Privacy Policy

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.

It is important that you read this Privacy Notice together with any other privacy notice we may provide when we collect or process your personal data so that you are fully aware of how and why we are using your data.

In particular, please read this Privacy Notice in conjunction with our Cookie Policy.

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 Are We?

We are C. & J. Clark International Limited and a collection of global subsidiaries and affiliate companies, including various entities across certain EU territories, that collectively are referred to as Clarks. C. & J. Clark International Limited are the “data controller” of your personal information that is collected when you interact with our website.

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

We are registered with the Information Commissioners Office in the UK with reference number Z5755995.

In this privacy policy (“Policy”), when we mention “Clarks”, “we”, “us” or “our”, we are referring to all of Clarks’ global subsidiaries and affiliate companies. The term “personal data” as used herein is the same as “personal information” as defined in various applicable data privacy laws.

Introduction

Our commitment is to provide you with exceptional products and services “For the World Ahead”. We value and respect your privacy and strive to comply with all applicable data privacy laws and regulations in the various regions in which we do business globally. This Policy provides you information about what and how we collect your personal data, plus how we use, share, and/or otherwise process your personal data in accordance with applicable law. Like the Clarks business, this Policy is global in scope and intends to meet the requirements of all applicable data privacy laws to which Clarks is subject. As of the date of this Policy, this Policy specifically serves as notice to residents of the UK and Europe.

Scope

This Policy applies to (i) your in-store interactions with Clarks at our retail and outlet store locations owned or controlled by Clarks (excluding locations operated by third party licensed or franchise partners) (each a “Store”), and (ii) your online interactions with Clarks websites that are owned or controlled by Clarks. The Clarks family of websites covered by this Policy includes:

Legal basis for the processing of your personal data

Depending on the purpose for which we process your data from time to time, as explained in the following chart, we rely on specific legal bases such as consent, contract, and legitimate interest in certain cases. The types of personal data we process will generally include, depending on each case, the following:

Your identity data (e.g., your name, surname, preferred language, and contact details).
Transaction information (e.g., details provided in purchases, bookings, orders, returns, etc.).
Connection and browsing data.

When we request your personal data to grant you access to a particular functionality or service of the Platform, certain fields may be marked as compulsory. This information is necessary for us to provide the service or grant access to the functionality in question. Please note that if you choose not to provide such data, you may be unable to enjoy those services or functionalities.

Details To respond to requests or inquiries made through Corporate Contacts and Customer Contacts channels.

We will only process the personal data that are strictly necessary to manage or resolve your request or application.

Usability and quality analysis to enhance our services.

If you access our Platform, please be aware that we will process your browsing data for analytical and statistical purposes. This helps us understand how users interact with our Platform and allows us to make improvements based on user suggestions.

Types of personal data we collect and process and processing purpose

Category of Personal Data	Purposes for Collection and Processing
Contact Information: Name, Surname, email address, Address, Records of your purchases (if you purchase something), telephone, purchase details (products, colour size, quantity, price), returns.	By registering into the Clarks customer database through our Loyalty Club or website, you will have access to services and benefits reserved for our registered members. You can also manage your online account profile, book appointments, participate in other services, and pick up products at our stores. In addition, you can send requests or contact our Customer Care Team or Privacy Team to confirm your identity as a registered member. We provide and deliver products and services requested and respond to all your requests to manage your relationship with us. Please note that any data collected about your activities, including purchases, will remain linked to your account for convenience. You may use social media or other third-party platforms to log in to your account. If you choose this option, we may receive additional information from your public profile, such as your name, gender, and approximate age. However, we will not retain this information without your explicit consent. Please review the privacy policies of these third-party platforms to understand how they process your data. You can always withdraw your consent at any time.
Data subject's information related to the individual order: billing address, shipping address, together with purchase details (products, colour size, quantity, price), returns, Methods or payments/or any communications we have received about order or purchase.	You can use our website to place orders for remote sales. We will handle all management activities related to your order, such as administrative management of the contract, delivery of goods, payment processing, invoicing, management of any claims and litigation, and fraud prevention. We will also validate, confirm, verify, deliver, install, and track your order, including arranging for shipping, handling returns, exchanges, and refunds, and maintaining a record of your purchases.
Payment Information: Name, Card Issuer and Card Type, credit or debit card number (redacted), expiration date, and/or Billing Address.	To ensure the correct cardholder or account owner is making a purchase, meet card brand and account issuer requirements, and receive payment for purchases.
Any Connection, Geolocation, and Browsing Data (e.g., location data, unique device identifier, IP address, and advertising ID)	To gather anonymous data about our website's usage and ensure it functions optimally with your device, we aim to provide a seamless experience tailored to your device. Additionally, for analytical and demographic insights, we present offers that might appeal to you. When we gather your data from multiple sources, we may merge them under certain conditions to better comprehend your preferences and needs related to our offerings. This might mean merging data if, for example, you've made a guest purchase with an email associated with a registered account. Or, linking auto-collected data (such as IP or MAC addresses) with details you've actively shared during your engagement on our Site or in our physical stores, like purchase history and preferences.
Information you provide about a third party: name, surname, address and contact details of recipient for delivery of goods (such as sending a gift or virtual gift card), if different from yours.	To deliver to, or communicate with, the person at the address which you have requested.
Any data relating to your preferences and/or commercial choices	Customise the services we offer to you, making recommendations based on your interaction with us through the Site. As long as you subscribe to our Newsletter, we'll use your personal data to manage your subscription, which includes sending you personalised information about our products or services via email. This data processing involves analysing your user or customer profile to determine your preferences and decide which products and services align with your style when sending you information. For example, based on your purchase and browsing history (i.e., based on items you've clicked on), we'll suggest products we believe you might be interested in, and if you're a registered user, we'll provide the "cart recovery" feature. Remember, you can unsubscribe from the Newsletter at any time without any cost by following the instructions we provide in every communication. You can deactivate push notifications via the Web Form if you don’t wish to receive push notifications. If you share on the Site or through our social media channels any photos or images you've publicly shared, as long as you give us your consent.
Data about your preferences and interests: your account settings including preferred store, your wish list, your contact channel and types of services/offers that interest you.	In order to make your experience more personalised and improve the services we provide to you.
Other voluntary information: Any voluntary information you may provide during your interactions with us (such as sending information through our web form, an email, through the website, contacting the Customer Service team or store staff or by responding to surveys.)	We will handle your requests and reach out to you as needed or requested. This includes responding to your comments and questions, providing customer service, and getting to know you better. We aim to make our communications with you more personal and gather feedback from your surveys to continuously improve our services.
Personal Data we may collect from third parties
Legal Information: fraud checks or flags raised about your transactions, declined payment cards, potential illegal activities, complaints, and/or assertions.	To safeguard you, our other patrons, and our enterprise from unlawful actions and threats, it's essential to ensure we recognise and fulfil our legal responsibilities towards you and everyone else and can uphold our rights.
Social Media: When you engage with us via social platforms or sign in using social credentials, based on your social media preferences, we might obtain details like your name, email, age, gender, and whereabouts.	This enables you to sign up on our site using your social media credentials, tailoring your user experience, and improving the services we provide to you.
Digital Payment Details: When you opt to settle your online order using a digital payment method (like Google Pay, Apple Pay or PayPal), we might receive details from that platform, including your name, email, and address.	This enables us to manage and complete your purchase, oversee related administrative tasks, coordinate shipping, manage returns, swaps, and reimbursements, keep track of your buying history, and ensure the delivery of the requested products and services.

Minor’s data subject

In order to register an account with Clarks you must be over 16 years of age to provide us with your Personal Data (to write to us for information and/or subscribe to our newsletter and/or consent to the transmission of commercial communications and/or allow us to use your personal data for marketing purposes).

If we become aware that a minor under the age of 16 (or a minor of a different age established by the law of the country or state of residence of the Data Subject) has provided his or her personal data through the Site without the verifiable consent of a parent or legal guardian, we will deactivate the minor's account and take all reasonable measures to delete his or her personal data.

If a user believes that we are in possession of personal data of a person under the age of 16, he or she may report this to us by writing to privacy@clarks.com.

Data retention period

Clarks will retain personal data for the time strictly necessary to provide users with the requested services or to fulfil legal or tax obligations for the minimum period prescribed by law.

In order to establish the retention period for personal data collected and stored through the Website with the User's consent, Clarks will consider multiple factors to ensure that personal data is not stored for a period longer than is strictly necessary for the purposes for which it was collected or for compliance with legal obligations. These criteria also include:

the purpose for which the Website retains personal data;
legal, tax, and regulatory obligations;
the type of ongoing relationship with the Data Subject user or customer (how often the user accesses their personal account on the Website, whether the user maintains active consent to receive commercial communications, how often they browse and/or make purchases on the Website, etc.);
any specific requests from the Data Subject regarding the erasure of personal data.

Therefore, Clarks shall retain:

personal data collected and processed in relation to the Data Subject's personal account for a maximum period of 2 years from the date of the last interaction between the Data Subject and the Website or other contact (email, customer service) with Clarks;
the detailed data of each online purchase is stored for a period of up to 10 years from its last registration.

Clarks undertakes to implement procedures that ensure the timely and secure erasure or anonymization of your personal data from the moment it is no longer necessary or the grounds for its lawful retention cease to exist.

People with whom we may share your personal data

Exclusively within the scope of the processing activities carried out for one or more of the purposes described above, Clarks may share or transmit some of your personal data to the following categories of Third Parties:

Clarks Group’s companies when they assist us in providing products to the user;
Entities that assist us in fulfilling your order (e.g., payment service providers, warehouse operators, and delivery companies);
Marketing service providers and advertising partners;
Customer service providers to offer assistance before, during, and after your purchase;
IT support service providers, including companies that perform data analysis and/or send communications to our customers and/or develop our website and app;
Professional consultants (legal, accounting, etc.);
Credit reference agencies, law enforcement agencies, and fraud prevention agencies, to help combat fraud and other illegal activities;
Professionals or companies that manage websites and/or social media pages;
Third-party hosting providers for event companies and companies that assist in administering competitions and promotions.

Please be informed that if any part of our business is outsourced, sold, or merged, where permitted by law, we will share your personal data with the new entity so that we can continue to sell and provide support for our products. The new entity may use your personal data in the same manner as described in this Privacy Policy. We will, of course, inform you of such changes and provide you with the opportunity to opt out of sharing your personal data with the new entity.

We will never provide your personal data to third parties who do not perform necessary services on our behalf or to whom we are not permitted or required by law to provide data.

Categories of Personal Data We Share with Third Parties

Possible transferring of your personal data

We are committed to protecting your personal data to the highest global standards. In order to process your personal data for the purposes set out in this Privacy Policy, we may transfer your personal data to third parties and other companies in Clarks Group located outside the EEA or the UK. Occasionally, we may manage/process your personal data and provide you with additional services/support from countries other than the one in which you reside. We may transfer your personal data to other countries that have an adequacy status with the UK and/or within a country of the European Union or the European Economic Area (“EU/EEA”).

In the event that there is a business need to transfer your personal data to a country that does not have an adequacy status with the UK or the European Union, we will ensure that appropriate transfer mechanisms are implemented as required by the UK GDPR and/or the EU GDPR.

Links to third-party sites

Data subjects rights

Data Subjects have specific rights regarding the protection and correct processing of their personal data, as detailed in the legislation of the country in which they reside. For residents of at least the UK and EU/EEA, your rights are as follows:

Right to Access: You can request information about the personal data we hold on you at any time.
Right to Portability: If we process your personal data through automated means based on your consent or an agreement, you have the right to receive a copy of your data in a commonly used format.
Right to Rectification: You can request correction of your personal data if it is inaccurate or incomplete.
Right to Erasure: You have the right to request the erasure of your personal data under certain conditions. However, please note that this right is not absolute and does not apply if we have an ongoing matter with Customer Service, if you have an open order or unsettled balance, or if we are legally required to retain your data for bookkeeping related to a transaction. (Also known as “Right to be Forgotten” or “Delete My Data”).If you choose to exercise this right, please be aware that all account information and associated orders will be permanently lost. Before proceeding, you must confirm that there are no outstanding purchases or orders pending.
Right to Restriction: You can request the restriction of processing of your personal data under specific circumstances, such as when you contest the accuracy of your data, the processing is unlawful, or the data is no longer needed by us but required by you for legal claims.
Right to Withdraw Consent: You have the right to withdraw your consent for processing of your personal data at any time. This does not affect processing that has already occurred based on your prior consent. If you receive marketing communications from us on social media or web browsers, you should manage this directly with your platform provider.
Right to Object to Processing: You have the right to object to processing of your personal data that is based on our legitimate interest.

We will cease processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims.

You can exercise one of your rights by writing to the following email address privacy@clarks.com or clicking here:(https://onetrust.com/)

We will process all data subject’s requests within 30 days of receipt.

Please note that where you subsequently object to our processing, or otherwise request that your data is erased, we will be required to retain some of your personal data until we have delivered your ordered goods or performed your requested services, unless you inform us you wish to cancel your order. When exercising any of the rights listed above, we will ask you to verify your identity before proceeding to ensure that your personal data is adequately protected from unauthorised use. Likewise, if you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

If we need more time to handle your request, we will inform you in writing of the reason why an extension of the deadline is necessary. Our response will be reasoned (e.g., when the requirements for fulfilling the erasure request are not met). Processing and responding to the Data Subject is free of charge, but the Clarks reserves the right to charge administrative costs for repeated and/or clearly frivolous and unfounded requests. If we believe that the request justifies charging a fee, we will provide you with a cost estimate for the costs (copying rights) in advance before completing the processing of your request.

Clarks shall only process and respond to verified requests from the user, that is, requests made only:

Directly by the Data Subject,
By one of the parents or by a person exercising parental or legal authority over a minor Data Subject, or by another natural person who can demonstrate that they are authorized to act on behalf of the Data Subject

Obligation to notify third parties about the acceptance of the exercised Data Subject’s right

Clarks, once it has accepted and fulfilled a request to exercise one of the Data Subject's rights, undertakes to comply with the obligation to notify the recipients to whom the personal data have been transmitted before about any rectifications or erasures or restrictions of processing carried out, unless this proves impossible or involves a disproportionate effort.

Obligation to notify third parties about the acceptance of the exercised Data Subject’s right

How to contact us

We recognize the importance of your personal data. If you have any comments, questions, or requests regarding this Privacy Policy or our handling of your personal data, you can use this link: (https://onetrust.com/) to exercise all your privacy and data protection rights or click here

If you prefer to send us direct requests by mail, you can send a registered post to the following addresses:

Privacy Team, C. & J. Clark International Limited, 40 High Street, Street, Somerset, BA16 0EQ

Or send an e-mail to: privacy@clarks.com

If the issue pertains to another matter, please do not hesitate to contact our customer service team who will be happy to assist you.

How to File a Complaint

If you have concerns about how Clarks processes and safeguards your personal data and privacy, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) in the UK, or with any other relevant supervisory authority in your country of residence.

The Supervisory Authority in the United Kingdom is the Information Commissioners Office (ICO), which can be contacted at https://ico.org.uk
The Supervisory Authority in Italy is the Italian Data Protection Authority (Garante per la protezione dei dati personali), which can be contacted at https://www.garanteprivacy.it/.
The Supervisory Authority in France is the French Data Protection Authority (Commission Nationale de l'Informatique et des Libertés - CNIL), which can be contacted at https://www.cnil.fr/en.
The Supervisory Authority in Germany is the German Data Protection Authority (Bundesbeauftragter für den Datenschutz und die Informationsfreiheit - BfDI), which can be contacted at https://www.bfdi.bund.de/.
The Supervisory Authority in the Netherlands is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens - AP), which can be contacted at https://www.autoriteitpersoonsgegevens.nl/en.
The Supervisory Authority in Spain is the Spanish Data Protection Authority (Agencia Española de Protección de Datos - AEPD), which can be contacted at https://www.aepd.es/.

Keeping Your Personal Information Safe

We take the security of your personal data very seriously and have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised manner, altered or disclosed. Furthermore, we limit access to your personal data to those persons and third parties (employees, collaborators, professional consultants or suppliers) who have a need to know. They will process your personal data on the basis of our instructions and have undertaken to operate in the strictest confidence. We do not allow third-party processors to use your personal data for their own personal purposes or for purposes other than those for which we have authorised them to process it on our behalf in accordance with our instructions. We have also adopted procedures for managing any suspected data breaches and will notify the user and any competent supervisory authority of any data breaches where there is a legal obligation to do so.

Privacy Policy Changes and Updates

Any future changes to this Privacy Policy will be published on the Site and, where appropriate, communicated to users by email. Users are encouraged to periodically review this Privacy Policy to check for any updates or changes.

Latest update of the privacy policy: 26/04/2024

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