Privacy Policy

ECCO PRIVACY POLICY

Effective Date: 12/23/22

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE

ECCO USA, Inc. (referred to herein as “ECCO,” “we,” “us” and “our”) respects your privacy and takes our responsibility seriously.

This Privacy Policy describes how we directly and indirectly collect information in connection with your use of our websites and any other microsites or mobile websites (the “Website”), information you provide to us when you visit an ECCO owned and operated retail store (referred to as “ECCO Stores”), information in connection with your use of our mobile applications we make available for download on your personal device (our “Apps”), or information you provide to us when you visit our Facebook, Instagram, YouTube, Twitter, and other social media platforms (our “Social Media Pages”). Additionally, this Privacy Policy describes how we use and share that information. Please take the time to read this Privacy Policy.

We may revise this Privacy Policy periodically and will post any changes to the Website. Additionally, this Privacy Policy may be supplemented or amended from time to time by other “privacy notices” posted on the Website or specific pages within the Website. These privacy notices describe in more detail the information we collect on particular pages or areas of the Website. 

1. Information We Collect

The personal information we collect depends on how you interact with us. In the past 12 months we may have collected various categories of personal information about you, including:

  • Device Information:  When you visit our Website, use our Apps, interact with our Social Media Pages or online ads, or open our emails, we may learn about your browser, device type, IP address, MAC address, internet service provider, the name and version of your operating system, the name and version of your browser, the date and time of your visit, the pages you visit, and any search terms you enter while on the Website.
  • Location Data: We use various technologies to learn your geographic location, including by collecting your IP address or other device information, which may depend on your device’s settings for location services and how you interact with us.
  • Website/Apps Interactions: We collect information about your interactions with our Website and Apps, including pages visited, links clicked, buttons clicked, mouse movement, scroll behavior, and non-sensitive keystroke activity. This data may then be used to create a “session replay” of your interaction, which may be used to troubleshoot customer service issues, either individually or in the aggregate, to improve site functionality and to analyze user interaction. This information could include personal information, depending on what information you provide.
  • Contact Information: We may collect your contact information, including first and last name, address, telephone number, email address, billing address, or shipping address.
  • Payment Card Information and Payment Details: We may collect your payment card information or payment details if you make an order or add your payment details to your account with us, if any.
  • Shopping History & Transactional Data: We keep track of your shopping history with us, including the items you purchase at an ECCO Store or Website, return or exchange, or add to your shopping cart.
  • Call records, email records, text records, video, and chat logs: If you call, email, text, or chat with our customer service agents, we may keep records of those conversations including all such information you have provided to us in connection with such conversation.
  • Security camera footage: If you visit our stores or offices we may have security camera footage of you.
  • Submitted Content: We collect any content you submit to our Website, Social Media Pages, or to us in person including photos, videos, or reviews.
  • Demographic Information: We may collect demographic details about our customers such as birthdate, gender, ZIP code, Social Media information and profile data, and other similar details.
  • Social Media Usage: We receive aggregated information about people who visit and interact with our Social Media Pages.
  • Job Application Data: If you apply for a job with us, we will, in addition to the Contact Information you provide us, also collect such information as your educational background, employment history, résumé, and other information relating to your job search or application relevant for the recruitment process.
  • ECCO Account Data: If you want to register or have a registered account with ECCO, we will collect your Contact Information, passwords for the account, Demographic Information, Preferences, and Shopping History & Transactional Data.
  • Preferences: We may collect information about your preferences, such as products you may be interested in.
  • Inferences: We may draw inferences about any of the information above that may relate to your preferences, or other matters.

2. How Your Information is Collected

We may collect the information described above directly from you, from third parties we partner with, or through cookies or other automated means. These sources may include:

  • You: We collect information directly from you, whenever you: make a purchase; visit a store; contact us with questions or comments; upload content to our Website, Apps, or Social Media Pages; enter our contests, sweepstakes, or other promotions; add items to your shopping cart; create an ECCO account; respond to a survey; make a product review; opt in to text messages; apply for a job; or fill out any forms on our Website, Apps, or Social Media Pages.
  • Your Device or Browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Website, use our Apps, interact with our Social Media Pages or online advertising, or open our emails.
  • Third Parties: We work with third parties who provide services to us, like analytics or advertising companies, advertising networks, data brokers, recruitment agencies etc. These third parties may share information they have collected with us. Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy notices.
  • Service Providers and Contractors: We work with different kinds of vendors who as Service Providers or Contractors collects and processes personal information on our behalf and under our control and in accordance with our instructions.
  • Operating systems and platforms: We use different kinds of operating systems and platforms to run our business and make relevant services available. These operating systems and platforms and the use hereof may create information, which could be personal information about you.
  • Social Media Platforms: Social media platforms share information, which is typically aggregated and doesn’t include personal information, with ECCO. You can learn more about how social media platforms collect and use your information by reviewing their privacy policies and settings. If you contact us via social media platforms to make a complaint or service request, then we will collect information related to such complaint of service request from the social media platform.
  • Cookies: ECCO uses cookies (small files stored on your device or browser), pixel tags (tiny graphic images embedded in a website or email), web beacons, and other similar technologies to automatically collect information when you visit our Website, use our Apps, or interact with our emails. Through the use of cookies, we may link information about your interactions with our Website, Apps, or emails over time, for example, which pages you visit, which links you use, and how long you stay on each page. We also contract with third party advertising or analytics companies to serve you online ads on other websites. These companies use cookies or similar technologies to collect information about your interactions with our Website and Apps and interactions with other websites. These advertising companies may use and share the information gathered to deliver ads more tailored to your interests. We receive aggregate information from these third parties to understand our advertising effectiveness. Any information collected by us or by third parties through the use of cookies or similar technologies may be linked with other information we collect about you.
  • Publicly Available Data: We may combine the information you provide to us with data that is publicly available.

3. How We Use Your Information

  • Fulfillment: Fulfilling your orders and other requests, including, but not limited to, processing payments, confirming or updating you on the status of your order, delivering packages, and responding to your customer service inquiries.
  • Advertising: Presenting advertising online and via email, or other communication channels, including through partnerships with social media platforms and internet search engines.
  • Understanding our customers: Analyzing your activity with us (including your interactions with our Website, Apps, Social Media Pages, and emails or other forms of communications, analyzing trends and statistics). We keep track of the pages you visit and the manner in which you use the Website to determine what products are most popular and whether to make changes to the Website. We may, from time to time, review your information and information of other customers to help us analyze trends, purchasing patterns and preferences, and demographics.
  • Personalization: Using your preferences and other collected information to personalize your shopping experience by using your product interests, shopping patterns, and purchase information to recommend other products, services or promotions that we believe you may be interested in as well as personalizing advertising and experiences on our Website, Apps, emails, and ads.
  • Communications: Communicating with you, including responding to your requests and asking for feedback through surveys, product reviews or other messages.
  • Promotions: Running contests, sweepstakes, or other promotions.
  • Social Curation: Using Submitted Content on our Websites, Apps, Social Media Pages, and other ECCO Group owned and operated websites, apps, and social media pages.
  • Hiring: Recruiting and hiring ECCO employees. If you apply for a job with ECCO, we will be using your Job Application Data for recruiting and employment purposes. If you are hired by ECCO, the information you provide during the recruiting process will become part of our employee records. If you are not hired by ECCO, we may retain your information to allow us to contact you if another suitable employment opportunity becomes available.
  • ECCO Account: Operating the ECCO Accounts, including making certain services available, offering rewards and/or special promotions to ECCO Account members.
  • Customer Experience: Serving content on our Website, Apps, and Social Media Pages and developing our products and services.
  • Security: Protecting ECCO and our customers from fraud, security threats, and other illegal or harmful activity. We and our third party service providers may disclose specific individual information if we or they reasonably believe it is necessary to: (i) investigate any suspected misuse of a Website; (ii) protect or defend the rights, property and interests of ECCO, our customers, or the interests of our third party service providers; or (iii) under exigent circumstances, to protect the personal safety of users of a Website or the public.
  • Legal Obligations: Complying with legal and regulatory requirements and responding to requests from courts or other government bodies.

4. How We Share Information with Service Providers and Third Parties and For What Purposes

ECCO may exchange personal information with service providers, contractors and other third parties for certain purposes. For example, we share personal information with:

  • Service Providers: We partner with third parties to assist with many aspects of our business, including fulfilling orders, advertising, analyzing your interests and activity on our Website and Social Media Pages, and helping us communicate with customers. These third parties may provide services related to any of the purposes described in section 3 “How We Use Your Information,” and we may share with them any types of information described in section 1 “Information We Collect.” We may also receive information collected by these third parties and combine it with the information we have collected. Some of these third parties may be located outside the United States. Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy notices.
  • Marketing Agencies and Data Analytics Providers: We partner with third parties to assist with the advertising and marketing of our business and performing business analytics. We may share with them the types of information described in section 3 “How We Use Your Information.”
  • ECCO Affiliates: We are part of the Danish family owned “ECCO Group”, which are companies either owned and controlled by, owning or controlling, or under common ownership or control with ECCO Sko A/S with its registered address at Industrivej 5, 6261 Bredebro, Denmark. We make use of various services from ECCO Affiliates across the world in order to operate our business including but not limited to IT, finance, legal, marketing services, etc. We may disclose certain personal information for our ECCO Affiliates’ use such as, for example, Submitted Content for use on websites, apps, social media pages owned and operated by other ECCO Affiliates.
  • Other Third Parties: We will disclose information about you, including to government bodies or law enforcement agencies, when we believe it to be necessary for compliance with the law or to protect our Website and App users, our Website and App, or the public.

ECCO will not purchase consent, or sell, rent or share consent to opt-in to our mobile SMS/texting program.

If you are a California resident, you can learn more about your privacy rights below in section 16.1 “Your Californis Privacy Rights” and Opt-Out from any sale or share of your personal information through our Do Not Sell or Share My Personal Information page.

If you are a Virginia resident, you can learn more about your privacy rights below in section 16.2 “Your Virginia Privacy Rights“ and Opt-Out from any sale of your personal information the processing of your personal information for targeted advertising through our Do Not Sell or Share My Personal Information page.

5. How We Retain and Delete Your Personal Information

Your personal information will be held by us and kept in a form, which permits identification of you for no longer than is necessary for the purposes for which the personal information is collected and legitimately processed.

This implies that we will keep and process your personal information as long as we are providing services to you, interacting with you and/or consider having a relationship with you, and also afterwards for as long as would be needed for

    i) for the establishment, exercise or defence of potential legal claims and disputes.

    ii) compliance with tax, VAT, accounting and other mandatory regulation.

Thereafter, we will within reasonable time either delete your personal information or anonymise/deidentify it so that it no longer can be used to identify you.

We will also honor any statutory right you have to request your personal information to be deleted or anonymized. you can learn more about your privacy rights below in section 16 “Your Privacy Rights”.

6. Your Privacy Choices

You can control the information we collect and use in the following ways:

  • Location Data: You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Website from accessing your location information. Note that some services may not be available if you disable location-based services, and you may experience difficulties shopping online at the Website.
  • Emails: You can unsubscribe from marketing emails by clicking the unsubscribe link in the footer of such email.
  • SMS/Text Messages: You can unsubscribe from SMS/text by texting STOP to 57683.
  • Online Accounts: You can keep your contact information and payment methods accurate and up to date by logging into your account on our Website. If you wish to cancel your account, email us at eccousa@ecco.com.
  • Social Media: This privacy policy does not cover the privacy and security practices of social media platforms on which ECCO has Social Media Pages. Please review the terms, policies, and settings of those social media platforms if you have questions about how they collect and use your data.
  • Online Advertising: For information about opting out of third party advertising, visit Network Advertising Initiative’s website at https://optout.networkadvertising.org/?c=1 or Digital Advertising Alliance’s website at https://digitaladvertisingalliance.org/. You will leave this Website for a separately managed online site where you can specify your preferences. We may use more than one third party company for placing this advertising, which would require you to opt out of each company.
  • Parties to a Business Transaction: Your information may be transferred to another entity that succeeds to all or part of ECCO’s business in connection with a sale, reorganization, consolidation, or merger. Your information may be shared under obligations of confidentiality and non-disclosure to a prospective successor or purchaser of ECCO’s business.

7. Children

ECCO does not knowingly or purposefully request or collect personal information from any person under the age of 16 years old. If you believe that your child under the age of 16 has submitted personal information to ECCO in connection with our Website or Apps, please contact us at ECCOUSA.Privacy@ecco.com.

8. Security

We take steps to help protect the confidentiality and security of your personal information. Although we use measures to protect your personal information, in general, information transmitted through the Internet may not be completely secure. Accordingly, we cannot guarantee the security of information provided over the Internet or stored in our databases. Your transmissions are, therefore, at your own risk. You can protect your information by selecting strong, unique passwords for your Website account and any associated email addresses.

9. Supported Web Browsers and Do Not Track Signals

We recommend that you use the latest web browser versions to optimize your experience. Older web browser versions may not be able to access or utilize all pages on our website as intended. ECCO may not be able to receive or honor web browser “Do Not Track” signals and our Website may continue to collect information in the manner described within this privacy notice.

10. Website Terms and Conditions

This Privacy Policy constitutes an integrated part of ECCO’s Terms & Conditions, located at https://us.ecco.com/legal-pages/legal-terms-of-use.html.

11. Updates

We reserve the right to modify, alter, or otherwise update this Privacy Policy at any time, so we encourage you to review this policy from time to time. Changes to this Privacy Policy are effective at the time they are posted and your continued use of our sites after posting will constitute acceptance of, and agreement to be bound by, those changes. If we make any material changes to our privacy practices, we will update this Privacy Policy and change the effective date at the top of this page.

12. Governing Law

This Privacy Policy will be governed by and construed in accordance with the laws of the State of New Hampshire, without giving effect to its conflicts of law provisions. By accessing or using the Website, you consent and submit to the exclusive jurisdiction and venue of the state and federal courts located in New Hampshire.

13. Links to Other Websites.

This Website may, from time to time, contain links to websites owned and operated by third parties (“Third Party Sites”). We encourage you to review the privacy policies of such Third Party Sites so that you understand how those websites collect, use, and share your information. We are not responsible for the privacy policies or other content on Third Party Sites.

14. Miscellaneous

In the event that any provision of this Privacy Policy conflicts with applicable law, rule, regulation or order or if any provision is held invalid by a court with competent jurisdiction, then such provision will be deemed to be restated to reflect as nearly as possible the original intentions of the parties, and the remainder of this Privacy Policy will remain in full force and effect. Any failure by ECCO to insist upon or enforce strict performance of any provision of the Privacy Policy or to exercise any right under the Privacy Policy will not be construed as a waiver or relinquishment of ECCO’s right to assert or rely upon any such provision or right in that or any other instance, rather, the same will be and remain in full force and effect.

15. Contact Us

We welcome your comments and questions. Please contact us at:

ECCO USA, Inc.
Attn: Privacy Policy Inquiries
16 Delta Drive
Londonderry, NH 03053
Phone: 877-240-2365
Email: ECCOUSA.Privacy@ecco.com

16. Your Privacy Rights

We respect that you according to applicable data protection regulation under certain conditions may have certain rights to object to the processing of your personal information, request from us access to and rectification and/or erasure of your personal information.

In below section 16.1 you can read more about the specific privacy rights you have if you are a California resident and in section 16.2 you can read more about the specific privacy rights you have if you are a Virginia resident.

We always respect that any consents you have given to process your personal information can be withdrawn at any time. In case you withdraw a consent, then we will cease to process your personal information, unless and to the extent the continued processing is permitted or required according to the applicable privacy regulation or other applicable laws and regulations. The withdrawal from your consent will in no event effect the lawfulness of processing based on consent before its withdrawal.

If you refrain from providing required consent, or later withdraw from the consents, it might have as a consequence that you are not able to benefit from the services based on the consent.

If you want to make use of any of your rights, then please send us your request via the points of contact listed in Section 15 above or such other mean described below.

You can unsubscribe from newsletters and de-register from accounts, in the following ways:

    a) You can withdraw from a consent to receive newsletters and similar and to unsubscribe from an e-mail list, following the instructions in any e-mail or other communication you receive from us.

    b) If you have created an account with us, then you can also manage and deleted your account by logging into the account and administer your account.

Please provide us with relevant information to take care of your request, including your full name and email address so that we can clearly identify you. We will respond to your request as soon as possible.

16.1 Your California Privacy Rights

As a resident of California, you have rights under the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations and as may be amended from time to time, “CCPA”) relevant to your Personal Information (as defined under the CCPA), as well as other laws. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.

If your Personal Information is subject to the CCPA, you may have certain privacy rights with regard to that information. You may have the right to:

  • Request that we provide you access to the following no more than twice in a 12-month period:
    • the categories and specific pieces of Personal Information that we have collected about you;
    • the categories of sources from which the Personal Information is collected;
    • the business or commercial purpose for collecting or sharing your Personal Information;
    • the categories of third parties with whom we share your Personal Information; and
    • the categories of Personal Information that are sold or shared (as defined under the CCPA) and the categories of third parties to whom the Personal Information was sold or shared.
  • Request that we delete your Personal Information, subject to exceptions under the CCPA or other applicable law;
  • Request that we correct inaccurate Personal Information about you;
  • Request that we not “sell” or “share” your Personal Information by opting out of the sale or sharing of your Personal Information; and
  • Request that we limit the use or disclosure of Sensitive Personal Information.

California residents also have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by the CCPA, as described in this section. ECCO will not discriminate against you because you have exercised any of your rights under the CCPA.

How to Submit a Request Access to or Deletion of or Correction of Your Personal Information:

If you wish to exercise your right to request access to your Personal Information; deletion of your Personal Information or correction of your Personal information, please submit your request through our toll free number: 877-240-2365 or by email: ECCOUSA.Privacy@ecco.com. To ensure we can verify your identity and help us respond to your request please provide us with your full name, email, and home address, and clearly indicate which of the rights you wish to exercise.

ECCO is required to provide you with access to your Personal Information; delete your Personal Information or correct your Personal information only in response to verifiable consumer requests. We will compare the information you have provided as part of submitting the request to any information we may have in our possession in order to verify your request. We may also contact you to request additional information in relation to your request. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Information is not disclosed to any person who does not have the right to receive it. The information collected through this process will be used only for verification purposes and responding to your request.

How to opt out of the sale or sharing of your Personal Information:

If you wish to exercise your right to request that we opt you out of the sale or share of your Personal Information, please submit your request through this webform.

Alternatively you may also exercise your right to opt out by calling our toll free number 877-240-2365 or sending us an email at ECCOUSA.Privacy@ecco.com. Please help us by providing us with your full name, email, and home address, and clearly indicate that you wish to exercise your right to opt out of the sale of your Personal Information. The information collected through this process will be used only for responding to your request.

For more information on your right to opt out of the sale or share of your Personal Information, please visit our Do Not Sell or Share My Personal Information page.

How we process Opt-put preference signals

We are not currently able to receive or honor opt-out preference signals.

How to opt in again:

If you have opted-out of the sale of your Personal Information, you are welcome to opt back in at any time. To opt-in, contact us via email at ECCOUSA.Privacy@ecco.comand clearly request to opt-in to the sale of your Personal information.

Requests made through Agents:

Please note that you may authorize an agent to exercise any of these rights. If you use an agent, we will take measures to verify your agent’s authorization to act on your behalf and we may require more information to ensure proper verification of you and your agent’s identity and authorization.

Categories of Personal Information Sold

In the previous 12 months, ECCO has not sold (as defined under the CCPA) any of your Personal information.

Categories of Personal Information Shared

For the purpose of cross-context behavioral advertising (as defined under the CCPA) ECCO may have in the previous 12 months shared as defined under the CCPA) the following categories of Personal Information: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal information has been shared with the following categories of third parties: Marketing Agencies, Data Analytics Providers and Social Media Networks.

Categories of Personal Information Disclosed for a Business Purpose

We exchange your Personal Information with Service Providers, Contractors and other third parties for business purposes, such as operational purposes and other purposes related to providing you with the products and services you seek from us. For more information about the business purposes for which we disclose Personal Information, see section 4 “How ECCO Shares Information with Service Providers and Third Parties and For What Purposes” and see section 1 “Information We Collect” for what types of information may be shared.

Use or Disclosure of Sensitive Personal Information

We do not use or disclose Sensitive Personal Information (as defined in the CCPA) for purposes other than those specified in CCPA Regulation section 7027 subsection (m).

The purposes listed in the CCPA Regulation section 7027 subsection (m) are:

    1) To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.

    2) To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.

    3) To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.

    4) To ensure the physical safety of natural persons, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.

    5) For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.

    6) To perform services on behalf of the business, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.

    7) To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.

    8) For purposes that do not infer characteristics about the consumer.

Financial Incentive Notice

We sometimes offer special price discounts, rewards, coupons, services, and other benefits to customers who: (1) sign up to receive communications from us via email, text, chat, and social media; (2) download our app; and (3) create an online account with us (collectively “programs”). For example, customers who create an account with us receive free shipping and returns on all purchases. Through these program offerings, consumers may provide us with some Personal Information (e.g., name, postal address, email address, phone number, birthday, and other similar forms of personal information) when they opt-in to our programs. There is no obligation to opt in and consumers who opt in may opt out at any time. The details of each program are contained in the program offering. We offer these programs to, among other things, enhance our relationship with customers. The value to our business, in the aggregate, of customers’ Personal Information depends on specific facts, such as the special offer provided at the time the customer signs up, whether and to what extent the customer takes advantage of any offerings, the amount purchased by the customer using that special offer, and the value of future special offers the customer receives from us and uses to make purchases.  For example, a 20% discount offer will be valued differently depending on how much the customer purchases. We do not calculate the value of the customers’ information for our accounting statements. To the extent we would, however, such valuation would be directly or reasonably related to the cost associated of acquiring or developing such information.

You may opt in to our programs by signing up in the manner invited for an individual program, either online or in stores, and you can opt out of these programs at any time by contacting a customer service representative through our toll free number: 877-240-2365, or by using the unsubscribe methods provided for that communication channel such as unsubscribe links in email messages, and replying "Stop" to text messages. We will not discriminate against you for exercising your privacy rights.

Additional California Privacy Rights

California residents may also ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. California residents may make one request per calendar year.

To make this request, you may contact us at ECCOUSA.Privacy@ecco.com. In your request, please include a subject line that states “CA Shine the Light Request”, state that you are a California resident, and provide a current California address for our response.

16.2 Your Virginia Privacy Rights

As a resident of Virginia, you have rights under the Virginia Consumer Data Privacy Act, Va. Code Ann. § 59.1-571 et seq., (with any implementing regulations and as may be amended from time to time, “VCDPA”) relevant to your Personal Data (as defined under the VCDPA). The rights described herein are subject to exemptions under the VCDPA and other limitations under applicable law.

If your Personal Data is subject to the VCDPA, you may have certain privacy rights with regard to that information. You may have the right to:

  • Request that we confirm whether we are processing your Personal Data, and provide you access to your Personal Data, which may include a request, no more than two times per calendar year, that we provide you with your Personal Data in a portable and, to the extent technically feasible, readily usable format;
  • Request that we delete your Personal Data;
  • Request that we correct inaccuracies in your Personal Data; and
  • Opt out of our processing of your Personal Data for purposes of (i) targeted advertising, (ii) the sale of your Personal Data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects that concern you.

How to Submit a Request for Access to or Deletion of or Correction of Your Personal Data:

If you wish to exercise any of your rights under the VCDPA with respect to access to or deletion or correction of your Personal Data, please submit your request through our toll free number: 877-240-2365 or by email: ECCOUSA.Privacy@ecco.com. To ensure we can verify your identity and help us respond to your request please provide us with your full name, email, and home address, and clearly indicate which of the rights you wish to exercise.

In order for us to comply with your request to exercise your rights, we may need to verify your identity. To do so, we will compare the information you provide as part of submitting the request to any information we may have in our possession. We may also contact you to request additional information in relation to your request. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Data is not disclosed to, or deleted or altered by, any person who does not have the right to do so. The information collected through this process will be used only for verification purposes and responding to your request.

How to opt out of the sale of your Personal Data and the processing of your Personal Data for targeted advertising:

If you wish to exercise your right to request that we opt you out of the sale of your Personal Information and/or processing of your Personal Data for targeted advertising, please submit your request through this webform.

Alternatively you may also exercise your right to opt out by calling our toll free number 877-240-2365 or sending us an email at ECCOUSA.Privacy@ecco.com. Please help us by providing us with your full name, email, and home address, and clearly indicate that you wish to exercise your right to opt out of the [sale of your Personal Information][and/or][processing of your Personal Data for targeted advertising]. The information collected through this process will be used only for responding to your request.

Processing of Sensitive Personal Data:

We do not process sensitive personal data (as defined in the VCDPA).

Requests made through Agents:

Please note that you may authorize an agent to exercise any of these rights. If you use an agent, we will take measures to verify your agent’s authorization to act on your behalf and we may require more information to ensure proper verification of you and your agent’s identity and authorization.

Appealing ECCO’s Declination to Take Action on a Consumer Request:

If ECCO declines to take action in response to your request to exercise your rights under the VCDPA, you may appeal that decision by our toll free number 877-240-2365 or sending us an email at ECCOUSA.Privacy@ecco.com. Please help us by providing us with your full name, email, and home address and the decision you are appealing. If your appeal is denied, you may contact the Virginia Attorney General here.

 

Copyright © 2022 ECCO USA, Inc. All rights reserved. Any rights not expressly granted herein are reserved.

 

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Privacy Policy

ECCO PRIVACY POLICY

Effective Date: 12/23/22

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE

ECCO USA, Inc. (referred to herein as “ECCO,” “we,” “us” and “our”) respects your privacy and takes our responsibility seriously.

This Privacy Policy describes how we directly and indirectly collect information in connection with your use of our websites and any other microsites or mobile websites (the “Website”), information you provide to us when you visit an ECCO owned and operated retail store (referred to as “ECCO Stores”), information in connection with your use of our mobile applications we make available for download on your personal device (our “Apps”), or information you provide to us when you visit our Facebook, Instagram, YouTube, Twitter, and other social media platforms (our “Social Media Pages”). Additionally, this Privacy Policy describes how we use and share that information. Please take the time to read this Privacy Policy.

We may revise this Privacy Policy periodically and will post any changes to the Website. Additionally, this Privacy Policy may be supplemented or amended from time to time by other “privacy notices” posted on the Website or specific pages within the Website. These privacy notices describe in more detail the information we collect on particular pages or areas of the Website. 

1. Information We Collect

The personal information we collect depends on how you interact with us. In the past 12 months we may have collected various categories of personal information about you, including:

  • Device Information:  When you visit our Website, use our Apps, interact with our Social Media Pages or online ads, or open our emails, we may learn about your browser, device type, IP address, MAC address, internet service provider, the name and version of your operating system, the name and version of your browser, the date and time of your visit, the pages you visit, and any search terms you enter while on the Website.
  • Location Data: We use various technologies to learn your geographic location, including by collecting your IP address or other device information, which may depend on your device’s settings for location services and how you interact with us.
  • Website/Apps Interactions: We collect information about your interactions with our Website and Apps, including pages visited, links clicked, buttons clicked, mouse movement, scroll behavior, and non-sensitive keystroke activity. This data may then be used to create a “session replay” of your interaction, which may be used to troubleshoot customer service issues, either individually or in the aggregate, to improve site functionality and to analyze user interaction. This information could include personal information, depending on what information you provide.
  • Contact Information: We may collect your contact information, including first and last name, address, telephone number, email address, billing address, or shipping address.
  • Payment Card Information and Payment Details: We may collect your payment card information or payment details if you make an order or add your payment details to your account with us, if any.
  • Shopping History & Transactional Data: We keep track of your shopping history with us, including the items you purchase at an ECCO Store or Website, return or exchange, or add to your shopping cart.
  • Call records, email records, text records, video, and chat logs: If you call, email, text, or chat with our customer service agents, we may keep records of those conversations including all such information you have provided to us in connection with such conversation.
  • Security camera footage: If you visit our stores or offices we may have security camera footage of you.
  • Submitted Content: We collect any content you submit to our Website, Social Media Pages, or to us in person including photos, videos, or reviews.
  • Demographic Information: We may collect demographic details about our customers such as birthdate, gender, ZIP code, Social Media information and profile data, and other similar details.
  • Social Media Usage: We receive aggregated information about people who visit and interact with our Social Media Pages.
  • Job Application Data: If you apply for a job with us, we will, in addition to the Contact Information you provide us, also collect such information as your educational background, employment history, résumé, and other information relating to your job search or application relevant for the recruitment process.
  • ECCO Account Data: If you want to register or have a registered account with ECCO, we will collect your Contact Information, passwords for the account, Demographic Information, Preferences, and Shopping History & Transactional Data.
  • Preferences: We may collect information about your preferences, such as products you may be interested in.
  • Inferences: We may draw inferences about any of the information above that may relate to your preferences, or other matters.

2. How Your Information is Collected

We may collect the information described above directly from you, from third parties we partner with, or through cookies or other automated means. These sources may include:

  • You: We collect information directly from you, whenever you: make a purchase; visit a store; contact us with questions or comments; upload content to our Website, Apps, or Social Media Pages; enter our contests, sweepstakes, or other promotions; add items to your shopping cart; create an ECCO account; respond to a survey; make a product review; opt in to text messages; apply for a job; or fill out any forms on our Website, Apps, or Social Media Pages.
  • Your Device or Browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Website, use our Apps, interact with our Social Media Pages or online advertising, or open our emails.
  • Third Parties: We work with third parties who provide services to us, like analytics or advertising companies, advertising networks, data brokers, recruitment agencies etc. These third parties may share information they have collected with us. Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy notices.
  • Service Providers and Contractors: We work with different kinds of vendors who as Service Providers or Contractors collects and processes personal information on our behalf and under our control and in accordance with our instructions.
  • Operating systems and platforms: We use different kinds of operating systems and platforms to run our business and make relevant services available. These operating systems and platforms and the use hereof may create information, which could be personal information about you.
  • Social Media Platforms: Social media platforms share information, which is typically aggregated and doesn’t include personal information, with ECCO. You can learn more about how social media platforms collect and use your information by reviewing their privacy policies and settings. If you contact us via social media platforms to make a complaint or service request, then we will collect information related to such complaint of service request from the social media platform.
  • Cookies: ECCO uses cookies (small files stored on your device or browser), pixel tags (tiny graphic images embedded in a website or email), web beacons, and other similar technologies to automatically collect information when you visit our Website, use our Apps, or interact with our emails. Through the use of cookies, we may link information about your interactions with our Website, Apps, or emails over time, for example, which pages you visit, which links you use, and how long you stay on each page. We also contract with third party advertising or analytics companies to serve you online ads on other websites. These companies use cookies or similar technologies to collect information about your interactions with our Website and Apps and interactions with other websites. These advertising companies may use and share the information gathered to deliver ads more tailored to your interests. We receive aggregate information from these third parties to understand our advertising effectiveness. Any information collected by us or by third parties through the use of cookies or similar technologies may be linked with other information we collect about you.
  • Publicly Available Data: We may combine the information you provide to us with data that is publicly available.

3. How We Use Your Information

  • Fulfillment: Fulfilling your orders and other requests, including, but not limited to, processing payments, confirming or updating you on the status of your order, delivering packages, and responding to your customer service inquiries.
  • Advertising: Presenting advertising online and via email, or other communication channels, including through partnerships with social media platforms and internet search engines.
  • Understanding our customers: Analyzing your activity with us (including your interactions with our Website, Apps, Social Media Pages, and emails or other forms of communications, analyzing trends and statistics). We keep track of the pages you visit and the manner in which you use the Website to determine what products are most popular and whether to make changes to the Website. We may, from time to time, review your information and information of other customers to help us analyze trends, purchasing patterns and preferences, and demographics.
  • Personalization: Using your preferences and other collected information to personalize your shopping experience by using your product interests, shopping patterns, and purchase information to recommend other products, services or promotions that we believe you may be interested in as well as personalizing advertising and experiences on our Website, Apps, emails, and ads.
  • Communications: Communicating with you, including responding to your requests and asking for feedback through surveys, product reviews or other messages.
  • Promotions: Running contests, sweepstakes, or other promotions.
  • Social Curation: Using Submitted Content on our Websites, Apps, Social Media Pages, and other ECCO Group owned and operated websites, apps, and social media pages.
  • Hiring: Recruiting and hiring ECCO employees. If you apply for a job with ECCO, we will be using your Job Application Data for recruiting and employment purposes. If you are hired by ECCO, the information you provide during the recruiting process will become part of our employee records. If you are not hired by ECCO, we may retain your information to allow us to contact you if another suitable employment opportunity becomes available.
  • ECCO Account: Operating the ECCO Accounts, including making certain services available, offering rewards and/or special promotions to ECCO Account members.
  • Customer Experience: Serving content on our Website, Apps, and Social Media Pages and developing our products and services.
  • Security: Protecting ECCO and our customers from fraud, security threats, and other illegal or harmful activity. We and our third party service providers may disclose specific individual information if we or they reasonably believe it is necessary to: (i) investigate any suspected misuse of a Website; (ii) protect or defend the rights, property and interests of ECCO, our customers, or the interests of our third party service providers; or (iii) under exigent circumstances, to protect the personal safety of users of a Website or the public.
  • Legal Obligations: Complying with legal and regulatory requirements and responding to requests from courts or other government bodies.

4. How We Share Information with Service Providers and Third Parties and For What Purposes

ECCO may exchange personal information with service providers, contractors and other third parties for certain purposes. For example, we share personal information with:

  • Service Providers: We partner with third parties to assist with many aspects of our business, including fulfilling orders, advertising, analyzing your interests and activity on our Website and Social Media Pages, and helping us communicate with customers. These third parties may provide services related to any of the purposes described in section 3 “How We Use Your Information,” and we may share with them any types of information described in section 1 “Information We Collect.” We may also receive information collected by these third parties and combine it with the information we have collected. Some of these third parties may be located outside the United States. Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy notices.
  • Marketing Agencies and Data Analytics Providers: We partner with third parties to assist with the advertising and marketing of our business and performing business analytics. We may share with them the types of information described in section 3 “How We Use Your Information.”
  • ECCO Affiliates: We are part of the Danish family owned “ECCO Group”, which are companies either owned and controlled by, owning or controlling, or under common ownership or control with ECCO Sko A/S with its registered address at Industrivej 5, 6261 Bredebro, Denmark. We make use of various services from ECCO Affiliates across the world in order to operate our business including but not limited to IT, finance, legal, marketing services, etc. We may disclose certain personal information for our ECCO Affiliates’ use such as, for example, Submitted Content for use on websites, apps, social media pages owned and operated by other ECCO Affiliates.
  • Other Third Parties: We will disclose information about you, including to government bodies or law enforcement agencies, when we believe it to be necessary for compliance with the law or to protect our Website and App users, our Website and App, or the public.

ECCO will not purchase consent, or sell, rent or share consent to opt-in to our mobile SMS/texting program.

If you are a California resident, you can learn more about your privacy rights below in section 16.1 “Your Californis Privacy Rights” and Opt-Out from any sale or share of your personal information through our Do Not Sell or Share My Personal Information page.

If you are a Virginia resident, you can learn more about your privacy rights below in section 16.2 “Your Virginia Privacy Rights“ and Opt-Out from any sale of your personal information the processing of your personal information for targeted advertising through our Do Not Sell or Share My Personal Information page.

5. How We Retain and Delete Your Personal Information

Your personal information will be held by us and kept in a form, which permits identification of you for no longer than is necessary for the purposes for which the personal information is collected and legitimately processed.

This implies that we will keep and process your personal information as long as we are providing services to you, interacting with you and/or consider having a relationship with you, and also afterwards for as long as would be needed for

    i) for the establishment, exercise or defence of potential legal claims and disputes.

    ii) compliance with tax, VAT, accounting and other mandatory regulation.

Thereafter, we will within reasonable time either delete your personal information or anonymise/deidentify it so that it no longer can be used to identify you.

We will also honor any statutory right you have to request your personal information to be deleted or anonymized. you can learn more about your privacy rights below in section 16 “Your Privacy Rights”.

6. Your Privacy Choices

You can control the information we collect and use in the following ways:

  • Location Data: You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Website from accessing your location information. Note that some services may not be available if you disable location-based services, and you may experience difficulties shopping online at the Website.
  • Emails: You can unsubscribe from marketing emails by clicking the unsubscribe link in the footer of such email.
  • SMS/Text Messages: You can unsubscribe from SMS/text by texting STOP to 57683.
  • Online Accounts: You can keep your contact information and payment methods accurate and up to date by logging into your account on our Website. If you wish to cancel your account, email us at eccousa@ecco.com.
  • Social Media: This privacy policy does not cover the privacy and security practices of social media platforms on which ECCO has Social Media Pages. Please review the terms, policies, and settings of those social media platforms if you have questions about how they collect and use your data.
  • Online Advertising: For information about opting out of third party advertising, visit Network Advertising Initiative’s website at https://optout.networkadvertising.org/?c=1 or Digital Advertising Alliance’s website at https://digitaladvertisingalliance.org/. You will leave this Website for a separately managed online site where you can specify your preferences. We may use more than one third party company for placing this advertising, which would require you to opt out of each company.
  • Parties to a Business Transaction: Your information may be transferred to another entity that succeeds to all or part of ECCO’s business in connection with a sale, reorganization, consolidation, or merger. Your information may be shared under obligations of confidentiality and non-disclosure to a prospective successor or purchaser of ECCO’s business.

7. Children

ECCO does not knowingly or purposefully request or collect personal information from any person under the age of 16 years old. If you believe that your child under the age of 16 has submitted personal information to ECCO in connection with our Website or Apps, please contact us at ECCOUSA.Privacy@ecco.com.

8. Security

We take steps to help protect the confidentiality and security of your personal information. Although we use measures to protect your personal information, in general, information transmitted through the Internet may not be completely secure. Accordingly, we cannot guarantee the security of information provided over the Internet or stored in our databases. Your transmissions are, therefore, at your own risk. You can protect your information by selecting strong, unique passwords for your Website account and any associated email addresses.

9. Supported Web Browsers and Do Not Track Signals

We recommend that you use the latest web browser versions to optimize your experience. Older web browser versions may not be able to access or utilize all pages on our website as intended. ECCO may not be able to receive or honor web browser “Do Not Track” signals and our Website may continue to collect information in the manner described within this privacy notice.

10. Website Terms and Conditions

This Privacy Policy constitutes an integrated part of ECCO’s Terms & Conditions, located at https://us.ecco.com/legal-pages/legal-terms-of-use.html.

11. Updates

We reserve the right to modify, alter, or otherwise update this Privacy Policy at any time, so we encourage you to review this policy from time to time. Changes to this Privacy Policy are effective at the time they are posted and your continued use of our sites after posting will constitute acceptance of, and agreement to be bound by, those changes. If we make any material changes to our privacy practices, we will update this Privacy Policy and change the effective date at the top of this page.

12. Governing Law

This Privacy Policy will be governed by and construed in accordance with the laws of the State of New Hampshire, without giving effect to its conflicts of law provisions. By accessing or using the Website, you consent and submit to the exclusive jurisdiction and venue of the state and federal courts located in New Hampshire.

13. Links to Other Websites.

This Website may, from time to time, contain links to websites owned and operated by third parties (“Third Party Sites”). We encourage you to review the privacy policies of such Third Party Sites so that you understand how those websites collect, use, and share your information. We are not responsible for the privacy policies or other content on Third Party Sites.

14. Miscellaneous

In the event that any provision of this Privacy Policy conflicts with applicable law, rule, regulation or order or if any provision is held invalid by a court with competent jurisdiction, then such provision will be deemed to be restated to reflect as nearly as possible the original intentions of the parties, and the remainder of this Privacy Policy will remain in full force and effect. Any failure by ECCO to insist upon or enforce strict performance of any provision of the Privacy Policy or to exercise any right under the Privacy Policy will not be construed as a waiver or relinquishment of ECCO’s right to assert or rely upon any such provision or right in that or any other instance, rather, the same will be and remain in full force and effect.

15. Contact Us

We welcome your comments and questions. Please contact us at:

ECCO USA, Inc.
Attn: Privacy Policy Inquiries
16 Delta Drive
Londonderry, NH 03053
Phone: 877-240-2365
Email: ECCOUSA.Privacy@ecco.com

16. Your Privacy Rights

We respect that you according to applicable data protection regulation under certain conditions may have certain rights to object to the processing of your personal information, request from us access to and rectification and/or erasure of your personal information.

In below section 16.1 you can read more about the specific privacy rights you have if you are a California resident and in section 16.2 you can read more about the specific privacy rights you have if you are a Virginia resident.

We always respect that any consents you have given to process your personal information can be withdrawn at any time. In case you withdraw a consent, then we will cease to process your personal information, unless and to the extent the continued processing is permitted or required according to the applicable privacy regulation or other applicable laws and regulations. The withdrawal from your consent will in no event effect the lawfulness of processing based on consent before its withdrawal.

If you refrain from providing required consent, or later withdraw from the consents, it might have as a consequence that you are not able to benefit from the services based on the consent.

If you want to make use of any of your rights, then please send us your request via the points of contact listed in Section 15 above or such other mean described below.

You can unsubscribe from newsletters and de-register from accounts, in the following ways:

    a) You can withdraw from a consent to receive newsletters and similar and to unsubscribe from an e-mail list, following the instructions in any e-mail or other communication you receive from us.

    b) If you have created an account with us, then you can also manage and deleted your account by logging into the account and administer your account.

Please provide us with relevant information to take care of your request, including your full name and email address so that we can clearly identify you. We will respond to your request as soon as possible.

16.1 Your California Privacy Rights

As a resident of California, you have rights under the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations and as may be amended from time to time, “CCPA”) relevant to your Personal Information (as defined under the CCPA), as well as other laws. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.

If your Personal Information is subject to the CCPA, you may have certain privacy rights with regard to that information. You may have the right to:

  • Request that we provide you access to the following no more than twice in a 12-month period:
    • the categories and specific pieces of Personal Information that we have collected about you;
    • the categories of sources from which the Personal Information is collected;
    • the business or commercial purpose for collecting or sharing your Personal Information;
    • the categories of third parties with whom we share your Personal Information; and
    • the categories of Personal Information that are sold or shared (as defined under the CCPA) and the categories of third parties to whom the Personal Information was sold or shared.
  • Request that we delete your Personal Information, subject to exceptions under the CCPA or other applicable law;
  • Request that we correct inaccurate Personal Information about you;
  • Request that we not “sell” or “share” your Personal Information by opting out of the sale or sharing of your Personal Information; and
  • Request that we limit the use or disclosure of Sensitive Personal Information.

California residents also have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by the CCPA, as described in this section. ECCO will not discriminate against you because you have exercised any of your rights under the CCPA.

How to Submit a Request Access to or Deletion of or Correction of Your Personal Information:

If you wish to exercise your right to request access to your Personal Information; deletion of your Personal Information or correction of your Personal information, please submit your request through our toll free number: 877-240-2365 or by email: ECCOUSA.Privacy@ecco.com. To ensure we can verify your identity and help us respond to your request please provide us with your full name, email, and home address, and clearly indicate which of the rights you wish to exercise.

ECCO is required to provide you with access to your Personal Information; delete your Personal Information or correct your Personal information only in response to verifiable consumer requests. We will compare the information you have provided as part of submitting the request to any information we may have in our possession in order to verify your request. We may also contact you to request additional information in relation to your request. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Information is not disclosed to any person who does not have the right to receive it. The information collected through this process will be used only for verification purposes and responding to your request.

How to opt out of the sale or sharing of your Personal Information:

If you wish to exercise your right to request that we opt you out of the sale or share of your Personal Information, please submit your request through this webform.

Alternatively you may also exercise your right to opt out by calling our toll free number 877-240-2365 or sending us an email at ECCOUSA.Privacy@ecco.com. Please help us by providing us with your full name, email, and home address, and clearly indicate that you wish to exercise your right to opt out of the sale of your Personal Information. The information collected through this process will be used only for responding to your request.

For more information on your right to opt out of the sale or share of your Personal Information, please visit our Do Not Sell or Share My Personal Information page.

How we process Opt-put preference signals

We are not currently able to receive or honor opt-out preference signals.

How to opt in again:

If you have opted-out of the sale of your Personal Information, you are welcome to opt back in at any time. To opt-in, contact us via email at ECCOUSA.Privacy@ecco.comand clearly request to opt-in to the sale of your Personal information.

Requests made through Agents:

Please note that you may authorize an agent to exercise any of these rights. If you use an agent, we will take measures to verify your agent’s authorization to act on your behalf and we may require more information to ensure proper verification of you and your agent’s identity and authorization.

Categories of Personal Information Sold

In the previous 12 months, ECCO has not sold (as defined under the CCPA) any of your Personal information.

Categories of Personal Information Shared

For the purpose of cross-context behavioral advertising (as defined under the CCPA) ECCO may have in the previous 12 months shared as defined under the CCPA) the following categories of Personal Information: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal information has been shared with the following categories of third parties: Marketing Agencies, Data Analytics Providers and Social Media Networks.

Categories of Personal Information Disclosed for a Business Purpose

We exchange your Personal Information with Service Providers, Contractors and other third parties for business purposes, such as operational purposes and other purposes related to providing you with the products and services you seek from us. For more information about the business purposes for which we disclose Personal Information, see section 4 “How ECCO Shares Information with Service Providers and Third Parties and For What Purposes” and see section 1 “Information We Collect” for what types of information may be shared.

Use or Disclosure of Sensitive Personal Information

We do not use or disclose Sensitive Personal Information (as defined in the CCPA) for purposes other than those specified in CCPA Regulation section 7027 subsection (m).

The purposes listed in the CCPA Regulation section 7027 subsection (m) are:

    1) To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.

    2) To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.

    3) To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.

    4) To ensure the physical safety of natural persons, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.

    5) For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.

    6) To perform services on behalf of the business, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.

    7) To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.

    8) For purposes that do not infer characteristics about the consumer.

Financial Incentive Notice

We sometimes offer special price discounts, rewards, coupons, services, and other benefits to customers who: (1) sign up to receive communications from us via email, text, chat, and social media; (2) download our app; and (3) create an online account with us (collectively “programs”). For example, customers who create an account with us receive free shipping and returns on all purchases. Through these program offerings, consumers may provide us with some Personal Information (e.g., name, postal address, email address, phone number, birthday, and other similar forms of personal information) when they opt-in to our programs. There is no obligation to opt in and consumers who opt in may opt out at any time. The details of each program are contained in the program offering. We offer these programs to, among other things, enhance our relationship with customers. The value to our business, in the aggregate, of customers’ Personal Information depends on specific facts, such as the special offer provided at the time the customer signs up, whether and to what extent the customer takes advantage of any offerings, the amount purchased by the customer using that special offer, and the value of future special offers the customer receives from us and uses to make purchases.  For example, a 20% discount offer will be valued differently depending on how much the customer purchases. We do not calculate the value of the customers’ information for our accounting statements. To the extent we would, however, such valuation would be directly or reasonably related to the cost associated of acquiring or developing such information.

You may opt in to our programs by signing up in the manner invited for an individual program, either online or in stores, and you can opt out of these programs at any time by contacting a customer service representative through our toll free number: 877-240-2365, or by using the unsubscribe methods provided for that communication channel such as unsubscribe links in email messages, and replying "Stop" to text messages. We will not discriminate against you for exercising your privacy rights.

Additional California Privacy Rights

California residents may also ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. California residents may make one request per calendar year.

To make this request, you may contact us at ECCOUSA.Privacy@ecco.com. In your request, please include a subject line that states “CA Shine the Light Request”, state that you are a California resident, and provide a current California address for our response.

16.2 Your Virginia Privacy Rights

As a resident of Virginia, you have rights under the Virginia Consumer Data Privacy Act, Va. Code Ann. § 59.1-571 et seq., (with any implementing regulations and as may be amended from time to time, “VCDPA”) relevant to your Personal Data (as defined under the VCDPA). The rights described herein are subject to exemptions under the VCDPA and other limitations under applicable law.

If your Personal Data is subject to the VCDPA, you may have certain privacy rights with regard to that information. You may have the right to:

  • Request that we confirm whether we are processing your Personal Data, and provide you access to your Personal Data, which may include a request, no more than two times per calendar year, that we provide you with your Personal Data in a portable and, to the extent technically feasible, readily usable format;
  • Request that we delete your Personal Data;
  • Request that we correct inaccuracies in your Personal Data; and
  • Opt out of our processing of your Personal Data for purposes of (i) targeted advertising, (ii) the sale of your Personal Data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects that concern you.

How to Submit a Request for Access to or Deletion of or Correction of Your Personal Data:

If you wish to exercise any of your rights under the VCDPA with respect to access to or deletion or correction of your Personal Data, please submit your request through our toll free number: 877-240-2365 or by email: ECCOUSA.Privacy@ecco.com. To ensure we can verify your identity and help us respond to your request please provide us with your full name, email, and home address, and clearly indicate which of the rights you wish to exercise.

In order for us to comply with your request to exercise your rights, we may need to verify your identity. To do so, we will compare the information you provide as part of submitting the request to any information we may have in our possession. We may also contact you to request additional information in relation to your request. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Data is not disclosed to, or deleted or altered by, any person who does not have the right to do so. The information collected through this process will be used only for verification purposes and responding to your request.

How to opt out of the sale of your Personal Data and the processing of your Personal Data for targeted advertising:

If you wish to exercise your right to request that we opt you out of the sale of your Personal Information and/or processing of your Personal Data for targeted advertising, please submit your request through this webform.

Alternatively you may also exercise your right to opt out by calling our toll free number 877-240-2365 or sending us an email at ECCOUSA.Privacy@ecco.com. Please help us by providing us with your full name, email, and home address, and clearly indicate that you wish to exercise your right to opt out of the [sale of your Personal Information][and/or][processing of your Personal Data for targeted advertising]. The information collected through this process will be used only for responding to your request.

Processing of Sensitive Personal Data:

We do not process sensitive personal data (as defined in the VCDPA).

Requests made through Agents:

Please note that you may authorize an agent to exercise any of these rights. If you use an agent, we will take measures to verify your agent’s authorization to act on your behalf and we may require more information to ensure proper verification of you and your agent’s identity and authorization.

Appealing ECCO’s Declination to Take Action on a Consumer Request:

If ECCO declines to take action in response to your request to exercise your rights under the VCDPA, you may appeal that decision by our toll free number 877-240-2365 or sending us an email at ECCOUSA.Privacy@ecco.com. Please help us by providing us with your full name, email, and home address and the decision you are appealing. If your appeal is denied, you may contact the Virginia Attorney General here.

 

Copyright © 2022 ECCO USA, Inc. All rights reserved. Any rights not expressly granted herein are reserved.

 

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