Effective date: November 30, 2019
Superfeet Worldwide, LLC, a company incorporated in the State of Washington in the United States of America and having its registered office at 1820 Scout Place, Ferndale, WA 98248 and Superfeet Worldwide UK Limited, a company registered in England and Wales with the company number 07886500, with its registered office at The Pinnacle, 170 Midsummer Boulevard, Central Milton Keynes, Buckinghamshire, MK9 1BP (together "Superfeet", "us", "we", or "our") operate the https://www.superfeet.com, https://www.superfeet.com/en-gb, https://www.superfeet.com/en-us, https://www.superfeet.com/en-ca, https://www.superfeet.com/en-eu, https://www.superfeet.com/de-us, https://www.superfeet.com/de-ca, https://www.superfeet.com/de-gb, https://www.superfeet.com/de-eu, https://www.superfeet.com/fr-us, https://www.superfeet.com/fr-ca, https://www.superfeet.com/fr-gb, and https://www.superfeet.com/fr-eu websites (hereinafter together referred to as the "Service").
We strive to protect the privacy of all personally identifiable information collected during the course of our activities and it is important for you to know how we process your data. We will process your personal information under the terms of this policy and in accordance with any agreement with you.
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices and rights you have associated with that data.
Service are the https://www.superfeet.com, https://www.superfeet.com/en-gb, https://www.superfeet.com/en-us, https://www.superfeet.com/en-ca, https://www.superfeet.com/en-eu, https://www.superfeet.com/de-us, https://www.superfeet.com/de-ca, https://www.superfeet.com/de-gb, https://www.superfeet.com/de-eu, https://www.superfeet.com/fr-us, https://www.superfeet.com/fr-ca, https://www.superfeet.com/fr-gb, and https://www.superfeet.com/fr-eu websites operated by us.
- Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
- Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small files stored on your device (computer or mobile device).
- Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
We are a "data controller" in terms under European Union and United Kingdom data protection law (including the EU General Data Protection Regulation 2016 and the Data Protection Act 2018).
- Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
- Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you and for marketing and promotional purposes.
Types of Data Collected
This list includes all the ways we may use your personal information, and which of the reasons we rely on to do so. This is where we tell you what our legitimate interests are.
Personal Information We May Process:
Our Reasons for Processing
Our Legitimate Interests
If you have purchased goods or services via our Service or if you have signed up to receive marketing and promotional materials we may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
We will obtain this information from you directly.
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Service, to improve and customise our Service.
You can enable or disable location services when you use our Service at any time by way of your device settings.
Tracking & Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
Use of Data
We use the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Who do we share your information with?
The information you provide to us may be accessed by our staff, our auditors, our professional advisors and carefully selected third parties in the course of providing goods and/or services to us under suitable obligations of confidentiality.
We may also use information in aggregate, where personally identifiable information is removed, for marketing and strategic development to improve and support our activities.
We employ administrative, electronic and physical security measures to ensure that the information that we collect about you is protected from access by unauthorised persons and protected against unlawful processing, accidental loss, destruction and damage.
Retention of Data
Our typical retention periods are as follows:
Type Of Personal Data
Personal Data collected when a Data Subject uses our Service
 years from the last time the Data Subject used the Service
Personal Data within promotional and marketing databases
 years from the date the data subject actively responded to marketing or promotional correspondence
We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. Superfeet Worldwide UK Limited may send personal data to Superfeet Worldwide, LLC, based in the USA. If and when this occurs, there will be protections in place to ensure the recipient protects the data to the same standard as the European Economic Area ("EEA"). The protections include:
- putting in place a contract with the recipient that means they must protect personal data to the same standards as the EEA; and/or
- transferring personal data to organisations in the USA that are part of Privacy Shield. This is a framework that sets privacy standards for personal data sent between the US and EEA countries which makes sure standards are similar to what is used within the EEA.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Superfeet may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Superfeet Worldwide, LLC.
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of Users of the Service or the public
- To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Our Policy on "Do Not Track" Signals under the California Online Protection Act (CCPA)
- We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
- You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
- If you are a resident of the EEA, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
- If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us by using the email address noted at the end of this policy.
In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Superfeet Worldwide, LLC. relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA.
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Such carefully selected third parties that we contract with, may send personal data to countries outside the European Economic Area (‘EEA'). If and when this occurs, there will be protections in place to ensure the recipient protects the data to the same standard as the EEA. The protections include:
- transferring to a non-EEA country with privacy laws that give the same protection as the EEA;
- putting in place a contract with the recipient that means they must protect personal data to the same standards as the EEA; and/or
- transfer personal data to organisations in the USA that are part of Privacy Shield. This is a framework that sets privacy standards for personal data sent between the US and EEA countries which makes sure standards are similar to what is used within the EEA.
We may use third-party Service Providers to monitor and analyse the use of our Service.
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processor we work with is Authorize.net. Please refer to its privacy notice if required.
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.