Updated June, 2021
This Privacy Notice (the “notice”) sets out how we, Bestol Group Footcare Limited subsequently referred to as “Bestol Footcare”and each of its local and international subsidiaries, business units and sales offices from time to time (Group, we, us, our) process the personal data of individuals (each a “User”, “you”, “your”) who contact us or who use our websites, services, programs, content and related features (collectively, the “Services”) or who visit us at trade shows, events or at our premises.
If you have any questions about this Notice, please contact us by email at email@example.com. If you wish to contact our local offices, please refer to our Contact page for details.
This notice, together with our Conditions of Use and any other documents referred to in these documents, set out our views and practices regarding your personal data and how we will treat it. Please read these documents carefully. By visiting our website or using our Services, you acknowledge the processing described in this Notice, our Conditions of Use and related documents.
Our Services are not intended for children under the age of 13. We do not knowingly collect, use or disclose personal data from or about visitors under 13 years of age. If you are under the age of 18, you must obtain the consent of your parent or guardian to use our Services and to provide us with your personal data.
This version of our privacy notice was published in June 2021.
What are personal data?
“Personal data” means any information relating to an identified or identifiable natural person, known as ‘data subject’, who can be identified directly or indirectly; it may include name, address, email address, phone number, IP address, location data, cookies, call recording and similar information. It may also include “special categories of personal data” such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a data subject, data concerning health or data concerning a natural person’s sex life or sexual orientation.
What personal data do we process?
We may process the following personal data:
- Information provided by you. You may give us information about you by filling in forms such as the contact form on our website, requesting Services, requesting a quote, ordering product, responding to a survey, uploading information, making applications in respect of job postings, corresponding with us by e-mail, phone or otherwise. This information may include your name, email address, billing address, shipping address, phone number, position and place of employment, payment information, the content of any email you send to us and similar information.
- Information about others. You may also provide to us personal data relating to third parties, such as people who you work with, the person who pays for your orders, services or promotions, and other individuals.
- Information about your device. With regard to each of your visits to our website we may collect technical information about your device such as IP address, operating system, browser, time zone setting, the Internet address of the website from which you linked directly to our website, URL clickstream data, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- Information from third party sources. This may include information received from credit reference agencies, shipping companies, our service providers and other third parties.
Generally, you are under no obligation to provide this information, but without it, we may be unable to provide you with some of our Services. Some personal data will be mandatory in order for us to comply with mandatory client due diligence processes before we are able to provide the Services.
Information about third parties should only be provided if you have demonstrable permission to do so or if the information is available in the public domain.
We will consider the information provided by you as accurate, complete and up to date and you agree to ensure that this will be the case.
How do we use your personal data?
We will only process personal data, in accordance with applicable law, for the following purposes:
- responding to your queries, requests and other communications;
- providing the Services including our website and related features, sale of products and services, and other Services;
- enabling suppliers and service providers to carry out certain functions on our behalf in order to provide the Services, including webhosting, data storage, identity verification, technical, logistical and other functions, as applicable;
- allowing you to use features on our website, when you choose to do so;
- sending you personalised marketing communications as permitted by law or as requested by you. You have the right to unsubscribe by email to firstname.lastname@example.org;
- serving personalised advertising to your devices, based on your interests in accordance with our Cookie Statement below. You have the right to disable cookies as set out below;
- publishing marketing materials, such as User testimonials. If you wish to make the request that your testimonial be removed you may contact us at email@example.com;
- connecting you to third party features, such as social media. Our Websites may include social media features, such as the Facebook “Like” button, or other functionality, such as the “share this” button. These features may collect your IP address or the page you are visiting on our site, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy statement of the company providing them;
- contacting third parties, such as sending a friend referred by you a one-time invitation;
- ensuring the security of our business and preventing and detecting fraud;
- administering our business, including complaints resolution, troubleshooting of our website, data analysis, quality control, staff training, testing of new features, research, statistical and survey purposes;
- developing and improving our Services; and
- complying with applicable law, including in response to a lawful request from a court or regulatory body.
The legal basis for our processing of personal data for the purposes described above will typically include:
- processing necessary to fulfil a contract that we have in place with you or other data subjects, such as processing for the purposes set out in paragraphs a), b), c), d) and j);
- your consent, such as processing for the purposes set out in paragraphs e), f), g), h) and j);
- processing necessary for our or a third party’s legitimate interests, such as processing for the purposes set out in paragraphs a), b), c), d), g), i), j),k), l) and m), which is carried out on the basis of our legitimate interests to ensure that Services are properly provided, ensure the security of our business and our Users and for the proper administration and development of our business;
- processing necessary for compliance with a legal obligation to which we are subject, such as processing for the purposes set out in paragraph n); and
- other applicable legal grounds.
The cookies placed on our website. For example, we may use the following cookies on our website:
- Strictly necessary cookies. These cookies are essential in order to enable you to move around our website and use its features. Without these cookies, Services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.
- Performance cookies. These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it and the approximate regions that they are visiting from. These are first party cookies. For example, this website uses Google Analytics to help analyze how Users use the website. The information generated by the cookie about your use of the website (including IP address) is transmitted to Google. This information is then used to evaluate Users’ use of the website and to compile statistical reports on website activity for the Group.
- Functionality cookies. These cookies allow our website to remember choices you make (such as your user name, language or the region you are in, if applicable) and provide enhanced, more personal features. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.
- Targeting or advertising cookies. These cookies allow us and our advertisers to deliver information more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of advertising campaigns. They remember that you have visited our website and may help us in compiling your profile. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
- Social Media cookies. These cookies allow you to connect with social media networks such as Facebook, twitter, LinkedIn and Google+. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
- Other cookies and similar technologies from time to time.
We may combine information from these types of cookies and technologies with information about you from other sources.
Cookie consent and opting out. By using our Services, we assume that you are happy to have us place cookies on your device. Most Internet browsers automatically accept cookies. However, if you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. Learn how to disable cookies for your browser here. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website, our platforms and Services.
You may also opt-out from third party cookies by selecting appropriate options on http://www.youronlinechoices.com/.
Disclosure of personal data
There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. These scenarios include disclosure to:
- our Group companies worldwide, including in the EU, USA, Japan and elsewhere;
- our suppliers and service providers to facilitate the provision of the Services, including webhosting, identity verification (in order to verify your identity against public databases), customer services, job application portal, payment platform, analytics, consultants, for example, in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
- subject to appropriate legal basis such as consent, our advertising and marketing partners who enable us, for example, to deliver personalised ads to your devices or who may contact you by post, email, telephone, SMS or by other means;
- payer, such as your employer or principal, who pays for our products and services;
- successor or partner legal entities, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event relating to our business. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;
- public authorities where we are required by law to do so; and
- other third parties where you have provided your consent.
International transfer of your personal data
We may transfer your personal data to a third party in countries outside the country in which the personal data were originally collected for further processing in accordance with the purposes set out above. In particular, your personal data may be transferred across our group of companies in the US and other countries. Where this is the case, we will ensure that appropriate transfer mechanisms, such as standard contractual clauses, are in place to ensure an adequate level of data protection.
If we transfer personal data to private organisations abroad, such as our suppliers and service providers, we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means, such as standard contractual clauses. You may contact us for a copy of such safeguards in these circumstances.
Retention of personal data
We retain personal data for as long as is necessary for the purposes listed above or longer as may be required by the law. Please contact us for further details of applicable retention periods.
We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
Security of personal data
We will use appropriate technical and organisational information security measures to try to prevent unauthorised access to your personal data. Some of these measures include encryption software, firewalls, and use of Secure Socket Layers (SSL) protocols.
However, please be aware that the transmission of information via the internet is never completely secure. While we can do our best to keep our own systems secure, we cannot control the whole of the internet and we cannot therefore guarantee the security of your information as it is transmitted to and from our website.
Where you have created or received a password or verification link which enables you to access certain parts of our website or content, you are responsible for keeping such information confidential. We ask you not to share such information with anyone.
Third party sites
Third party policies for related services and offerings linked to or from our Services have their own privacy statements that can be viewed by clicking on the corresponding links within each respective website. Since we do not have control over the policies or practices of participating merchants and other third parties, we are not responsible for the privacy practices or contents of those sites. We recommend you review their policies before you provide any personal data or complete any transaction with them.
Bestol Footcares’ Notice to California Residents
The California Consumer Privacy Act of 2018, (Cal. Civ. Code §1798.100 et seq., as amended, “CCPA”) gives California residents rights and control over their personal information. Bestol Footcare provides this statement to those residents in accordance with requirements under the CCPA to make certain disclosures about the collection and processing of their personal information. This is Bestol Footcare’ California-specific description of consumers’ privacy rights under the CCPA.
We do not sell your personal information
Under the CCPA, a business that sells California residents’ personal information to others: 1) must give notice to California residents before selling their personal information to others; and 2) must provide the right to opt out of the sale of their personal information.
Bestol Footcare does not sell personal information, including personal information of anyone under 16 years old. Thus, these notification and opt-out requirements do not apply to Bestol Footcare.
Your rights under the CCPA
The CCPA provides California residents with certain rights related to their personal information. To submit a request based on these rights, please contact us at firstname.lastname@example.org. With respect to their personal information, California residents may exercise the rights described below.
- Right to know what personal information is being collected, for what purposes and with whom it is shared
- Right to know whether your personal information is sold or disclosed for a business purpose and to whom.
- Right to say no to the sale of your personal information – Again, Bestol Footcare does not sell personal information.
- Right to non-discrimination of service or price if you exercise your privacy rights
- Right to deletion of personal data
Exemptions under the CCPA
The CCPA provides exemptions, until and including June 1, 2021, from certain of the above described disclosures pertaining to the last 12 months including a business-to-business exemption:
Personal information reflecting a written or verbal communication or a transaction between Bestol Footcare and a natural person, where the natural person is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency and whose communications or transaction with Bestol Footcare occur solely within the context of Bestol Footcare conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, nonprofit or government agency.