Hunter Boot Limited ("Hunter", "we" or "us") is the "data controller" in respect of your personal information. We take our relationship with all our users seriously, and this includes how we handle your personal information. Hunter is committed to protecting the privacy of our customers' personal information. This Policy sets out the ways we process any personal data relating to you.
1. The personal data we collect about you
Through your use of our websites and our social media channels, sometimes during visits to our stores and events, or where we communicate with you (e.g. by telephone, post, or email), we may collect and process the following information about you:
• your full name, age, date of birth and sex;
• your contact details (e.g. address, phone number and e-mail);
• where you have registered a user account with us, your user name and password;
• your communication and shopping preferences and interests;
• your browsing and shopping activities;
• feedback and survey responses;
• information about your device (e.g. IP address, operating system and browser type);
• your location;
• correspondence with us; and
• other personal information (such as suggestions, inquiries, feedback, photographs, messages or other materials) ("User Content") that you post, e-mail, share, reproduce or otherwise make available to us.
Where lawful to do so we may also obtain personal information about you from (or combine it with information from) public sources, third party service providers, individuals who have indicated you have agreed for them to provide your personal information, government authorities and other third parties. For example, if you are on another website and you opt-in to receive information from Hunter, that website may submit to us your email address and other information about you so that we may contact you as requested. You may also use a third party app or feature (such as one of our Facebook or Twitter apps) through which you allow us to collect (or the third party to share) information about you (such as details of your friends/connections, "likes", comments you have shared, groups and location). In addition, we may receive information about you if other users of a third party website give us access to their profiles and you are one of their friends/connections or information about you is otherwise accessible through your friends'/connections´ web page, profile page, or similar page.
We may supplement the information we collect about you directly with the information we receive from third parties in order to improve our products/services, to tailor our content to you and send you details of promotions and/or offers which we believe may be of interest to you.
We will indicate where any personal information we have requested is mandatory or optional. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some circumstances this may mean we are unable to provide you with a certain service or product.
2. How do we use information about you?
We may use your personal information for the following purposes:
• to process an order placed via our websites or over the telephone;
• to respond and/or deal with your request or enquiry;
• to enter you in contests and notify you of results;
• to administer our websites and social media channels and personalise content for you;
• for internal record keeping;
• to provide you with information at your request, or as a result of searches undertaken using our websites;
• to provide marketing that you have requested or agreed to receive or which we are otherwise lawfully entitled to undertake with you as a customer or prospective customer and provided you have not opted out;
• to record your marketing preferences;
• to personalise offers, promotions and advertising provided to you based on our understanding of your browsing and shopping habits or purchase history;
• to register you for certain features on our websites;
• to improve our products and services (for example to speed up your searches, recognise you when you return to our websites, respond to your feedback, respond to problems, and tailor what we do to suit your requirements further);
• in relation to User Content, on our websites, social media channels and marketing communications to promote our products, provided in each case that we have your permission;
• where necessary as part of any restructuring of Hunter or sale of Hunter's business or assets;
• management analysis, audit, forecasting, business planning and transactions, ensuring our compliance with applicable laws, regulatory requirements, and Hunter policies, and dealing with legal claims and related administrative activities and related records retention requirements; or
• to establish or exercise our legal rights and to comply with law enforcement or other government agency requests or court orders. We may also anonymise your personal data and use it for the purposes described above as part of aggregated non personal data for research, statistical and other purposes (such as improving our websites, products and services) or measuring the effectiveness of our advertising.
3. Who does Hunter share your personal data with?
We may share your personal data with third party companies (such as advertising and marketing agencies, social media agencies and platforms, software providers, and service providers such as couriers, customer services and payment services providers) for the purposes set out in this Policy including for example to complete your order, to facilitate your experience of our websites, enable offers, advertising or other promotional activity or materials about our products and services to be provided to you, to operate recognition or reward programmes, respond to your queries and / or to provide you with certain services such as aftercare services.
We may also share your personal data with:
• individuals and/or companies within the Hunter group of companies as required for management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our product and/or service offering, order or customer request fulfillment and for use by those companies for the other purposes described in this policy;
• government authorities, law enforcement and regulatory authorities where required or permitted by law and for tax or other purposes;
• parties to whom you authorise Hunter to release your personal data; and
• other entities (including actual or prospective buyers and our affiliates) in the event that Hunter is involved in a bankruptcy, merger, reorganization or sale of any of its group company businesses and/or assets.
If you give us consent then we may share your personal data with our partners or subsidiary companies in order that they can contact you with information, promotions, products, services and offers that may be of interest to you.
5. Legal Basis for processing your personal data
We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:
• Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the "unsubscribe" link at the bottom of any marketing email we send you.
• Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively as a premium manufacturer and retailer of footwear, outerwear and accessories provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example we will rely on this legal basis when we conduct certain market analysis to understand our customers in sufficient detail so we can create new services and improve the profile of our brand.
• Performance of a contract with you: For example, where you have purchased goods from our website and we need to use your contact details and payment information in order to process your order and send the goods to you.
• Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation. 6. Your rights
You have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information.
We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please contact us using the contact details below.
You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.
9. What do we do to safeguard personal data?
We have put in place safeguards to check that our internal procedures meet our high policy standards. We also use reasonable efforts to ensure that our service providers agree to protect your personal data.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website(s) and/or social media channels; any transmission is at your own risk.
Our websites are not intended for children under the age of 13 and do not knowingly collect personal information online from visitors of this age group.
10. How long will we store your personal data?
We take steps to ensure that your personal information is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised.
Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information.
11. Where do we store your personal data?
The personal information that we collect may be transferred to, and stored at, a destination outside the European Economic Area (the "EEA"), including countries, which have less strict, or no data protection laws, when compared to those in Europe.
Whenever we transfer your information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this Policy. In these cases, we rely on approved data transfer mechanisms (such as the EU "Standard Contractual Clauses" and the EU-US "Privacy Shield") to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
12. Other Websites and Services
We may offer links to third party websites and you may see our advertising on third party websites (such as social media platforms). However, we are not responsible for the information collection policies of any such third party websites. If you visit a third party website, we advise you to review their privacy and other policies before you submit any personal data to them. We do not accept any responsibility or liability for these policies.
13. Changes to this Policy
We may change this Policy at any time. Any changes to this Policy will be posted on our websites. The date this Policy was last updated appears at the bottom.
14. Contact us
If you have any questions regarding this Policy, please contact us online using the 'Contact Form' on our website or at Hunter Boot Limited, Westcott House,4 Ferrymuir, South Queensferry, Edinburgh, EH3 7HA, Scotland.
This Policy was last updated on 24th May 2018