This Privacy Notice aims to give you information about how we collect and process your personal data when you use the website or app this Privacy Notice is linked to. This Privacy Notice covers any personal data you provide when you create an account, purchase a product or otherwise interact with us.
We want to make sure you know who we are, how you can contact us, the personal data we process, how we use it, who we share it with, how long we keep it for and the choices you have to exercise your legal rights.
This Privacy Notice covers the following topics:
- Important information
- Who we are
- How to contact us
- The personal data we collect and use
- Who we share your personal data with
- How long your personal data will be kept for
- Transfer of your personal data out of the EEA (European Economic Area)
- Control over your information
- Keeping your personal information secure
- How to complain
- Changes to this privacy notice
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.
When we mention “Clarks”, “we”, “us” or “our” in this Privacy Notice, we are referring to C. & J. Clark International Limited.
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.
How to contact us
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 in relation to this notice or how we handle your personal data, please address them to Privacy, Box No. 87, C. & J. Clark International Limited, 40 High Street, Street, Somerset, BA16 0EQ or email us at: firstname.lastname@example.org.
The personal information we collect and use
If you have created an account with us, or ordered items from us or otherwise interact with our website or app, we will use your personal data in several different ways. The table below sets out how we use your personal data, showing what personal data we collect and why.
Log information: information about how you use our website or app such as the types of content you view or engage with, the frequency and duration of your activities, access times, language, your IP address and pages you visit before or after navigating away from the website
Device and log information will not be associated with you as a named individual unless you are logged into your account
We ensure that the collection and use of your personal data is lawful. Therefore, for the purposes listed above, we only use your personal data if one of the following conditions apply:
- You have given us your consent
- We need your personal data for the performance of a contract you enter into with us, such as when you purchase a product through the website or app
- We need to comply with legal obligations
- We need to protect your vital interests
- Your data is necessary for the public interest, or
- We have a legitimate interest in processing the personal data.
Who we share your personal information with
We share your personal data with the following categories of companies as part of being able to provide our services to you:
- Members of the Clarks group of companies, where they assist us in providing our services to you
- Companies that help us get your order to you, such as payment service providers, warehouses operators and delivery companies
- Marketing service providers, such as marketing agencies and advertising partners who help us market our business
- Technology service providers, such as companies that support our IT, help us analyse the data we hold, send communications to our customers and help us develop and host our websites and apps
- Professional advisors, such as companies that provide us with legal or financial advice
- Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud and other unlawful activities
- 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’.
How long your personal data 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 personal data out of the EEA
In order to process your personal data for the purposes set out in this Privacy Notice, we may transfer your personal data to third parties and other companies in our group that are based outside of the EEA.
Whenever we transfer your personal data out of the EEA, we attach a similar degree of protection to it (as it would receive in the EEA) by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries, territories or sectors within a country that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- The transfer is subject to a legally binding and enforceable commitment on the recipient to protection the personal data (e.g. through the use of European Commission approved standard contractual clauses).
- 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.
- The transfer is made subject to binding corporate rules.
- The transfer is based on a derogation from restrictions on transferring personal data outside of the EEA (such as where you give your consent, the transfer is necessary for the performance of contract with you, or the transfer is necessary for the establishment, exercise or defence of legal claims).
Control over your information
Under the General Data Protection Regulation, you have several important rights available to you. In summary, those include rights to:
- Be informed about how your personal information is being used (hopefully this privacy notice 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 or to ask us to transfer that information to another service provider
- Stop any direct marketing
- Object to processing of your personal data
- You can ask us to restrict or suspend processing of your personal data under certain circumstances, for example if you want us to restrict processing while the accuracy of personal data is being established
- Right not to be subjected to automated decision-making that significantly affects you, however, we will only use automated decision making in limited circumstances
- Right to withdraw your consent, where processing of your personal data is based on consent, you can remove it at any time
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 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 28/01/2019.
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 email@example.com write to Privacy, PO Box 87, 40 High Street, Street, Somerset, BA16 0EQ. or call 01458 899 904.