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Privacy Policy


Important Information

This Privacy Notice aims to give you information on how we collect and process your personal data using this website, including any data you may provide through this website when you purchase a product or otherwise interact with us.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Notice together with any other Privacy Notice or Fair Processing Notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are truly aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.

Who we are

C. & J. Clark International Limited is a company registered in England and Wales (company number 00141015) with a registered office at 40 High Street, Street, Somerset, BA16 0EQ.

It is part of a group of companies of which the ultimate parent Company is C. & J. Clark Limited, another Company registered in England and Wales (Company number: 03314066) and also with a registered office at 40 High Street, Street, BA16 0EQ. This Privacy Notice is issued on behalf of the C. & J. Clark Group so when we mention Clarks, “we”, “us” or “our” in this privacy notice, we are referring to the relevant Company in the Clarks Group responsible for processing your data.

When you use our services, you’ll share some information with us. We want to be upfront about the information we collect, how we use it, who we share it with and the choices we give you to control, access and update your information. For the purposes of data protection legislation, we are the data controller of your personal data. We are registered with the Information Commissioners Office in the UK with reference number Z5755995.

Please read this privacy policy carefully in conjunction with our Cookie Policy

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Notice. If you have any comments, questions or requests regarding this privacy policy please address to Privacy, Box No. 87, C. & J. Clark International Limited, 40 High Street, Street, Somerset, BA16 0EQ or email us at: privacy@clarks.com.

The personal information we collect and use

Information collected by us

If you have registered with us, or ordered items from us, we will have your email address, telephone number, postal address and the method you chose to make your purchase with. We also collect information about how you use our services, such as the types of content you view or engage with or the frequency and duration of your activities.

In addition, our servers, logs, and other technologies automatically collect certain information (see below) to help us administer, protect, and improve our services; analyse usage; and improve users’ experience. We share personal information with others only as described in this policy, or when we believe that the law permits or requires it.

Information we collect automatically

Cookies: We may use cookies and other technologies such as web beacons, web storage and unique advertising identifiers to collect information about your activity, browser and device. This data helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. If you prefer, you can remove or reject browser cookies through the settings on your browser or device. However, rejecting or removing cookies could affect the availability and functionality of our services. For further information on our use of cookies, please see our Cookie Policy.

Device information: We may also collect information about your device each time you use a site. If you have an account with us, we may collect information from or about the computers, phones or other devices where you log into our services. We may associate the information we collect from your different devices, which helps us provide consistent services across your devices. Here are some examples of the device information that we collect:

  • Attributes such as the operating system and hardware version.
  • Browser type and IP address

Log information: We also collect log information when you use our website. That information includes, among other things:

  • Details about how you’ve engaged with us.
  • Device information, such as web browser type and language.
  • Access times.
  • Pages viewed.
  • IP address.
  • Identifiers associated with cookies or other technologies that may uniquely identify your device or browser.
  • Pages you visit before or after navigating to our website.

How we use your personal information

We use your information in several different ways. The table below set this out in detail, showing what we do, and why we do it.


Category of personal data
Name and contact details
Purpose for processing
Legal basis under the GDPR
Deliver your purchase to you
Performance of a contract

Send you service messages by email or text, such as order updates
Performance of a contract

Send you information by email or post about our new products or services
Consent

So that you can book a fitting
Consent

Fraud prevention and detection
Legal obligation

Showing you Clarks adverts as you browse the web
Consent
Date of birth information
Fraud prevention and detection
Legal obligation
Payment information (we don’t store this information)
Take payment and give refunds
Performance of a contract

Fraud prevention and detection
Legal obligation
Contact history with Clarks e.g. over the phone, email or on social media
Provide customer service and support
Performance of a contract

Train our staff
Legitimate interests

Information about your phone or laptop, and how you use our website and app
Improve our website and set default options for you (such as language and currency)
Legitimate interests

Fraud prevention and detection
Legal obligation

Who we share your personal information with

We share your data with the following categories of companies as an essential part of being able to provide our services to you:

  • Members of the Clarks Group of companies, as sometimes different entities in our group are responsible for different activities
  • Companies that get your order to you, such as payment service providers, warehouses, order packers, and delivery companies
  • Professional service providers, such as marketing agencies, advertising partners and website hosts who help us run our business
  • Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud
  • Companies approved by you, such as social media sites

For a list of our third-party suppliers click here. Some of those third-party recipients may be based outside the European Economic Area — for further information including how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.

We will not share your personal information with any other third party.

How long your personal information will be kept

We will hold on to your information for as long as you have your account, or as long as is needed to be able to provide the services to you, or (in the case of any contact you may have with our Customer Care team) for as long as is necessary to provide support-related reporting and trend analysis only.

If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also keep hold of some of your information as required, even after you have closed your account or it is no longer needed to provide the services to you.

Transfer of your information out of the EEA

We may transfer your personal information to the United States of America [being the jurisdiction in which our customer service operations are hosted].

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is attached to it by ensuring at least one of the following safeguards is implemented:

  • 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.
  • Where we use certain service providers, we may use specific countries approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use service 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 Europe and the US.

Job applicants, current and former Clarks employees

All the information you provide will only be used for progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the EEA. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.

How long your personal information will be kept

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. Therefore, if you unsuccessfully apply for a role with us, we will delete or anonymise your personal information once we have communicated this to you. There may be circumstances in which we will retain your data for a future opportunity and if this is the case, we will seek your express consent beforehand.

The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.

Within the application stage, if you use our online application system, this will be collected by 3D MarComms a data processor on our behalf. We ask for your personal details including name and contact details. We also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all this information.

You will be asked to provide equal opportunities information. This is not mandatory information – if you do not provide it, it will not affect your application. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.

If we make you a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our employees, their right to work in the United Kingdom and seek assurances as to their trustworthiness, integrity and reliability.

We therefore use your information in several different ways. The table below set this out in detail, showing what we do, and why we do it.


Category of personal data
Name and contact details
Purpose for processing
Legal basis under the GDPR
Application process
Performance of a contract

Contact applicants to progress application
Performance of a contract

Where you’ve given us permission, to provide you with job s
Consent
Previous employment history, references, educational history
Assess suitability for the role
Performance of a contract

Gender, ethnicity, religion and nationality
Equal opportunities monitoring
Legal obligation

Passport/visa details
Confirm identity and right to work in the United Kingdom
Legal obligation

Health and disability
To make any required adjustments
Consent

Establish fitness to work
Legal obligation

Provide health & safety, first aid assistance, emergency evacuation, hazard risk assessment, accident monitoring
Vital interests

Criminal record relating to unspent convictions
Assess suitability for the role
Consent

Annual leave and sick leave details
To ensure performance of contractual obligations
Performance of a contract

Performance details
Maintain staff records
Performance of a contract

Emergency contact details
In case of emergency to contact next of kin
Vital interests

Banking information
Payroll purposes
Performance of a contract

National insurance number and tax information
Ensure national insurance contributions and tax contributions are properly recorded
Performance of a contract

Pension details
Payroll purposes
Performance of a contract

Children

If you would like to participate in Clarks Moments, your personal data and information about your child (including their photograph) will be captured using Facebook Messenger on the ClarksKids Facebook page.

We will not process any information you provide us for direct marketing unless you give us your permission. However, to enable you to receive your Clarks Moments animation we will require you to provide us with the information set out in this privacy notice.

The information we collect

When you request a Clarks Moments animation we will need the following information:

  • Your child's first name.
  • Your child's date of birth.
  • Your child's shoe size.

What we do with the personal information

We will only collect information about children where we have the express consent from the child’s parental guardian. The information we collect will only be used by Clarks and our animation partner Echomany, for creating your Clarks Moments animation. We need to use the information that you provide to fulfil our agreement with you to provide the animation.

Control over your information

Under the General Data Protection Regulation, you have several important rights available to you for free. In summary, those include rights to:

  • be informed about how your personal information is being used (hopefully this privacy policy explains it all)
  • Access the personal information we hold about you
  • Request that we transfer elements of your data to another service provider
  • Request us to correct any mistakes in your information which we hold
  • Request the erasure of personal information concerning you in certain situations
  • Receive the personal information concerning you which you have provided to us, in a structured format
  • Stop any direct marketing
  • Object to processing of your personal data

For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of these rights, please:

  • email, call or write to us at Privacy, Box No. 87, C. & J. Clark International Limited, 40 High Street, Street, Somerset, BA16 0EQ or email Privacy@Clarks.com, phone 01458 899 904
  • let us have enough information to identify you;
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
  • let us know the information to which your request relates

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 many requests. In this case, we will notify you and keep you updated.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information. If you are not happy with how Clarks manages your personal data, you have the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/.

Changes to this privacy notice

This privacy notice was published on 01/05/2018 and last updated on 01/05/2018.

Any changes we make to this notice will be posted on this page.

How to contact us

If you wish to contact us please send an email to privacy@clarks.com write to Privacy, PO Box 87, 40 High Street, Street, Somerset, BA16 0EQ. or call 01458 899 904.

Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.