1.Privacy Information
We are committed to protecting your personal data and your privacy. This privacy notice aims to give you information on how we collect and process your personal data through your use of our website (including any data that you may provide through our website) and through your other communications with us.
It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your rights?” section below.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This version of our privacy notice was last updated on 01 December 2022.
2.Information about our website
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
For more information about the cookies we use, please see our Cookie Notice.
3.To whom does this privacy notice apply?
This privacy notice applies to all individuals (other than our own employees or workers) whose personal data we may process, whether online or offline (in-store).
Generally, we process personal data relating to our existing and potential customers, visitors to our website and registered users of our website (customers).
We also process personal data relating to our business contacts. You are considered a business contact if you are a sole trader, trustee, partner in a partnership, member of an unincorporated club or association, owner, director or officer of a corporate entity or an employee of any of these, where you or your business supply goods or services to us, provide profession services to us, have expressed an interest in us or our business or have any other business relationship with us (including where your organisation is a public authority, an industry body, a regulatory authority or similar).
4.Children
Our website is not intended for children and we do not knowingly collect from children any data relating to such children. However, we do operate a “Kids” club where we receive limited personal data about children from their parents (or other person with parental responsibility). Further information about the processing of any such children’s data is provided to you when you sign up for the “Kids” club.
5.What personal data do we collect and process?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, social media username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details (solely for the purpose of processing payments).
- Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
- Technical Data includes internet protocol (IP) address, MAC address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Image and Voice Data includes images captured on CCTV and voice recordings captured on recorded telephone calls.
- Location Data includes your location where this is determined via your mobile phone.
- Business Contact Data includes your name, business or work contact details, details about who you work for and your role in any such organisation and your credentials.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or we may aggregate your Profile and Transaction Data to create an “average customer” profile. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any “special categories of personal data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
6.How is your personal data obtained?
We use different methods to collect data from and about you including through:
- Direct interactions with customers. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, via social media, live chat or otherwise. This includes personal data you provide when you:
- order our products online or by telephone;
- purchase our products in-store;
- create an account on our website including joining the loyalty scheme, The Schuh Club;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Direct interactions with business contacts. You may give us your Identity, Contact and Business Contact Data by filling in forms or by corresponding with us by post, phone, email, via social media or otherwise. This includes personal data you provide when you:
- negotiate and/or enter into a contract with us; or
- provide us with your business card.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment/devices, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Notice for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out:
- Technical Data from analytics providers, advertising networks or search information providers (such as Google Analytics, Google (adwords), Microsoft (Bing) UET Tag, Mention Me, Awin, Criteo, Salesforce and Facebook).
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity, Contact and Profile Data from social media providers (such as Twitter or Facebook) where you use these to correspond with us.
- Business Contact Data from your business or from third party references or from professional advisors.
- Business Contact and Identity Data from publicly available sources such as Companies House or your business’s website.
- In-store. We obtain your personal data when you visit one of our stores as follows:
- We operate CCTV cameras in all of our stores and therefore we will capture Image Data of visitors to our store.
- We use Google services (via beacons and GPRS) which can provide us with Location, Profile and Transaction Data where you use other Google services (for example using Google’s search services or gmail).
- We use third party “mystery shoppers” who may capture Image Data of visitors to our store.
- Due to COVID – 19 we are currently operating a Test and Trace / Test and Protect facility in our stores in England, Scotland, Northern Ireland, Wales, Jersey & Republic of Ireland. This means we will capture Contact Data of visitors using specific services. In our Guersney store we are now obligated to collect the contact details for all customers visiting our store. This means we will capture Contact Data of customers visiting our store.
- Recorded telephone calls. We record all of our outgoing and incoming telephone calls and therefore we will capture Voice Data of any person who contacts us by telephone.
7.Failure to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
8.How will we use your personal data?
Personal data will be processed by us where you consent to the processing or where that processing is necessary for 1) the performance of a contract with you; or 2) compliance with a legal obligation to which we are subject; or 3) the purposes of our legitimate interests (or those of a third party).
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including bases of legitimate interest |
|---|---|---|
| To register you as a new online customer and to administer such online account with us To manage The Schuh Club loyalty account registered with us | Identity Contact | Performance of a contract with you Your consent |
| To process and deliver your order (online, by telephone and in-store) including: managing payments, fees and charges collecting and recovering money owed to us dealing with any customer complaints or product returns where you have provided your e-mail address for this purpose, sending an e-receipt for your purchase | Identity Contact Financial Transaction Marketing and Communications | Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us and to manage customer relationships and to remunerate our third party traffic providers) Necessary to comply with a legal obligation |
| To manage our online relationship with you which will include notifying you about changes to our terms and conditions or our privacy policy | Identity Contact Profile Marketing and Communications | Performance of a contract with you Necessary to comply with a legal obligation |
| To manage our offline (in-store) relationship with you which will include: In-store promotions and surveys Notifying you about changes to our terms and conditions or our privacy policy | Identity Contact Transaction Financial | Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services (including customers’ opinions of our products)) |
| To manage and provide (where you have agreed to participate) certain discounts (such as student discounts), a prize draw or competition | Identity Contact Profile Usage Marketing and Communications | Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services (including customers’ opinions of our products), to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Technical | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Technical Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To use CCTV cameras in-store | Image Identity | Necessary for our legitimate interests (to ensure the safety of our customers and security of our stores, crime prevention) |
| To record all of our incoming and outgoing telephone calls | Voice Identity Contact Transaction | Necessary for our legitimate interests (to assist with the training of staff and with quality control) |
| To manage our business relationships with professional advisors, regulatory authorities, public authorities and others, which will include: assessing the suitability of any existing or potential supplier of goods and services to us, including undertaking appropriate background checks negotiating and entering into appropriate contracts for the supply of goods or services to us, carrying out any obligations under such contracts (including obligations of payment) and if necessary enforcing any such contracts undertaking on-going monitoring and management of our relationship with suppliers investigating any complaints or enquiries | Identity Contact Business Contact | Performance of a contract with you Necessary for our legitimate interests (to perform a contract with your organisation or business, to manage third party relationships, to run our business efficiently and profitably, to enhance, modify and improve our services and products, and to pursue our commercial objectives where this does not override your rights and freedoms as a data subject) |
| To establish, exercise and defend our legal rights | All data | Necessary for our legitimate interests (in protecting our legal rights) |
| To collect the contact data of individuals using specific services for Test and Trace / Test and Protect purposes. | Contact | Necessary for our legitimate interests, in the interests of the individual, the organisation and the public health effort to tackle COVID -19 and when required by law |
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
9.With whom do we share your personal data?
We may have to share your personal data with the parties set out below for the purposes set out above.
- Payment and credit card providers (including Klarna & Adyen).
- Internet search engine providers (such as Google: please refer to Google’s privacy notice here – https://policies.google.com/privacy/update?gl=GB&hl=en-GB)
- Service providers acting as processors who provide IT and system administration services (including Amazon Web Services), CCTV and telephone recording services.
- Service providers who provide live chat facilities on our website (vee24: please refer to their privacy notice here – https://v1.vee24.com/clients/schuh/en-gb/legal.aspx) (WhatsApp: please refer to their privacy notice here – https://www.whatsapp.com/legal/privacy-policy/?lang=en)
- Service providers who provide online marketing and advertisement services and who provide discounts and cashback incentives, including Criteo, Microsoft (Bing) UET Tag, Affiliate Window, Mention Me, Google (adwords), Salesforce, Vibes, OS (loyalty scheme partners) & EQL.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Any relevant regulatory authority or law enforcement agency, including HM Revenue & Customs, Trading Standards, Advertising Standards Authority, courts or tribunals who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
Any sharing of your personal data will only take place either where we are legally obliged to do so, where it is necessary for the performance of a contract with you or where it is in our legitimate interests to do so, including as follows:
- to maintain network and information security;
- to develop and improve our services and products in order to remain competitive;
- to ensure payment for our products;
- to obtain information about our customers’ interests as well as about conversion rates of internet searches to online or in-store purchases;
- to undertake reference checks, credit checks and risk assessments;
- to protect and defend our legal rights;
- to pursue our commercial objectives where this does not override your rights and freedoms as a data subject.
- When it is required by a public health authority to tackle COVID-19
10.How long do we retain your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your request).
For tax purposes, we retain basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
For Test and Trace / Test and Protect purposes we retain data for 21days after the date of collection.
11.Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and the Information Commissioner’s Office of a breach where we are legally required to do so.
12.Your rights
Your personal data is protected by legal rights, which include your rights to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, following your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party (data portability). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights), or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in data protection laws both in the EEA and the UK. We will inform you of relevant exemptions we rely upon when responding to any request you make.
If you wish to exercise any of these rights, please contact us using the details above.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have concerns about how we process your personal data or you believe that a violation of data protection law has occurred, you also have the right to complain to the Information Commissioner’s Office or the data protection authority of the place where you live, work or you consider that a violation has occurred.