Privacy Policy

CONFIDENTIALITY STATEMENT

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY BEFORE USING THIS WEBSITE

ECCO Europe AG, with registered office at Rothusstrasse 17, 6331 Hünenberg, Switzerland (hereinafter referred to as "ECCO", "we", "us" and "our"), respects your privacy and takes our responsibility seriously.

This Privacy Statement describes how we collect information related to your interactions with us, such as when you use our websites and any other microsites or mobile websites (the “Website”), the information you provide when you visit an ECCO-owned and ECCO-operated retail store (hereinafter, the “ECCO Stores”), when you use our mobile applications that we make available for download to your personal device (our “Apps”), or when you use your ECCO membership account on any of our ECCO channels, or the information you provide when you visit our Facebook, Instagram, TikTok, Pinterest, and other social media platforms (our “Social Media Pages”). This Privacy Statement also describes how we use and share that information. Please take the time to read this Privacy Statement.

With this Privacy Statement, we want to ensure that you receive adequate information about the collection and processing of your personal data, including information that we are required to provide to you under applicable data protection regulations, including the EU Regulation No. 2016/679 , the "General Data Protection Regulation" ("GDPR").

In this Confidentiality Statement, we use the term "Personal Data" as a synonym for "personal information" or similar expressions, as defined in applicable privacy regulations, which is information that identifies, refers to, describes, is reasonably likely to be associated with, or could reasonably be linked, directly or indirectly, to a particular individual or household.

We will update this Privacy Statement periodically and post updates on the Website. In addition, this Privacy Statement may be supplemented or modified from time to time by other "privacy notices" posted on the Website or specific pages within the Website or other channels where we interact with you. These privacy notices describe in more detail the information we collect on certain pages or areas of the Website, the App, or other channels where we interact with you.

OUR CONTACT DETAILS

The entity responsible for processing the personal data explained herein is ESCO Europe AG , with registered office in Rothusstrasse 17, 6331 Hünenberg, Switzerland Unless otherwise stated here, please expand the sections below for more information on how to contact us.

Identity of the data controller(s) and the designated representative

Unless otherwise specified, the legal entity responsible for collecting and processing your personal data under this Privacy Statement (the “Data Controller”) is:

ECCO Europe AG Rothusstrasse 17 6331 Hünenberg Switzerland Email: legal@ecco.com

ECCO Europe AG has appointed the following representative in the European Union. The appointed representative is authorized to receive inquiries from, in addition to or instead of the data controller, in particular supervisory authorities and data subjects, regarding all matters relating to the processing of personal data by the data controller.

ECCO Sko A/SIndustrivej 5

6261 Bredebro

Denmark

Email: legal@ecco.com .

Telephone: +45 7491 1625

Our contact details

If you have any questions or need to contact us, we encourage you to do so through our Customer Service representatives, either by:

Email: customer.service@pa.ecco.com

Telephone: +507 6834-4111

Contact details of the Group's Data Protection Officer

You can contact our Group Data Protection Officer by:

Email: legal@ecco.com

Telephone: +45 7491 1733

Letter: ECCO Holding A/S, Legal Department, Industrivej 5, 6261 Bredebro, Denmark, to the attention of: Group Data Protection Officer

HOW WE COLLECT AND USE YOUR PERSONAL DATA

When you interact with us, we will collect personal data about you and use it for various purposes, such as operating this Website and the App, enabling you to use our various services, including our online store, membership program, newsletter subscriptions, creating accounts with us, or contacting our Customer Support representatives. We also use your personal data to assess and evaluate your interests and preferences in order to personalize your website experience, improve our services, and offer you services better suited to your interests and preferences.

If you are asked to provide information, doing so is optional. However, the information may be required for legal, contractual, or practical reasons. We will always clearly indicate if the information is mandatory. If you refrain from providing information we consider mandatory, we may not be able to provide you with the services you have requested (for example, subscribing to a newsletter, creating a subscription, or making a purchase through our online store).

To help personalize and continually improve our services and communication with you, for example, through our newsletters, we may occasionally ask for information about your personal interests, demographics, or your experience with our products and services. Providing this additional information is always voluntary and is used solely to improve our products and services.

How we collect and use your personal data depends on how you interact with us and the services you use.

We firmly believe in and are committed to protecting the personal data under our custody and control, and have therefore implemented what we believe to be appropriate technical and organizational security measures to protect such personal data against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

By expanding the sections below, you can access more information about how we collect and process your personal data in different situations, including the general categories of personal data that are processed; the source of personal data that we do not obtain directly from you; the purposes for which personal data is processed and the legal basis for the processing.

How we collect your personal data

We may collect the personal data described here directly from you, from third parties with whom we collaborate, or through cookies or other automated means. These sources may include:

You: We collect information directly from you whenever you: make a purchase; visit a store; contact us with questions or comments; upload content to our Website, Apps, or Social Media Pages; participate in our competitions, sweepstakes, or other promotions; add items to your shopping cart; create an ECCO subscription; respond to a survey; review a product; agree to receive text messages; apply for a job; or fill out any form on our Website, Apps, or Social Media Pages.

Your device or browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Website, use our Applications, interact with our Social Media Pages or online advertising, or open our emails.

Third parties: We work with third-party service providers, such as analytics or advertising companies, data brokers, etc. These third parties share the information they have collected with us. Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy policies.

Social media platforms: Social media platforms share information with ECCO, which is typically aggregated and does not include personal data. You can learn more about how social media platforms collect and use your information by reviewing their privacy statements and settings. If you contact us through our Social Media Pages to file a complaint or request service, we will collect information related to that complaint or service request from the Social Media Page.

Cookies : ECC uses cookies (small files stored on your device or browser), pixel tags (small graphic images embedded in a website or email), web beacons, and other similar technologies to automatically collect information when you visit our Website, use our Applications, or interact with our emails. By using cookies We may link information about your interactions with our Website, Apps, or emails over time, such as which pages you visit, which links you use, and how long you stay on each page. We also engage 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 our Apps, as well as your interactions with other websites. These advertising companies may use and share the collected information to deliver advertisements more tailored to your interests. We receive aggregated information from these third parties to understand the effectiveness of our advertising. Any information collected by us or by third parties through the use of cookies or similar technologies may be linked to other information we collect about you.

Public data: We may combine the information you provide with publicly available data and data we collect in ECCO stores, at our marketing events, or that we receive from other sources.

Information about cookies

This Website uses cookies We use first-party and third-party technologies and similar technologies to optimize your user experience and for statistical and marketing purposes. You can find more information about the cookies and how you can manage and reject them in our Information about Cookies on the Website and the Application.

Below you can find more information about the types of personal data and the legal basis for the different purposes for which we use the data when you have given your consent for us to place cookies :

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

The personal data we process for this purpose are:

IP Address

Data about your behavior on our Website

If you have made a purchase

Compilation of visited pages

The legal basis for this processing is Article 6, paragraph 1, point a) of the GDPR, i.e., the consent you have given by agreeing to us place cookies functional, statistical or marketing.

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

We hire 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 our Apps, as well as your interactions with other websites. These advertising companies may use and share the collected information to deliver advertisements more tailored to your interests. We receive aggregated information from these third parties to understand the effectiveness of our advertising. Any information collected by us or by third parties through the use of cookies or similar technologies may be linked to other information we collect about you. The personal data we process for this purpose includes:

IP Address

Data about your behavior on our Website

If you have made a purchase

Compilation of visited pages

The legal basis for this processing is Article 6, paragraph 1, point a) of the GDPR, i.e., the consent you have given by agreeing to us place cookies marketing.

General marketing studies, profiling, and adaptation or improvement of our Websites, Applications, and service offerings:

To conduct general marketing research, we use all the information collected about you, as described in this section. We may also use information collected about you through other channels, as described in the SECTION 2.9 (PROFILING FOR MARKETING PURPOSES) .

In order to personalize your experiences in the store, on the website, or in the app, tailor the content of future newsletters and your member account to better suit your interests, and provide you with personalized offers, we may also create profiles and inferences based on the personal data described above in this section and on information collected about you through other channels, as described in the SECTION 2.9 (PROFILING FOR MARKETING PURPOSES) .

By subscribing to the Newsletters:

You have the opportunity to subscribe to receive information via email and text message (SMS) about ECCO products (shoes, handbags, leather goods, and related accessories) and services, contests, and promotions from us and other ECCO Affiliates (“Newsletters”). Click here To access an overview of relevant ECCO Affiliates. The list of relevant ECCO Affiliates will be updated periodically as changes occur.

We will only send you newsletters and other marketing materials if you have given your express consent to do so.

Below you will find more information about the types of personal data and the legal basis for the different purposes for which we use the data when you subscribe to a Newsletter:

Registration, verification of email validity, and sending of the corresponding newsletter

The personal data we process for this purpose is the mandatory information you provided when subscribing to the Newsletter:

Name

Last name(s)

Email address

The legal basis for this processing is Article 6, paragraph 1, letter a), of the GDPR, i.e., the consent you have given when subscribing to receive Newsletters.

Tailor our services and offers to you (personalize the newsletters we send you)

The personal data we process for this purpose includes both mandatory and non-mandatory information that you provided when subscribing to the Newsletter:

Name

Last name(s)

Email address

Gender

Shoe size

Phone number

The legal basis for this processing is Article 6, paragraph 1, letter f), of the GDPR, namely our legitimate interest in improving our services and offering you content tailored to your segment.

Monitoring newsletters to conduct general marketing studies and optimize their distribution and use

The personal data we process for this purpose are:

Tracking pixels* (included in the Newsletter), which are used to collect and process personal data, such as information about when you open the email and which links in the email you have clicked.

A tracking pixel is a small graphic embedded in emails, sent in HTML format, to allow for the storage and analysis of log files. This enables statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, we can see if and when the recipient opened an email, as well as which links within the email they clicked.

The legal basis for this processing is Article 6, paragraph 1, letter f), of the GDPR, namely our legitimate interest in understanding customer behavior and interests and ensuring effective marketing and advertising of ECCO's products and services.

General marketing studies, profiling, and adaptation or improvement of our Websites, Applications, and service offerings

For the purpose of conducting general marketing research, we use all the information collected about you, as described above in this section. We may also use information collected about you through other channels, as described in the SECTION 2.9 (PROFILING FOR MARKETING PURPOSES) .

As a member of ECCO.

If you create an ECCO account with us, you will be asked to provide some basic information to create and manage your account and subscription program. We may also give you the opportunity to provide additional information beyond what we have clearly indicated as mandatory. We recommend that you keep your ECCO membership details up to date at all times.

Please note that consent to receive newsletters is included in the subscription process, so we will use your email address or phone number to send you newsletters. You can unsubscribe from the newsletter at any time while maintaining your ECCO subscription.

You can use your ECCO subscription to manage your account data and provide us with additional information, which will help us improve the services and offers we provide. You will also have access to certain transactional data about your recent purchases and returns. Furthermore, you will have access to all information about your subscription, including your level, points, available rewards, and any other information related to your personal member profile. We may periodically request additional information to improve our offers and provide you with personalized content.

To provide you with a higher level of online security, access to your personal data in certain sections of our Websites and our App may be protected by a password that you have chosen. We strongly recommend that you do not reveal your password to anyone. We will never ask you to reveal your password.

You can manage your ECCO account by logging in to manage it. See also the SECTION 5 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENT AND UNSUBSCRIBE).

Below you will find more information about the types of personal data and the legal basis for the different purposes for which we use the data when you are a member of ECCO:

Create an account for your ECCO subscription and make it available to you.

The mandatory personal data that you provide when registering as an ECCO member are:

Name

Last name(s)

Email address

Password

We cannot create a subscription or make an account available to you unless you provide us with the required information.

The legal basis for this processing is Article 6, paragraph 1, letter a), of the GDPR, namely the consent you have given when creating the account.

To provide you with additional services as part of your ECCO subscription.

By having an ECCO subscription, we will retain and you will have access to the following information:

Transactional data about your recent purchases

Transactional data about your latest returns

Information about the subscription, including level, points, and available rewards

Stores will also have access to your subscription information, such as:

Transactional data about your recent purchases

Transactional data about your latest returns

Information about the subscription, including level, points, and available rewards

ECCO Walks: If you use the ECCO Walks feature, we will collect data about:

their walking route, including location data to verify that they are following the chosen route,

the number of steps.

We will also suggest routes and products based on your preferences and previous choices.

The legal basis for this processing is Article 6, paragraph 1, letter f), of the GDPR, namely our legitimate interest in providing you with access to information about your transactions with us and about your subscription.

Provide you with notifications push to inform you about your subscription, promotions, and service messages.

If you have given your consent to receive messages push By using the Application, we will send you notifications push To communicate with you about your orders, routes, member rewards, events, and promotions, and to provide you with service messages. In order to send notifications push We use information about:

Age

Gender

Birthdate

Family information

Shoe size

Shipping and billing address

Other demographic data or information about your interests and purchasing preferences

Device information

Information about the subscription, including level, points, and available rewards

You can turn off notifications push You can manage this at any time by accessing "Settings" on your mobile device. Please note that if you disable notifications, this may affect your settings. push We may need to contact you by email to send you important messages related to your ECCO account and your purchases.

The legal basis for this processing is Article 6, paragraph 1, letter f), of the GDPR, namely our legitimate interest in improving our services and offering you content tailored to your segment.

To improve our services and offers for you.

We can also give you the opportunity to provide us with the following additional information to that which we have clearly indicated as mandatory:

Phone number

Age

Birthdate

Gender

Family information

Shoe size

Shipping and billing address

Preferred store

Information about the subscription, including level, points, and available rewards

Other demographic data or information about your interests and purchasing preferences.

It is up to you to decide whether to provide us with this additional information.

The legal basis for this processing is Article 6, paragraph 1, letter f), of the GDPR, namely our legitimate interest in improving our services and offering you content tailored to your segment.

To offer you better services when you visit our stores.

In order to provide you with better service in ECCO stores managed by our Affiliates, staff will have access to the following information about you:

Name

Last name(s)

Gender

Email address

Transactional data

Information about the subscription, including level, points, and available rewards

Any other additional information you have provided

Store staff will only access your information if you identify yourself to them by providing your email address, name, or phone number.

ECCO stores may use the data to serve you and may record information on our behalf about your visit, such as the date of your visit, details about your purchases and returns, and the use of rewards as a member.

The legal basis for this processing is Article 6, paragraph 1, letter f), of the GDPR, namely our legitimate interest in improving our services and tailoring them to you.

General marketing studies and adaptation or improvement of our Websites, Applications and service offerings.

2.5. By using our ECCO online stores

We offer you the opportunity to purchase ECCO products through our online store. Purchases made through the online store at es.ecco.com They are made to ECCO Europe, with registered office in [Include the address of the local ECCO entity] However, the processing of your personal data related to the use of the online store is under our control.

Below you can find more information about the types of personal data and the legal basis for the different purposes for which we use the data if you make or take steps to make a purchase on this Website or any of our other Websites or Applications:

Complete the purchase and deliver the purchased items.

The mandatory personal data that you provide when making a purchase are:

Name

Last name(s)

Email address

Mailing address

Billing address

Phone number

Details of the items purchased

Other information needed to complete the purchase and deliver the items purchased.

The legal basis for this processing is Article 6, paragraph 1, letter b), of the GDPR, namely, that the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

Payment management on this website

The personal data we process for this purpose are:

Name

Last name(s)

Mailing address

Billing address

Transactional data

Email address

IP Address

Phone number

Mobile phone number

Other information required for processing the payment

In order to manage payments on this Website, we have integrated components of the following online payment service provider: Altapay A/S, Gyngemose Parkvej 50, 2860 Søborg, Denmark (hereinafter referred to as the “Online Payment Service Provider”). By selecting the relevant payment method, we automatically transfer personal data to the Online Payment Service Provider, which is necessary for processing the payment.

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

The legal basis for this processing is Article 6, paragraph 1, letter b) of the GDPR, namely that the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

Click & Collect Management

If you have chosen Click & Collect, we process the following personal data.

Name

Last name(s)

Email address

Billing address

Phone number

Details of the items purchased

The legal basis for this processing is Article 6, paragraph 1, letter b), of the GDPR, namely that the processing is necessary for the performance of a contract to which you are a party and Article 6, paragraph 1, letter f), of the GDPR, namely our legitimate interest in providing services to customers.

Management of vouchers, member rewards and gift cards

If you have received a voucher, a membership award, or a gift certificate, we will process your personal data in order to manage that voucher, award, or gift certificate and allow you to use it. The personal data we process for this purpose includes:

Name

Last name(s)

Email address

Information about the subscription, including level, points, and available rewards

Transaction history

The legal basis for this processing is Article 6, paragraph 1, letter b), of the GDPR, namely, that the processing is necessary for the performance of a contract to which you are a party.

Prevention of fraud, abuse of services and money laundering

If you place an order through our online store, we conduct automated fraud checks to minimize the risk of exposure to fraudulent activity and credit card misuse. The personal data we process for this purpose includes:

Name

Last name(s)

Mailing address

Billing address

Phone number

Transactional data

Email address

Credit Card Number

Expiration date

Security code

Purchase behavior for automated decision-making without human intervention, in order to determine if there is a risk of being exposed to fraudulent behavior and misuse of credit cards.

The legal basis for this processing is Article 6, paragraph 1, letter f), of the GDPR, namely our legitimate interest in preventing and protecting ourselves and third parties against fraud, misuse of services and money laundering.

If we suspect fraudulent activity, the purchase will not be completed. If your purchase is denied and you wish to appeal, please contact our customer service department in accordance with the SECTION 1 (OUR CONTACT DETAILS).

Manage refund requests and issue refunds

If you return any purchased item to us, we will process the following personal data:

Name

Last name(s)

Email address

Mailing address

Billing address

Details of the items purchased

Reason for return

Phone number

Shoe size

Spoken languages

General marketing studies and adaptation or improvement of our Websites, Applications and service offerings.

When you visit our ECCO stores

You can visit ECCO stores managed by our ECCO Affiliates without providing any information about yourself.

Below you can find more information about the types of personal data and the legal basis for the different purposes for which we use the data if you decide to use one or more of the services offered in our stores:

Electronic receipt

We offer to provide you with an electronic copy of your invoice via email when you make a purchase at one of the ECCO stores managed by our ECCO Affiliates. If you use this service, we will process the following personal data:

Email address

Copy of the invoice

The legal basis for the above is Article 6, paragraph 1, letter f), of the GDPR, namely, our legitimate interest in providing services to customers.

We will not use your email address to send you newsletters or other marketing content unless you have specifically signed up to receive newsletters.

Be a member of ECCO or subscribe to receive newsletters

In order to provide you with better service in ECCO stores, staff will have access to your personal data if you are subscribed to our newsletter or are an ECCO member and identify yourself to staff by providing your email address, name, or telephone number. The personal data processed in such cases includes:

Name

Last name(s)

Email address

Phone number

Transactional data

ECCO store visit data

Information about the subscription, including level, points, and available rewards

Any other additional information you have provided

ECCO stores may use the data to serve you and may record information on our behalf about your visit, such as the date of your visit and details about your purchases and returns.

The legal basis for the processing described in this section is Article 6, paragraph 1, letter a), of the GDPR, namely the consent you have given when creating the account.

See also the SECTION 2.4 (AS A MEMBER OF ECCO ) and the SECTION 2.9 (PROFILING FOR MARKETING PURPOSES) .

Management of vouchers, member rewards and gift cards

If you have received a voucher, a membership award, or a gift certificate, we will process the following personal data:

Name

Last name(s)

Email address

Coupon code

Information about the subscription, including level, points, and available rewards

Transaction history

The legal basis for this processing is Article 6, paragraph 1, letter b), of the GDPR, namely, that the processing is necessary for the performance of a contract to which you are a party.

Home delivery management

We can offer to deliver your order to your home address. If you choose to use this service, we will process the following personal data:

Name

Last name(s)

Email address

Mailing address

Details of the items purchased

The legal basis for this processing is Article 6, paragraph 1, letter b), of the GDPR, namely, that the processing is necessary for the performance of a contract to which you are a party.

General marketing studies, profiling, and adaptation or improvement of our Websites, Applications, and service offerings:

When you contact us through customer service or send us an email

You can always contact us through one of our Customer Service representatives or send us an email with a complaint, comment, or question.

Below, you can find more information about the types of personal data and the legal basis for the different purposes for which we use the data if you choose to contact us through one of our Customer Service representatives or send us an email:

Customer Service: managing requests

When you contact us through one of our Customer Service representatives or email us with a comment or question, we will retain and use the following information to respond to your request:

Name

Last name(s)

Email address

Phone number

Country of residence

Information about the subscription, including level, points, and available rewards

Other information that may be necessary to respond to your request

It is always optional for you to provide us with any information you choose. However, please note that if we do not have enough information to process your request, we may not be able to fully address your inquiry.

The legal basis for this processing is Article 6, paragraph 1, letter f) of the GDPR, namely our legitimate interests in providing services to the customer, understanding customer behavior and interests and establishing, exercising or defending legal claims.

Customer Service: handling complaints

When you contact us through one of our Customer Service representatives or email us with a complaint, we will retain and use the following information to respond to you:

Name

Last name(s)

Email address

Phone number

Country of residence

Information about the subscription, including level, points, and available rewards

Information about the claim

The legal basis for the above is Article 6, paragraph 1, letter f), of the GDPR, namely our legitimate interest in processing complaints and providing customer service.

If necessary for the establishment, exercise or defense of the claim, we may also request other information, such as:

Health data

Biometric data

Other special categories of data, if relevant to the claim.

The legal basis for the above is Article 6(1)(f) of the GDPR, namely our legitimate interest in establishing, exercising, or defending legal claims. The exception that applies to our processing of special categories of data is Article 9(2)(f) of the GDPR, namely, that the processing is necessary for the establishment, exercise, or defense of legal claims.

General marketing studies, profiling, and adaptation or improvement of our websites and service offerings

By participating in contests, product reviews, surveys, etc.

Occasionally, we may offer you the opportunity to participate in contests, leave product reviews, take part in surveys, etc. If you choose to participate, we will ask you to provide us with certain information.

Below you can find more information about the types of personal data and the legal basis for the different purposes for which we use the data if you choose to participate in a competition, a product review or a survey:

Contests and surveys

The personal data we collect and process depends on the specific contest or survey, etc., but may include:

Name

Last name(s)

Email address

Age

Gender

Family information

Shoe size

Other demographic information

Information about the subscription, including level, points, and available rewards

Information about your interests and purchasing preferences

You can always decide whether to participate in a contest or answer a survey, and therefore, the information you choose to provide is always optional. However, providing specific information may be mandatory to participate in a contest or complete a survey, and failure to provide this information could prevent you from participating.

The legal basis for the above is either Article 6(1)(a) of the GDPR, i.e., the consent you have given by choosing to participate in the competition or survey, or Article 6(1)(b) of the GDPR, namely, that the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

Product reviews

From time to time, we may ask you to give us your feedback on the products you have purchased. If you participate in a product review, we collect and process the following personal data:

Name

Last name(s)

Email address

Age

Gender

Nationality

Shoe size

Other demographic information

Data collected through the use of our Websites

Transactional data

Information about your interests and purchasing preferences

Recording images and videos of you

Your opinion about our products

You can always decide whether you want to participate in a product review, and therefore, the information you choose to provide is always optional. However, please note that providing specific information may be mandatory, and if you do not provide it, you will not be able to participate in the product review.

The legal basis for the above is Article 6, paragraph 1, letter a), of the GDPR, i.e., the consent you have given by choosing to participate in the product review.

General marketing studies and adaptation or improvement of our Websites, Applications and service offerings.

We use the information to organize contests or surveys, but we also use it for general market research purposes and to tailor or improve our Websites, Applications, subscription programs and service offerings.

Profiling for marketing purposes

ECCO wants to better understand our customers to ensure we provide them with a relevant experience and to guarantee effective marketing and advertising of ECCO products and services. To better understand our customers and personalize the experience of our Newsletters, Apps, and Websites, we use the personal data we hold to analyze or predict aspects of the personal preferences, interests, and behavior of each of our customers, Newsletter recipients, members, and Website visitors, as well as to conduct general marketing research, including customer analysis, customer segmentation, and statistics.

If you have identified yourself to us, for example, by making a purchase, creating an ECCO subscription, or providing us with your name, email address, or telephone number, we may link the personal data we have collected about you as described in the above sections.

If you disagree and wish to object, please contact us in accordance with the SECTION 1 "OUR CONTACT DETAILS" We will now stop using your personal data for profiling purposes for marketing purposes.

Below you can find more information about the types of personal data and the legal basis for the various purposes for which we use the data when creating profiles of our customers:

General marketing studies, including customer analysis, customer segmentation, and statistics

The personal data we process for this purpose are:

Name

Last name(s)

Email address

Phone number

Data collected through the use of our Websites

Newsletter tracking data

Directions

Information about the subscription, including level, points, and available rewards

Information about your demographics, interests and preferences (e.g., gender, date of birth, shoe size, your and your family members' shoe preferences, etc.).

Online and offline transaction data, including abandoned shopping carts, returns, and interactions with Customer Service.

We use your data for various analytical purposes to better understand: a) how you navigate and use our platforms; b) which products interest you; c) which features of our products and platforms you like; d) the quality of our services, including customer service, marketing and advertising campaigns targeted to you, and your reaction to these services; e) the design of our products and websites; f) whether you liked the overall user experience; and g) which rewards you redeem most frequently in your subscription program. We use this analysis to understand, improve, and develop our marketing communications with you and the quality of your personalized experience across all our channels and platforms.

The legal basis for the above is Article 6, paragraph 1, letter f), of the GDPR, namely our legitimate interest in understanding customer behavior and interests and ensuring effective marketing and advertising of ECCO's products and services.

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

In addition, we may use the information to evaluate and assess your individual interests and preferences in order to personalize your purchases and experiences on the Website, your member experience and rewards, and to optimize the service you receive from us and our Affiliates.

Personalize newsletter content and special offers

If you have signed up to receive newsletters, we will also use your personal data to tailor the newsletter content to your interests and provide you with personalized offers.

The legal basis for the above is Article 6, paragraph 1, letter a), of the GDPR, i.e., the consent you have given by subscribing to receive Newsletters.

Target audience management

We create a profile about you by aggregating all the information you have provided to us directly or indirectly. This allows us to personalize our interactions with you. We use audience management technologies to ensure that you receive the right messages and information at the right time through the channels you have previously used or expressed a preference for. This includes sending you marketing messages about offers, products, or news, or targeting you in digital media through advertisements on ECCO brand platforms. The level of personalization depends on the consents you have given us and the duration and nature of our relationship with you.

The legal basis for the above is Article 6, paragraph 1, point (a) of the GDPR, namely the consent you have given when subscribing to receive newsletters or when accepting cookies .

Improve data models

We use data science and your personal and profile data to create data models that help us improve the logic in our analytical activities. These models provide us with more information about your comments, opinions, interactions, preferences, and needs regarding our products and services. We will compare the data model we create using your profile with other similar consumer profiles and categories to further predict and analyze your preferences.

Social networks

ECCO maintains and manages several social media pages on platforms such as Facebook, TikTok, and Instagram. We use these to communicate with you and provide 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 respond to or communicate with you.

If you use a hashtag that includes ECCO, our product names or other information we seek, we may also use your information to contact you, communicate with you and, with your consent, use your user-generated content on our Website or Social Media Pages.

Below you can find more information about the types of personal data, the legal basis and the different purposes for which we use them for data processing on social media:

By visiting our Social Media Pages or by interacting with us through them

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

The personal data we process about you for this purpose includes any publicly available social media information, such as your social media accounts, social media interactions and public posts, your "likes" and other reactions, your social media connections, your public photos, or photos you send us by mentioning us or following our social media posts using " handles " either " hashtags » and comments or messages that you have shared with us publicly or privately on social media platforms.

In addition, we may obtain information indirectly from social media companies (Facebook, Google, etc.) when we advertise on these platforms. The personal data we process for this purpose includes your participation in and membership of certain topics or groups, your profile settings and preferences, and your behavior on different platforms owned by the same company.

The legal basis for the above is Article 6, paragraph 1, letter f), of the GDPR, namely our legitimate interest in understanding customer behavior and interests, ensuring effective marketing and advertising of ECCO's products and services, and providing good customer service.

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

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

By submitting your images to us through social media platforms, you agree to our use of them as described in the license agreement. The personal data we process for this purpose includes information about your social media activity, images, videos, comments, sound recordings, and other files provided through the social media platform promoted by ECCO, as well as your social media interaction and activity.

The legal basis for the above is Article 6, paragraph 1, letter a), of the GDPR, i.e., the consent you provide when you agree to our use of your user-generated content.

Advertising on social media

We use third-party advertising platforms, such as Facebook, TikTok, Google, YouTube, Instagram, etc., to send you targeted messages based on your behavior and browsing patterns, at specific times and places on these platforms to increase the effectiveness of our advertising campaigns.

To do this, we share your personal data with our partner advertising agencies and social media platforms. We use third-party solutions, such as Google Analytics and Facebook Business Manager, to help us better target our campaigns and messages to our consumers.

Social media platforms will attempt to match your profile with their database to determine the optimal time and place (the page you are browsing) to show you an ECCO ad. We also need to analyze the information necessary to understand the impact of our campaigns.

If you do not consent to being tracked for this purpose, you will still see ECCO ads on social media and other third-party platforms randomly. Please also read the privacy statements of the social media platforms to learn how they use your personal data for this purpose.

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

Google's personalized advertising: https://support.google.com/adspolicy/answer/143465?hl=es

Google's advertising policies: https://support.google.com/adspolicy/answer/6020956

Similar Facebook audiences: https://www.facebook.com/business/help/164749007013531

Facebook Custom Audiences Terms and Conditions: https://www.facebook.com/legal/terms/customaudience

TikTok's advanced terms of service: https://ads.tiktok.com/i18n/official/policy/business-products-terms

Pinterest Analytics Terms and Conditions: https://help.pinterest.com/es/business/article/pinterest-analytics

Meta as co-responsible for the treatment

Meta is a joint controller and the information required by Article 13, paragraph 1, letters a) and b) of the GDPR can be found in Meta's data policy at https://www.facebook.com/about/privacy .

Information about your use of the Applicable Products and the purposes for which the collection and transmission of Personal Data that constitutes the Joint Processing takes place are set out in the Applicable Products Terms and Conditions.

For more information on Meta's processing of Personal Data, including the legal basis on which Facebook Ireland relies and how to exercise your rights as a Data Subject against Facebook Ireland, please see Meta's data policy at https://www.facebook.com/about/privacy.

Meta and ECCO have signed a Data Controller Appendix to determine their respective responsibilities for compliance with obligations under the GDPR with respect to activities for which we are jointly responsible.

Meta and ECCO have agreed that ECCO is responsible for providing Interested Parties, at a minimum, with the information required under the GDPR and set out in this Privacy Statement.

Meta and ECCO have also agreed that between Meta and ECCO, Meta is responsible for responding to the rights of Interested Parties under Articles 15-20 of the GDPR with regard to Personal Data stored by Meta after Joint Processing.

TikTok as a co-controller of the processing

We use the TikTok Pixel, provided by TikTok, to collect information about your use of our Website in order to display targeted advertising and measure the performance of our advertising campaigns.

The TikTok Pixel allows us to retarget you with products and services you have viewed on our Digital Property on TikTok and measure when you have clicked on our Digital Property after viewing one of our ads on TikTok.

Information about how TikTok collects, uses, and protects information collected using the TikTok Pixel is available in TikTok's User Privacy Policy at https://www.tiktok.com/legal/privacy-policy-eea?lang=es .

Pinterest as a joint controller of the processing

Pinterest Europe is a joint controller and the information required by Article 13, paragraph 1, letters a) and b) of the GDPR can be found in Pinterest Europe's Privacy Policy at: https://policy.pinterest.com/es/privacy-policy

Criteo as joint controller of the processing

We use the Criteo tag, provided by Criteo, to collect information about users and their activity on our Website in order to target advertising to the user across different channels and devices.

Information about how Criteo collects, uses, and protects the information collected using the Criteo Pixel is available in Criteo's Privacy Policy at https://www.criteo.com/privacy/.

Awin as joint controller of the processing

We use the Awin tag, provided by Awin, to identify conversions to attribute sales and commissions to relevant publishers, to identify purchased products to attribute sales and commissions based on product types to relevant publishers, and to collect information about user activities on the Website in order to improve publisher partnerships.

Information about how Awin collects, uses, and protects the information collected using the Awin Pixel is available in Awin's Privacy Policy at https://www.awin.com/es/privacidad.

General marketing studies, profiling, and adaptation or improvement of our Websites, Applications, and service offerings:

Online marketing and reorientation

By entering the ECCO Website and Application and to the extent you have given us your consent to place cookies on your device, we will use cookies and similar technologies to track your activities on our Website and use your information to send you advertising through different channels and devices (also known as "cross-context behavioral advertising").

In addition to the technology of cookies and the information processed through its use, we may also process other personal data we have about you for online marketing and retargeting purposes.

If you have identified yourself to us, for example, by making a purchase, creating an account, or providing us with your name, email address, or telephone number, we may also use the personal data we have collected about you as described in the sections above.

If you disagree and wish to object, please contact us in accordance with the SECTION 1 "OUR CONTACT DETAILS" We will now stop using your personal data for profiling purposes for marketing purposes.

Below you can find more information about the types of personal data and the legal basis for the different purposes for which we use them for online marketing and retargeting:

Online marketing and reorientation

The personal data we process for this purpose are:

Email address

Data collected through the use of our Websites and Applications

Newsletter tracking data

Information about the subscription, including level, points, and available rewards

Information about your demographics, interests and preferences (e.g., gender, date of birth, shoe size, family status, product preferences, etc.).

Online and offline transaction data, including abandoned shopping carts, returns, and interactions with Customer Service

His profile, deduced from this information, can be seen in the SECTION 1.9 (PROFILING FOR MARKETING PURPOSES)

The legal basis for the above is Article 6, paragraph 1, point (a) of the GDPR, i.e., the consent you give when you accept our use of cookies marketing.

HOW WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES

In order to make our services available to you, provide you with the services and support you have requested, and generally operate our business, we will need to communicate and transfer your personal data to other ECCO Affiliates and third parties, such as IT providers, marketing agencies, logistics service providers, payment service providers, etc.

When we use service providers and contractors to process your personal data on our behalf (also referred to as "data processors"), we require them to process your personal data only in accordance with our instructions. We also require data processors to sign relevant contracts that provide sufficient guarantees to implement appropriate technical and organizational measures so that data processing complies with applicable data protection regulations and ensures adequate protection of your rights.

If we disclose your personal data to third parties who are not acting as data processors under our instructions, but as independent data controllers, we will do everything possible to ensure that they are trustworthy and have implemented appropriate technical and organizational measures to protect your data.

Expand the following sections to learn more about how we share your personal data.

3.1. Categories of recipients

The main categories of potential recipients of your personal data are:

Service providers acting as data processors

We may share your personal data with our trusted third-party service providers, who, on our behalf, operate, maintain or support our computer systems and IT infrastructure and our websites, manage our payment solutions, perform statistical analysis, send newsletters, provide customer support and perform other important services for us.

Service providers acting as data controllers

We may also share your personal data with our trusted third-party service providers, who will use your personal data for their own purposes and will therefore act as independent data controllers. These third-party service providers include logistics service providers, payment service providers, and our external auditors.

External advertising partners such as Facebook, Google, and TikTok

We use third-party advertising partners to collect information about your use of our Website in order to display targeted advertising and measure the performance of our advertising campaigns. The third-party partners we use may collect this information using tracking technologies, such as pixels, cookies , API and SDK.

Facebook (Meta): You can find out more about how Facebook Ireland processes your personal data in its data policy at https://www.facebook.com/about/privacy.

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

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

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

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

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

Awin: You can find out more about how Awin uses the information shared with them here: https://www.awin.com/es/privacidad .

ECCO Sko A/S

We may share your personal data with ECCO Sko A/S, with registered office at Industrivej 5, 6261 Bredebro, Denmark, and other companies that are owned or controlled by ECCO Sko A/S or that are owned or controlled by ECCO Sko A/S (“ECCO Affiliates”) so that they can provide us with the relevant services.

Other ECCO Affiliates

If you have created an account with us, we may share your personal data with other companies that we own or control for the operation of the account. MY ECCO , see the SECTION 2.4 (WHEN YOU HAVE A MY ECCO ACCOUNT).

If you have made a purchase from one of our ECCO Affiliates through our online store, the transaction details will be communicated so that the ECCO Affiliate can comply with the relevant accounting and tax regulations, etc.

We may also share your personal data with other ECCO Affiliates in other situations so that they can provide us with the relevant services.

Successors

A transfer of your personal data to another legal entity may occur as part of a transfer of our business or parts of it in the form of a reorganization, sale of assets, consolidation, merger or similar.

Other disclosures

In addition to when you have given your consent for the disclosure of personal data or when disclosure is necessary to achieve the purposes for which it was collected, personal data may also be disclosed in special situations, when we have reason to believe that it is necessary to do so in order to identify, contact or take legal action against any person who damages, harms or interferes (intentionally or not) with our rights or property, with users or with any other person who could be harmed by such activities, or when necessary for the establishment, exercise or defense of legal claims.

Transfer of data to third countries

The use of service providers and the disclosure of your personal data to other ECCO Affiliates and other recipients may involve the transfer of your personal data to countries that may not have data protection regulations as stringent as those in your jurisdiction and that the European Commission or a national data protection authority may consider not to offer an adequate level of protection for personal data (so-called "unsafe third countries"). These countries include, but are not limited to, the United States, Canada, China, Hong Kong, Macau, Taiwan, Vietnam, Singapore, Thailand, Malaysia, Japan, South Korea, Russia, the UAE, Turkey, Indonesia, Australia, and New Zealand.

We require all recipients of your personal data to provide appropriate safeguards to protect your personal data when transferred to "non-secure third countries" by adhering to the standard data protection clauses adopted by the European Commission (see Article 46(2) of the GDPR). Please see the following link for more information on the standard data protection clauses we use here.

If you have any questions, please contact our Customer Service representatives according to the SECTION 1 (OUR CONTACT DETAILS).

HOW WE STORE AND DELETE YOUR DATA

Your personal data will be kept by us in a form that permits your identification for no longer than is necessary for the purposes for which it is lawfully collected and processed.

This means that we will retain and process your personal data while we are providing you with services and will also retain it afterwards for as long as necessary to:

The establishment, exercise or defense of possible legal claims and litigation.

Compliance with tax, VAT and accounting regulations and other mandatory rules.

We will remove any information that, in our reasonable assessment, appears to be inaccurate or outdated due to the time elapsed since it was collected or due to any other information in our possession.

If you provide us with a written request, we will also delete or anonymize your personal data without undue delay, unless we have a valid legal reason to continue retaining your personal data. See also the SECTION 5 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENT AND UNSUBSCRIBE) .

YOUR RIGHTS AND HOW TO WITHDRAW CONSENT AND UNSUBSCRIBE

You have certain rights under applicable data protection regulations. Some of these rights are quite complex and include exemptions, so it is recommended that you read the relevant laws and guidance from regulatory authorities for a full explanation. However, the sections below provide a summary of your rights.

Right of access

You have the right to obtain confirmation as to whether or not we are processing your personal data. Furthermore, you have the right to obtain more detailed information about the personal data we hold and how we process it, and, in certain circumstances, the right to receive a copy of that personal data.

Right of rectification

You have the right to have inaccurate personal data about you rectified and, taking into account the purpose of the processing, to have incomplete personal data completed.

Right of erasure

In some cases, you have the right to have your personal data erased without undue delay. These circumstances include: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw your consent to processing based on consent; (iii) the processing is for direct marketing purposes; or (iv) the personal data have been unlawfully processed. However, there are certain general exclusions to the right to erasure. These general exclusions include cases where processing is necessary: (i) for exercising the right of freedom of expression and information; (ii) for compliance with a legal obligation; or (iii) for the establishment, exercise, or defense of legal claims.

Right to restriction of processing

In some cases, you have the right to restrict the processing of your personal data. When processing has been restricted, we may continue to retain your personal data. However, we will only process them in any case i) with your consent; ii) for the establishment, exercise, or defense of legal claims; iii) for the protection of the rights of another natural or legal person; or iv) for important reasons of public interest.

Right to data portability

To the extent that the legal basis for processing is your consent, and such processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format. However, this right does not apply where it adversely affects the rights and freedoms of others.

Right to object

You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that it is necessary (i) for the performance of a task carried out in the public interest or in the exercise of official authority vested in ECCO; or (ii) for the purposes of legitimate interests pursued by us or by a third party. We will cease processing your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

You also have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you object, we will stop processing your personal data for this purpose.

Right to withdraw consent .

To the extent that the legal basis for the processing is your consent, you have the right to withdraw it at any time.

If you withdraw your consent, we will stop processing your personal data unless and to the extent that continued processing is permitted or necessary under applicable data protection regulations or other applicable laws and regulations. Withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal.

If you refrain from providing the required consents, or later withdraw your consents, you may not be able to benefit from some of the service offers we provide.

Right to lodge a complaint with the supervisory authority responsible for data protection

You can always file a complaint with your local data protection supervisory authority. The data protection supervisory authority in Spain is

Spanish Data Protection Agency

C/ Jorge Juan, 6

28001, Madrid, Spain

We make every effort to ensure the protection of your personal data, keep you informed about how we process it, and comply with applicable data protection regulations. If you are not satisfied with the processing and protection of your personal data or with the information you have received from us, please let us know so we can improve. Please do not hesitate to contact us if you wish to exercise your rights.

Please contact us through the contact points listed in the SECTION 1 (OUR CONTACT DETAILS) Please also provide us with the relevant information to process your request, including your full name and email address so we can identify you. We will respond to your request without undue delay.

You can always withdraw your consent to receive newsletters, etc., and unsubscribe from an email list by following the instructions in any email or other communication you receive from us.

If you have created an account with us, you can also manage it by accessing it.

LINKS TO OTHER WEBSITES

We may provide links to third-party websites. These linked websites are not under our control, and therefore we cannot accept any responsibility for the conduct of third parties linked to our websites. Before submitting your personal data on any other website, we advise you to review that website's terms of use and privacy policies.

CHANGES TO THIS CONFIDENTIALITY STATEMENT

We reserve the right, at our discretion, to add to, modify, or remove portions of this Privacy Statement in the future to ensure that the information contained herein provides relevant and appropriate information about our collection and processing of your personal data.

This Confidentiality Statement may be supplemented by other information received from us or other ECCO Affiliates and by other terms and conditions applicable to this Website, or that you have agreed to as part of your interaction with us or another ECCO Affiliate.

You can always find the updated version of our Privacy Statement at es.ecco.com

If you have consented to receive newsletters and other information from us, we will also inform you directly about any updates to this Privacy Statement via email.

Version [August/2023]

List of ECC Europe Affiliates

ECCO Europe Affiliates	Country
ECCO Distributors DAC	Ireland
ECCO France SAS	France
ECCO Holding A/S	Denmark
ECCO Holst A/S	Denmark
ECCO Leather BV	Netherlands
ECCO Shoes Trade Ltd.	Türkiye
ECC Shops Vestdanmark A/S	Denmark
ECCO Sko A/S	Denmark
ECCO Europe (Austria) GmbH	Austria
ECCO Europe (Cyprus) Ltd.	Cyprus
ECCO Europe (Czech Republic) sro	Czech Republic
ECCO Europe (Denmark) A/S	Denmark
ECCO Europe (Deutschland) GmbH	Germany
ECCO Europe (Great Britain) Ltd.	UNITED KINGDOM
ECCO Europe (Hungary) Kft.	Hungary
ECCO Europe (Norway) AS	Norway
ECCO Europe (Poland) Sp.zoo	Poland
ECCO Europe (PORTUGAL), LDA	Portugal
ECCO Europe (Sweden) AB	Sweden
ECCO Footwear, SL	Spain
ECCO Europe Adriatic doo	Croatia
ESCO Europe AG	Swiss
ECC Footwear Romania SRL	Romania
ECCO Europe Footwear doo Beograd-Novi Beograd	Republic of Serbia
ECCO Europe Kenkä Oy	Finland
ECCO Europe OBUTEV SL, trgovsko podjetje, doo	Slovenia
ECCO Europe Retail (Slovakia) sro	Slovakia
ESCO Europe Switzerland AG	Swiss
SIA ECC Europe Baltic	Latvia

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