PP-Section3.1

This Website and our Apps uses 1st and 3rd party cookies and similar technologies to optimize your user experience, and for statistical and marketing purposes. Read more about the cookies and how you can administer and reject these in our Cookie Information available on the Website and in the App.

Below you can read more about the types of Personal Data for the different purposes that we use data for when you have consented to our placement of cookies:

Optimizing your user experience on our Website or in the App:

The Personal Data we process for this includes IP address, data on your behaviour on our Website, whether you have made a purchase and compilation of visited pages.

Sharing of data with third party advertising and analytics companies to show you ads on other websites and to understand our advertising effectiveness

We 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.

The Personal Data we process for this includes IP address, data on your behaviour on our website, whether you have made a purchase and compilation of visited pages.

General marketing research and profiling to tailor or improve our websites, Apps and our service offerings

For the purposes of performing general marketing research, we use all information collected about you, as described above in this section. We may also use information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

For the purposes of being able to personalize your store, website and/or Apps experiences, adapt the content of future Newsletters and your membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the Personal Data described above in this section and information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

Sale/Sharing of Personal Data:

We do not sell any of the Personal Data mentioned in this section. We do however share for the purposes of cross-context behavioural advertising the following categories of Personal Data: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal Data shared with the following categories of third parties: Social Media Partners and Advertising Partners. You can find our Notice of Right to Opt-out of sale/sharing at https://profile.ecco.com/CCPARequest

Please also refer to SECTION 4.1 (SALE OR SHARE OF PERSONAL DATA TO THIRD PARTIES) and SECTION 6 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section3.2

You have the opportunity to sign up to receive information by e-mail and text messages (SMS) about ECCO’s products (shoes, bags, leather goods and related accessories) services, contests and promotions from us (“Newsletters”)

We will only send you newsletters and other marketing material, if you have specifically consented to receive Newsletters from us.

Registration, checking the validity of the e-mail and providing you with relevant Newsletter

The Personal Data we process for these purposes are the mandatory information that you have provided to us when signing up for the Newsletter, such as your name and e-mail address.

Tailoring our services and offerings to you (personalizing the Newsletters sent to you)

The Personal Data we process for these purposes are the mandatory and also the non-mandatory information that you may have provided to us when signing up for the Newsletter, such as your name, e-mail address, gender and shoe size.

Tracking of Newsletters to perform general marketing research and to optimize the distribution and use of Newsletters

For these purposes, we are using tracking pixels* included in the Newsletter, which is used to collect and process Personal Data such as information on when you open the e-mail, which links in the e-mail you have clicked on and when.

*A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, we may see if and when an e-mail was opened by the recipient, and which links in the e-mail were called up by the recipient.

General marketing research and profiling to tailor or improve our websites, Apps and our service offerings

For the purposes of performing general marketing research, we use all information collected about you, as described above in this section. We may also use information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

For the purposes of being able to personalize your store, website and/or Apps experiences, adapt the content of future Newsletters and your membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the Personal Data described above in this section and information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

Sale/Sharing of Personal Data:

We do not sell any of the Personal Data mentioned in this section. We do however share for the purposes of cross-context behavioral advertising the following categories of Personal Data: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal Data shared with the following categories of third parties: Social Media Partners and Advertising Partners. You can find our Notice of Right to Opt-out of sale/sharing at https://profile.ecco.com/CCPARequest

Please also refer to SECTION 4.1 (SALE OR SHARE OF PERSONAL DATA TO THIRD PARTIES) and SECTION 6 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section3.3

If you create an ECCO membership with us, then you will be asked to provide certain basic information which we need to create and operate the account and membership programme. We may also give you the opportunity to provide us with other supplementary data than the data which we have clearly indicated as mandatory. We recommend that you keep your ECCO membership account data updated at all times.

Please be informed that newsletter consent is included in the membership creation process, therefore we will use your e-mail address or phone number to send you Newsletters. You may always unsubscribe from the Newsletter if you wish and keep your ECCO membership. Please refer to SECTION 3.2 (WHEN SIGNED UP TO NEWSLETTERS) for more details on how we process your Personal Data when signed up to Newsletters.

You can use your ECCO membership account to manage your account data and provide us with supplementary data, which will help us improve our services and offerings to you. You will also have access to certain transactional data about your recent purchases and returns. In addition, you will have access to all your membership information, including tier level, points, available rewards and any other information that relates to your personal membership profile. We may ask you for additional information periodically to improve our personalized offers and content to you.

To provide you with an increased level of security online, access to your Personal Data on certain parts of our websites and Apps may be protected with a password that you have selected. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password.

You can manage your ECCO membership account by logging into the account to administer it.

Below you can read more about the types of Personal Data and the different purposes that we use data for when you are having an ECCO membership:

To create an account for your ECCO membership and make it available to you.

The Personal Data we process for these purposes are the mandatory information that you have provided to us when you sign up for an ECCO membership account, namely your name, e-mail address, phone number and your password.

We cannot create a membership and make an account available to you unless you provide us with the mandatory information.

To provide additional services to you as part of your ECCO membership.

When having an ECCO membership we will for these purposes store, and you will have access to transactional data about your recent purchases and returns. Our ECCO stores will also have access to your membership information, including tier, points, and available rewards.

if you use the ECCO Walks feature, we will be collecting data about your walking route, including precise location data to see that you are following the chosen route, and number of steps. We will also be providing you with suggested routes and products based on your preferences and previous choices.

To provide you with push notifications to inform you about your membership, promotions, and service messages.

If you have consented to receive push messages, when using the App, we will send you push notifications to communicate with you about your orders, your walks, your membership rewards, events and promotions and to provide service messages. For the purpose of sending push notifications, we use information about your age, gender, date of birth, family information, shoe size, shipping and billing address and other demographic information or information about your interests and purchasing preferences and device information.

You can switch off push notifications at any time by going to “Settings” in your mobile device. Please be aware, that if you switch off push notifications, we may need to contact you via e-mail for important messages relating your ECCO account and purchases.

To improve our services and offerings to you.

For these purposes we may also give you the opportunity to provide us with supplementary data than the data which we have clearly indicated as mandatory for us to improve our service offerings to you. The data we may process are data about your age, gender, birth date, family information, shoe size, shipping and billing address and other demographic information or information about your interests and purchasing preferences.

It is your own choice whether you will provide such supplementary data to us.

To provide you with better services when visiting our stores

For the purpose of providing you with a better service in our ECCO Stores, the staff in these ECCO Stores will have access to the information about you, including information about your name, gender, e-mail address, phone number, transactional data, membership information and other supplementary information you have provided to us.

The store staff will only access your information, if you identify yourself to the staff either by providing your e-mail, name, or phone number, and you are not obliged to do so.

The ECCO Stores may use the data to service you, and may on our behalf register information about your visit, such as the date of the visit, details about your purchases, returns and usage of membership rewards.

General marketing research and profiling to tailor or improve our websites, Apps and our service offerings

For the purposes of performing general marketing research, we use all information collected about you, as described above in this section. We may also use information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

For the purposes of being able to personalize your store, website and/or Apps experiences, adapt the content of future Newsletters and your membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the Personal Data described above in this section and information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

Sale/Sharing of Personal Data:

We do not sell any of the Personal Data mentioned in this section. We do however share for the purposes of cross-context behavioral advertising the following categories of Personal Data: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal Data shared with the following categories of third parties: Social Media Partners and Advertising Partners. You can find our Notice of Right to Opt-out of sale/sharing at https://profile.ecco.com/CCPARequest

Please also refer to SECTION 4.1 (SALE OR SHARE OF PERSONAL DATA TO THIRD PARTIES) and SECTION 6 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section3.4

We offer you the opportunity to make purchases of ECCO products through our online shop.

Below you can read more about the types of Personal Data and the different purposes for which we use data if you make or take steps to make a purchase on this website or any of our other websites:

Completing the purchase and delivery of the purchased items to you

For the purpose of completing the purchase and delivery of the purchased items to you we will be collecting and processing the mandatory Personal Data you provide to us when making a purchase including information about your name, e-mail address, shipping address, billing address, phone number, details of the purchased items and other information necessary for these purposes.

Managing Click & Collect

If you have chosen Click & Collect, then we will for this purpose process information about your name, e-mail address, billing address, phone number and details of the purchased items and the selected ECCO Store.

Managing payments on this website

For the purpose of managing payment on this website we will be processing information about your name, e-mail address, shipping address, billing address, transactional data, IP address, phone number and other data necessary for payment processing.

For the purpose of managing payments on this website, we have integrated components of the following online payment service provider: CyberSource Corporation with its principal office at PO Box 8999, San Francisco, CA 94128 (Hereinafter referred to as the “Online Payment Service Provider”). When having selected the relevant payment method, we automatically transfer Personal Data to the Online Payment Service Provider, which is necessary for payment processing.

You will provide your credit card details directly to the Online Payment Service Provider, who will then further transfer necessary data to the relevant credit card agencies for identity and creditworthiness checks and payment clearance.

Managing vouchers, membership rewards and gift certificates

If you have received a voucher, membership reward or a gift certificate, then we will for the purpose of managing such voucher, membership reward or a gift certificate and enabling you to benefit from it, process Personal Data about you, including information about your e-mail address, name, membership status, and transaction history if necessary.

Prevention of fraud, misuse of services and money laundering

If you make an order through our online shop, we perform automated fraud checks to minimize the risk of being exposed to fraudulent behavior and the misuse of credit cards etc. The Personal Data we process for this include your name, e-mail address, shipping address, billing address, transactional data, credit card number, expiry date and security code.

We further process data about purchase behavior for automated decision-making without human intervention to determine whether there is a risk that we are exposed to fraudulent behavior and misuse of credit cards.

If we suspect fraudulent behavior, then the purchase will not be completed. In case you experience that the purchase is denied, and you want to object to this, please contact our Customer Care in accordance with SECTION 10 (OUR CONTACT DETAILS).

Managing return request and returning money

If you return any purchased items to us, then we process information about your name, e-mail address, shipping address, billing address, details of the purchased items and payment information.

General marketing research and profiling to tailor or improve our websites, Apps and our service offerings

For the purposes of performing general marketing research, we use all information collected about you, as described above in this section. We may also use information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

For the purposes of being able to personalize your store, website and/or Apps experiences, adapt the content of future Newsletters and your membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the Personal Data described above in this section and information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

Compliance with mandatory accounting regulation etc.

For the purpose of compliance with tax, VAT, accounting and other mandatory regulation we will be keeping copies of receipt and shipping documents etc. containing your Personal Data as described above in this section including your name, e-mail address, shipping address, billing address, details of the purchased items, payment details and other information necessary for these purposes.

Sale/Sharing of Personal Data:

We do not sell any of the Personal Data mentioned in this section. We do however share for the purposes of cross-context behavioural advertising the following categories of Personal Data: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal Data shared with the following categories of third parties: Social Media Partners and Advertising Partners. You can find our Notice of Right to Opt-out of sale/sharing at https://profile.ecco.com/CCPARequest

Please also refer to SECTION 4.1 (SALE OR SHARE OF PERSONAL DATA TO THIRD PARTIES) and SECTION 6 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section3.5

Below you can read more about the types of Personal Data and the different purposes that we use data for when you visit our ECCO Stores:

Electronic Receipt

We may offer to provide you with an electronic copy of your invoice by e-mail, when you make a purchase in one of our ECCO Stores. If you make use of this service, we will process your e-mail address and copy of invoice.

We will not use your e-mail to send you newsletters or other marketing material, unless you specifically have signed up to receive Newsletters.

Having an ECCO membership or signed up to receive Newsletters

In order to give you a better service in the ECCO Stores, the staff in the staff in the ECCO Stores will have access to your Personal Data, if are signed up to our Newsletters or have an ECCO membership and you identify yourself to the staff either by providing your e-mail, name or phone number. The Personal Data processed in such case include your name, e-mail address, phone number, transactional data, data of visits to ECCO stores, membership information and other supplementary information you have provided to us.

The ECCO Store may use the data to service you, and the ECCO Stores may register information about your visit, such as the date of the visit, details about your purchases and returns.

Please also refer to

SECTION 3.2 (WHEN SIGNED UP FOR NEWSLETTERS), SECTION 3.3 (WHEN HAVING AN ECCO MEMBERSHIP) and SECTION 3.9 (MARKETING RESEARCH & PROFILING).

Managing vouchers, membership rewards and gift certificates

If you have received a voucher, membership reward or a gift certificate, then we will for the purpose of managing such voucher, membership reward or gift certificate and enabling you to benefit from it, process Personal Data about you, including information about you name, e-mail address, membership status, and transactional data (if necessary).

Managing home deliveries

We may offer you to send your order to your home address. If you chose to use this service, the information we process about you include your name, e-mail address, shipping address and details of the purchased items and other information necessary for these purposes.

General marketing research and profiling to tailor or improve our websites, Apps and our service offerings

For the purposes of performing general marketing research, we use all information collected about you, as described above in this section. We may also use information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

For the purposes of being able to personalize your store, website and/or Apps experiences, adapt the content of future Newsletters and your membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the Personal Data described above in this section and information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

Sale/Sharing of Personal Data:

We do not sell any of the Personal Data mentioned in this section. We do however share for the purposes of cross-context behavioural advertising the following categories of Personal Data: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal Data shared with the following categories of third parties: Social Media Partners and Advertising Partners. You can find our Notice of Right to Opt-out of sale/sharing at https://profile.ecco.com/CCPARequest

Please also refer to SECTION 4.1 (SALE OR SHARE OF PERSONAL DATA TO THIRD PARTIES) and SECTION 6 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section3.6

You may always contact us through one of our Customer Care representatives, our online chat function (if available) or e-mail us with a claim, comment or questions.

Below you can read more about the types of Personal Data and the different purposes that we use data for if you decide to contact us through one of our Customer Care representatives, or e-mail us:

Customer care – request handling

When you contact us either through one of our Customer Care representatives, our online chat function or e-mail us with a comment or questions we will retain and use information about you in order to respond to your request, including information about your name, e-mail address, phone number, country of residence, membership information, the content of your request, further communication with you, and other information, which might be needed to manage and reply to your request. If you use our chat function we will collect and retain a transcript of the chat.

It is always optional for you what information you chose to provide us with. However, please note that in case we do not have sufficient information to process your request, then it may have as a consequence, that we will not be able to accommodate your request.

Customer care – claim handling

When you contact us either through one of our Customer Care representatives, our online chat function or e-mail us with a claim we will retain and use information in order to respond to your claim, including information about your name, e-mail address, phone number, country of residence, membership information, the content of your claim and further communication with you, and other information, which might be needed to manage and reply to your claim. If you use our chat function we will collect and retain a transcript of the chat.

If needed for establishing, exercising or defending the claim we may also request other relevant information, including health data, biometric data, other special categories of data, which might be considered sensitive Personal Data.

It is always optional for you what information you chose to provide us with. However, please note that in case we do not have sufficient information to process your claim, then it may have as a consequence, that we will not be able to accommodate your claim.

General marketing research and profiling to tailor or improve our websites, Apps and our service offerings

For the purposes of performing general marketing research, we use all information collected about you, as described above in this section. We may also use information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

For the purposes of being able to personalize your store, website and/or Apps experiences, adapt the content of future Newsletters and your membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the Personal Data described above in this section and information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

Sale/Sharing of Personal Data:

We do not sell any of the Personal Data mentioned in this section. We do however share for the purposes of cross-context behavioural advertising the following categories of Personal Data: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal Data shared with the following categories of third parties: Social Media Partners and Advertising Partners. You can find our Notice of Right to Opt-out of sale/sharing at https://profile.ecco.com/CCPARequest

Please also refer to SECTION 4.1 (SALE OR SHARE OF PERSONAL DATA TO THIRD PARTIES) and SECTION 6 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section3.7

Occasionally we may give you the opportunity to participate in competitions, make product reviews or surveys etc. If you choose to participate, then we will process Personal Data about you.

Below you can read more about the types of Personal Data and the different purposes that we use data for if you decide to participate in a competition, product review or survey:

Participating in competitions and surveys

For the purpose of participating in the competition or surveys we offer you to participate in we will collect, and process your Personal Data including your name, e-mail address, age, gender, family information, shoe size, other demographic information, membership information and Information about your interests and purchasing preferences all depending on the specific competition or survey.

It is always optional for you to participate in a competition or answering a survey and thus it is always optional what information you chose to provide us with. But please be aware that providing specific data may be mandatory and to the extent you will not provide such mandatory data you cannot participate in the competition or survey.

Conducting product or service reviews

We may from time to time ask you to provide your feedback about products or services you have acquired from us. If you participate in a product or service review, the information we collect and process include information about your name, e-mail address, age, gender, nationality, shoe size, other demographic information, data collected through your use of our websites, transactional data, information about your interests and purchasing preferences, image and video recording of you and your opinion about our products and/or services.

It is always optional for you, if you want to provide a product review and thus it is always optional what information you chose to provide us with. But please be aware that providing specific data may be mandatory and to the extent you will not provide such data you cannot provide the product or service review.

If you provide us with a product or service review, we reserve the right to share the review on social media and other websites operated by us or our ECCO affiliated companies.

General marketing research and profiling to tailor or improve our websites, Apps and our service offerings

For the purposes of performing general marketing research, we use all information collected about you, as described above in this section. We may also use information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

For the purposes of being able to personalize your store, website and/or Apps experiences, adapt the content of future Newsletters and your membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the Personal Data described above in this section and information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

Sale/Sharing of Personal Data:

We do not sell any of the Personal Data mentioned in this section. We do however share for the purposes of cross-context behavioural advertising the following categories of Personal Data: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal Data shared with the following categories of third parties: Social Media Partners and Advertising Partners. You can find our Notice of Right to Opt-out of sale/sharing at https://profile.ecco.com/CCPARequest

Please also refer to SECTION 4.1 (SALE OR SHARE OF PERSONAL DATA TO THIRD PARTIES) and SECTION 6 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section3.8

ECCO is present on and operates various social media pages on platforms like Facebook, TikTok and Instagram. We use the social media pages to communicate with you and provide you with information related to ECCO, our products and services and promotional updates. We may receive information from you through your comments, shared images, messages, and reactions, which we use to answer or communicate with you.

If you use a hashtag that includes ECCO, our product names or other information that we search for, we may also use your information to reach out to you, communicate with you and, subject to your consent, use your user generated content on our Website and/or Social Media pages.

Below you can read more about the types of Personal Data and the different purposes that we use for processing data on social media:

When visiting our social media sites or when you are engaging with us via social media sites

We obtain information about you through different social media channels such as Facebook, Instagram, TikTok, Google, etc. when we use these channels for advertising, analytics purposes or to enrich your profile with ECCO.

The Personal Data we process for this about you include any social media information that is publicly available such as your social media handles, social media interactions and public postings, your “Likes” and other reactions, your social media connections, your photos that are public, or those you send to us by mentioning us or following our social media posts by using “handles” or “hashtags”, and comments or messages you shared with us publicly or privately on social media platforms.

Also, we may be able to obtain information indirectly from social media companies (Facebook, Google, etc.) when we advertise on these platforms. The Personal Data we process for this include your participation and membership on particular topics and/or groups, your profile settings and preference and your behaviour on different platforms owned by the same company.

When we use your user-generated content in marketing of our products

From time to time we invite you to provide your images to us via social media platforms by following specific instructions on the use of hashtags. We will be using the images you provide for our campaign communications. We will obtain rights to your image through a licence agreement in the form of our terms and conditions.

By submitting your images via social media platforms to us, you will agree for us to use your images as described in the licence agreement. The Personal Data we process for this include information about your social media handle, images, videos, comments, sound recordings and other files provided through the social media platform promoting ECCO and social media interaction and activity.

Advertisement via Social Media

We use third-party advertising platforms, such as Facebook, TikTok, Google, YouTube, Instagram, etc. to send you messages that are targeted at you, based on your behaviour and browsing pattern, at specific times and locations of these platforms to increase the efficiency of our advertising campaigns.

In order to do this, we share your Personal Data with our advertising agency partners as well as Social Media Platforms. We use third-party solutions such as Google Analytics and Facebook Business Manager tools to help us do a better job at targeting our campaigns and messages for our consumers.

Social Media Platforms will attempt to match your profile in their database to determine the optimal time and place (the page you are browsing) to show you an advertisement from ECCO. We also need to analyse necessary information to understand the impact of our campaigns.

If you don’t accept that we track you for this purpose, you will still see ECCO advertisements on Social Media Platforms and other third-party platforms at random. Please also read the privacy notice on the Social Media Platforms to understand how your Personal Data is used by them for this purpose.

You can learn more about how our advertising partners and social media platforms help us achieve this purpose by visiting their sites:

Google Personalised Advertising: https://support.google.com/adspolicy/answer/143465?hl=en

Google Advertising Policies: https://support.google.com/adspolicy/answer/6020956

Facebook Lookalike Audiences: https://www.facebook.com/business/help/164749007013531

Facebook Custom Audience Terms: https://www.facebook.com/legal/terms/customaudience

TikTok Advanced Matching Terms: https://ads.tiktok.com/i18n/official/policy/business-products-terms

Pinterest Analytics term: https://help.pinterest.com/en/business/article/pinterest-analytics

General marketing research and profiling to tailor or improve our websites, Apps and our service offerings

For the purposes of performing general marketing research, we use all information collected about you, as described above in this section. We may also use information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

For the purposes of being able to personalize your store, website and/or Apps experiences, adapt the content of future Newsletters and your membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the Personal Data described above in this section and information collected about you through other channels as described in SECTION 3.9 (MARKETING RESEARCH & PROFILING).

Sale/Sharing of Personal Data:

We do not sell any of the Personal Data mentioned in this section. We do however share for the purposes of cross-context behavioural advertising the following categories of Personal Data: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal Data shared with the following categories of third parties: Social Media Partners and Advertising Partners. You can find our Notice of Right to Opt-out of sale/sharing at https://profile.ecco.com/CCPARequest

Please also refer to SECTION 4.1 (SALE OR SHARE OF PERSONAL DATA TO THIRD PARTIES) and SECTION 6 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section3.9

In ECCO we want to better understand our customers to ensure we provide an experience that is relevant and to ensure effective marketing and advertisement of ECCO product and services. To better understand our customers, to improve and develop our business, products and services and to personalise the experience of our Newsletters, Website and Apps, we use the Personal Data we are in possession of to analyze and/or predict aspects concerning our individual customers’, newsletter recipients’, members’ and app users and website visitors’ (generally referred to as our “customers”) personal preferences, interests, behaviour etc. and to perform general marketing research incl. customer analysis and customer segmentation and statistics.

Below you can read more about the types of Personal Data and the different purposes that we use data for when profiling and building inferences of our customers etc. performing general marketing research incl. customer analysis and customer segmentation and statistics:

General marketing research incl. customer analysis and customer segmentation and statistics

The Personal Data we process for general marketing research include information about your name, e-mail address, phone number, data collected through the use of our websites, newsletter-tracking data, membership information, addresses, information from you concerning demographics, interests and preferences (e.g. gender, birth date, shoe size, family situation, product preferences etc.), online and offline transactional data incl. abandoned shopping baskets, returns and Customer Care interactions.

We use your data for different analytical purposes to better understand: a) how you browse and use our platforms; b) which products you are interested in; c) which features of our products and platforms you like; d) the quality of our services including customer service, marketing and advertising campaigns addressed to you, and your reaction to these services; e) our product and website design; f) whether overall user experience worked for you or not; and g) which rewards you most commonly redeem in ECCO’s membership programme. We use this analysis to understand and improve and develop our marketing and merchandising approach and efforts and the quality of our personalisation experience across our channels and platforms.

Personalize your shopping and website experiences and optimizing the service you receive

Furthermore, we may use the information mentioned above to evaluate and assess your individual interests and preferences in order to personalize your shopping, website and Apps experiences, membership experiences and rewards and optimizing the service you receive from us.

Customizing newsletter content and special offers

If you have signed up to receive Newsletters, then we will also use your Personal Data in order to adapt the content of Newsletters to better suit your interests and to provide you with personalized offerings.

Audience Management

We create a profile about you by consolidating all the information you provided to us directly or indirectly. This allows us to personalise our interaction with you. We use audience management technologies to ensure the right messages and information reach you at the appropriate moment through the channels you have previously used or expressed a preference for. This includes sending you marketing messages of offers, products and news or addressing you across digital media through ads on ECCO branded platforms. The level of personalisation depends on the consents you have provided to u and the length and nature of our relationship with you.

Improve data models

We use data science and your profile and Personal Data to create data models that can help us improve the logic in our analytics activities that give us more insight about your comments and feedback, your interactions, preference and needs in our products and services. We will compare the data model we created using your profile with other similar consumer profiles and categories to further predict and analyse your preference.

Sale/Sharing of Personal Data:

We do not sell any of the Personal Data mentioned in this section. We do however share for the purposes of cross-context behavioral advertising the following categories of Personal Data: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal Data shared with the following categories of third parties: Social Media Partners and Advertising Partners. You can find our Notice of Right to Opt-out of sale/sharing at https://profile.ecco.com/CCPARequest

Please also refer to SECTION 4.1 (SALE OR SHARE OF PERSONAL DATA TO THIRD PARTIES) and SECTION 6 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section3.10

When entering the ECCO website and Apps and to the extent your cookie permissions allows us and our third parties to place relevant cookies on your device, we will be using cookies and similar technologies to track your activities on our website and use your information to target advertising to you across different channels and devices (also known as “cross-context behavioral advertising”). Please also refer to SECTION 3.1 (WHEN YOU VISIT OUR WEBSITE OR APPS).

Besides cookie technology and information processed by use hereof, we might also process other Personal Data we have about you for online marketing and re-targeting purposes.

The Personal Data we process about you for online marketing and re-targeting include information about your e-mail address, data collected through the use of our websites, Newsletter-Tracking Data, Facebook profile information, Google account information, information from you concerning demographics, interests and preferences (e.g. gender, birth date, shoe size, family situation, product preferences etc.), membership information and transactional data incl. abandoned shopping baskets, returns and Customer Care interactions and your profile inferred through this information cf. SECTION 3.9 (MARKETING RESEARCH & PROFILING).

Sale/Sharing of Personal Data:

We do not sell any of the Personal Data mentioned in this section. We do however share for the purposes of cross-context behavioural advertising the following categories of Personal Data: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal Data shared with the following categories of third parties: Social Media Partners and Advertising Partners. You can find our Notice of Right to Opt-out of sale/sharing at https://profile.ecco.com/CCPARequest

Please also refer to SECTION 4.1 (SALE OR SHARE OF PERSONAL DATA TO THIRD PARTIES) and SECTION 6 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section3.11

If you apply for a position we will collect and use Personal Data about you for the purpose of managing our recruitment process, which includes processing your application, assessing your qualifications for positions within ECCO and eventually offering you a contract, if we would like to hire you etc.

The Categories of Personal Data we collect and use include:

• Audio/Visual data, which might include Personal Data contained in pictures, videos and voice recordings

• Contact Information, which might include Personal Data revealing an individual's contact details, names, e-mail addresses, phone numbers, private addresses

• Demographic information and preferences, which might include Personal Data revealing an individuals preferences, demographic characteristics, and similar including but not limited to age, date of birth, citizenship, gender, nationality, language preferences, VISA and Work Permits

• Education, Skills and CV data, which might include Personal Data revealing an individuals educational and professional skills and background incl but not limited to background checks, diplomas, education & trainings, former employments, professional memberships, qualifications & certifications, skills, curriculum vitae

• Employment Information, which might include Personal Data revealing details of an individuals past employment relationship with ECCO incl but not limited to appraisals benefits and entitlements, titles, organizational data, corporate credit card numbers, employment start/end dates, employment history, grievances and complaints, working time, absence records, salary, wages, secondments, suspension and garden leave, warnings & disciplinary sanctions, application details, performance ratings, employee ID, termination reasons, work accidents, workers compensation claims.

• Family Information, which might include Personal Data revealing details of an individual’s family relationships incl but not limited to marital status, emergency contact details, partner’s name, children’s names and age

• Government Identifiers, which might include Personal Data vested in an individual’s official ID numbers issued by governmental bodies, including but not limited to fx social security No., Passport No., Drivers License No. etc.

• Other Identifiers, which might include Personal Data vested in other unique ID numbers than “Government identifiers” and Digital Footprints which can be used to identify an individual incl but not limited to Employee ID number

• Profiling & inferences, which might include Personal Data derived from automated processing of Personal Data used to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individuals performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. This include but is not limited to data derived from the psychometric tools used by us

• Social Media data, which might include Personal Data related to individual’s activities and information on social media

• User Generated Content (UGC), which might include Personal Data revealed in content generated by an individual

• Criminal records

• Sensitive Personal Data such as

  • social security, driver’s license, state identification card, or passport number,

  • information concerning health

The purposes for which we collect and use the Personal Data include

• recruitment and staffing

• company administration

• organizational development

• business development

• crime prevention, detection and investigation

• internal communication

• external communication

• compliance with legal obligations

• establishing, exercising and/or defending legal claims.

Sale/Sharing of Personal Data:

We do not sell or share any of the Personal Data mentioned in this section as defined under the CCPA (as amended) or any other applicable data protection regulation.

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section3.12

If you are employed by us or an affiliate we will collect and use you Personal Data part of our HR management and operations, payroll and finance administration, health & safety administration, IT security & IT operations, Internal communication etc.

The Categories of Personal Data we collect and use include:

• Audio/Visual data, which might include Personal Data contained in pictures, videos and voice recordings

• Contact Information, which might include Personal Data revealing an individuals contact details, names, private and work related e-mail addresses, phone numbers, private addresses

• Demographic information and preferences, which might include Personal Data revealing an individuals preferences, demographic characteristics and similar including but not limited to age, date of birth, citizenship, gender, nationality, language preferences, VISA and Work Permits

• Digital footprints (incl. Browsing information and geolocation data), which might include Personal Data related to an individuals digital activities including browsing information, cookie information, application use, logs etc.

• Education, Skills and CV data, which might include Personal Data revealing an individuals educational and professional skills and background incl but not limited to background checks, diplomas, education & trainings, former employments, professional memberships, qualifications & certifications, skills, curriculum vitae

• Employment Information, which might include Personal Data revealing details of an individuals employment relationship with ECCO incl but not limited to appraisals benefits and entitlements, titles, organizational data, corporate credit card numbers, employment start/end dates, employment history, grievances and complaints, working time, absence records, salary, wages, secondments, suspension and garden leave, warnings & disciplinary sanctions, application details, performance ratings, employee ID, termination reasons, work accidents, workers compensation claims.

• Family Information, which might include Personal Data revealing details of an individual’s family relationships incl but not limited to marital status, emergency contact details, partner’s name, children’s names and age

• Financial Information, which might include Personal Data revealing details of an individual’s financial information incl. but not limited to bank account number, remuneration, travel & expense details, company credit card info, insurance info, pension info, social security info, tax information, retirement info etc.

• Government Identifiers, which might include Personal Data vested in an individual’s official ID numbers issued by governmental bodies, including but not limited to fx social security No., Passport No., Drivers License No. etc.

• Other Identifiers, which might include Personal Data vested in other unique ID numbers than “Government identifiers” and Digital Footprints which can be used to identify an individual incl but not limited to Employee ID number

• Profiling & inferences, which might include Personal Data derived from automated processing of Personal Data used to evaluate certain personal aspects relating to an individual, in particular to analyze or predict aspects concerning that individuals performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements. This include but is not limited to data derived from the psychometric tools used by us

• Sales and Transactional data, which might include Personal Data revealing details of an individual’s sales/purchase activities and other transactional information

• Social Media data, which might include Personal Data related to individual’s activities and information on social media

• Survey and training data, which might include Personal Data tied with an individual’s responses in surveys and trainings etc.

• User Account Information, which might include Personal Data revailing an individuals user accounts incl. but not limited to fx log in details, passwords, usage history etc.

• User Generated Content (UGC), which might include Personal Data revealed in content generated by an individual

• Criminal records and background checks

• Sensitive Personal Data such as

  • social security, driver’s license, state identification card, or passport number,

  • Account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account

  • precise geolocation,

  • racial or ethnic origin, religious or philosophical beliefs, or union membership,

  • information concerning health and sex life or sexual orientation.

The Purposes for which we collect and use the Personal Data include

• recruitment and staffing

• personnel administration

• time & attendance management

• performance management

• training, development and talent management

• succession and contingency planning

• VISA and work permit administration

• company administration

• organizational development

• business development

• payroll administration

• pension administration

• insurance administration

• benefits administration

• health & safety administration

• work accident management

• social security administration

• IT security

• IT access management

• IT operations

• IT incident management

• facility access managing

• property and facility management

• physical security

• crime prevention, detection and investigation

• internal communication

• external communication

• business cooperation

• employee branding

• historical archiving

• finance & accounting

• tax & VAT administration

• compliance with contractual obligations

• compliance with legal obligations

• protecting the vital interests of the Employee or any other natural person

• establishing, exercising and/or defending legal claims.

Sale/Sharing of Personal Data:

We do not sell or share any of the Personal Data mentioned in this section as defined under the CCPA (as amended) or any other applicable data protection regulation.

Retention of Personal Data:

Your Personal Data will be retained 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 Data is collected and legitimately processed as explained above. This implies that we will keep and process your Personal Data as long as we are providing services to you, interacting with you, have or consider having a relationship with you. We may retain your Personal Data for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your Personal Data in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your Personal Data, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Data; and applicable legal requirements.

PP-Section4.1

1. Sale of Personal Data:

We do not sell any of your Personal Data

2. Sharing of Personal Data for cross-context behavioral advertising

For the purposes of cross-context behavioral advertising, we have in the preceding 12 months shared and might in the future share the following categories of Personal Data: device information, location data, website interactions, transactional data, social media usage, and profile information. The Personal Data has been and might also in the future shared to the following categories of third parties: Social Media Partners and Advertising Partners.

Below you can read more about how the third parties we cooperate with processes your Personal Data:

Facebook (Meta): You can read more about how Facebook processes your Personal Data in their Data Policy at https://www.facebook.com/about/privacy.

Google: You can read more about how Google uses information shared with them here: https://policies.google.com/technologies/partner-sites

TikTok: You can read more about how TikTok uses information shared with them here: https://www.tiktok.com/legal/privacy-policy-eea?lang=en.

Instagram: You can read more about how Instagram uses information shared with them here: https://privacycenter.instagram.com/policy.

Pinterest: You can read more about how Pinterest uses information shared with them here: https://policy.pinterest.com/en/privacy-policy.

Rakuten: You can read more about how Rakuten uses information shared with them here: https://www.rakuten.com/help/article/privacy-policy-and-notice-of-personal-information-collection-360002101688#5

Criteo: You can read more about how Criteo uses information shared with them here: https://www.criteo.com/privacy/

We do not have actual knowledge that ECCO sells or shares the Personal Data of persons under 16 years of age.

PP-Section4.2

For the purposes of payment transactions we might in the preceding 12 months have disclosed and might in the future disclose the following categories of Personal Data: name, e-mail address, shipping address, billing address, transactional data, IP address, phone number, payment method. The Personal Data has been and might also in the future be disclosed to the following categories of third parties: payment service providers

For the purposes of shipping orders we might in the preceding 12 months have disclosed and might in the future disclose the following categories of Personal Data: name, e-mail address, shipping address, phone number. The Personal Data has been and might also in the future be disclosed to the following categories of third parties: logistic service providers.

PP-Section4.3

We may also disclose your Personal Data to our trusted external service providers and contractors, who according to a written contract complying with applicable privacy regulation processes your Personal Data on our behalf and under our instructions in order to provide us with services related to operating, maintaining, and/or supporting our IT systems and IT infrastructure, our websites, perform statistical analysis, sending newsletters, provide customer support and perform other important services for us.

We may also disclose your Personal Data to ECCO Sko A/S with its registered address at Industrivej 5, 6261 Bredebro, Denmark and other companies, which are owned or controlled by ECCO Sko A/S or owns or controls ECCO Sko A/S (“ECCO Affiliates”) in order for them to provide us with relevant services.

PP-Section4.4

A transfer of your Personal Data to another legal entity may occur as part of a transfer of our business or parts thereof in form of a reorganization, sale of assets, consolidation, merger or similar.

In addition to above Personal Data may also be disclosed in special situations, where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities, or otherwise where necessary for the establishment, exercise or defence of legal claims.

PP-Section4.5

The processing of your Personal Data might imply a transfer of your Personal Data outside the country/state your are residing in, which include but is not limited to countries within European Economic Area, UK, the United States, Canada, China, Hong Kong, Macau, Taiwan, Vietnam, Singapore, Thailand, Malaysia, Japan, South Korea, Russia, UAE, Turkey, Indonesia, India, Australia and New Zealand.

We do our outmost to require that all recipients of your Personal Data provide appropriate safeguards to protect your Personal Data.

PP-Section6.1

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 Data/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, selling or sharing your Personal Information;

  • the categories of third parties to whom we disclose 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.

  • The specific pieces of Personal Information we have collected about you.

• Request that we delete your Personal Information, subject to exceptions under the CCPA or other applicable law; and

• 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.

• Request that we limit the use or disclose 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, 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.

Categories of Personal Information Disclosed for a Business Purpose

We disclose your Personal Information to 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 WE DISCLOSE YOUR PERSONAL DATA TO OTHERS) and see SECTION 1 (CATEGORIES OF PERSONAL DATA WE COLLECT) for what types of information may be disclosed.

Sale and/or Sharing of Personal Information

We have in the preceding 12 months not sold but we have shared (as defined under the CCPA) Personal Information. For more details, please refer to SECTION 4.1 (SALE OR SHARE OF PERSONAL DATA TO THIRD PARTIES)

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 or share 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-out preference signals

A “do-not-track” signal is a privacy preference feature in some web browsers that tells a website that a user does not want their online activity to be tracked. We currently support Global Privacy Control (GPC), a specification designed to allow internet users to notify businesses of their privacy preferences, such as whether they want to have their Personal Data sold or shared with third parties for purposes of targeted advertising. It consists of a setting or extension in the user’s browser or mobile device and acts as a mechanism that websites can use to honor the user’s privacy settings. If you would like to use GPC, you can download and enable it via a participating browser or browser extension. If your browser has enabled GPC, it will override any cookie preferences selected in our Website’s cookie management console.

How to opt-in again:

If you have opted out of the sale or share 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.com and clearly request to opt-in to the sale or share 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.

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, non-personalized 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.

Notice of Financial Incentive

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 Apps; and (3) create an ECCO membership 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 with 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.