DATA PROTECTION NOTICE FOR CUSTOMERS
This Data Protection Notice (“Notice”) sets out the basis which Skechers Singapore Pte Ltd (“SKECHERS”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1. As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, made any purchase from us, or entered into any contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
2. Depending on the nature of the customer’s interaction with us, some examples of personal data which we may collect from them include name, residential address, email address, telephone number, gender and date of birth.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally do not collect customers’ personal data unless (a) it is provided to us voluntarily by them directly or via a third party who has been duly authorised by the customer to disclose their personal data to us (their “authorised representative”) after (i) the customer (or their authorised representative) have been notified of the purposes for which the data is collected, and (ii) the customer (or their authorised representative) have provided consent to the collection and usage of the customers’ personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using the customers’ personal data for a purpose which has not been notified to them (except where permitted or authorised by law).
5. We may collect the following personal data from customers:
a. Full Name
b. Mobile Number
c. Date of Birth
d. Email Address
e. Shipping Address
f. Billing Address
6. Your personal data will be collected and processed via the platforms and personnel below:
a. In-stores via hardcopy membership registration forms
b. Online via Ascentis (outsourced CRM vendor) membership portal
c. Online via skechers.com.sgwhen making purchase
d. SMS vendor for SMS blast
e. EDM vendor for EDM blast
f. Customer Service personnel
g. Marketing personnel
7. We may use the personal data for any or all of the following purposes:
a. performing obligations in the course of or in connection with our provision of the goods and/or services requested by customers;
b. verifying the customer’s identity;
c. responding to, handling, and processing queries, requests, applications, complaints, and feedback from customers;
d. managing customer’s relationship with us;
e. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
f. marketing and communication purposes;
g. any other purposes for which you have provided the information;
h. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
8. In order to provide users and subscribers with the most efficient and enhanced service and better understand your preferences, we may request your gender, shopping preference and product interest. SKECHERS members can specify email notification preferences. Whether or not you provide this information is entirely up to you.
9. We also use automatic data collection technologies to collect additional non-personally identifiable information (for example, details of your visits to our website, information about your computer and Internet connection, such as browser type, browser version, operating system and IP address) which will concern the general use of our website. The navigational information allows us to see which areas of our website are most visited and helps us improve the quality of your online experience by recognizing and delivering more of the most desired features and services. Note that we may also record user sessions. The technologies we use for this automatic data collection may include cookies and web beacons.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
10. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of SKECHERS. In relying on the legitimate interests exception of the PDPA, SKECHERS will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
11. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
a. Fraud detection and prevention;
b. Detection and prevention of misuse of services; and
c. Collection and use of personal data on company-issued devices to prevent date loss.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
• Required cookies. These cookies are required to enable core site functionality including log-in, the shopping cart, checking out and estimated shipping. Required cookies are automatically enabled when you visit the Skechers website.
• Functional cookies. These cookies enable additional functionality such as status of SKECHERS membership and promotion codes, and allow us to collect statistics that help optimize and improve your experience with the SKECHERS website. For example, they allow us to recognize and count the number of visitors and see how they move around our website, which can help us to improve the website design.
• Advertising cookies. These cookies are used by SKECHERS and third party companies to deliver content tailored to your interests both on our site and elsewhere. They record information such as your visit to our website, the pages you have visited and the links you have followed. This may be shared with other organisations such as third party advertisers.
15. SKECHERS may use automatic data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking).
HOW WE RESPOND TO DO NOT TRACK SIGNALS
16. Although some browsers offer a "do not track" feature in order for you to request that the websites you visit do not track your online activities, our website is not currently set up to respond to do not track signals.
PROTECTION OF PERSONAL DATA
17. To safeguard customer’s personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, and web security measures against risks.
19. The consent that customers provide for the collection, use and disclosure of their personal data will remain valid until such time it is being withdrawn by them in writing. They may withdraw consent and request us to stop collecting, using and/or disclosing their personal data for any or all of the purposes listed above by submitting their request in writing or via email to our Data Protection Officer at the contact details provided below.
20. Upon receipt of their written request to withdraw their consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with them) for their request to be processed and for us to notify them of the consequences of us acceding to the same, including any legal consequences which may affect their rights and liabilities to us. In general, we shall seek to process your request within seven (7) business days of receiving it.
21. Whilst we respect the customer’s decision to withdraw their consent, please note that depending on the nature and scope of their request, we may not be in a position to continue providing our goods or services to them and we shall, in such circumstances, notify them before completing the processing of their request. Should they decide to cancel their withdrawal of consent, please inform us in writing in the manner described in clause 19 above.
22. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
23. You can choose to cancel e-mails by updating your contact preferences on our website. To unsubscribe from SMS or other mobile messaging, you may also follow the instructions in the messages you receive. Similarly, all e-mails you receive will provide you with information as to how to get off the e-mail mailing list if you so desire.
ACCESS TO AND CORRECTION OF PERSONAL DATA
24. If the customer wish to make (a) an access request for access to a copy of the personal data which we hold about them or information about the ways in which we use or disclose their personal data, or (b) a correction request to correct or update any of their personal data which we hold about them, they may submit their request in writing or via email to our Data Protection Officer at the contact details provided below.
25. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
26. We will respond to the customer’s request as soon as reasonably possible. In general, our response will be within seven (7) business days. Should we not be able to respond to their request within thirty (30) days after receiving their request, we will inform them in writing within thirty (30) days of the time by which we will be able to respond to their request. If we are unable to provide them with any personal data or to make a correction requested by them, we shall generally inform them of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
ACCURACY OF PERSONAL DATA
27. We generally rely on personal data provided by customers (or their authorised representative). In order to ensure that their personal data is current, complete and accurate, please update us if there are changes to their personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
28. We may retain the customer’s personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
29. We will cease to retain the customer’s personal data, or remove the means by which the data can be associated with them, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
SHARING OF PERSONAL DATA WITH THIRD PARTIES
31. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfilment and shipping, marketing and promotional material distribution, website evaluation, data analysis and, where applicable, data cleansing. We may need to share personal information with these third parties so that they can perform these services; however, we limit the personal information that we give to them and authorize them to use this information only for the purpose of performing those services.
32. In proceeding with your online order, you agree that both your name and address and those of the delivery name and address (if different) may be checked using third parties such as credit agencies. If you are providing a delivery name and address which is not your own, you must have that person's permission to give us their personal information and for us to use it for the purposes specified. By providing it, you are saying that you have their permission.
33. We share aggregated demographic information about our user base with our agents, including agencies or third party vendors so that they can provide marketing analysis and consult on advertising strategies. This information does not identify individual users. We also may share non-personal information (such as the number of users who visited the website during a specific time period or who purchased a specific product through the website) with our marketing partners, advertisers and others from time to time. This information generally is shared in an aggregated form.
34. We may release personal information if we believe in good faith that: the law or legal process requires it; if we have been advised by counsel; we have received a valid administrative request from a law enforcement agency; or such release is necessary to protect the rights, property or safety of SKECHERS or any of our respective affiliates, business partners, customers or others.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
37. We generally do not transfer customer’s personal data to countries outside of Singapore. However, if we do so, we will obtain their consent for the transfer to be made and we will take steps to ensure that their personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA PROTECTION OFFICER
38. Customers may contact our customer service to speak to our Data Protection Unit personnel if they have any enquiries or feedback on our personal data protection policies and procedures, or if they wish to make any request, in the following manner:
Contact No. : 6202 7240
Email Address : firstname.lastname@example.org
EFFECT OF NOTICE AND CHANGES TO NOTICE
39. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of customer’s personal data by us.
40. We may revise this Notice from time to time without any prior notice. Customers and staff may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Customer’s continued use of our services constitutes their acknowledgement and acceptance of such changes.
Effective date : 29 September 2021
Last updated : 29 September 2021