Effective Date: September 1, 2021
Information We Collect About You
The types of information we collect about you depends on your use of the Site, our App and the ways that you interact with us. For example, you may provide some of this information to us directly when you use or visit our Site, subscribe to a mailing list, sign up for a user account on the Site and/or App or contact us through our Site and/or App.
Information You Provide to Us
We may collect information that you choose to provide using the Site and/or App. For example, when you:
1. register for one of our mailing lists or contact us through the Site. This information may include your name, address and/or telephone number;
2. use our foot-scan application to order products;
3. purchase one of our products through our Site and/or App or through a third-party payment provider. This information may include your name, address, telephone number, email address and/or credit card information; and
4. sign up for a user account on our Site and/or App. This information may include your name, address, telephone number and/or e-mail address.
Automated Data Collection
Information regarding your use of the Site and/or App may be collected automatically. This automatically collected information may include:
1. your IP address, your browser-type and the type of operating system you use;
2. your feature usage data using the Site, the pages you visit on the Site, the time and date you access the Site, the time you spend on portions of the Site and if you linked from another website, the address of the linked website; and
3. your ISP or mobile carrier, and the type of handheld or mobile device that you used.
Summary of Personal Information We Collect
A detailed summary of the types of personal information that we may collect about you, and the reasons why we process it, include:
Type of Personal Data Reason Purpose
Password Enabling you to create your account
Login ID Managing your account and personal preferences
Order History Processing and shipping your orders Contractual necessity
Shipping address Enabling you to access your order history
Delivery preferences Your customer service needs
Order History Documenting transactions you made on our Site and/or App. Legitimate interests to protect our business and legal rights
Email address Providing you with exclusive email updates, promotions, and Your consent (unless a legal exception applies)
notifications including information about our products
Name Processing and responding to any inquiry that you may. Contractual necessity
address to us
Your inquiry and your inquiry history
Order History Fraud prevention Legal obligation(s)
Account details Administering and maintaining our Site and/or App Legitimate interest to offer, maintain and improve our Site and/or App or products
IP address Data analytics, statistics and audience measurement Legitimate interest to understand how our Site and/or App is used and to help us customize and improve our Site and/or App
Pages visited on Site and/or App
“Cookies” are small alphanumeric identifiers sent from a web server that are stored on your device for the purpose of identifying your browser or storing information or settings in your browser. “Local shared objects,” sometimes known as Flash cookies or Flash LSOs, are used to store your website preferences and to personalize your visit to the Site and/or App. Flash LSOs are distinct from browser cookies because of the amount and type of data stored. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, are tiny graphics with a unique identifier, similar in function to cookies. Web beacons are embedded invisibly on web and application pages. We may use web beacons in connection with our Site and/or App to, among other things, track the activities of visitors and application users, help us manage content, and compile statistics about usage, and link web pages to web servers and their cookies.
One or more of these technologies may be used on the Site and/or App, or by third parties in accordance with their own privacy policies to transmit information to you or about you and connect information about you from different sources, websites, devices, and mobile applications.
You may refuse to accept cookies by activating the setting on your browser that allows you to refuse the setting of cookies. You can find information on various browsers and how to adjust cookie preferences in your browser settings at the following websites:
Microsoft Internet Explorer
We do not combine the information collected using Google Analytics with personally identifiable information. Google may transfer certain information it collects to third parties if required to do so by law or where such third parties process such data on behalf of Google. Google provides that they will never combine your IP address with other data Google may hold.
Third Party Sources of Information
We may collect information from third parties, such as third-party websites you may use to purchase our products. We may add information that you provide to us with information we receive from other sources, as well as with other information that is automatically collected. The combined information may include information about your use of the Site, App and/or your use of a third-party website or service to purchase our products.
How We Use Your Information and What We Use Your Information For
We may use the information we collect to:
1. operate our business, including the management of customer information;
2. provide customer and technical support;
3. communicate with you about your purchase. For example, we may contact you to discuss your account, to remind you about features of the Site and/or App that are available for your use or to update you about a support request;
4. ship and deliver your purchase;
5. perform data analytics and trend analysis;
6. evaluate and improve our business, including developing new products and analyzing the effectiveness of existing products, Site and/or App;
7. improve our advertising, mainly to prevent targeting you with irrelevant advertisements;
8. to send you periodic emails. Depending on the marketing preferences you choose we may send you occasional marketing emails about our products, Site and/or App, which you can unsubscribe from at any time using the link provided in the e-mail; and
We may also combine information that we have about you. For example:
• Information we obtain through automated means with information you provide to us; and
• Information we may receive from a third-party service provider with information we have collected from you.
We do not sell or otherwise share information about you that we collect or receive with third parties, except as described below:
1. we may share information if we believe we are required to do so to establish, exercise or defend our legal rights or for the purpose of investigating suspected or actual illegal activity or fraud. For example, we may share information in response to a subpoena, court order or in response to requests by a government agency or investigatory body.
2. we may share information with any successor to all or part of our business. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation); and
3. We may engage third party service providers to provide their services in connection with the Site and/or App so you can receive the products and services you require. We require such providers to maintain information about you as confidential and to use the information only to perform the services specified by us in a manner consistent with their privacy policies.
We may, however, use and share aggregated non-personal information with third parties for marketing, advertising, and analytics purposes. We may collect the following categories of your personal information for business and operational purposes, such as data security, product improvement, customer service, debugging, fulfillment, marketing, analytics, and servicing and maintaining accounts:
• Commercial information;
• Online activities;
• Geolocation data;
• Records of your interactions with us;
• Demographics; and
How We Protect Your Information
We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Despite these protective measures, we cannot guarantee perfect security of networks, servers and databases we operate or that are operated on our behalf. For example, we implement a series of security measures to maintain the safety of your personal information when you enter or submit this information to us such as the use secure servers for information storage. Further, information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our gateway provider’s database. Once encrypted and stored in the database, stored information may only be accessed by those with special access rights to such system. Additional examples of our security measures include:
• Ensuring business continuity by encrypted daily backups of our data stored in multiple different locations;
• Conducting regular penetration testing to identify and address potential vulnerabilities; and
• Maintaining logical access controls by allowing only designated, authorized operations team members to access certain information and to configure infrastructure.
Where We Store and Process Information
European Union Residents & Your Rights When You Make Your Data Available to Us
If you are a resident of the European Union, have the following data protection rights under the EU General Data Protection Regulation or GDPR:
1. If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the details provided under the “Contact Us” heading below.
2. In certain circumstances, as explained in the applicable data protection legislation, you can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. You can exercise these rights by contacting us using the “Contact Us” details below.
3. If you gave us consent to collect and process your personal information, then you can withdraw your consent at any time. Withdrawing your consent will not impact the legality of any processing we may have conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted on other lawful processing grounds.
4. You have the right to opt-out of marketing communications we send you at any time. You may unsubscribe from our newsletters or marketing email notifications at any time by clicking the unsubscribe link at the bottom of each email.
5. For any complaints or concern about how we are processing your personal information, we will make reasonable efforts to address these concern(s). If you believe we have not sufficiently addressed your complaint or concern, you have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain countries are available: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
We will respond to all requests related to the exercise of your data protection rights in accordance with applicable data protection laws.
If you are a resident of the EU and you have any comments, questions or concerns about our use of your personal information or you would like to exercise any of your rights described above, please contact us at: email@example.com.
International Transfers of Data Outside the EU
Linking to Other Websites
The Site and/or App may contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies, and we urge you to review them. The privacy policies of these linked websites will govern the use of your information that you may submit while visiting these websites. We do not accept any responsibility or liability for the privacy practices of any third party websites and your use of such websites is at your own risk.
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Notice to California Residents
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. Below is a description of your CCPA rights and an explanation of how to exercise those rights:
Access to Specific Information
California residents have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once you submit and we confirm your verifiable consumer request, we will relay to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• The business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
California Civil Code Section 1798.83 entitles California users to request information concerning whether a business has disclosed certain information about you to any third parties for the third parties’ direct marketing purposes. If we have disclosed your personal data to any third parties for a business purpose over the past 12 months, we will identify the categories of personal data shared with each category of third-party recipient. California users who wish to request further information in compliance with this law or have questions or concerns about our privacy practices may contact us at firstname.lastname@example.org.
California residents have the right to request that we delete any of your personal information that we collected about you and retained, subject to certain exceptions in the CCPA. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies, and we will direct our service providers to similarly delete your personal information from their records.
Right to Opt-Out of Sales
California residents have the right to opt-out of our sale of your personal information. In this section, we use the term ‘sell’ as it is defined under the CCPA. We do not sell your personal information.
Verifiable Consumer Request: How to Exercise Your Rights
To exercise the access, data portability, and deletion rights described above, please submit a “verifiable consumer request” (defined below) to us by either:
• Calling us at [INSERT A PHONE NUMBER]; or
• E-mailing your verifiable consumer request to email@example.com.
Only you or someone you authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
A verifiable consumer request must:
• Provide enough information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
• Describe your request with enough detail that allows us to properly understand, evaluate, and respond to it; and
• State under the penalty of perjury, that you are exercising your rights under the CCPA as a California resident solely for lawful purposes, and in a way that does not and would not unduly burden or otherwise abuse our data request system.
You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. We will not be able to respond to your request or provide you with your personal information if we cannot verify your identity or ability to make the request and confirm the personal information that you are requesting relates to you. Sending a verifiable consumer request does not require you to create a user account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity and/or ability to make the request.
We will not discriminate against you for exercising any of your CCPA rights. We will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, provide you a different level or quality of goods or services, or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
How to Contact Us
For customer or technical support questions, please contact us at firstname.lastname@example.org.
For privacy-related questions, please contact us at email@example.com.
Last Updated: September 1, 2021