PRIVACY POLICY

 

Last Updated: October 6, 2022

This Privacy Policy describes how People Footwear US, LLC. through this website People Footwear (the “Site”, “we”, “us”, or “our”) collects, uses, and discloses the Personal Information (as defined below) of its visitors (“you”, “your”, or “yours”).

We are committed to protecting your privacy rights and recognize the importance of protecting the information that we collect about you. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Information we collect:

• directly from users of our Site, and recipients of our emails, including use of any of our services (through a mobile device, mobile application or otherwise) or other offerings (collectively, the “Services”);
• when you purchase any of our products (“Products”); and
• as otherwise indicated in this Privacy Policy.

In conjunction with this Privacy Policy, you should also review our Terms of Services for a more complete understanding of the rules governing our Site, Products and Services.

By visiting our Site, purchasing our Products or using our Services, you acknowledge that we handle your Personal Information under the terms of this Privacy Policy, and you understand that our collection, use and disclosure of your Personal Information is as set out in this Privacy Policy.

1. Who We Are

The People Footwear US, LLC. (collectively, “People Footwear”) are authorized licensees of the PEOPLE FOOTWEAR trademark in (among other jurisdictions) Canada and the United States, respectively, including for the purposes of operating this Site. The terms of this Privacy Policy cover all of our operations through this Site in the United States and Canada. Your data controller is People Footwear US, LLC. (and its affiliates), a US company registered under enterprise number 88-4127416 and having its offices at 6309 Monarch Park Place, Ste 101, Niwot, CO 80503. In other words, People Footwear US, LLC. is responsible for collecting, processing and protecting your personal data.

Our Site is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application.

The region-specific terms of this Privacy Policy only apply to the Aldo entity that is in such geographic locations, or as applicable law requires.

2. What Information We Collect & How We Use It

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases of Products or use of the Services, as applicable. Further, we collect Personal Information from you when you voluntarily provide us with this information, such as when placing an order for Products on the Site, establishing an account, contacting us with a question or comment, or signing up to receive emails about our latest Products and/or Services.

In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”, which is more particularly defined or limited under applicable law, and includes information such as: name, address, telephone number, email address, and other information incidental to providing with the Products or Services.

We will only process your Personal Information where we have a legal basis to do so. The legal basis will depend on the reasons we collected and our needs for the use of your information. See the list below for more information about what Personal Information we collect and why.

1. Device information

• Examples of Personal Information collected:
• version of web browser
• IP address
• time zone
• cookie information
• what sites or products you view
• search terms
• how you interact with the Site
• user name
• password

 

• Purpose of collection:
• to load the Site accurately for you
• to perform analytics on Site usage to optimize our Site and the overall shopping experience
• to improve the Sites, marketing endeavors or our Services
• to customize your experience on the Site or to serve you specific content or ads that are relevant to you
•  
• Source of collection:
• collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels
• See also our “Cookies”  section below

 

• Disclosure for a business purpose:
• shared with our processor Shopify
• shared with our third-party service providers for analytical purposes, such as Google Analytics, Google Optimize, Facebook, and Hotjar
• see also our “Interest-Based Advertising” section below

 

1. Order information

• Examples of Personal Information collected:
• name
• billing address
• shipping address
• payment information (including a billing address, currency, payment method, truncated credit card number, expiration date, card verification value, and similar information)
• transactions
• email address
• phone number
• language
• gift cards

 

• Purpose of collection:
• to provide Products or Services to you to fulfill your order request
• to process your payment information
• to arrange for shipping
• to provide you with invoices and/or order confirmations
• to communicate with you
• to screen our orders for potential risk or fraud
• to contact you with regard to your use of the Site and, in our discretion, changes to the Site and/or Site’s policies

 

• Source of collection:
• collected from you
• Disclosure for a business purpose:
• shared with our processor Shopify

• see also our “Sharing Your Personal Information” section below

 

1. Customer support information

• Examples of Personal Information collected:
• data and Personal Information that is necessary to perform the purchase contract for the Products, such as your name, address, telephone number, bank account number, truncated credit card number, truncated debit card number, or any other payment and financial information
• data or personal information that is necessary for compliance with our legal obligations

 

• Purpose of collection:
• to provide customer support
• to notify you of product recalls or providing other information concerning Products you have purchased
• for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy

 

• Source of collection:
• collected from you
• Disclosure for a business purpose:
• shared with our processor Shopify

1. Registered User Account

• Examples of Personal Information collected:
• your name
• address
• telephone number
• date of birth (optional)
• email
• Purpose of collection:
• Manage your user registration account

 

• Source of collection:
• collected from you
• Disclosure for a business purpose:

• shared with our processor Shopify

 

1. Contest, Surveys and Newsletters

• Examples of Personal Information collected:
• your name
• address
• telephone number
• date of birth (optional)
• email
• Purpose of collection:
• Manage your user registration account

 

• Source of collection:
• collected from you when you voluntarily complete a survey, an entry form to participate in a contest, a promotion or to subscribe to our newsletter
• Disclosure for a business purpose:

• shared with our processor Shopify

 

3. Cookies

Like many commercial websites, we also automatically collect information by way of electronic means, using cookies. Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. They are widely used to make websites function properly, as well as to provide business and marketing information to the owners of the site. For example, cookies will remember your chosen language and country, so that the pages we present you are in that language, and the exposed merchandise is the one of your country or region. Similarly, if you're halfway through a purchase, cookies will allow you to browse other areas of the website and then return to your purchase. Cookies also provide information on how people use the site, for instance whether it is their first time visiting or if they are a frequent visitor. For further information about cookies, you can visit the following website: www.allaboutcookies.org.

We use the following cookies to optimize your experience on our Site and to provide our Services.

• Shopify - Cookies Necessary for the Functioning of the Site

Name	Function
_ab	Used in connection with access to admin.
_secure_session_id	Used in connection with navigation through a storefront.
cart	Used in connection with shopping cart.
cart_sig	Used in connection with checkout.
cart_ts	Used in connection with checkout.
checkout_token	Used in connection with checkout.
secret	Used in connection with checkout.
secure_customer_sig	Used in connection with customer login.
storefront_digest	Used in connection with customer login.
_shopify_u	Used to facilitate updating customer account information.

• Shopify - Reporting and Analytics

Name	Function
_tracking_consent	Tracking preferences.
_landing_page	Track landing pages.
_orig_referrer	Track landing pages.
_s	Shopify analytics.
_shopify_fs	Shopify analytics.
_shopify_s	Shopify analytics.
_shopify_sa_p	Shopify analytics relating to marketing & referrals.
_shopify_sa_t	Shopify analytics relating to marketing & referrals.
_shopify_y	Shopify analytics.
_y	Shopify analytics.

 

• Google Analytics and Google Optimize

We use Google Analytics and Google Optimize, web analytics services provided by Google Inc. (“Google”). Google Analytics uses cookies to help website operators analyze how users use the site. The information generated by the cookie about your use of the Site will be transmitted to and stored by Google on servers in the United States. Google will use this information to evaluate your use of our Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

• Facebook Pixel

 A Facebook Pixel installed, which allows us to track things such as purchases and web traffic. See also our section “Interest-Based Marketing”.

• Hotjar

We use Hotjar to better understand our visitors’ needs and to optimize this Site. Hotjar is a tool used to analyze your user patterns on this Site. Hotjar uses cookies and other similar technologies to collect data on our users’ behavior and their devices.

 

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our Site may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls. You may refuse to accept cookies by altering the settings on your internet browser). Please note that if you choose not to permit cookies some areas of our Site may not function properly or be accessible. For further information about how to refuse cookies, please refer to your browser ‘help’ section or see www.allaboutcookies.org.

Here are some links to disable cookies in the browser you are using:

• Apple Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Google Chrome: https://support.google.com/accounts/answer/32050 
• Microsoft Edge: https://support.microsoft.com/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy 
• Mozilla Firefox: https://support.mozilla.org/kb/enable-and-disable-cookies-website-preferences

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Interest-Based Advertising” section.

4. Retention of Your Personal Information

When you place an order for Products through the Site, we will retain your Personal Information for our records as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, as necessary or appropriate to provide the Services, and for business continuity purposes, unless and until you ask us to erase this information. We also retain information as permitted or required under applicable law to comply with applicable law, to resolve disputes, and to enforce our rights and agreements.

For more information on your right of erasure, please see the “Your rights” section below.

5. Sharing Your Personal Information

We share your Personal Information with service providers to help us provide our Services and fulfill your purchase of Products, as described above. For example:

• Public Authorities. We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

• Internal and Services-Related Usage. We use your Personal Information to continue improving and developing Products and Services that we may offer you, and to optimize your experience with us. Further, we use and retain information, including Personal Information, to analyze interactions with and performance of our Services, and to improve, supplement, or enhance our Services, or develop new Products and Services.

 

• Affiliates. We may share your Personal Information with our affiliates, which may include a parent company, subsidiaries, joint venture parties, or other companies that we control or are under common control with us, in which case their use of your Personal Information will be treated in accordance with this Privacy Policy. Further, in the event of a corporate sale, merger, reorganization, spin-off, or similar event, we expect that information that we have collected, including Personal Information, would be transferred to one or more surviving or acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such Personal Information as set forth in this Privacy Policy. This policy shall be binding upon us and our legal successors in interest, including (to the extent applicable) the owner of the “PEOPLE FOOTWEAR” brand – Bata Brands, SA.

 

• Displaying to Other Users. Any content that you post in a publicly viewable forum through our Services may be publicly displayed on our Site. You acknowledge and understand that any such channel or forum are for the public and not private mode of communication.

 

• Information to Process Your Purchases. We may also share your personal information with the following third parties and for the following reasons:

 

• With financial institutions, credit card companies, credit reference agencies and anti-fraud screening service providers to process payments and (where necessary) to carry out fraud-screening.

 

• Technical services providers, logistic, transport, delivery partners and providers of customer support, to complete the contract that we have with you.

 

• Advertising and marketing related partners, to assist us in our marketing campaigns.

 

• Third party service providers we are using to provide services that involve data processing, for example, to carry out marketing initiatives or run customer surveys on our behalf.

 

This includes the following third-party providers:

• Shopify. We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
• Klaviyo. We use Klaviyo as an email provider. You can read more about how Klaviyo uses your Personal Information here: klaviyo.com/privacy
• Stamped.io. We use Stamped.io to enable the reviews feature. You can read more about how Stamped uses your Personal Information here: https://stamped.io/privacy

 

• Information From Third Parties. We may collect information about you from third parties or supplement the information we collect from you with additional records received from third parties. We also collect information from third parties in order to enhance our ability to serve you, to tailor our content to you, to offer you information that we believe may be of interest to you, and to inform our commercial and operational decisions. See our “Interest-Based Advertising”.

 

6. Direct Marketing

We would like to send you information about Products and Services that we think you might like. We will only send you these marketing campaigns if you have specifically agreed to receive them. Note that you may always opt out of them at a later date.

If you no longer wish to be contacted for marketing purposes, please click on the link at the bottom of any promotional message or contact us at the contact information provided in the section “Contact”. However, should you wish for your details to be removed from our customer relationship management system completely, you will need to contact our Customer Services using the contact details in our Site.

7. Interest-Based Advertising

As described above, we may use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you (interest-based advertising). Interest-based marketing is a way of serving advertisements on the websites you visit and make them more relevant to you and your interests: shared interests are grouped together based upon previous web browsing activity and web users are then served advertising which matches their shared interests. This way, advertising can be made as relevant and useful as possible. Relevant ads can also be delivered based upon the website content you have just been viewing. This is known as retargeting.

We conduct remarketing campaigns using third-party vendor remarketing tracking tools, including Facebook pixel. It allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you. If you do not wish to see ads from us, you can opt out in several ways:

• opt out of a third-party vendor’s use of cookies by visiting the following links and help you opt-out of online interest-based marketing:
• Network Advertising Initiative (NAI) - https://optout.networkadvertising.org/
• Digital Advertising Alliance (DAA) - https://optout.aboutads.info/
• Digital Advertising Alliance Canada (DAAC) - https://youradchoices.ca/choices
• opt out of Instagram and Facebook’s targeted marketing by following the steps laid out in their respective Privacy and Cookie policies and/or websites. This won’t stop them from tracking you, it simply means that information won’t be used to show ads targeted to you.

However, doing so:

• does not mean that the advertising of our products and services on our own websites will stop being personalized to your interests;
• may not stop all online behavioral advertising, since these websites apply to the third-party advertising agencies that have signed up to those services;
• does not mean that there will no more advertising on this website or other websites you access. However, the advertising that you do see is likely to be less relevant to your interests.

Deleting browser cookies can remove your opt-out preferences, so you may need to opt out again.

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

8. How We Protect Your Personal Information

We implement commercially reasonable and appropriate physical, administrative and technical security measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. While we implement these security measures with respect to our Site, please note however that no data transmissions over the Internet can be guaranteed as 100% secure. Your own conduct may dictate your level of protection. As such, we cannot guarantee the security of any Personal Information you transmit to us. You understand that any Personal Information that you transfer to us is done at your own risk.

Rest assured that we only share your Personal Information to non-affiliated third parties in the ways permitted by applicable law or that are outlined within this Privacy Policy. Furthermore, if the disclosure of information contemplated within this Privacy Policy involves a transfer of the information to jurisdictions located outside your country of residence which does not have equivalent regulation regarding data privacy obligations, we will ensure that such recipient offers an adequate level of protection of your personal information, and if such a thing is not possible, we will ask for your prior consent before engaging in such a data transfers, detailing the information, the purposes and the person with whom we intent to share the information.

9. Your Rights

Depending on your geographic location or place of residence, you may have certain statutory rights in relation to your Personal Information, such as:

• The right to erasure– You may have the right to request that we erase your personal data, under certain conditions.

 

• The right to cancel or restrict processing– You may have the right to request that we restrict the processing of your personal data, under certain conditions.

 

• The right to object to processing– You may have the right to object to our processing of your personal data, under certain conditions.

 

• The right to data portability– You may have the right to request us to transfer the data that we have collected to another organization, or directly to you, under certain conditions.

 

• The right to correct. You may have the right to request access to your information, to seek to update it, to correct it, or delete your Personal Information where it is inaccurate or has been processed in violation of this Privacy Policy.

Regardless of your rights, we may not be able to alter or delete certain Personal Information if we are required to retain it to provide you with Services that you have requested or for us to fulfill other obligations to you, for security reasons, to comply with applicable law or regulations, for internal business, or other valid reasons.

Furthermore, information that you have shared with others such as reviews or forum postings may continue to be publicly visible, and some copies of your information (e.g. log records, residual copies) may remain in our database, after being however anonymized.

Finally, if we are unable, for technical reasons, to delete some information from our systems, we will inform you and put in place appropriate measures to prevent any further use of the data.

10. Privacy Requests

If you make a request, we have one month to respond to you. If you would like to exercise any of the rights set forth in the section “Your Rights”, please contact us and we will then provide you with the requested information via email at the contact information provided in the section “Contact”. However, if you require additional copies, we may need to charge a reasonable fee. It must be noted that you are responsible for keeping your Personal Information up-to-date, but you can also ask us to correct inaccurate or incomplete Personal Information that you cannot update yourself.

If you wish to receive a copy of any other information we hold on you, we recommend that you make a request in writing and include the following information with your request:

• Name and postal address
• Details of your request
• Corroborating information to establish your identity (e.g. photocopy of your passport or driving license)
• Signature and date of the request
• if you are applying on behalf of another person then signed authority from the individual is required

 

When collecting Personal Information to verify your identity, we will only use that information for the purpose of completing verification.

11.     California Residents & CCPA

Under the California Consumer Privacy Act (“CCPA”), if you are a resident of California, you have certain specific rights regarding your Personal Information in addition to those set forth hereunder, such as the right to access the Personal Information we hold about you and to specific disclosure, to port it to a new service, to ask that your Personal Information be corrected, updated, or erased, and the right not to be discriminated against by a business on account of exercising privacy rights provided by the CCPA. If you would like to exercise these rights, please contact us at the contact information provided in the section “Contact”.

We do not sell personal information of consumers, as those terms are defined under the CCPA.

12. International Visitors

The Site is hosted in the United States and intended for users located in the United States and Canada. However, like almost every Site our Site can be accessed by international visitors. If you are located outside of the United States or Canada, please be aware that information we collect, including Personal Information, will be transferred to, and processed, and stored in the United States, as well as used in Canada. The data protection laws in the United States or Canada may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. In addition, such data may be stored on servers located outside your resident jurisdiction and in jurisdictions which may have less stringent privacy practices than your own.

By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States and Canada as set forth in this Privacy Policy.

13. Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

14. Third-Party Websites and Features

The Site may contain links to other websites and may include or contain certain social media or other features provided by third party platforms (i.e., Pinterest). These features may collect certain of your information and may set a cookie to enable the feature to function properly. The use of these third-party feature may involve the third-party operator providing certain information, including Personal Information, to us. If you click on social media icons on the Site we may have access to your Personal Information you provided on those third-party sites or applications. Your interactions with these features or other website are governed by the privacy policy of the third-party providing it. Our Privacy Policy applies only to our Site.

15. Minors

The Site is not intended for individuals under the age of 13. We do not knowingly collect personal information online from visitors in this age group without parental consent. If you are the parent or guardian and believe your child under 13 of age has provided us with Personal Information, please contact us to request deletion at the contact information provided in the section “Contact”.

16. Changes

This Privacy Policy is effective as of the date stated at the top of this policy. We may change this Privacy Policy from time to time to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons, and will post any changes on this page. To the fullest extent permitted by applicable law, our use of information is governed by the Privacy Policy in effect at the time we use the information. By accessing the Site after any such changes to this Privacy Policy, you are deemed to have accepted such changes.

17. Contact

For more information about our privacy practices or our data collection/processing practices, if you have questions or concerns, or if you would like to make a complaint, please contact us using the following details: Data Protection Officer, People Footwear US, LLC. 6309 Monarch Park Place, Ste 101, Niwot, CO 80503 , or by contacting us at hello@peoplefootwear.com.