Privacy
When you are shopping at Foot Locker in Australia or when using our Sites, you will be sharing certain personal data (“Personal Data”) with us. With this Customers Privacy Statement (“Statement”) we inform you on how we process your Personal Data.
This Statement has the following chapters:
1. Introduction
2. Who are we?
3. What Personal Data do we collect from you?
4. Why do we use your Personal Data?
5. How long do we retain your Personal Data?
6. Who do we disclose your Personal Data to?
7. Do we transfer your Personal Data outside of Australia?
8. Children’s data privacy
9. How do we protect your Personal Data?
10. Links to other sites
11. What are my rights?
12. How can I file a complaint?
13. Updates to this Privacy Statement
14. Contacts
1. Introduction
Transparency is one of the key principles of data protection legislation. With this in mind, we inform you on how your Personal Data is being processed and we promote the objective of strengthening your rights as an individual, our accountability and the lawful and fair processing of Personal Data.
This Statement contains information on how we process your Personal Data when you visit our websites and stores (“Sites” and “Stores”), sign up for our newsletters (“Newsletter”), use our mobile applications (“Apps”), register through the creation of a personal account (“Personal Account”), respond to a survey (“Customer Satisfaction Program”) and when you contact us (collectively the “Services”). This Statement applies to all Personal Data of Customers collected by Foot Locker Australia, Inc. (“Foot Locker”, “we”, “us”, “our”). You acknowledge and agree that if you do not provide sufficient or adequate information to us, we may not be able to provide you with a full range of our Services or may not be able to fully assist you with your enquiry.
Foot Locker Australia Holdings, LLC is the Data Controller responsible for Personal Data in respect of its Australian Customers.
3. What Personal Data do we collect from you?
3.1 Personal Data you share with us directly
We collect the following categories of Personal Data when you use our Services (depending on which of the Services you are using):
a. Customer personal details: full name, title/salutation, contact details, date of birth, gender, preferred language, address;
b. Interests and preferences: historical product purchases (including returns or orders cancelled), shoe and/or apparel size, interests, feedback and survey data;
c. Customer account details: customer ID, account information, choice and opt-in of Foot Locker communications (Newsletters);
d. Order information: order (tracking) number, order status and history, sales order information, invoice and shipping address, bank account information, purchase history; and
e. Communications with Customer Service.
3.2 Special categories of Personal Data
Your racial or ethnic origin may be apparent in CCTV footage taken at our stores. Otherwise, Foot Locker does not usually collect special categories of Personal Data, such as data regarding religious or philosophical beliefs, sex life or sexual orientation, health data, political opinions or trade union memberships during your use of our Services.
3.3 Personal Data we collect from you indirectly
We collect the following categories of Personal Data when you use our Services:
a. Online activity: your online interaction with us through the use of cookies, web beacons, pixel tags, log files or other similar technologies when you use our Services or interact with our emails or advertisements on our Site, our App, or other sites. For more information, please read our Cookies Statement;
b. Customer personal details: for example, name, email address, profile image, gender, date of birth, place of residence, list of friends, interests and likes. Only information you have consented to be used is shared with us. For more information, please read our Cookies Statement; and
c. Your image(s) from you when you visit our Stores to record you on video through the use Closed-Circuit Television (“CCTV”). For more information, please read our CCTV Statement.
3.4 Personal Data we receive from other sources
We receive the following Personal Data when you use our Services:
a. Customer personal details: for example, name, username, demographic information, address, contact information, interests and online activity. We obtain such Personal Data from other sources that you use to connect with us. For example, from social networks. To disable this, please adjust your privacy and advertising settings through the applicable (browser) service provider used; and
b. Online activity: your online interaction with us if you have provided your consent for the use of third party (tracking) cookies. For more information, please read our Cookies Statement.
4. Why do we use your Personal Data?
We use your collected Personal Data for the following specific purposes and categories of use:
4.1 To process and execute your order
This includes processing and delivering your order, contacting you concerning the status of your order or any other information related to your order which we have to communicate with you.
The failure to provide us the required Personal Data means that we cannot execute such contract and deliver you the purchased or requested product or service.
4.2 To provide you with customer service
We wish to answer any of your questions or requests, and we communicate with you with regard to a purchase, the use of our Services and to solve any of your possible issues in relation to the Services.
4.3 To comply with applicable laws and regulations
When you purchase products or take services from us, we are required by law to keep certain Personal Data. We may also need to process your Personal Data to comply with court orders or governmental requests.
4.4 Personal Account
When you shop at Foot Locker, you can register your Personal Data and create your own profile. Even though the registration is not required, it provides you with a quick and simple checkout experience.
4.5 Newsletter
You can subscribe for our Newsletter in order to receive future e-mails about sneaker releases, news, surveys, initiatives and events, to remind you to complete a purchase or a transaction and to send you specific content based of your preferences and interests.
4.6 Customer Satisfaction Program
When you shop you may have the possibility to participate in our survey for research program and opinion polling to develop and improve our Services obtaining your feedback. The data collected in this context is not used by us for advertising purposes. Your answers are neither passed on to third parties nor are published.
4.7 For marketing purposes to provide you with customized content, targeted offers and advertising on our Services.
We provide you with customized content, targeted offers, and advertising in order to improve your shopping experience, to provide you more relevant content and to know more about you. This may include generating tailored adds on social media like Facebook. If you are receiving marketing and promotional information from us and no longer wish to receive this information, please contact us at service@footlocker.com.au or at 1800 941 107 and ask to be removed from our mailing lists, or use the unsubscribe facilities included in our marketing communications.
4.8 To operate our business and analyze, develop and improve our Services
We maintain security of our Services. We also enable your use of our Services to administer accounts, diagnose and resolve technical and Service related problems and other internal functions. This includes analyzing trends and Site traffic and administer and optimize our Services. This is partially done via the use of internet Cookies. For more information, please read our Cookies Statement.
4.9 For litigation case management and evidentiary purposes
We may store your Personal Data if relevant for any possible future court case, legal advice and/or any other litigation and disputes.
4.10 To prevent and detect offences and to protect you, our employees and your and our property
We record how you use our Services to prevent and/or detect fraud, abuse, illegal use or violations of our policies and procedures or our general terms and conditions. This includes the use of CCTV. For more information, please read our CCTV Statement.
4.11 Or otherwise as described to you at the point of Personal Data collection
5. How long do we retain your Personal Data?
We retain your Personal Data for as long as is necessary to fulfil the relevant purposes we collected it for, as described in this Statement, unless a longer retention period is required or permitted by the applicable law.
We typically keep your personal data for no longer than is necessary to fulfil the purposes notified in this Statement in order to enable us to deal with any issues or concerns you may have about the products or services you have received, and to allow us to bring or defend legal proceedings.
If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent and combat fraud and abuse, or enforce our terms and conditions, we will also keep hold of some of your Personal Data, even if it is no longer needed to provide our Services to you.
6. Who do we disclose your Personal Data to?
We may disclose your Personal Data in the following ways:
6.1 With other Foot Locker entities that are part of the Foot Locker Group
We may share your Personal Data with entities that are part of our group organization, to the extent required for internal and administrative management or for the fulfillment of our Services and related actions and requirements.
6.2 With third party vendors
We use third party vendors for business, professional and technical support as processors. These companies only use your Personal Data on behalf of us and under our written instructions. Specifically, we use such third party vendors and their servers and services for our web platforms, storage and business related data processing. In limited circumstances these vendors might have access to your Personal Data when this is required for maintenance or problem solving.
We have data processing agreements in place with such vendors where required by law.
6.3 With a competent public authority
In order to comply with a subpoena or other legal process or obligations, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to legitimate government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.
6.4 With cardholder and credit card issuing companies and investigative, criminal or judicial authorities
In case of fraud, confirmed by the cardholder and or credit card issuing company, we will share your Personal Data with investigative, criminal or judicial authorities for fraud prevention, investigation and prosecution purposes. This includes the transfer to the specialized eCommerce prevention department of Europol. In case of governmental inquiries or requests, we share the requested Personal Data to comply with the law.
7. Do we transfer your Personal Data outside of Australia?
Some of your Personal Data that we collect may be transferred and stored in countries outside of Australia.
The laws in those countries may not provide the same level of data protection compared to the country in which you initially provided your data. When we transfer your Personal Data to recipients in other countries, we will protect that Personal Data as described in this Statement and in compliance with applicable laws.
8. Children’s data privacy
Our Services do not target children under the age of sixteen, and we do not knowingly collect their Personal Data. We will only knowingly collect and process Personal Data of children under the age of sixteen if explicit parental consent is provided. If you are concerned about your child’s data privacy, we encourage you to use web-filtering technology to supervise your child’s access to our Services.
9. How do we protect your Personal Data?
Foot Locker has implemented appropriate physical, organizational, administrative and technical security measures to protect your Personal Data against unlawful access, loss, misuse or alteration. Foot Locker uses a variety of secure techniques to protect your Personal Data, including secured servers, firewalls, and encryption of application data and of your communications via the Internet. To safeguard your transactions, we encrypt your Personal Data using encryption technology Secure Socket Layer (SSL) coding. Our systems will only be accessed by authorized staff involved in the performance in their tasks. Personal Data is only made available internally on a need to know basis and per department or even per associate if so applicable. We also have an ongoing Foot Locker privacy training program to raise awareness on privacy compliance.
10. Links to other sites
Our Services contain links to other sites and applications. We are not responsible for the privacy practices or content of such other sites or applications that are not affiliated with or maintained by Foot Locker. We recommend that you review the privacy statement posted on any external site or app that you access through our Services.
You have the right:
11.1 Of access to your Personal Data that we process about you;
11.2 To rectification of inaccurate or incomplete Personal Data;
11.3 To object to or withdraw consent to direct marketing.
To exercise any of these rights, please use the following webpage www.footlocker-emea.com/privacy. We will provide you with information on the action taken or let you know by when we will provide a response within 30 days after the successful submission of your request via this webpage.
We are required to verify your identity including, but not limited to, the verification of your email address. If you do not allow us to verify your identity, we cannot proceed to process your request.
Please note that the above-mentioned rights, with the exception of the right to object to direct marketing, are not absolute. Under certain conditions and in line with applicable data protection legislation, we may refuse a request. When such a restriction (partially) applies to your request, we will inform you on the reason of our refusal to comply with your request.
13. How can I file a complaint?
If you are unsatisfied with the way we have handled your Personal Data, please contact team by email at service@footlocker.com.au or at 1800 941 107.
The Privacy team will investigate your concerns and take any necessary steps to resolve your complaint. In so doing, Foot Locker may need to contact you if it needs further information to investigate your complaint and will advise you of the outcome of the investigation as soon as it is completed. Foot Locker will endeavor to investigate and resolve your complaint within 30 days after receiving your complaint.
If you are not satisfied with the outcome of the investigation, you can contact Foot Locker to discuss your concerns or you may complain to the Office of the Australian Information Commissioner via www.oaic.gov.au.
14. Updates to this Privacy Statement
We amend this Statement from time to time to keep the information provided up to date. We encourage you to review this Statement periodically.
Last Updated: 5 October 2021
15. Contacts
If you have any questions, concerns or complaints regarding this Statement or the processing of your Personal Data, please contact us at: service@footlocker.com.au or at 1800 941 107.