.
By way of example, some of our websites use SessionCam for analysis purposes and specifically to identify any technical issues or difficulties the users of our websites are having during the customer journey. To do this, SessionCam records your mouse clicks, mouse movements, scrolling of pages and the text that you key into forms on our websites. The information that we collect about you through SessionCam does not include your bank details or any special categories of personal data, but does include your name, address, telephone number, email address and anything else you may insert when completing an order. The information collected by us through SessionCam is used for our internal purposes only and is used to improve our websites' usability and is stored and used only for the purposes of collecting aggregates and statistics relating to the functional performance of our websites. SessionCam is operated for the JD Group by SessionCam Ltd.
Please note that, from time to time, we will combine personal data that we receive from other sources with personal data you give to us and personal data we collect about you.
WHERE DO WE GET THIS INFORMATION FROM?
We collect some of your information directly from you, either through information that you give to us or information that we collect during your visits to our websites, stores, or through your communications with us. We may also obtain some information from third parties, including retail analytics companies, consumer insight companies and credit reference agencies and publicly available sources to assist us with understanding customer demographics and shopper behaviours, or where we merge with or otherwise acquire another business.
Information that you give us
You may share personal data about yourself with us by:
·filling in forms on our websites, including when you purchase products online, submit queries to us, create an account on one of our websites and/or sign up to receive promotional material and newsletters;
·responding to a survey or entering a competition with us;
·giving us information about yourself in any communication with us, either by telephone, e-mail, post or otherwise, either in connection with your account, purchases, or to report a complaint or issue.
You are not obliged to provide your personal data to us. However, if you do not provide your personal data to us, we may not be able to fulfil your order or provide other services to you or respond to your queries.
Information that we collect about you
We collect personal data about you:
·when you visit our websites, including details of your visits to our websites including, but not limited to, Internet Protocol (IP) address used to connect your computer to the internet, MAC addresses, traffic data, location data, your login information, time-zone setting browser type and version, browser plug-in types and versions, operating system and platform, weblogs, cookies and other communication data, and the resources that you access. For more information please see our cookies policy https://www.activinstinct.co.uk/customer-service/cookies/
·when you link your Twitter, Instagram or Facebook accounts with us, to enable you to log onto our websites simply and securely without having to create a new account;
·when you visit one of our stores, including CCTV images;
·when you contact us in relation to our products, services, a complaint or another query or issue. In particular, calls to our contact centres will be recorded for training and monitoring purposes from time to time.
Information that we receive from other sources
We will receive personal data about you from other third parties, including:
·in connection with any mergers or acquisitions where we obtain your information from another company.
·When we work with retail analytics companies, consumer insight companies, credit reference agencies and through our use of information from publicly available sources.
WHY DO WE NEED YOUR INFORMATION?
The main purpose for which we use your information is to provide you with the products that you purchase from us and to send you offers and promotions that you might be interested in.
In particular, we use your information:
to provide you with the products that you have purchased from us and any receipts of purchase, including to deliver your products, and to send you order status updates;
to take payments for the products that you have purchased and to give refunds or exchanges;
to provide customer service and support to you;
to develop and improve our products and services;
to develop and improve our websites and set default options for you (such as language and currency) and to ensure that content is presented in the most effective manner;
to provide you with information that you request from us or which we feel may interest you. We may send you marketing information by email, SMS or post. This can include information about new products and offers that you may find interesting;
to research our customers' preferences and trending products;
to run surveys and competitions;
to notify you about changes to our products;
as part of our efforts to keep our stores safe and secure (for example through the use of CCTV in our stores);
to prevent and detect fraud and crime (for example, through the use of CCTV in our stores).
BASIS FOR USING YOUR INFORMATION
Compliance with legal obligations
As a corporate group there are certain laws we need to comply with. In particular, we will need to process your personal information to verify your identity and for fraud and crime prevention purposes. Failure to provide the requisite personal information on sign-up / as you use our websites, may mean we cannot provide our products to you, as to allow you to purchase our products may mean we may be in breach of our legal obligations. You will not be able to object to processing or ask for the deletion of your personal information insofar as it falls under this category.
Necessary for the entry into or performance of a contract
When you enter into a transaction with us or one of our brands, a contract between you and the relevant brand will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to place an order and receive products from us), we will need to collect and process your personal information. Failure to provide the requisite personal information on sign-up to an account or on placing an order and payment information or objecting to this type of processing / exercising your deletion rights will mean we cannot provide our products to you.
Legitimate business interests
provide you with products as requested by you;
carry out research to understand our customers and how they purchase and use our products;
develop and improve our products.
As indicated below, we will also pass your personal data to members of the JD Group and other third parties and this is also for our legitimate business interests.
We are required to carry out a balancing test of our legitimate business interests in using your personal data outlined above against your interests and rights under the Data Protection Laws and regulations in the relevant territory. As a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that we have a legitimate business interest.
We have a legitimate interest in processing your information as:
·we both benefit from the effective management of your account(s) (where applicable);
·we both benefit from the effective management, operation and administration of our websites;
·we both benefit from the provision of products, services and support and from improvements to our services;
·we both benefit from updates to our websites;
·we will both benefit from the ability to enforce or apply rights under any contract between us;
·we are required to ensure the health and safety of our customers and the security of our stored data and have a legitimate interest in ensuring any processes relating to the same are effective and that fraud and other crimes are prevented and detected;
·we would be unable to provide our products and services without processing your information; and
·we have a legitimate interest in processing your information in connection with any mergers, acquisitions or reorganisation of our business, in which case some of your information may be shared with a prospective buyer or otherwise but only so far as is strictly necessary for the purposes of such sale or administration.
Impact of processing
We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as the processing of your personal data does not unreasonably intrude on your privacy.
As set out above, we will send you marketing communications where you have not told us that you wish to unsubscribe and where you have purchased similar products and/ or services from the same brand or legal entity (as set out in the table above). You will also receive marketing communications from us where you have signed up, or otherwise consented, to receive marketing messages from a brand or entity within the JD Group.
WHO DO WE SHARE YOUR INFORMATION WITH?
We do not, and will not, sell any of your information to any third party, including your name, address, email address or credit card information. However, we do share your information with a number of select third parties to enable us to provide our products and services to you, to send marketing information and to improve our business operations as set out below.
we will share your information with other members of the JD Group where you have consented for us to do so for the purposes of receiving marketing from those other JD Group members;
we will share your information with other members of the JD Group for group analysis and business information purposes, to improve our products and services.
We will also use a number of carefully selected third parties to help us to provide you with products, services and to market to you. In particular, we disclose your information to:
Companies that do things to get your purchases to you, such as payment service providers, warehouses, order packers and delivery companies;
Our trusted service providers, such as marketing agencies, advertising partners, website hosts and other third parties who provide services to help us to tailor our marketing to you;
Credit reference agencies, law enforcement and fraud prevention agencies;
Companies approved by you, such as social media sites, including companies such as Facebook and Google; and
We will provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you.
We will only share your information with third party suppliers where it is necessary for them to provide us with the services we need.
We may disclose your information to other companies in connection with any merger, acquisition, insolvency situation or otherwise, in which case we will only disclose your information so far as is necessary.
We may also need to disclose personal data to third parties to comply with a legal or regulatory obligation, or if necessary for legal proceedings.
WHAT AUTOMATED DECISIONS DO WE MAKE ABOUT YOU?
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.
The impact of any automated decision is to ensure you experience the best service possible.
We use information that we learn about you such as your gender, preferences, hobbies, interests and purchase history to make sure the marketing you receive from us and the way our websites are displayed to you are appropriate and tailored to you.
WHERE IS YOUR INFORMATION STORED AND HOW LONG DO WE KEEP IT FOR?
Transfers outside of the European Economic Area
The information which we collect about you may be transferred outside the European Economic Area. In the event of such transfer, we will ensure the adequate standard of security is in place for example by incorporating the European Commission approved clauses into our agreements with such third parties to ensure the security of your personal data. A copy of the European Commission approved model clauses is available here: http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010D0087&from=en
Retention of your personal data
marketing consents will be refreshed/deleted after 4 years, however, our aim is only to market to you for as long as we believe you want to continue hearing from us based on how you interact with us.
If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we will also keep hold of some of your information, even if it is no longer needed to provide our services to you.
Security of your personal data
Transmission of information via the internet is not and cannot be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
WHAT NON-PERSONALLY IDENTIFIABLE INFORMATION DO WE COLLECT?
We may also collect non-personally identifiable information (that is, information that does not specifically identify you), for the purposes of aggregates and statistics.
WHAT RIGHTS DO YOU HAVE?
In some instances, we may be unable to carry out your request, in which case we will contact you to explain why.
1. You have the right to request access to your personal data
You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.
2. You have the right to ask us to rectify your personal data
You have the right to request that we rectify your personal data if it is not accurate or not complete.
3. You have the right to ask us to erase your personal data
You have the right to ask us to erase or delete your personal data where there is no reason for us to continue to process your personal data. This right would apply if we no longer need to use your personal data to provide products to you, where you withdraw your consent for us to send you marketing information, or where you object to the way we process your personal data (see right 6 below).
4. You have the right to ask us to restrict or block the processing of your personal data
You have the right to ask us to restrict or to block the processing of your personal data that we hold about you. This right applies where you believe the personal data is not accurate, you would rather we block the processing of your personal data rather than erase your personal data, where we don't need to use your personal data for the purpose we collected it for but you may require it to establish, exercise or defend legal claims.
5. You have the right to port your personal data
You have the right to obtain and reuse your personal data from us to reuse for your own purposes across different services. This allows you to move personal data easily to another organisation, or to request us to do this for you.
6. You have the right to object to our processing of your personal data
You have the right to object to our processing of your personal data on the basis of our legitimate business interests, unless we are able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims.
7. You have the right not to be subject to automated decisions
You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you.
8. You have the right to withdraw your consent
You have the right to withdraw your consent where we are relying on it to use your personal data, for example where we are relying on your consent to send you marketing information.
We always give you the choice of whether or not you wish to receive marketing communications from us.
By contacting us Privacy.Support@jdplc.comyou can tell us that you do not wish to receive marketing communications from us and we will update your records. You can also click on the unsubscribe link in any promotional emails.
WHAT IF YOU HAVE A COMPLAINT?
You can also contact the Information Commissioner's Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk.
Our websites may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or your use of those websites.
This policy was last reviewed and updated in May 2018.
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